hazardous waste .management plan afb/kafb1001.pdf · 2018. 7. 31. · hazardous wastes originator...

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! ii lj ii ii I ....... j \' '."' R . RTMENT OF THE AIR FORCE HEADQ AR ERS 1606th AIR BASE WING _ . .....- . .,, KIRTLAND AIR FORCE BASE, NEW MEXl"CO 87117 HAZARDOUS WASTE .MANAGEMENT PLAN :f, ) _; I , ' !. OPLAN 195-83 SEPTEMBER 1983 FOR OFFICIAL USE ONLY RECEIVED OCT 2 51983 _e E M SECTJON KAFB1001 I llllllll llll lllll lllll llll lllll lllll llll/ 11111111

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Page 1: HAZARDOUS WASTE .MANAGEMENT PLAN AFB/KAFB1001.pdf · 2018. 7. 31. · hazardous wastes originator retains responsibility for the waste until the waste is transferred to the Defense

! ~\

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R . RTMENT OF THE AIR FORCE

HEADQ AR ERS 1606th AIR BASE WING (MA<~) _ . .....-. .,,

KIRTLAND AIR FORCE BASE, NEW MEXl"CO 87117

HAZARDOUS WASTE

.MANAGEMENT PLAN :f, ) _; ·~

I , ' -~· ~ !.

OPLAN 195-83

SEPTEMBER 1983

FOR OFFICIAL USE ONLY

RECEIVED

OCT 2 51983

_e E M SECTJON

KAFB1001

I llllllll llll lllll lllll llll lllll lllll llll/ 11111111

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HAZARDOUS HASTE MANAGEMENT PLAtJ HWM OPLAN 195-83

KIRTLAND AFB, NEW MEXICO

Prepared for

l606th AIR BASE WING UNITED STATES AIR FORCE

KIRTLAND AIR FORCE BASE, NEW MEXICO ENVIRONMENTAL PROTECTION ·

HWM OPLAN 195-83

by

CAMP DRESSER & McKEE, Inc. 5301 Central Avenue, N. E.

Suite 1204 Albuquerque, New Mexico 87108

environmental engineers. scientists, planners, & management consultants

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

SECURITY INSTRUCTIONS

l. The long title of this Plan is Kirtland Air Force Base, Hazardous

Waste Management Operational Plan. (H\-lvt)

2. The short title is HWM OPLAN.

3. This document is unclassified and does not come within the scope of

directives governing the protection of information affecting national

security.

4. The office of origin of this OPLAN is the Engineering and

Environmental Planning Branch, 1606 Air Base Wing, Kirtland Air Force

Base, New Mexico, 87117.

5. Cor1111anders of all tasked organizations are authorized to reproduce

this OPLAN or extract and reproduce all portions which are essential

and necessary for planning and operational purposes.

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Change Ti tl e

l 606th Air Base Wing (MAC} Kirtland Air Force Base, NM 87117

Record of Changes

KAFB Hazardous Waste Plan, August, 1983

Date Entered by

(name & grade) Symbol

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

TABLE OF CONTENTS

I. PLAN SUt-tMARY • • • • • • • • • • • • • • • • • • • • • • • • . • • • • . • • • • • • • • • • • • • • • 1

I I • GENERAL • • • • • • • • • • • • • • • • • • • . • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 5

A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

B. Applicable Regulations and Laws...................... 5

l. Federal . • • • . • . . . . . . . . . • . . . . • • • • . . . . . . • • . • • . • . . • . . 5

2. New Me xi co State Regulations . . • . . . . . . . . . . . • . • . • . • 7

III. RESPONSIBILITIES......................................... 9

A. Wing Commander • • • • • • • • • • • • • • • • . • • • • • • • • • • • . • . • • • • • • • . 9

B. Environmental Protection Committee................... 9

C. Wastes Materials Control and Recovery Subcommittee ... 10

D. Civil Engineer ..•..••......•••.••..••......•.•.•...•.. 11

E. Base Environmental Coordinator •••.•.................. 11

F. Fuels Management Officer ...•.............•........... 13

G. 'Base Safety and Fire Safety .••......•..•............. 13

H. Bioenvironmental Engineer . • . . . . . . • • . . . . . • . . . . . • . . . . . • 14

I. Defense Property Disposal Office ...•.•••......•••.•.. 14

J. Waste Originators •.•.•...•....•••••..........•..•.... 15

K. Central Procurement, Contract Administration and Tenants . . . . . • . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . 18

L. Preservation and Packaging Section, Packaging Contractor . . . . . . . . • • . . . . . . . . . . . . . . . . . . . . . . . 19

M . Base Supply . . . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . l 9

i

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1606th Air Base Wing (MAC} Kirtland Air Force Base, NM 87117

N. Personnel, Civilian Employee, Development and T .. ra1n1ng ...•.............................•...•..•.... 20

O. Judge Advocate ....•......••....•.•.•......•..••••••.. 20

P. Public Affairs Division .•...•.•.••.•..•.••.••.•••••.• 20

IV. COLLECTION AND SEGREGATION .•.•.•....•...•.....••••.••...• 21

A. Technical Orders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

B. Record Keeping of Collection and Disposal Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

C. Collection Container.................................. 22

1. Container Selection •.•.•.•.••••.•••••.•••.••••••• 22

2. Container Management ..••••..•••••.•..•••....•.•••• 23

3. Container Location ............................... 24

4. Collection Time Limits •......•......•••...••...•. 24

5. Container Marking •.•..•...•••.•.•.••••.•........• 25

D. Segregation of Materials •..•••.••.•.••....•..•••.••.. 27

1. Halogenated Wastes ..••..••..•••••...•..•.....••.. 27

2. Polychlorinated Biphenyls •..•..•....•••••.....••. 27

3. Silver Bearing Photographic Property and Precious Metals ....••..•...•..•••...••...•..•.... 28

4. Acids and Bases . . . . . . . . . . . . . • . . . . . . • . • . . . . . . . . . . . 28

5. Non-Halogenated Solvents and Organic Compounds . • • • • • • • • • • • . • • • • • • • • • • • • • • • • • • • • • • • • • . . 28

6. POL . . . . . . . . • . . . . . . . • . . . . . . . . . • • . . . . . • . . . • . • • . . . . . 28

7. Water Contamination ............................... 30

ii

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v.

VI.

VI I.

1606th Air Base Wing (MAC} Kirtland Air Force Base, NM 87117

STAGING AND STORAGE AREAS . ............................... . 31

A. Collection Points . ................................... . 31

B. Storage Areas ................................... ·~· ... . 31

c. Spill Prevention 32

DISPOSITION OF WASTE PRODUCTS ............................. 33

A. Disposition of Fuels . ................................ . 33

l. Aircraft Fuels .................................... 33

2. Ground Fuels •••••••••••••••••.•••••• ; ••••••••••••. 34

B. Disposition of Used Oils . ............................ . 34

l. Mineral Oils ······························•4••···· 34

2. Synthetic Turbine Engine Oils .••••••••••••.••••••• 35

3. Prohibited Practices ••.••••••..••...••.•.••••.•••. 35

c. PCB s ................................................. . 35

D. Surplus Chemicals and Chemical Waste •••••••••••••••.•• 35

TURN-IN PROCEDURES ••••••••...••••.•••••••••••••..••.•..•.. 37

A. Technical Infonnation 37

1. Chemi ca 1 Names •••....••.•..••••••.•.•••.••••.•.•. 37

2. Chemical Contents ................................. 37

3. Shipping r~ame .................................... . 37

B. Documents .••...••••...••.•.•..••..••.•..•••.•.•.•.•.•. 37

1. DD Form 1348-1 .................................... 38

2. Labels ....................•....................... 38

3. Off-Base Shipments •..••••..•••••••....•••••••••... · 38

iii

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VII I.

IX.

x.

XI.

1606th Air Base Kirtland Air Force Base,

Wing (MAC) NM 87117

c. Packaging ............................................. 39

D. Turn-In to DPDO ....................................... 39

NEW WASTE SOURCES '

.......................... 40

A. Notifi ca ti on . ........... . 40

PERSONNEL TRAINING PROGRAM . .............................. . 41

A. Responsibility and Scope .............................. 41

1. Training Manager ............................. 41

2. Training Participants ............................. 41

B. Schedules . ........................................... . 42

c. Training Program Contents . ........................... . 42

o. Records . ............................................. . 43

l. Job Descriptions .................................. 43

2. Records ........................................... 43

WASTE ANALYSIS . .......................................... . 44

A. Unknown Wastes . ...................................... . 44

B. Test Sampling Methods . ............................... . 46

EMERGENCY RESPONSE ................................. 47

A. Scope . ••.•..•.••• . .................................... . 47

B. Response Actions .••.•.•.••••..•••.• . .................. . 47

c. Arrangements for Outside Services. 47

D. Facility Emergency Coordinator •.•••.......•.•••.••..•.. 48

E. Emergency Eq ui pme nt . ..••••••..••••.••.••..••••...••.... 48

iv

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XI I.

F.

G.

1606th Air Base Hing (r1AC) Kirtland Air Force Base, NM 87117

Evacuation ............................................ . 49

Po st Er.iergency Procedures ••••••••••••••••.••••••••••••• 51

CLOSURE ................................................... 53

A. Originators •••••••••••••••••••••••••••••••••••••••••••• 53

B. DPDO Storage Facilities •••••••••••••••• , ••••••••••••••• 53

APPENDICES

A. Abbreviations and Definitions • • • • • • • • • • • • • • • • • • • • • • • • • A-1

B. Trai.ning Program., ........•....•........•••.......•.•... B-1

C. Haste Sar.ipling and Analysis Procedures ••••••••••••••••• C-1

D . Figures. • . • • • • • . • • • • . • . • . . • . • . . . • . • • • • . • . • • • . • • • . • . . • . . D-1

1. Inspection Log ••••••••••••••••••••••••••••••••••••• D-1

2. Hazardous Waste Label •••••••••••••••••••••••••••••• D-2

3. Blank DD Fann 1348-1 .••......•.•..•.....•.....••.•. D-3

3a. Instructions for DD Forr.1 1348-1 •••••••••••••••••••• D-4

4. Exar.ipl e DD Fon:i 1348-1 ••••••••••••••••••••••••••••• D-6

5. Blank Form AF 813 ••••••••••••••.••••••••.•••••.•••• D-7

6. Blank DD Fonn 1387-2 •....••.....••...•••••.......•. D-8

v

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I. PLAN SUMMARY

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

The objective of this OPLAN is to facilitate the responsible management

of hazardous wastes (HW) within the boundaries of Kirtland Air Force Base

{KAFB). Hazardous wastes include surplus hazardous substances and may

include, under circumstances described herein, petroleum, oils and lubri­

cants {POL). The OPLAN emphasizes the reuse or recycling of hazardous

materials whenever practical or economically feasible, with disposal of

hazardous waste as a last resort.

The OPLAN provides guidance for the collection, storage, and disposal of

hazardous wastes and excess hazardous materials on Kirtland Air Force

Base (KAFB). Originators of hazardous wastes are required to adhere to

the requirements of this OPLAN and write their own internal implementing

regulations. A Waste Materials Control and Recovery Subconnni ttee ( WMCRS)

of the Environmental Protection Connnittee will monitor implementation of

the OPLAN and provide reconnnendations for improvements. The subcommittee

will be chaired by the Base Environmental Coordinator (OEEV) and will

iriclude membership as specified in paragraph III C.

This OPLAU will implement the requirements of the Resource Conservation

and Recovery Act {RCRA) as established by 40 CFR 260, 261, 262, 263, 264,

265, and 267 and adopted by the state of New Mexico. Also, regulations

issued by the US Department of Transportation (DOT) under 49 CFR 171,

172, 173, 178, and 179 will be implemented, as well as Headquarters Air

Force Engineering and Services Center (AFESC) and Defense Logistics Agency -1-

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

(DLA) guidance. This OPLAN is effective until superseded, amended, or

requirement is eliminated through change in public law.

This OPLAN applies to all KAFB organizations and tenants, with the

exception of the US Department of Energy and Sandia National Laboratories

and associated contractors who are responsible for hazardous wastes under

a separate Environmental Protection Agency permit. KAFB organizations

and tenants employing contractors which deal with hazardous wastes must

task the contractors to comply with this OPLAN to the extent necessary to

ensure that such wastes are handled in a manner compatible with this

OPLAN and applicable law. The KAFB Civil Engineering/Environmental

Section may provide technical guidance to KAFB organizations, tenants and

agencies regarding contractor compliance.

This OPLAN will be implemented at all times. It is ultimately the

responsibility of the 1606 ABW Wing Commander, who has delegated

responsibilities as described herein. Annual updates of this OPLAN will

be completed by 30 January each year, as determined by 1606 ABW/DEEV.

The successful and cost effective management of hazardous wastes and POL

requires proper segregation of waste by category. Segregation maximizes

the chance of sale for non-waste purposes and, where disposal of wastes

by 1 i censed contractor is required, segregation minimizes disposal costs. , \ , d•<':~r· ~J . This OPLAN excludes: (1} asbestos products, (2) hydrazine, and (3) 1 · 1 ·1,~'t~ ~~~t~

u:vt''' .

radioactive material, which are all covered by other regulations or 1/19·~(Ji/\'

OPLANS. Petroleum Products contaminated with solvents (with the 2

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

exception of PD680/Stoddard solvent) are considered hazardous waste and

are subject to tbis plan.

This OPLAN provides for inspection, record keeping, and manifesting to

account for the generation, transportation, and storage of hazardous '

wastes on the Base, as well as shipment to approved off site disposal

facilites. Wastes transferred on the Base will be accompanied by DD

Fonn 1348-1. Wastes transferred off the Base for proper disposal will be

accompanied by the proper hazardous wastes manifest as required under

. Environmental Protection Agency (EPA) and State regulations.

The implementation of this OPLAN will take best advantage of the existing

skills and resources available on the Base, while ensuring that the

hazardous wastes originator retains responsibility for the waste until

the waste is transferred to the Defense Property Disposal Office (DPDO).

The originator of a hazardous waste is responsible for properly

identifying \·tastes and obtaining and filling suitable containers for

disposal. If the \'!aste characteristics are unknmm, the originator is

responsible for analyzing a representative sample of the "'aste for the

parameters necessary to make a proper disposal decis~on. The originator

is further responsible for working with the on call packaging contractor,

\'thich will provide the appropriate shipping labels and dunnage for the

containers. The on call packaging contractor will affix and complete a

DD Forr.t 1387-2 to each container prior to movement. After suitable

3

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1606th Air Rase Hing 01AC) Kirtland Air Force Base, NM 87117

packaging, labeling, and certification the originator must obtain

authorization fror.i DPDO, \·1hi ch Hi 11 direct the originator to deliver the

wastes to a designated DPDO storage facility on the Base. Upon delivery,

the DPDO \'Jill inspect and \·till acce~t accountability and physical control

of the wastes. If possible, DPDO \'fill proceed with arrangements to sell

the material or transfer it to other agencies for use. Othen-ti se, DPDO

will arrange for off site disposal by a service contract.

There \·1ill be no ultimate on site disposal of hazardous \'taste on KAFB.

All wastes will be shipped to approved off site facilitie::.

This OP LAN addresses emergency/contingency response to all hdzardous

waste incidents. \/hile this may duplicate portions of other plans, it is

intended to provide a ready reference for the reporting, containment,

neutralization, and cleanup of all hazardous materials and wastes.

4

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I I. GENERAL

A. Introduction

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

KAFB currently generates a variety of surplus unused chemicals, chemical

hazardous wastes, and POL wastes. The type and quantity of wastes vary

from year to year as research activities and other mission assignments on

the Base change. While the DPDO attr:mpts to find markets for the use and

reuse of surplus and waste hazardous materials, most hazardous wastes

\·1ill require disposal via the hazardous wastes system.

The objective of this OPLAN is to fac11itate responsible management of

hazardous wastes uithin the boundaries of KAFB. The.plan emphasizes

reuse or recycling of hazardous materials whenever practical or economi-,

cally feasible. Implementation of the GPLAN will take the best advantage

of the skills and resources available, while ensuring that the hazardous

wastes originator retains responsi bi1 i ty for the wastes until the time of

turn-in to the DPOO for disposal.

B. Applicable Regulations and Laws

1 . Federal

a. EPA-Resource Conservation and Recovery Act (RCRA)

Regulations promulgated under RCRA and published in 40 CFR parts 260-267

and parts 117-120 cover the "cradle to grave" management of hazardous

-5-

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

wastes. These regulations are enforced by EPA, which contemplates

delegating the authority to the State of New Mexico in 1983.

b. EPA--Toxic Substances Control Act (TSCA}

Regulations.promulgated under TSCA and published in 40 CFR Part 761 cover

the.disposal of polychlorinated biphenyl (PCB) liquids, mixtures, equip­

ment and contaminated materials. The regulations are enforced by EPA.

c. DOT

Regulations promu1 gated by the US Departr.ient of Transportation and

published in 49 CFR Parts 171, 172, 173, 178, and 179 cover the packaging,

labeling and shipment of hazardous substances and hazardous wastes. These

regulations are enforced by the Materials Transportation Bureau of the

Departr.ient of Transportation.

d. Department of Defense, Defense Environmental Quality

Program Policy Memorandum

The Department of Defense and the Air Force have Program Policy Memoranda

and regulations which are modeled after the EPA and DOT regulations on

hazardous wastes transportation, storage, treatment and disposal. The

military regulations direct facilities to comply with the current state

and federal regulatior.s under environmental and transportation laws.

6

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'e. EPA - Clean Water Act

1606th Air Base Wing (MAC) Kirtland Air Force Base, Nl1 87117

Regulations promulgated under CWA and published in 40 CFR Parts 110 to

117 cover the prevention, reporting, and cleanup of oil and hazardous

material spi 11 s affecting wateNays.

f. EPA - Comprehensive Environmental Response, Compensation

and Liability Act (CERCLA) or "Superfund. 11

Proposed regulations under CERCLA would extend the spill response

requirements of the CWA to include a 1 a rger number of materials and al so

spills not affecting waterways. The regulations would be published in

40 CFR Part 302.

g. OSHA - Occupational Safety and Health Act, (OSHA)

Regulations promulgated under OSHA and published ih 29 CFR cover employee

exposure to hazardous chemicals. The regulations al so adopt a portion of

the National Fire Protection Association codes and standards for storage

of flammable liquids.

2. New Mexico State Regulations

-7-

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l606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

a. New Mexico Environmental Improvement Division (EID) will

seek authorization from the EPA to implement a state hazardous waste

program under the New Mexico Hazardous Wastes Act, as amended in 1981.

The New Mexico regulations, proposed under New Mexico statutes as

amended, Chapter 8, Sections 2-14, when final, will be enforceable by the

Health and Social Services Department. When originally promulgated,

these hazardous waste regulations were identical to the RCRA regulations

promulgated by EPA. State regulations may be more but not less stringent

than EPA's.

8

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III. RESPONSIBILITIES

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

This Section of the OPLAf~ describes the roles of the organizational

groups on the Base responsible for hazardous wastes management.

A. Wing Commander

l. Direct, as the sole person responsible, the successful

operation of this OPLAN.

2. Delegate authority for implementation of the OPLAN. The

1606 ABW Vice Commander (1606 ABW/CV) is designated as the chairperson of

the Environmental Protection Committee.

3. Order corrective actions.

4. Direct submission of required reports of Base activites.

B. Environmental Protection Committee (EPC)

1. Appoint a technical subcommittee to act for the EPC in

matters dealing with proper, legal, and safe management of hazardous

wastes on the Base.

2. Designate operational activities to implement this OPLAN.

3. Review annual revisions to the OPLAN, including the annual

forecast of waste materials, provide OPLAN approval, and submit the OPLAN

to HQ MAC/DEE for review.

-9-

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1606th Air Base Hing (MAC) Kirtland Air Force Base, tH'I 87117

C. Waste Materials Control and Recovery Cor.nnittee Subcommittee

(EPC Technical Subcor.1r.1ittee)

l. The committee may include representatives from the follow­

; ng organi zati ons/offi ces.

1606 ABU/SE 1606 ABW/PA 1606 ABH/JA 1606 ABW/SGPB 1606 ABH/DEEV 1606 ABW/DEF 1606 ABW/DPCT

10

1606 ABH/LGT 1606 ABW/LGSF 1606 ABH/TRTC AFCMD/PKB DPDO/DLA AFHL/PRA AFHL/PRP 1550 ATTH

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disposal.

2. Prepare Plans for

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

a. Waste reduction, recovery and recycling.

b. Hazardous materials control, storage, transportation and

c. Oil and hazardous substances Spill Prevention, Control

and Countermeasures plan (SPCC).

d. Data accumulation and special environmental evaluations.

3. Recommend to the Wing cormnander corrective action by Base

organizations and tenants as needed to achieve and maintain compliance

with the EPA, DOT, and state environmental regulatory programs.

D. Civil Engineer (1606 ABW/DE)

1. Provide resources to maintain permits, develop and maintain

this OPLAN, and prepare the required reports for the Base.

E. Base Environmental Coordinator (DEEV)

1. Interface with federal and state regulatory authorities on

hazardous waste management and obtain the necessary permits for the Base.

2. Coordinate the activities of the Waste Materials Control and

Recovery SubcoCllllittee.

-11-

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1606th Air Base Wing (MAC) Kirtland Air Force Base, tJM 87117

3. Advise Base activities and tenants on environmentally

acceptable procedures for storage and disposal of POLs and hazardous

wastes, as detenni ned by the Waste Materials Control and Recovery

Subcommittee.

4. Monitor corrective actions by Base activities where recom­

mendations or orders have been made by the Wastes Materials Control and

Recovery Subcommittee.

5. Develop and maintain a list of hazardous wastes originators

on the Base.

6. Prepare the annual revisions to this OPLAN.

7. Consolidate originator waste forecasts and publish a Base

forecast as part of the annual revision of the OP LAN.

8. Review hazardous waste information submitted by tenants on

the Base at the inception of new projects, as part of the forecasting of

hazardous waste generation and disposal needs.

9. Work with DPDO to determine the anticipated hazardous waste

loads and with SGPB to anticipate chemical analysis requirements.

10. Provide assistance to the Base tenants on the analysis of

unknown wastes to expedite the selection of proper disposal methods.

11. Provide training in cooperation with military and civilian .

personnel on KAFB waste management procedures to the responsible persons

from the waste generating organizations, as required •

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l606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

F. Fuels Management Officer ( 1606 AB W/LGSF)

l. Recycle fuel for further use where economically feasible.

2. Analyze, when appropriate and within the abilities of the

Base Fuels Laboratory, all questionable waste petroleum products to

determine the highest value recycling or reuse possibility.

3. Report off-specification fuels, which cannot be downgraded

locally or returned to a contractor, to fire protection branch (DEF) for

possible use in fire department training. Fuels containing more than

10 percent by volume of oil or lubricants may not be used for fire train­

; ng.

4. Assure that vehicles authorized to collect and store waste

fuels ~re clearly labeled and segregated from aircraft fueling equipment.

G •. Base Safety (SE) and Fire Safety (DEFT)

l. Conduct routine inspections of hazardous waste ori gi nati ng

activities and report to DEEV any unsafe collection storage, or transpor-,

tation of waste petroleum and hazardous wastes. Monitor and report

correction of hazardous conditions in accordance with AFR 127-12, as sup­

plemented. Assist DEEV and SGPB to prescribe corrective actions and

monitor implementation of the actions.

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.

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

H. Bioenvironmental Engineer (SGPB)

1. •Work with DEEV to detennine the analytical protocol for

identification of unknown wastes. Provide chemical analysis of the

wastes within the capabilities of the U.S. Air Force Occupational and

Environmental Health Laboratory.

2. Report to DEEV any improper collection, segregation, and/or

storage of waste petroleum products or hazardous wastes. Recommend cor-

rective actions where improper waste management is found.

3. Provide technical assistance to the Transportation Squadron

on the identification of proper chemical nomenclature necessary to

properly label wastes for transportation.

I. Defense Property Disposal Office (OPOO/DLA)

l. Detennine the governmental and civilian market demand for

used petroleum products, surplus hazardous substances and wastes. Report

to the Waste Materials Control and Recovery Subcommittee the demand and

price for these materials and advise on any collection or segregation

methods tthich might increase the market value or decrease disposal costs.

2. Dispose of hazardous wastes and POLs in accordance with

Defense Logistic Agency (OLA) policy procedures and comply with state and

federal regulations. Manifest hazardous wastes for shipment to off-base

disposal sites.

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

3. Maintain a hazardous waste storage facility in accordance

with federal and/or state regulations. Prepare a "Standard Operating ·

Procedure for Owners and Operators of Hazardous Waste Treatment, Storage,

and Disposal Facility" for KAFB's facility following the guidelines

established by DLA. TI1e facility is for temporary storage, pending off­

site disposal. Tenninal storage by DPDO is not authorized.

4. Maintain an inventory of hazardous \'lastes and POL turned in

to DPDO stored on the Base. Inspect the POL and hazardous wastes storage

areas under DPDO control weekly for leaks in containers and the integrity

of the storage faci 1 i ty. Keep records of the inspections and the waste

shipments in accordance with federal and/or state regulations.

J. Waste Originators

l. Prepare and document local plans for delegation of

hazardous waste responsibilities in accordance with this OPLAN within the

originator's command.

2. Collect, segregate and temporarily store waste POL, surplus

chemicals, and hazardous wastes according to the requirements of this

OP LAN.

3. Compile and maintain records of hazardous materials

characteristics to include in the waste manifest at the time of transfer

to DPDO for disposal. Request sampling and chemical analysis by SGPB of

unkno\/n wastes to expedite disposal. If Air Force testing is not

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1606th Air Base Wing (MAC} Kirtland Air Force Base, NM 87117

available on a timely basis, then the originator must obtain analysis

directly from a laboratory using EPA approved analytical methods.

4. Obtain sufficient DOT approved prime containers to segregate

and hold the wastes in temporary storage.

5. Arrange with the on call packaging contractor, if

practical, to package and overpack at the collection site. If not, the

on call packaging contractor will transport the wastes or hazardous

substances to a designated collection and packaging point for proper

overpacking and labeling. The originator will arrange to transport the

wastes to DPDO for final disposition, after approval from DPDO. All

wastes delivered to DPDO must·be accompanied by a completed DD

Fann 1348-1 {DOD single line item release/receipt document). The

originator must certify on the fonn that the wastes are as described.

The certification statement will be completed according to DOT/EPA

regulations. A Form 1387-2 will be affixed to each container.

6. Designate a responsible person and an alternate to manage

and control the wastes generated and provide information to emergency

response personnel on the nature and safe handling of hazardous sub­

stances during emergencies. Report their names, offices, and telephone

numbers to DEEV for publication in a list of designated persons.

7. Provide assistance to DPDO should problems arise related to

integrity of containers or labeling, before the waste leaves the Base.

8. Provide an annual calendar year forecast by 15 December

each year to DEEV of the types and quantities of POL and wastes expected

to be generated. Report the actual quantities and types of wastes

generated in the ongoing year and the present methods of segregation and

disposal.

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l606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

9. Inspect hazardous waste collection points on a daily

schedule. Record any deficiencies on inspection logs. Take corrective

action to correct any deficiencies. Inspection logs will be maintained

at the collection point for one year, then forwarded to DEEV for review.

10. Mark all waste collection containers with an identification

number, a date on which wastes were first placed in the container, and a

list of the type of hazardous wastes contained. Maintain records, for at

least one year from the date on which the container is filled and

turned-in to DPDO, of the identification of the container and the con-

tents of the container, including the characteristics of each increment

of wastes if the container was not filled at one time. Maintain records

'of weekly inspections of the originator's waste collection area.

11. Properly utilize oil-water-sand separators. Report to DEEV

any abnormal or full separator. An off-base contractor under the direc-

tion of 1606 ABW/DE will provide scheduled servicing of the separators.

12. Prevent unacceptable disposal practices such as dumping

liquid POL and hazardous wastes into sewers, storm drains, waters, dump­

sters, or landfills.

13. Prepare an AF Form 813 at the time of planning and

programming of new projects. Submit the form, including an estimate of

the type and quantity of wastes to be generated by the project, to DEEV

for inclusion in the wastes forecasts. Wastes omitted on the form and

subsequently generated by the project may not be eligible for disposal

through DPDO channels without further approval.

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1606th Air Base Wing (MAC) Kirt1and Air Force Base, NM 87117

14. Provide in cooperation with DEEV and.DPCT, training for all

persons handling hazardous wastes, record keeping, waste segregation and

' the procedures of this OPLAN. Ensure the task of handling of hazardous

waste is included in each affected person's job description. Maintain

records of personnel training.

K. Central Procurement ACFMCP, Contract Administration AFCMD/TM and

Tenants

1. Obtain from DEEV an AF Form 813 at the time of programm'i ng

of a new project at KAFB. Provide a best estimate of the quantity and

types of wastes to be generated. Transmit completed copies of the form

to DEEV and to DPDO.

2. Negotiate, with DPDO, the costs and method for disposal of

wastes to be generated by the project. Note that this requirement may be

waived by DEEV if the waste quantities are small.

3. Obtain from contractors and subcontractors a commitment for

·personnel training in hazardous waste handling, as required for military

and civilian personnel by this OPLAN.

L. Preservation and Packaging Contractor

1. Consult with originators, DEEV, SGPB, DPOO on the prime

container appropriate for hazardous waste and identification labels.

Provide the labels as appropriate.

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

2. Check the condition, materials, and labeling of prime con-

tainers to be overpacked for compliance with DOT requirements.

3. Provide the proper shipping labels and overpacking required

to meet DOT and EPA requirements for shipment of hazardous substances and

wastes off the Base.

4. Coordinate, with originators, on handling, containerizing,

and packaging of wastes at the collection site or at the designated

collection point, as appropriate. If special handling, loading, or

transportation equipment is required, coordinate with the originator to

obtain the equipment.

5. Provide, on request by the originator, or DPDO trained

personnel to pack, repack, or overpack the hazardous materials.

M. Base Supply

1. Maintain an inventory of absorbant materials for hazardous

substance spill cleanup, oversized 85-gallon drums (to contain leaking,

or suspect 55-gallon drums), and truck hazardous waste placards.

N. Personnel, Civilian Employee, Development and Training (DPCT)

1. Ensure that hazardous waste handlers have their responsi­

bilities and training requirements included in their job descriptions.

2. Provide hazardous waste handling training courses as

required by this OPLAfJ.

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1606th Air Base Wing (r.1AC) Kirtland Air Force Base, NM 87117

3. Assist commands in maintenance of training records.

0. Judge Advocate 1606 ABW/JA

l. Work with the Base comptroller to detenni ne damages in the

event of hazardous materials spi 11 s, per the Hazardous Substances

Pollution Contingency Plan.

2. Initiate legal action, as necessary, to recover damages, per

OPLAN 80-6.

3. Assist in the interpretation of applicable statutes and

regulations.

P. Public Affairs Division 1606 ABW/PA

l. Provide responses to inquiries from off-Base sources on

hazardous materials incidents or spills, per the Oil and Hazardous

Substances Pollution Conti gency Pl an.

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IV. COLLECTION AND SEGREGATION

1606th Air Base Wing (MAC) Kirtland Air Force Base, Nf.1 87117

This section describes the waste segregation and collection procedures

for waste· originators.

A. Technical Orders

Technical Orders for management of contaminated fuels and oils are set

forth in Orders numbers T0-35-1-3, 36-1-3, 42 8-1-l, and 42 8-1-23.

There are no corresponding Orders for hazardous wastes. Rather, the EPA,

DOT, and New Mexico regulations apply.

B. Record Keeping of Collection and Disposal Actions

The responsible person designated in paragraph III. 1. 6. shall maintain

specific records at the waste collection site including the date on which

Nastes were first placed in each numbered container, the date when the

container was filled, the contents, by percent, of each increment added

to the container, the date of transfer to DPOO and a description of the

waste and quantity. The records must be sufficiently detailed and com­

plete so that the originator can certify, in good faith, the contents of

the container at the time of disposal. For example, the originator may

have to certify that the wastes contain no halogenated solvents.

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

C. Collection Container, DOT Certified

Proper packing begins at the time of initial material accumulation. DPDO

wi 11 not accept hazardous t'iastes or materials unless they are properly

packaged, labeled, classed, and in good condition for transpor-t. It is

the responsibility of the hazardous waste originator to meet the follow­

; ng requirements.

1. Container Selection

Hazardous waste containers shall be approved by the Department of

Transportation (DOT) for hazardous waste transportation. The containers

shall be compatible with the waste. Hazardous waste analysis provides

infonnation useful in selecting compatible containers. Before a container

w~ich held any material is reused to store hazardous waste, the compati­

bility of the previous material and the \'/aste will be checked. If the

material and waste are incompatible, the container will be triple rinsed

\'lith a solvent capable of completely removing the previous material before

the container is reused. Compatibility of the waste and the cleaning

solvent sl1all be checked also. If there is a doubt about compatibility,

either triple rinse or don't use the container. Containers shall be in

good condition (i.e., no rust, no dents, proper seals, bungs with all

gaskets, etc.) and of a reusable type. DOT-certified drums can be iden­

tified by looking at the bottom of the drum for the DOT specification

number (e.g., l7E, 17H, 37H, 37P, etc.). The container used for

collection must be a container suitable for shipment. Small

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

containers may be packaged with other compatible materials. Contact the

on call packaging contractor and determine the correct container. Obtain

the container through one of the following: supply, DPDO, or after

coordination with DEEV, the packaging contractor.

Collection containers must be made or lined with materials which will not

react with and are otherwise compatible with the wastes to be stored, so

that the ability of the container to contain the waste is not impaired.

For small quantities of chemicals, that is up to 10 gallons, the

originator may use the container in which the raw material chemical was

received. For larger quantities suitable metal, plastic lined, or plastic

drums up to 55 galions may be preferred.

2. Container Management

Containers must not be opened, handled, or stored in a manner which may

rupture the container or cause it to leak. A damaged or leaking container

of hazardous waste may be placed in a DOT-approved overpack container, or

the contents transferred to another suitable container. All hazardous

waste containers must be closed during storage, except when adding or

removing waste. A minimum of four (4) inches of air space will be pro­

vided in all containers to allow for expansion. For fla1T111able liquids,

containers must be electrically grounded and have an appropriate closure

device to prevent vaporization or entry of water. The drums or

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

containers may be mounted on carts, doll eys, or trailers to facilitate

mobility, safety, and ease of handling.

3. Container Location

Waste Chemical or POL containers may be installed at the generator site,

after the location is approved by the Safety Office and the Fire Depart­

ment. Containers must be placed in locations which comply with the

Nati anal Fi re Protection Association Codes and the Base Spill Prevention

Control and Counter Measure Pl an. Containers must be stored with adequate

isles for emergency equipment access. Storage must be arranged such that

all sides of each container are visible for inspection, which precludes . stacking and "bunching" of containers.

4. Collection Time Limits

a. POL

A DPDO outside service contractor will collect waste POL from designated

collection points on the Base at 1 east once per month. Therefore, waste

POL storage should not exceed 60 days.

b. Surplus hazardous substances and hazardous wastes.

Originators shall arrange for proper disposal of full hazardous waste

containers or partially filled containers (into which no further wastes

will be placed) before they are filled and in no cases longer than 72

hours after the container is full. DPDO will be notified before the

containers are full to allow for inspection prior to turn-in. DPDO will

assign a container number.

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5. Container Marking

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

a. Containers for fl ammab 1 es (fl ash point temperature below

l00°F), such as petroleum products, solvents, paint thinner, and flam­

mable chemicals shall be painted red with a yellow band around the center.

TI1e yellow band shall not exceed 1/3 of the container height.

The identity of the contents, including name, United Nations {U.N.)

number, and other pertinent safety infonnation, e.g. "flammable" shall be

lettered in one-inch red letters in the yellow band. The markings shall

be in accordance with AFM G7-l, AFR 69-8, and for AFOSH standards. Also,

the proper label identifying the contents, per 49 CFR 172 shall be

applied to the container. These containers may be maintained on a

long-term basis by the originator and emptied on a monthly schedule by a

DPDO service contractor.

b. Containers of nonflammable POL products shall be painted

red with a yellow band around the center of the container. The yellow

band shall not exceed 1/3 of the container height or length. The identity

of the contents and any pertinent safety i nfonnation will be written in

one-inch-high red letters in the yellow band. The originator may maintain

the containers for long-term use. The containers will be emptied on a

monthly basis by a DPDO service contractor.

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1606th Air Base Hing (MAC) Kirtland Air Force Base, NM 87117

c. Storage tanks, bowsers, and tank trucks will not be used

for waste products unless specifically authorized and clearly narked in

accordance with TO 36-1-30.

d. Hazardous waste containers will be narked with the

yellow and black or yellow and red label required by EPA. The label will

pro vi de the foll O\'ti ng i nfomati on:

1. The noun and cheaical nar.ies of the hazardous waste( s),

percentage of each contaminant (if mixed), the DOT identification number,

and the DOT container specification number.

2. Uarne and address of the generator (in most cases this will

be Kirtland AFB, NM 87117).

3. The EPA pemit number for Kirtland AFB: rm-571824423.

4. The date when filling of container was begun.

5. The combined weight of the container and waste in kilograms.

6. The barrel or container number. These are assigned by DPDO

when hazardous waste turn-in is requested.

7. Containers will have all previously used labels removed

and/or covered to preclude possible error of identification. An example

of the 1 abel , \'lhi ch may be obtained from Base supply, is shown in

Figure 2. In addition, the proper DOT labels, e.g., 11 flar.u:1able, 11

11corrosive, 11 etc, must be attached to the container.

e. Surplus hazardous substances, e.g., unopened new

containers of chemical compounds, solvents, acids, or bases, should not

be 1 abel ed as hazardous waste unless DPDO detemi nes that there is no

reutilization, transfer, donation, resale, or r.iarket value for the

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1606th Air Base Wing {MAC} Kirtland Air Force Base, l~M 87117

substances and that the material must be disposed of as hazardous waste.

The proper DOT shipping i nfonnati on and 1 abel s must accompany turn-in of

such materials, even if they are not wastes. The originator must verify

that labels are attached and legible.

D. Segregation of Materials

Non-compatible wastes shall be segregated at all times. The segregation

of hazardous substances, hazardous wastes and POL into the categories

described below will minimize disposal costs in most cases. Where

di sposa1 alternatives and market conditions indicate that mixing certain

wastes is more practical, the DPDO and SGPB will advise the originator.

1. Halogenated Wastes

Halogenated solvents {those containing flourine, chlorine, bromine, or

iodine) shall not be mixed with nonhalogenated solvents or other

nonhalogenated compounds. Examples of halogenated compounds are methylene

chloride, trichloroettzylene, chlorinated waxes and oils, freons, and

methyl iodide. These compounds fonn corrosive acid mist and vapors when

burned. All halogenated wastes will be turned over to DPOO and disposed

of by a service contract, per RCRA regulations.

2. Polychlorinated Biphenyls (PCB}

PCBs are primarily used as dielectric fluids in electrical capacitors and

transformers. PCBs are toxic and their use and disposal is heavily

regulated under the TSCA. Any liquid or solid electrical unit with more

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l 606th Air Base Wing {MAC) Kirtland Air Force Base, NM 87117

than 50 ppm of PCB is regulated. Consequently, any mixing of PCB

materials with non-PCB materials or any PCB spills can result in a very

large and expensive clean-up and disposal cost. If a spill occurs, seek

immediate help from DEEV and SGPB and refer to the Oil and Hazardous

Substances Pollution Contingency Plan. Storage, manifesting and disposal '

of PCBs shall be arranged with DPOO. Trade names for PCBs include but

are not limited to: VV-1-1219, Askarel, Aroclor, Pydraul, Therminol,

Pyroclor, Santothenn, Dykanol, Elemex, Hyvol, No-Flamol, Saf-T-Kuhl,

Aroclor-B, Clorinol, Clorphen, and Eucarel.

3. Silver Bearing Photographic Property and Precious Metals

TI1ese chemical compounds and electrical units are to be segregated for

disposal through the Base precious metals reclamation program.

4. Acids and Bases

TI1ese wastes will be kept separate from each other and other noncompa­

tible vastes prior to disposal.

5. Non-halogenated Solvents and Organic Compounds

Materials in this category shall be kept separate unless DEEV and DPDO

authorize mixing. Some of these substances became hazardous waste by

definition after use.

6. POL

The petroleum products listed below describe the categories and

subcategories of POL for segregation purposes. Inclusion within a

category does not necessarily imply that a specific oil or lubricant may

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87-117

be mixed for disposal purposes, as a specific POL may be reclaimed for a

high value reuse.

a. Category l : Fuels

( l ) Calibrating Fluid· (ML-C-7024)

(2) Purging Fluid (MIL-F-38299)

(3) Jet Fuels and Kerosene

(4) Avgas

(5) Mo gas

(6) Diesel Fuel

b. Category 2: Hydraulic and Lubricating Fluids and Oils

(l) Hydraulic Fluid, Mineral Based (MIL-H-5606,

MI L-H-6083)

(2) Mineral Base Solvents (P-D-680)

(3) Lubricating Oils

(4) Preservative Oils

c. Category 3: Engine Oils

Category three oils may be contaminated by lead and

therefore considered a hazardous waste. This category

must be kept separate from other petroleum products.

(1) Used Motor Crankcase Oils (MIL-L-46152)

(2) Reciprocating Aircraft Engine Oils (MIL-L-6082,

MI L-L-22851 )

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l606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

d. Category 4: Synthetic Oils

Used Turbine Engine Oils (Synthetics) (MIL-L-7808,

MIL-L-23699)

e. Category 5: Mixed Liquids

~Ji xed petroleum 1 i quids can not meet the segregation

requirement of categories 1, 2, 3, and 4 above because

they are contaminated by halogenated solvents, oil/water

emulsions, industrial chemicals, or related materials.

Petroleum in this category is normally considered waste.

7. Water Contamination

Water ~an enter POL from condensation, from direct precipitation into the

containers, and by overpumping of oil/water separator sumps. Water

contamination reduces the recycling market value of the POL and should be

prevented by proper maintenance and operation of containers, funnels and

equipment. I

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V. STAGING AND STORAGE AREAS

A.' Collection Points

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

The collection point is a designated area at or near the waste

originating site, which has been approved by DEEV, SGPB, Base Safety and

Fire Safety. Collection points are restricted to accumulating only enough

wastes to compile a feasible load to transport to DPDO for resale or

disposal. Unless the collection point has an EPA pennit for waste stor­

age, waste ~aterials shall not be held longer than 90 days, except for

single drums of a specific waste, which may be held until full. The full

container must be transferred to DPDO within 72 hours.

B. Storage Areas

Storage areas require an EPA storage permit and be under the control of

the 1G06 ABW/CC and may hold wastes longer than 90 days. In this OPLAN,

DPDO will operate the storage areas and initiate waste disposal from these

areas, except where wastes are diverted for recycling, fire training, or

other uses sanctioned by DEEV. Storage areas must be operated in compli­

ance with EPA and DPDO requirements for:

l. Security

Access must be restricted by locked fences or doors.

2. Posting

Signs must indicate hazardous waste in/or at PCB storage.

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· 3. Inspections

1606th Air Base Wing (MAC) Kirtland Air Force Base, ~JM 87117

Weekly inspections for container condition etc, must be documented in

wr.i ting.

4. Communications

A telephone and/or radio must be immediately accessible at the storage

site unless two or more employees are present at all visits to the site.

5. Fi re Control

Suitable fire extinguishing equipment, including portable and/or fixed

devices must be provided.

6. Emergencies

A contingency plan for each collection site must be prepared to anticipate

the response to sudden and non-sudden release of hazardous waste to air,

soil, or surface water.

C. Spill Prevention

Collection and storage areas must have spill prevention measures such as

curbing or trays to contain potential spills. If the areas are outside,

they should be kept as clean as possible to prevent contaminated storm­

water runoff. ru1 collection in storage areas will be subject to the Oil

and Hazardous Substances Pollution Contingency Plan. Proper security

and/or limited access must be provided.

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VI. DISPOSITION OF WASTE PRODUCTS

A. Disposition of Fuels

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

All disposal shall be consistent with the spirit and the intent of

national and environmental pollution control acts and associated regula­

tions, Air Force directives, Technical Order, TO 42 B-1-23 and this plan.

1. Aircraft Fuels

a. Residual fuel removed from aircraft should be returned

to bulk storage tanks if the quality of the residual fuel can be deter­

mined locally to be acceptable. If the quality cannot be detennined, the

suspect fuel will be stored temporarily in tanks or drums until the Base

Fuels Laboratory detenni nes \'/hether or not the fuel is satisfactory for

reuse. When tests show the fuel is not usable in aircraft, support

equipment or ground vehicles, the fuel may be used for fire training, in

heating plants, or sold through DPDO. Only clean containers will be used '

to store the fuel temporarily. When a reclaimed product is returned to

Base stocks, a minimum of two filtrations is required. Reclaimed pro-

ducts should always be returned to bulk storage, and not to operating

tanks, except when there is no bulk storage. The reclaimed product should

be diluted at a ratio of at least 1 gallon to 25 gallons in the bulk

storage. Tiie reclaimed material should be returned to the bulk tank so

that is followed by a nonnal delivery of fuel to the transporting tank,

as a means of ensuring that the reclaimed product is not left in the

lines and subsequently issued undiluted to trucks or hydrants.

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2. Ground Fuels

l 606th Air Base I-Ii ng (MAC) Kirtland Air Force Base, NM 87117

a. All fuels drained from motor vehicles, heavy equipment,

power generators, etc., shall be collected in clean containers and either

returned to the sar.ie source fror.t which the fuel was taken, or returned to

Base stock in accord8nce with prescribed accounting procedures. Ground

fuels unsuitable for reuse shall be considered for fire departraent

training, fuel for heating plants, or as a last resort, sale through DPDO.

' B. Disposition of Used Oils

Mineral and synthetic oils will be evaluated for reuse prior to down-

grading for fuel oil or disposal.

l. Mineral Oils

Oils and hydraulic fuels drained from aircraft must be collected in clean

containers and segregated. If refining of oils is not feasible or

profitable, the blending of centrifuged, filtered or settled waste oii

with burner fuel (DD-F-815) should be considered. Waste oils blended for

fuel must be treated to remove solids to prevent burner nozzle clogging

and/or excessive stack emissions. Burning untreated or unblended waste

oil should not be attempted without prior consultation with OEEV. Mineral

oils contaminated with halogenated solvents will not be blended with fuel.

These require special off site disposal, as discussed ahove.

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l 606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

2. Synthetic Turbine Engine Oils

Synthetic turbine engine oils command a high resale price even after

use. Conseqwently, such oils must be segregated. More than 2 to 3

percent of contaminants such as jet fuel and hydraulic oils render the

synthetic oil unfit for recycling. Synthetic oils MIL-L-7808 and

MIL-L-23699 will be collected in clean 55-gallon drums labeled "used jet

engine oi 1 only. 11 All synthetic oils will be disposed of by DPDO.

3. Prohibited Practices

Waste oil will not be used for weed control, insect control, fire

training exercises, or road dust control or disposed of by open burning

or dlll1pi ng.

C. PCBs

Any transport or disposal of PCB articles, equipment, liquids, or spill

residue will be handled on a case-by-case basis. The originator should

contact DEEV and DPDO for instructions.

D. Surplus Chemicals and Chemical Waste

New hazardous chemical substances in their original container or another

container in good condition are not considered hazardous waste. These

chemicals may have significant reuse or resale value. The prime

container should be properly packaged for off-Base transport and the

material turned-in to DPDO. Contaminated or used chemicals should be

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

properly packaged in prime containers and then prepared for off site

shipment by the on call packaging contractor, including the proper

hazardous waste label. The originator will be responsible for

identifying by percent each identifiable contaminant. Otherwise the

wastes will be transferred to a licensed service contractor for

disposal. Small quantities of acids or bases may be neutralized by the

waste originator for disposal to the sewer system, after approval by DEEV

and SGPB.

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VII. TURN-IN PROCEDURES

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

This section describes procedures for originators to follow when

turning-in hazardous substances or \·1astes to DPDO.

A. Technical Infonnation

1 • Chemi ca 1 fJames

The originator must provide the proper generic chemical name for the

wastes. If there is doubt about the na~e, the originator should contact

DEEV or SGPB.

2. Chemical Contents

If the originator is uncertain of the chemical constituents in the

hazardous wastes he should refer to the Waste Analysis Pl an in Section X

of this OP LAN.

3. Shipping Name

The originator shall obtain the proper chemical name. Then, the proper

shipping name will be detennined by consulting with the on call packaging

contractor.

B. Documents

Hazardous wastes and hazardous substances turned-in to DPDO must be

accompanied by the following completed documents. The listing in DD Form

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l 606th Air Base ~/i ng (MAC) Kirtland Air Force Base, NM 87117

1348-1 and the labels must be consistent with each other and accurately

reflect the container contents.

1. DD Form 1348-1 (DOD Single Line Item Rele-ase/Receipt

Document).

A OD Form 1348-1 must be completed for each type of waste in a shipment.

The l~ttered areas shown in Figure 3 and Figure 3a must be completed and

a certification nust be signed. A certification, for instance, that

there ire no halogenated \'tastes in shipment, must also be included at the

direction of DPOO. Example of completed fonns 1348-1 are shm·m in Figure

4,. Any analytical test results which describe the wastes must be

attached to the form.

2. labels

A completed hazardous waste 1 abel must be affixed to each hazardous \'taste

container. An example of the label is shown in Figure 2, and is des­

cribed in Section IV.C.4.d. of this Plan. The hazardous waste label does

not apply to waste POL. The label is also not applicable to hazardous

chemical substances which are uncontaminated and likely to be sold for

their intended purposes. PCB \·tastes require special labeling, which may

be obtained from DEEV. In addition, the originator must affix the proper

DOT shipping labels to each container. labels shall indicate character

of container contents, e.g., flammable, corrosive, etc.

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3. Off-base Shipments

1606th Air Base Wing (MAC) Kirt1and Air Force Base, NM 87117

If hazardous wastes to be turned-in to OPOO must be transported over

pub1ic highways, the proper DOT manifest must accompany the shipment.

C. Packaging

The originator must arrange with the on ca11 packaging contractor for

proper overpacking, including dunnage, palletization, etc., for off-Base

transport. The on call packaging contractor will also verify the

correctness of the DD Form .1348-1, the application of the proper

Hazardous Waste label (if any), the DD Form 1387-2, and that the

container markings are consistent.

D. Turn-in to DPDO

After completion of the identification, labeling, and packing of the

waste materials, the originator shall obtain authorization from DPDO to

deliver the materials directly to one of the DPDO's hazardous waste

storage areas. A DPDO representative will meet the originator at the

storage area and accept the waste by signing the DD Form 1348-1. If

special transport, handling equipment, or other services are required

from the Transportation Squadron, these arrangements will be made by the

originator.

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VIII. NEW WASTE SOURCES

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

This section describes the procedures for forecasting and planning to

manage new waste disposal loads.

A. Notification

Prior to programming and planning a new project, all KAFB organizations

and tenants must submit a completed AF form 813, Request for

Environmental Impact Analysis, to OEEV. Contractors and subcontractors

will provide information on the form through their sponsoring tenant or

Base organization. A sample form is shown as Figure 5. The form must

include a forecast of the chemical and/or POL wastes which will be

generated by the project. Waste container specifications and special

handling and/or disposal considerations must also be included. OEEV will

consult with TRTC and then advise the project manager (waste originator)

of the containers necessary to package of the proposed wastes and the .

disposal procedures. The originator may be required to negotiate the

packaging and handling costs with the on call packaging contractor, if

the waste quantities are large. DEEV may waive the fee requirements of

this section if, in tr.eir judgment, the project will not generate a

significant cost to properly handle the waste.

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IX. PERSONNEL TRAitHHG PROGRAM

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

This section describes the personnel training program necessary to ensure

proper handling of wastes on the Base and to comply with the Federal and

· State hazardous waste regulations.

A. Responsibility and Scope

1. Training Manager

The DEEV will act as training overseer. The DEEV's competence is based

on the knowledge of hazardous waste regulations, this plan, and training

received from onand off-Base seminars conducted by governmental or private

business organizations. Training seminars for on-Base personnel will be •

cond~cted by DPCT with assistance from DEEV, Base Safety, Fire Department,

Bioenvironmental Engineering, DPDO, and Transportation Squadron.

Originators shall provide on-the-job training as necessary.

2. Training Participants

Waste generating organizations, tenants, contractors, and subcontractors

will send their responsible persons and alternates to the on-Base train­

; ng program. The responsible persons from the organizations parti cipat­

ing in this OPLAN, as listed in Section III, will also attend the

training session.

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'..,..,,, -~::..• V,. • ' •• •• •••• - , ~· • V"

B. Schedules

< ... ··--··. '~·" • -"' •••• _,.,,.... .... •• '"'· ••• ' ' • • •? • •

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

Waste originators and participants in this OPLAN will provide on-the-job

training in hazardous waste handling procedures within six months of

assigning an employee to a hazardous· waste management role. Employees

must not \"#Ork in unsupervised hazardous waste roles before receiving

training. The DEEV will provide specially scheduled training to accom­

modate a significant number of employees with new hazardous waste

responsibilities.

C. Training Program Contents

A detailed description of the training program is included as Appendix B

of this OPLAN.

The training program will include:

1. The waste handling procedures described in this OPLAN.

2. Procedures for selecting containers, inspecting storage

areas, and properly labeling and manifesting waste shipments.

3. Operation of any special communication or alarm systems

related to hazardous waste storage.

4. Procedures to respond to fires and spills related to wastes.

5. Waste segregation methods.

6. Changes in the OPLAN, forthcoming changes in regulations,

and feedback from participating organizations on ways to improve this

OP LAN.

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D. Records

l. Job Descriptions

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

The responsible person and the alternate at the originating organization

and participants in this OPLAN will have a written description of their

hazardous waste responsibilities and training requirements in their job

description. KAFB Organizations and tenants along with DPCT, are

responsible for the job descriptions.

2. Records

A record of the initial, periodic, and on-the-job training received by

the participants in this Plan will be maintained as part of the indivi­

dual's personnel record. This record will be maintained for as long as

the hazardous waste facility is in operation or until at least three

.years beyond when the employee's responsibilities no longer include

hazardous waste management. The records, or summaries, shall be readily

available for review by DEEV, and inspectors of EPA or the New Mexico EID.

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X. WASTE ANALYSIS

1606th Air Base Wing (MAC) Kirtland Air Force Base, IJM 87117

This section describes the procedures for sampling and identifying the

composition of unknown wastes, to facilitate disposal.

A. Unknown Wastes

1. The composition of wastes which have not been tracked by the

record keeping procedures outlined in this OPLAN shall be sampled and

analyzed before the product will be turned-in to DPDO. The originator is

responsible for the analysis and the laboratory results must be submitted

with the turn-in documents. If the Air Force Occupational and Environ­

mental Health Laboratory cannot provide this service, then the originator

\"fill have to contract with an outside laboratory for the analysis.

Originators may contact the SGPB for assistance in collecting the sample

and having it analyzed. EPA approved analytical methods shall be used.

The originator has the following options in identifying the constituents

of the hazardous \"taste:

a. If the originator knows the general contents of the \·taste

and and can get a good feel the percentages (within 5%), he can use this

infomation in lieu of laboratory analysis (NOTE: Segregation of waste

aids in this type of identification).

b. If the originator has no idea what the waste is (perhaps

the waste is old or has just turned up in his work area) or whether or

not it is hazardouz, he should consult with SGPB on proper sanpling

techniques.

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1606th Air Base Hing (MAC) Kirtland Air Force Base, NM 87117

c. If the originator knows the general contents of the

waste, but has no feel for the percentages of the various constituents,

then he should ask the SGPB to take a sample and obtain a definitive

waste analysis. The originator must also provide a list of the known

constituents.

2. The originator \'Jill continue to use the waste identification

obtained as directed above on all wastes from the same process unti 1

either (1) his work process changes or (2) a check analysis perfonned by

a TSO facility (on or off-site) shows a discrepancy in the identification.

If a discrepancy is found, the originator may ask SGPB for a new sampling

and analysis. If the work process changes, the originator can rely on

one of the options of the previous paragraph to obtain new identification

infonnation. The originator will also formally notify DPDO whenever the

work process (and hence the waste cha racteri sti cs) change.

B. Test Sampling Methods

Methods for sampling unkno\'m hazardous waste products shal 1 be in

accordance with Appendix 1 of Part 261 of EPA Regulations, as given below:

1. Extremely viscous 1 i qui d--ASTM Standard 0140-70 crushed or

powdered material--ASTM Standard 0346-75 soil or rock-like rnaterial--ASTM

Standard 0420-69 Soi 1-1 ike materi al--ASTM Standard 01452-65.

45

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

2. Fly Ash-like material--ASTI-1 Standard 02234-76 (ASTI-1 Standards

are available from ASTM, 1916 Race St., Philadelphia, PA 19103.)

3. Containerized liquid wastes-- 11 COLIWASA 11 described in "Test

Methods for the Evaluation of Solid Waste, Physical/Chemical Methods,"

U.S. Environmental Protection Agency, Office of Solid Waste, Washington,

D.C. 20460. (Copies may be obtained from Solid Waste lnfonnation, U.S.

Environmental Protection Agency, 26 W. St. Clair Street, Cincinnati, Ohio

54268).

4. Liquid waste in pits, ponds, lagoons, and similar

reservoirs--"Pond .Sampler" de~cribed in "Test Methods for the Evaluation

of Solid Waste, Physical/Chemical Methods."

Test methods shall be in accordance with EPA standard test methods for

the particular material being analyzed. Further details of sampling and

analysis methods are provided in Appendix C of this OPLAN.

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XI. EMERGENCY RESPOt-JSE

A. Scope

l 606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

The timely and effective response to spills or mishaps involving

hazardous materials and wastes is mandatory in order to provide counter­

measures which will eliminate or reduce the possibility of exposure and

contamination of people and resources. This section is aimed at provid­

ing the procedures, i nstructi ans, and management structure to achieve

this end.

B. Response Actions

KAFB has developed plans for response to disasters of all types. There

are Air Force Regulations {AFR 93-2), an Oil and Hazardous Substances

Pollution Contingency Plan and a Spill Prevention Control and

Countermeasure Pl an ( SPCC) \-Jhi ch address the specifics. The KAFB SPCC is

the primary plan for response to all emergency/contingency conditions

involving hazardous material, chemicals, petroleum products, or wastes of

this nature on-base.

C. Arrangements for Outside Emergency Services

The facilities of KAFB are considered adequate to fight fires and provide

other emergency services for on-base emergencies. Cooperative agreements

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l 606th Air Base Wing (MAC} Kirtland Air Force Base, NM 87117

between KAFB and the City of Albuquerque exist for mutual aid in the

event of a major fire, ambulance, or hospital crisis.

D. Facility Emergency Coordinator

The emergency coordinator or his alternate will be available at all times

to coordinate emergency response measures. At KAFB, ·this coordinator

will not necessarily be the on-scene coll'lllander of the spill response •

team~ but will be a direct advisor to the on-scene commander.

E. Emergency Equipment

Emergency response equipment will be made available as listed bel0\'1; for

any spill on-base.

1. Area 600, AFWL Projects

a. Scott air packs (self-contained breathing apparatus)

b. Full chemical suits

c. Aprons, gloves, and faceshields

d. Absorbants (diatomaceous earth)

e. Ueutrali zing chemicals for acids or bases

f. Hand tools (brooms, shovels, etc.)

g. Fire extinguishers

h. Eye washes and showers (not mobile}

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2. DPDO Facility

1606th Air Base Wing (MAC} Kirtland Air Force Base, NM 87117

a. Aprons, chemical resistant coveralls, gloves, face­

shields, boots, and goggles.

b. Absorbents

c • Hand tool s

d. Fire extinguishers

e. Respirators - organic vapors

f. Eyewash - portable

g. Eyewash and deluge sho\'ter c0r.1bination (2)

3. DEEV

a. Aprons, chemical resistant coveralls, gloves, face-

shields, boots, and goggles.

b. Absorbents

c. Hand tools

d. Fire extinguishers

e. Respirators - organic vapors

f. Eyewash - portable

g. Eyewash and deluge shower combination (2)

h. 55-gallon drums for spill cleanup.

F. Evacuation

Any spi 11 s, ruptures, or discharges of hazardous waste at a hazardous

waste or hazardous material facility wi 11 be reported irnrnedi ately through

the SPCC Plan. In any such mishap where human health may be endangered,

evacuation of the facility and possibly even surrounding facilities must

be accomplished. The following procedures should aid in detennining when

and how facilities should be evacuated. 49

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l606th Air Base Wing (MAC) Kirtland Air Force Base, NM 8 7117

1. Spill response by Facility Operators

a. Notify all fellow personnel to evacuate the facility by

activating the fire alarm if spill involves any of the following:

- Fire

- Explosion

- Violent chemical reaction

- Noticeable gases.

2. Evacuation of Additional Areas

a. Immediately upon reporting to the spill scene or entry

control point, the on-scene commander of the spi 11 response team wi 11

determine if additional evacuation is required. The on-scene cor.inander •

will.also make the determination if evacuation is required at any time

during the cleanup effort.

b. Should the on-scene commander detenni ne that off-base

personnel may become endangered he should immediately notify local

authorities through Security Police.

3. Emergency Reporting Requirements for Off-Base Evacuation

Once the on-scene commander has detennined that areas outside the

facility should possibly be evacuated because of a threat to human health

or the environment and local authorities have been notified, he must

ensure completion of the following:

a. The on-scene commander or his representative must

remain available to help appropriate officials decide whether local areas

should be evacuated.

b. Notify the National Response Center (24-hour toll free

number is 800/424-8802) with the following information:

- ~Jame and telephone n1.m1ber of reporter;

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1606th Air Base Wing {MAC) Kirtland Air Force Base, NM 87117

- Name and address of facility;

- Time and type of incident;

- Name and quantity of material(s) involved, to the

extent known;

The extent of i nj uri es, if any; and

- The possible hazards to human health, or the

environment, outside the facility.

G. Post Emergency Procedures

1. Cleanup

Once the emergency condition is over, the on-scene commander or emergency

coordinator will ensure that all emergency equipment is cleaned and fit

for its intended use. No additional wastes will be accepted at the site

of the emergency until these cleanup procedures have been co~pleted.

(The EPA Regional Administrator, and the appropriate state and local

authorities must be notified that the cleanup has been accomplished

before wastes can be accepted again.)

2. Reports

The facility operator must note in the operating record the time, date,

and details of any incident that requires implementing the contingency

plan. Within 15 days after the incident, he must submit a written report

on the incident to the EPA Regional Administrator and the State. The

report must include:

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1606th Air Base Wing {MAC) Kirtland Air Force Base, NM 8 7117

Name, address and telephone number of the owner or

operator;

- tJame, address and telephone number of the facility;

- Date, time, and type of incident;

- Name and quantity of material(s) involved;

The extent of i nj uri es, if any;

- An assessment of actual or potential hazards to

human health or the environment, where applicable;

and

- Estimated quantity and disposition of recovered

material that resulted from the incident.

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XII. CLOSURE

1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

This section describes the procedure for closing the hazardous storage .. areas maintained by OPOO. These procedures also apply to the temporary

storage areas (less than 90 days) at the individual waste originator

activities.

I~- . I'\-~" ,; I \ ,, I .. -:1') \ ,0 , iY A. Originators

Within 90 days of waste generation

.I.II') ,) \

'l' ,,, . ~~'-··'{\"· "

(except for single drums) or at the . C~{ .. ,11 t \ \•

close of a project, whichever comes first, the originator will turn-in

all waste from the collection point to OPDO according to the procedures

described in this OPLMJ. The same procedure will be followed by DPOO in

the event of a closure of KAFB. Consequently, there will be no remaining

wastes on the Base and no further closure plan is required.

B. DPOO Storage Facilities

The DPDO storage facility is not for tenninal storage. Surplus hazardous

substances and wastes should be removed for recycling or disposal within

a maximum of one year. At the time of storage site closure, all wastes

will be recycled or removed by an off-Base service contractor and disposed

of at EPA permitted sites. Any contaminated soil or other materials at-?,. '~

the storage area will also be collected and disposed of at a permitted / . site. The estimated costs of closure other than packaging,

transportation, and disposal should not exceed $7,000.00. The financial

53

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

resources necessary to close the storage site are expected to be within

the nonnal operating budget of DPDO. No special financial security

arrangements are required to prepare for closure. After closure, records

of the receipt and di sp.osi ti on of waste materials wi 1l

be retained for at least three years by DPDO. A certification must be'

placed in the Land Title or registry of deeds that there are no residual

chemicals at the site.

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l606th Air Base Wing {MAC) Kirtland Air Force Base, NM 87117

APPENDIX A

ABBREVIATIONS AND DEFINITIONS

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ABBREVIATIONS

OLA - Defense Logistics Agency

DOT - Department of Transportation

DPDO - Defense Property Disposal Office

DTID Disposal Turn-In Document

EPA - Environmental Protection Agency

GC - Gass Chromatography

HM - Hazardous Material

HW - Hazardous Waste

HWMP - Hazardous Waste Management Plan

IR - Infrared Analysis

MS - Mass Spectrometer

NSN - National Stock Number

PCB - Polychlorinated Biphenyls

RCRA - Resource Conservation and Recovery Act

TIO - Turn-In Document

TSO - Treatment, Storage, Disposal

A-1

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DEFINITIOtJS

Container means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.

Designated Facility means a hazardous wa~te treatment, storage, or disposal facility which has received a state plan approval, an EPA permit (or a facility with interim status} in accordance with these regulations, that has been designated on the manifest by the generator.

Disposal means the discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or on any

·land or water so that such wastes or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters, including ground waters.

EPA Hazardous Waste Number means the number assigned by EPA to each hazardous waste.

EPA Identification Number means the number assigned to each generator, transporter, and treatment, storage, or disposal facility.

Facility means any land and appurtenances, thereon and thereto, used for the treatment, storage, and/or disposal of hazardous waste.

Generator--the 1606 ABW is the holder of the hazardous waste license for ge11erat1 on and temporary storage of these wastes. The Wing Commander is the responsible party for all activities on Kirtland AFB.

Hazardous Substances and Hazardous Materials, as terms, are derived from Department of rransportat10n and EPA I 1 sts of chemicals which require packaging or \'lhich trigger notification requirements if spilled. For the purposes of this OP LAN hazardous substances, hazardous wastes, and hazardous materials do not include radioactive materials. Radioactive waste disposal procedures are outlined in KAFBR 160-1, Base Radiation Protection Program.

Hazardous Waste is officially defined by EPA in 40 CFR Part 261. Hazardous waste may be designated by virtue of a characteristic; e.g., corrosive, ignitable, or toxic, or by specific listing in Part 261. In general, chemicals, and mixtures of chemicals with other substances, which are of no commercial value are hazardous waste.

Incompatible Waste means a hazardous waste which is unsuitable for placement in a particular device or facility because it may cause corrosion or decay of containment materials (e.g., container inner liners or tank walls). It can also be a chemical which when mixed with another chemica·l Hill explode, produce·dangerous gas, or ignite.

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Management or Hazardous Waste Management means the systematic control of the :ollection, source separation, storage, transportation, process1ng, treatment, recovery, and disposal of hazardous waste.

Manifest means the fonn used for identifying the quantity compos1t1on, and the origin, routing, and destination of haza;dous waste during its transportatfon from the point of generation to the point of disposal, treatment, or storage.

Mani fest Document Number means the serially increasing number ass~gned to the manifest by the DPDO for record keeping and reporting purposes.

oeerator means the person responsible for the overall operation of a facil l ty

Originator means any person, organization, tenant, contractor or subcontractor whose act or processes produces hazardous waste, surplus hazardous materials, or waste POL.

Personnel or Facility Personnel means all persons who work at, or oversee the operations of, a hazardous waste facility, and whose actions or failure to act may result in noncompliance with the EPA or DOT rEqui rements.

POL includes petroleums, oils, and lubricants. In the event that waste POL cannot be sold for reclamation, it becomes hazardous waste.

Polychlorinated Biphenyl (PCB) and (PCBs) means any chemical substance that is limited to the biphenyl molecule that has been chlorinated to varying degrees or any combination of substances which contains such substances (see 40 CFR 761. (b) for the applicability of the PCB regulations). PCB and PCBs as contained in PCB Items are defined in subsection 761 .29(x).

Prime Container means the container in direct contacf with the hazardous substance or waste. The Transportation Squadron (Packaging) can assi~t with identification of the proper container.

Representative Sample means a sa~ple of a universe or whol~ ~e.g., waste pile, lagoon, ground water) which can be expected to exh1b1t the av~rage properties of the universe or whole.

Run-off means any rainwater, leachate or other 1 iqui d that drains over land from any part of a facility.

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Sludfe r.ieans any solid, ser.ii-solid, or liquid \·taste generated fror.i a municipa , commercial, or industrial v1astev1ater treatment plant, Nater supply treatment plant, or air pollution control facility exclusive of the treated effluent from a wasteNater treatment pl ant.

Solid Haste means any garbage, refuse, sludge (including sludge fron a waste treatment plant, water supply treatment plant, or air pollution control facility), or other discarded r.iaterial, including solid, liquid co1:111ercial, mining, or agricultural operations and from community activities but does not include solid or dissolved material in dor.iestic sewage or in irrigation return flows or discharges for \·1hich a pemit is re qui red.

Spill means the accidental spilling, leaking, pur.iping, pouring, emitting, emptying, or dumping of hazardous wastes or material which, when spi 11 ed, becor.ie hazardous \·tastes, into or on any 1 and or water.

Storage means the holding of hazardous waste for a temporary period, at the end of \'lhich the hazardous \•1aste is treated, disposed of, or stored elsewhere.

Storage Facility means facility which stores hazardous \'laste, except for generators who store their own waste on-site for less than 90 days for subsequent transport off-site.

Tank means a stationary device, designed to contain an accur.iulation of hazardous waste which is constructed primarily of non-earthen materials (e.g., wood, concrete, steel, plastic) t·thich provide structural support.

Transportation r.ieans the r.iover.ient of hazardous waste by air, rail, road\'/ay, or \'later.

Transporter means a person engaged in the off-site mover.ient of hazardous waste by air, rail, roadway, or water.

Treatr.ient means any method, technique, or process, including neutralization, designed to change· the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste; or so as to render such waste nonhazardous, or less hazardous, safer to transport, store, or dispose of, or amenable for recovery or storage; or so as to reduce the volume of the waste.

- Oplans The current Oil and Hazardous Substances Pollution Contingency Pl an is 1606 ABH OPLAN 80-6.

The current Spill Prevention Control and Countenneasures Plan is the SPCC Pl an.

Subsequent revisions to these plans nay change the titles and/or numbers. However, the purpose of the pl ans wi 11 be to prevent and, when necessary, control and correct spills.

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1606th Air Base Wing (MAC) Kirtland Air Force Base, NM 87117

APPENDIX B

TRAINING PROGRAM

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TRAINIIJG PRaiRAM

1. OIL AND HAZARDOUS SUBSTANCE WORKER TRAINING

Al 1 personnel including contractors and subcontractors working at oi 1 and hazardous substance sites must take part in periodic spill prevention and response (SPR) training programs (40 CFR 112.7,

. 264.16, 265.16, proposed 40 CFR 125. 104, 151.7). The SPR Plan must designate the major features of the training program and, at a mini mum, require that each worker be familiar with the fo 11 owing information as it applies to his/her work area:

o The heal th effects of exposure to the oi 1 and hazardous substances present.

o Applicable first aid procedures to be used following exposure.

o Protective equipment requirements and how to use and maintain the equipment.

o Evacuation procedures, if required (40 CFR 264. 16, 265. 16).

o Combustibility of spill material and potential for flashback along vapor trai 1 s.

o Applicable fire fighting procedures and special hazards of combustion products (40 CFR 264.16, 265.16).

o Reactivity of spill material with common materials including water.

o The use and maintenance of all alarms and monitoring equipment that impact on spill prevention and response (40 CFR 264. 16, 265. 16).

o Initial general spill response procedures as described in the SPR Plan. TI1e training should also include the use of site-specific contingency plans and where the plans are kept (40 CFR 112.7, 264.16, 265.16, proposed CFR 151.7).

o Immediate spill response actions including the location of pump controls and valves to stop spill flows and the location and use of fire extinguishers, sorbents, neutralizing agents and other immediate spill response procedures, as appropr-1ate l4o CFR 112.7, 264. 16, 265. 16, proposed 40 CFR 151.7).

o The many aspects of visual inspection, as described in Section 3.2 . of this document, that a worker can perform as part of a daily

routine. This is not designed to replace the requirements for detailed inspections.

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· o TI1e purpose and requirements of good housekeeping.

o The ~se of the SPR Plan. Tryis should include the legal requ1rements that resulted 1n the plan, the spill prevention aspects of the plan, the spill response organization including the function of the SRT, the designated spill response procedures and the locations where spill response equipment are stored (40 CFR 112.7), proposed 40 CFR 151 .7).

The training program, as just described, should consist of fonnal classroom training, on-the-job training, spill exercises, or preferably a combination thereof. In many instances, this training can be combined with other training programs such as fire or safety. It is essential, however, that the portion of the training required by the SPR Plan be conducted by someone familiar with oil and hazardous substance spill prevention and response, and hazardous waste management (40 CFR 264. 16, 265.16). The Spill Corrmittee and Environmental Protection Committee, in combination with supervisory personnel from the respective oil and hazardous substance sites, are recommended to give the training. Records of the type, extent, and frequency of each employee's training must be kept until closure of the applicable hazardous waste site or until three years after the date the employee last worked at the site (40 CFR 264.16, 265.16). The training of personnel working for Air Force contractors and subcontractors should be designated the responsibility of the contractor or subcontractor in all applicable contracts.

The frequency of training programs must also be designated in the SPR Plan and, minimally, they must be conducted as follows:

o Once per year for all personnel working on, or in close proximity to, oil and hazardous substance sites {40 CFR 112.7, 264.16, 265.16, proposed CFR 151.7).

o Within six months for all personnel starting in a position with direct supervision (40 CFR 264.16, 265.16). Within two weeks recommended.

o Before starting work for personnel entering an unsupervised position {40 CFR 264.16, 265.16).

o After revision of training requirements in applicable laws.

o After significant modification to oil and hazardous substance processes, or spill prevention and response procedures (SPR Plan).

o After a spill response in which deficiencies in training were noted.

o When directed by the Spill Committee or the Environmental Protection Committee.

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2. OIL ANO HAZARDOUS SUBSTANCE SPILL RESPONSE TEAM (SRT) TRAHJING

All base organizations and personnel designated pursuant to this document to be part of the spill response team must take part in periodic spill response training programs (40 CFR 264. 16, 265. 16). The training requirements must be designated in the SPR Pl an and consist of both general training requirements for all members of the SRT and detailed training specifically structured for the individual SRT members.

The general training should consist of the applicable laws; base responsibilities; Department of Defense and USAF policies; the potential hazard to personnel; property and the environment from spill events; the use of the OHSSPR Plan; the designated responsibilities of member organizations; and the general response procedures.

The detailed training should be specifically structured for members of each response organization and address the following:

o The responsibilities of the individual organization being trained.

o The detailed spill response procedures to be followed in the event of a spill.

o The location and use of spill response equipment. This should include training with existing equipment and familiarity with manufacturer• s recommended procedures and design limitations. An example of the latter would be the compatibility of protective clothing with a spill material.

o. The potential health and fire hazards associated with spill response activities. This should include mechanisms for obtaining this infonnation such as the CHRIS manual of CHEMTREC.

The training should consist of classroom training and spill exercises. The frequency of the training programs, at a minimum, should be on an annual basis. New SRT members should be given a copy of the SPR Plan and briefed when they are assigned to the team.

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1606th Air Base Wing (MAC) Kirtland Air Force Base, tJM 87117

APPEtJDIX C

WASTE SAMPLING ANO ANALYSIS PROCEDURES

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COL HJASA - LIQUIDS

l. Clean COLIWASA.

WASTE SAMPLING PROCEDURES*

2. Adjust sampler's locking mechanism to ensure that the stopper provides a tight closure. Open sampler by placing stopper rod handle in the T-position and pushing the rod down until the handle sits against the samp1er's locking block.

3. Slowly lower the sampler into the waste at a rate which pennits the level of liquid inside and outside the sampler to remain the same. If the level of waste in the sampler tube is lower inside than outside, tHe sampling rate is too fast and will produce a non-representative sample.

4. When the sampler hits the bottom of the waste container, push sampler tube down to close and lock the stopper by turning the T-handle until it is upright and one end rests on the locking block.

5. Withdraw COLIWASA from waste and wipe the outside with a disposable cloth or rag.

6. Place sampie tube at mouth of a container and discharge sample by slowly opening the sampler.

SCOOP AND SHOVEL - GRANULAR OR POWDERED MATERIALS

1. Clean sampler.

2. Obtain a ful 1 cross sec ti on of the waste material with the scoop or shove 1 large enough to contain the waste co 11 ected in one cross section sweep.

* See "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods," U.S. Environmental Protection Agency, Office of Solid Waste, Washington, D. C.

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WASTE ANALYSIS PROCEDURES*

1 . FOOl Through FOOS Wastes:

{a) Tes~ Parameters and Methods:

1. Flash point analyzed in accordance with Pensky-Martena Closed Cup Tester - ASTI~ Standard D-93-79.

2. Di sti 11 ation Analysis - accomplished through actual distillation or through automated gas chromatography providing boiling point profi 1 e.

3. Solvent Concentration - using Standard Methods or SW-846 (MS, GC, IR, etc.) the waste will be analyzed for the specific solvent contaminants identified on the label and TIO.

{b) Rationale for Parameter Selection:

l. The flash point and distillation or boiling point profile will verify that the waste is a halogenated or non-halogenated solvent and can be safely stored.

2. Analyzing for specific solvents will ensure that the material is grouped in the appropriate EPA Hazardous Waste Number.

2. F003 and F009 Wastes:

(a) Test Parameters and Methods:

l. Cyanides - using Standard methods or SW-846.

2. Metals {particularly Cd and Ag) - using EP Toxicity Test Procedure (40 CFR 261, Appendix II).

{b} Rationale for Parameter Selection: The cyanide analysis will verify .the presence of cyanide and how the waste should be stored. The metal analysis will identify the additional toxic contaminants most likely to be present.

* See "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, 11 SW-846, U. S. Environmental Protection Agency, Office of Solid Waste, Washington, D. C.

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3. 0001 Wastes:

(a) Test Parameters and Methods:

1. Ignitability - analyzed in accordance with the DOT methods.

2. Solvents - analyzed in accordance with Standard Methods or SW-846.

(b) Rationale for Parameter Selection:

l. The ignitability test will determine whether or not the waste meets this characteristic and where it may be stored.

2. The solvent analysis is needed because the solvents in FOOl through F005 are the 1 i sted wastes most 1 i kely to contaminate petroleum products.

4. 0002 Wastes:

(a) Test Parameters and Methods:

1. pH analyzed in accordance with Standard Methods.

(b} Rationale for Parameter Selection:

1. The corrosive wastes anticipated are aqueous acids and bases. The pH test will ensure these wastes are stored in Group 1-A (bases) or Group 1-B (acids).

5. 0003 and FOO? Wastes:

(a} Test Parameters and Methods:

1. Cyanides and pH - analyzed in accordance with Standard Methods or SW-846.

(b) Rationale for Parameter Selection:

1. The only waste materials anticipated in this category requiring storage are those containing cyanides. The pH and cyanide analyses will identify how the wastes can be stored.

6. 0006 Wastes:

(a) Test Parameters and Methods:

1. Ep Toxicity for cadmium using the EP Toxicity Test procedure.

(b) Rationale for Parameter Selection:

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1. The only waste identified in this category is cadmium contaminated sand blast media (used). The test analysis will ensure that the material does require handling as hazardous waste and is appropriate for storage.

7. F006 ~Jastes:

(a) Test Parameters and Methods:

1. pH - Standard Methods

2. Percent Solids - Standard Methods

3. Metals {Cd, Cr, Ni) and Cyanide - using Standard Methods or SW-846 and the EP Taxi city Test Procedures.

( b). Ration ale for Parameter Selection:

1. The metals and cyanides are the items making the material hazardous; analysis of these items will determine if delisting should ever be 'requested. The pH and solids concentration will also provide information of concern for disposal.

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('") I

(J1

EXTRACT ANO TEST FOR METALS

DETERMINE SOLID )FLASH POINT

OF ORGANIC

OBTAIN SAMPLE

GS OR MS~ FOR ID

YES RECYCLE

TEST FOR ORGANO HALI DES

TEST FOR -NITRATES -PHENOLS -PESTICIDES -ETC

TEST FOR YES I -SOLVENTS ~-PBBs

-PCBs -PESTICIDES

ill MEASURE

pH FOR CORROSIVES

NO

RECYCLABLE

YES RECYCLE

PETROLEUM PRODUCTS >---.-i EXEMPT FROM RCRA,

RECYCLE OR SELL

NO EXTRACT, TEST FOR

METALS

NO

DISPOSE OF I NO CONTROL I

RECYCLE

YES

DISPOSE OF AS

HAZARDOUS WASTE

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1606th Air Ra~P Win~ (MA~) Kirtland Air ~orce Dase, NM U/I I/

APPENDIX 0

FIGURES

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Material

.

FIGURE 1

INSPECTION LOG

Faci 1 i ty: ____________ _

Date waste Printed Date of Accumulation Condition of Name of

Inspection Began Containers Inspector

D-1

S1 gnature of

Inspector

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FIGURE 2

HAZARDOUS WASTE LABEL

'HAZARDOUS WASTE

FEDERAL LAW PROHIBITS IMPROPER DISPOSAL IF FOUND. CONTACT THE NEAREST POLICE. OR

PUBLIC SAFETY AUTHORITY. OR THE U.S. ENVIRONMENTAL PROTECTION AGENCY

PROPER D.O.T. SHIPPINGNAME Waste Acetone UN OR NA# 1 090

GENERATOR INFORMATION:

NAME Air Force Weapons laboratory

ADDRESS Kirtland Air Force Base c1TY A 1 buquergue STATE NM ZIP 87117

g~o. FNM-571824423 EPA WASTE NO. _.._;_,;FQ:;...::0=3 __ _

ACCUMULATION START DATE 15 Jan 8X

MANIFEST

DOCUMENT NO. ---*--

HANDLE WITH CARE! CONTAINS HAZARDOUS OR TOXIC WASTES

C LABELMASTER. CHICAGO. IL 60626

* To be completed by DPDO.

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0 I

w

; I~ l -~ ;T1i . j. I' j • j • j ·1 ! I ,.. ~- : I~ 5IU(" '"'V-0{9 i•Dl.Nl1.·1au¥l'I ISC .. --I I s

i ~ I I I (a) I

I I I ; SH•'"l0 UOM IS.HUit f0

(b)

' I I

(c)

I I I I I I I I I I AAAA• IOI rao,KT

I I I

(d)

"""" le

t t~~·ll~'" I. flllGHT IAll

.. I

, WAllMvUU lo.;.Al 101'

I U I C

i ... ·~~I ~:g I UNI! W(IGHI I ~~~~ I

,c L j, I !. i. ~VUlllUI( O"IA jll(fO)IC:,IP•AHY llQVIUlO)tltlGHT ClAHlflc:ATIOH NOMI.NCI.A(~) ' I : I

I I I I . . .,,

"' lllu.< NOMl.N(V.IUI( , l : \ ' X I J\'

(h).

I I

~I H•icrw •• ""o DAii jn-" of co..rA1N111s1.1or"4 wtrGHr i- 11~~1~tD n ~o 0 ... 11 HSrKUO IY AHO DAil

I • .I I' I ~ ! . l : :

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I I TO!Al ,.,(! oou .... i$ TC!l

I

I ' . ' I S t-~-.,,==~..,.,."::"":-""'.,.,-------t=-j • I PAC•lil lf ANO DAI( ,NO. Of CONIAINUl 'IO!Ai. (Ulf v ( w11.IHOUUD")"f AHO DAiii WA.UHOUU LOCAllOfol !

~ I I : I \, - ' I II s ' I I . I

i--1 1' (k) I is.... . . I ,_t_.: I i• 9 10 , •lt.-V.Ul I I

I I

I I

1._. (1) :.. -!a (m) :oL •.••••••• ~~? ................ 11••••••••••••••••••••••• •••• I I ~

f·IH OlSl•,.,,.l•CN AOOIUI "!£ 1""'~. :' 1

j! ., . '.' :

• l u,.,.i,cuAt•ON c ..... ac;v.lll ro

DO FO~M 134&-I

1• "'

I .IMI JI

• I

· 11 ~I : GG j' 1 1/ lAOINC:,, AWi. 01 lKllVIA'i· Sl"""IUli. (AHO- DAil) · 1 ·~· IK(IVU"S- OO(UM(Nf HUMlla

Figure 3 (DD Form 1348-1) Disposal Turn-in Document

000 SINGLE LIN( ITEM UUAU/ lECEll'T OOCUMlHT

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FIGURE 3a

INSTRUCTIONS FOR DD FORM 1348-1

(a) Top Line: Items 8-43, 65-66, and 74-80 need to be completed. This infonilation should be obtained from the organization supply or material control section. In Items 45-50, put SZ3028 for OPDO turn-in.

(b) Block A - "Shipped From": The generator's name, office syr.ibol, and phone number go in this block. The facility's EPA identification number is also put in this block.

(c) Block B - "Ship to": Put the following: VOL Bldg. 1025 844-9755 NM - 571824423

(d) Block C - "Mark For": Insert HW for hazardous \'1aste as identified in Appendix C or HM for hazardous materials.

(e) Block P - "Mat Cond": Insert the material condition code, obtained from supply or material control section.

(f) Block T - "Substitute Data": Put numbers of corresponding containers in this block as follows: "Drum No(s). XXXXXX-YYYYYY." Drum numbers are assigned by originator.

(g) Blocks U, V, and X: Place six character (two alpha, four numeric) DOT identification number from 49 CFR 172 (contact DEEV for additional infonnation} in Block U. Use Blocks V and X for noun name of the waste and percentage of each constituent. Do not use manufacturer's brand names or very general names like paint thinner or degreaser. Provide the NSN of the new item when possible.

(h} Block Y: Use this block for the deposit account number when necessary.

(i} Block 2: fill in type of container (i.e., drum, box, barrel, etc.}.

(j} Block 3: Fill in total weight of all material and containers to be turned in.

(k) Block 5: Fill in total nunber of containers accompanying the TIO.

(1) Blocks AA and 88: Use these two blocks for the transporter's name and EPA identification number (for off-base shipments only).

(m) Block CC: HC"t.ve transporter (identified in Blocks AA and BB) sign and date for receipt of shipment.

D-3a-l

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(n) Blocks DD, EE, FF, and GG: Insert the following statement in these blocks (stater.rent must be a rubber stamp, typewritten, or a r.iachine produced copy). "This is to certify that the above-named materials are properly classified, described, packaged, marked, and labeled; and are in proper condition for transportation according to the applicable regula­tio.ns of DOT and EPA." Annotate the DOT container specification number ir.1111ediately following the above statement.

D-3a-2

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FIGURE 4

EXAMPLE DD FORM 1348-1

., UN1090 trFlli HOM£NC:-l..lrv •

! ~ " I,

I •

... ···-CONDEMNED

n ti'', I ' ' - I • '"' ·' ;"',; ... • ~ 1 :, '1. •

·:'"'"·'.

(6 Part)

GENERATOR

----··-----i:-: L~-·~··- . ___ ..I:~

I

1-·········-···· ... ··--............ ..

Sl:Ll.C.tEO aY AlrtU 0A1t.

• TOTAL.C&.18e WAl'•Houe10 .,. AHO OAT• WA .. «HOV a LOCATION

s • tO

I I This is to certify that the above nam@d ma~a 1 i are properly classified described, packag

".tOHDEMH£D _ _. Lntt._ ... _____ _,'i-,c::-; ... '=====----~r-u"'rke.d...an.d ... l•heled .uul.. ..ia..~per...alndt ••R ... ''' ................ , ..... , .,,. 0 '"'r •"1""0 for transportation acco 1ng to the appl 1

regulation of DOT and E A. 11 II I'll QO ..-i .......... >iiO•rifu,NCiiA ......... L-iT(> t4 •~ ...... oaNc.aM.a·•..._,,,.. .._ .. ,..

-.. .;-,cw.--i .,,.. ·• · (6 Part)

D-4

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.. r 1 r.11111 1,

REQUEST FOR ENVIRONMENTAL IMPACT ANALYSIS

I REQUEST - -----------·--· -- -- ---- ------ --

I TO: t,.:nrironnrf"ntol l'lann1n11 l··t1ncllonl z f ROM. (Ur,:an11ulion and Offil"•· SvmbuO J

1606 ABW/OEEV 5 REQUESTOR (flla1"P. Office S:vJnl>ol aru.t """""Nu J 4

6. TY~E OF ANAL VSIS NEEDED I CAT£X ~ PRELIMINARY I I £NVIRONMENTAL

DETERMINATION ENVIRONMENTAL SURVEY ASSESSMENT

7. TITLE OF' PROPOSED ACTION

II DESCRIPTION OF PROPOSED ACTION ANO ALTERNATIVES 1110/'.HJ

•. PURPOSE OF' AND NEED F'OR ACTION l(."onlinued on Slteel•I

, DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES IC:onfinued on Sh•rl•J

[Describe the wastes to be generated, the volume and frequency, proposed storage location, the type of containers required, and special handling or disposal considerations.]

--

10. EPC MEM~ER DOPA A REVIEW CERTIF'ICATION (Name and Gradrl SIGNATURE

~

I 1. ORGANIZATIONAL APPROVAL (Name and Grade of Commonderl SIGNATURE

. Ill ADDITIONAL APPROVAL fAS Hf:(JUllU:m

IZ. CONTRACT CONSULTANT APPROVAL AUTHORITY SIGNATURE (N01fle ond Gradel

. IV ENVIRONMENTAL PLANN1NG RESPONSE

ll. RESPONSES ATTACHED

Prelimln.,y Envlronmental 1urvev IAF Form 8141 an•ched

Prop01ed action Qu•lifled for Cat•• (Appropriate Documentation ettechedl

Pro1>o••d action doew not quallfv for Cet••. awseHm•nt required

14. REMARKS

Is. ENVIRONMENTAL PLANNER CERTIFICATION (Namr and CiradeJ

16 ENVIRONMENTAL PROTECTION COMMITTEE APPROVAL ·(Nam•• and <1rvdrJ

AF F'ORM

JUL 79 813

D-5

SIGNATURE

SIGNATURE

f'IJ/t J·:.'>H'IHO.V.\/~:N"J .H. /'I.A N.Vl."G L'S/; OSI.\'

--------CONTROL NUMBER

ESTIMATED COMP DATE

I £NVIRONMENT AL IMPACT STATEMt:NT

the any

DATE

DATE

DATE

OATt:

DATE

Page 87: HAZARDOUS WASTE .MANAGEMENT PLAN AFB/KAFB1001.pdf · 2018. 7. 31. · hazardous wastes originator retains responsibility for the waste until the waste is transferred to the Defense

a ...... 1 •••

CONSIGNMeNT GAOSS We IC HT

'HANS>OHTAnON CON'ROC NO. 1 oeSTINATION

LOAO STOF.IAGEICAOIJP SUPPLeMeNTAL ll'o~OHMA !ION

CONTAINER IAW PARA. 178.116 OF TITLE 49 CFR COOT l 7E CONTAINER> FLASH l'OINT

PAt\AGAAPH ex EMPTION

49 cfr 173.28(p)

........ ,.." .. ----:=-=-==========-----------1 DOD .. f)OO.:J:U< tMILSTAMl'I x l 7J. 7 l•I

ADO RESS OF SHIPPER

TYPEO NAMc SIGNATURE ANO DATE

00 FOAM 13li7·2 l'HLVl\HJ:.i tDITION l:.i ua:..uLL rL SPECIAL

CONS11..l1'1MeNT GRCSS WEIGHT

-...----------~~--------------------------.1----------------------------""-------..,-------------------------' SUl'l'LEM~Nl•\L ,r-.;1 (iHMAllON

IAW DOD 4160.21M PARA 46b(2) "The hazardous mawrial is packaged in containers of equal or greater strength and efficiency as prescribed in the Department ofTransportation Hazardous Materials Regulation (Title 49, CFR, Parts 170-189.

LOAD STORAGE/GROUP

1--F-L_A_S_H_P_O_IN-T----·-1'

'fhti 1s tu c~rt1f'I th .. t th,· .. b.,..,. n.uncd 1n..tl.rt1•JS ..,,.,.. prupt"rlv cl~ahrd, dC"M:nlM.·d. /'.al·k,~c<J. •h"'rk.cll .u1d 1..h«""lt·l.I, illnd ,,uc- in proper cundttion for l11111a;-1..,r14l1un a1:cord1u, lu llu· •vvlu: .. bk- ''""YlllUuU> "' lh<" u .. vl of Tr .. n>µUtL•LluH. T llS IS A MILITAk \" Sllll'Mt.NT! /Com , .. , .. " li•·ubw bltX'k.I /Jf•luwf

This •luµm .. nl I> wulun lll .. llmJl.au .. n. , ...... ·nb.-1.1 ... , l'ASSt:Nc.a:K AIRCRAr·T ;CA KIOU·ON I.\' AlltCI(,\ t"1" ( Urld" nonlll'Pll<:•lllc .. orr.r10lll

AJ."J( 71·-l. TM :111-:!aU. NAVSUl'l'Uli i.ua. MCO 1'4030.l!I. DLAM -llol5.J. l'im1&ri1ph

DOD 4600.J:.?K lMll..'> l'AMI'>

ATAllATAllMCO REGULATIONS

PARAGRAPH EXEMPTION

49 ctr OOT-e 7573

!iil-~~~-~-~--~;_;_E_R---------~-------------------------------------------T-Y_P_E_O __ N_A_M_E_._s_'_G_N_A __ T_u_R_E_A_N_O_O_A_T_E ___________ ~ FORM 1387-2 DD

1 MAY 7~ SPECIAL HANDLING DATA/CERTIFICATION -~-~-~---'•>•> . ·· '-~--,~...-.... ----~---....... -~----a......-.....cr ·- -

--~~ .. ·~-"""=···---~-~ 'U -· ~, ' -· - .""':zz ...., 0 • l ~TeM NOMI:: NC LA Tl.Jr<t NET uUANl ITV PEH PACK.AGL TRAlllSPORTATION CONTROi. NO

CONS•GNM•NT GROSS W«GH' O•STONA>oO• ---{

SUPPLEMt:.NTAL INfOAMATION LOAD STORAGl:/GRQ,UP

CONTAINER IAW PARA. 178.82 OF TITLE 49 CFR COOT 5B CONTAINER) FLASH POINT

This •h•µntrnl 1> w11tun lh" hnul.aUu11> vrr••:rtU.,d ior l'ASSt:Nl.Ol·:K Ar A/IA T A/IMCU AECULA T IONS AIRCllAr.T/C,\IHoU·ONl.\" AIKCKA~·T llJ .. l""° nuo,pplai:;obk- ••f<ro.lll

At· it 71 ·-l. TM JIS·~50. NA VS Ul'l'Uli !>Ua. MClJ 1'4030.19. L>LAM 4 l-l5.J. l'Uillll"Ph

DOD 4600.J;tlt lMll.STAMl'l

AOORESS OF SHIPPER

DD FORM 1 MAY 7!J

0-6

f>,...A.:.GflAt'H

49 ctr 173.28(p)

17l. 7 lal

rvi>EO NAME SIGNATURE ANO CATE

EXEMPTION

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