1.0  Applicability.  A Disposition Plan is required for any program where physical equipment and/or system components are to be removed.  The goal of this document is to provide guidance to FAA personnel for disposition of such equipment and components when they contain hazardous materials.   

FAA equipment may contain hazardous materials in numerous components and parts such as PCB capacitors, lead acid batteries, nickel cadmium batteries, mercury switches, asbestos gaskets, PCB transformers, and parts painted with lead based paint.  Under applicable Federal, state, and local laws, the FAA may be liable for fines, penalties, clean-up costs, or other associated damages  if equipment containing hazardous materials is improperly handled, shipped, or disposed of.  Unless as part of the disposal process, FAA transfers ownership of equipment to another party, all of the shipping companies and handlers are simply agents for the FAA, and the FAA may still be liable for any improper disposal of hazardous materials.  Therefore, it is essential to track hazardous materials and hazardous waste with the proper paperwork, and preparation of an adequate disposal plan will minimize the risk that hazardous materials will be improperly managed.

2.0  General.  Disposition of equipment from FAA facilities shall comply with all applicable Federal, state and local laws.  The Integrated Product Team has overall responsibility for implementation of the disposition effort.  The IPT should consult with the Environment, Energy, and Employee Safety Division (AEE-200) for policy assistance and the Environment, Energy, and Safety Division (ANS-500) for technical assistance. 

2.1       If a piece of equipment contains components or parts suspected of containing hazardous materials, then the suspected components must be treated as hazardous material until proven otherwise.  When the equipment and/or components are discarded or declared as waste, the suspected hazardous material must be treated as hazardous waste until proven otherwise.

2.2       If a piece of equipment is to be disposed of by the local facility, the disposal requirements are the same as if disposed of by the contractor.  In such cases, FAA is responsible for ensuring that all Federal, state, and local requirements are followed.  It is recommended that the local facility utilize the services of a reputable organization or firm that specializes in the disposal of hazardous components, such as a Defense Reutilization Management Office (DRMO), whenever possible to ensure that the disposal is performed properly.  If disposal is performed by the local facility, it is recommended that the facility check with their State Environmental Protection Agency to determine the state requirements for disposal and shipping.  In some states, such as California, state requirements for disposal are much more stringent than Federal EPA requirements.  Under the Federal Facilities Act of 1992, states may levy fines and/or penalties against Federal officials who fail to comply with local and state environmental requirements.  A complete listing of State EPA contacts, as well as additional regulatory information may be obtained from the USEPA web site (http://www.epa.gov/); however, personnel should refer particular issues to the appropriate FAA office (i.e., AEE-200 and ANS-500).

3.0 Procedure.  Consistent with the policy of the Acquisition Management System (AMS), the responsible IPT should comply with the following:

3.1 Provide the necessary resources to properly dispose of the equipment, including any hazardous material contained in the equipment. 

3.2 Coordinate with ANS-500 and AEE-200 for technical support regarding hazardous waste content and regulatory requirements respectively.

3.3 Provide hazardous material identification information to all contractors involved in equipment handling, shipment, and disposal.

3.4 Coordinate the removal, transport, and disposal of the equipment.  When disposing of equipment as hazardous waste, the IPT will use the following guidelines:

3.4.1 Determine that the transporter and the receiving facility have United States Environmental Protection Agency (USEPA) identification numbers.  Consult the USEPA about any violations, infractions, inspections, or audits associated with either the transporter or the receiving facility.

 3.4.2 Complete a Uniform Hazardous Waste manifest.  Only staff trained in completing manifests may complete them.  Contractors may not sign hazardous waste manifests in lieu of government officials at the facility.  Some states require the use of state-specific manifests.  If there are no state specific requirements, the USEPA’s Uniform Hazardous Waste Manifest may be used (see 40 CFR 262.21 for rules of manifest use).

 3.5 Comply with all packaging and labeling requirements outlined in 40 CFR 260 – 280, and 40 CFR 761.

 3.6 Comply with all other applicable FAA reporting and record-keeping requirements covering environmental and safety compliance and PCBs outlined in FAA Orders 1050.17, and 1050.14A..

 3.7 Comply with DOT requirements for shipping and transportation in the Hazardous Materials Regulations of the Department of Transportation (49 CFR 171 – 180).

 3.8 Obtain a certificate of destruction (if incinerated) or a certificate of acceptance (if landfilled) from the waste disposal facility.

 3.9 If hazardous materials are being transported for recycling, the IPT will use the following guidelines:

 3.9.1 Use a licensed commercial recycler. 

 3.9.2 Ensure packaging and labeling for transport is in accordance with all regulations outlined in 49 CFR 171 – 180 and 40 CFR 260 – 280.

 3.9.3 Comply with proper FAA reporting and record-keeping requirements covering environmental and safety compliance and PCBs outlined in FAA Orders 1050.17, and 1050.14A.

 3.9.4 Attach a standard bill of lading to each shipment sent to the recycler.  Prior to signing the bill of lading, cross check the shipment to the bill of lading for accuracy.

 3.9.5 Obtain a certificate of reuse from the recycling facility.