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950R97028
UNITED STA TES ENVIRONMENTAL PROTECTION AGENCY
REGION III
MUL Th MEDIA INSPECTION REPORT
U.S. MARINE C0RP5
OUANTICO MARINE BASE
AUGUST 11-15, 1997
' MAIN REPORT
U.S. EPA Region III
Regional Center for Environmental
Information
1650 Arch Street (3PM52)
Philadelphia, PA 19103
Regional Center for Environmental Information
US EPA Region III
Philadelphia, PA 19103
v.
FACILITY INSPECTION PROGRAM
ANNAPOLIS, MARYLAND
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Table of Contents
Page No.
Background. . . . . . 2
Introduction/Facility Description f..3
Participating Personnel 3
Opening Conference 5
Summary of Findings. . 6
Technical Reports
RCRA. . 15
UST. 22
CAA. . . . . . : . 23
CWA. . . . 4 8
UIC. 58
TSCA. . 62
EPCRA 66
Solid Waste 69
Appendices: Attachments, & Photographs (under separate cover)
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Background
A Level D Multi-Media Compliance Inspection was conducted at
the U.. S. Marine Corps, Quantico'Marine Base located-:in Quantico,
Virginia from August 11, 1997 through August 15, 1997.
The inspection was conducted as a joint effort between EPA,
Region III and the Virginia State Department of Environmental
Quality'.
A number of factors were considered when selecting Quantico
Marine Base as a target for a multi-media inspection. These
considerations include, but are not limited to: 1) .geographic
diversity (it is a federal facility in Virginia not too far from
the District of Columbia); 2) it is the only U.S. Marine Corps base
in Region III; 3) it is .part of a regional geographic"initiative
(this facility is located in the Chesapeake Bay watershed and could
impact the area around the bay); 4) size (the facility covers
approximately 60,000 abres and is a unique facility in that there
arp several sites on the facility that are part of the CERCLA .
cleanup process); 5) potential problem areas (as of August, 1994,
facility had identified some 47 suspected leaking underground
storage tanks and had approximately 50 PCB.and PCB contaminated
transformers on the base, although a contract was awarded for the
complete removal of all 50 transformers);' and 6) recent spill
history (history,of significant spills reported to NRC in the past
year, e.g10/7/96, 100 gallon release of jet fuel).
All of these factors, plus the input of the various EPA Region
III media programs made this fapility a good candidate for a multi-
media inspection.
The objectives of the inspection were to determine the
facility's compliance with a number of environmental statutes
regulated by both the Environmental Protection Agency and the State
of Virginia's Department of Environmental Quality. Specifically,
the- inspection focused on the facility's compliance with the
following regulations':
• Hazardous waste management regulations .under the Resource
Conservation and Recovery Act (RCRA), including
regulations regarding underground storage tanks
• Water pollution control regulations under the CleaniWater
Act (CWA), including regulations regarding underground
injection control
• Air pollution control regulations under the Clean Air Act
(CAA) .
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PCB regulations under the Toxic Substances Control Act
(TSCA)
• Form R reporting . requirements under the Emergency
Planning and Community Right-To-Know Act (EPCRA)
In addition to the aforementioned regulations, the inspection
also included a review of the' facility1s procedures with respect to
solid waste management.
Introduction/Facility Description
The* Marine Corps Combat Development Command (MCCDC
Quantico),. located in Quantico, Virginia, consists of approximately
60,000 acres situated in Prince William, Fauquier, and Stafford
Counties, Virginia. The installation has been in operation since
1917 and is currently bordered by residential, park, farmland, and
commercial properties. MCCDC - Quantico, approximately 35 miles
south of Washington, D.C. is divided by Interstate 95 into two
areas: Mainside (east of 1-95) and Gaudalcanal (west of 1-95). The
primary mission of MCCDC-Quantico is to develop, assess, and
promulgate U.S. Marine Corps concepts, 1 plans, and doctrine; to
identify and assess changes to doctrine, training, Marine
Air/Ground Task Force (MAGTF) force structure and material; to
develop and implement policy and programs for the training and
education of all regular and reserve Marine Corps personnel and
units: to exercise cognizance of manual and automated war gaming;
and, to provide support for the Combat Development Command,
Operating Forces, Reserve Establishment, Supporting Establishment,
and HQMC (Marine Corps Headquarters).
In addition, Qauntico is host to a' number of tenant
organizations including, Drug Enforcement Administration, the FBI
Academy, and Marine Corps Air Facility. There is a population of
approximately 13,000 at Quantico.
Participating Personnel
Quantico Marine Base Representatives:
Brigadier General Edwin Kelley, Jr....... . . . .Base Commander
Major Fred Mock.........Deputy, Natural Resources and Environmental
Affairs Branch (NREA)
Ralph Phipps ..Chief, Environmental Affairs Section
Kristine Stein Environmental Affairs Section
Nicole Bennett. Environmental Affairs Section
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Cpl. Sean Jensen Environmental Affairs Section
Richard Gleason ...... Environmental Affairs Section
William Fennell. : . ... Chief', Environmental Engineering Section
Mark Branca .Environmental Engineering Section
EPA Representatives:
Gerard Crutchley. Team Leader, TSCA, Annapolis Office
George Houghton RCRA, Annapolis Office
Gerard Donovan. .UST, Annapolis Office
Charles Hufnagel . . . .NPDES, Annapolis Office
Humberto Monsalvo. .CAA, Philadelphia Office
Abraham Reich EPCRA, Philadelphia Office
Clark Conover .UIC, Philadelphia Office
Lisa Bradford... ...Superfurid, Fed. Fac. Branch, Philadelphia Office
Jeffrey Pike .RCRA, Philadelphia Office
Thomas Tandoc .Federal Facilities Enf. Office, EPA Hdqtrs.
Kelly Conrad . . .Federal Facilities Enf. Office, EPA Hdqtrs.
Gene Miller Federal Facilities Enf. Office, EPA Hdqtrs.
Virginia Department of Environmental Quality Representatives:
John Ely State Team Leader
Alice Nelson. ^ • • • •
Charles Williamson. NPDES
Stephen Turner;: . . . . ... . . .' UST
Jon Terry • RCRA
.Tammy Gumbita Solid Waste
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Opening Conference
An opening conference was held on Monday, August 11, 1997 with
the facility's command staff and lead environmental personnel. , The
facility's command staff emphasized their commitment to overseeing
base operations to ensure that the facility complies with all
applicable federal and state environmental regulations. The lead
personnel from EPA and the State of Virginia discussed with the
facility personnel the reason for the inspection and what we
expected to accomplish during the inspection.
The facility's Public Affairs Officer provided a brief
overview of the base operations for the entire inspection team and
the EPA team leader then discussed with the facility personnel and
the inspection team the logistics for inspection activities.
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Summary of Findings
.RCRA'
1. Weapons Training (27241) - This facility has in storage
kerosene and leadracid batteries. These types of waste' are
not generated as part of this activity. This material was
apparently dumped at the facility. Facility personnel did
state they were in the process of having the waste removed.
2. The EPA inspector recommended that the contingency.plans for
all of the <90 sites be reviewed and updated as necessary to
reflect current activities. The plans presently contain out
of date phone numbers and emergency contacts.
3. In the emergency/contingency plans for the generators, phone
numbers listed are seven digit numbers; however, . the operators
at various locations stated that they would call 911 in the
event of an emergency. If this is their procedure, it should
be reflected.in their emergency plans.
4. The contingency plan must include the relevant capabilities
for the emergency equipment listed in the plan.
5. After testing the drain valves in the <90 day storage sites,
facility personnel should ensure that the valves are
completely closed. The EPA inspector observed two valves that
were slightly open during the inspection.
6. FBI - gun cleaning room - cleaning pads (hazardous waste -
D008)¦ were observed in the trash instead of in the hazardous
waste accumulation drum. The operator indicated that this was
a constant battle and he routinely rummages through the'trash
and retrieves the pads . Retrieving pads from the trash
should be listed on the SOP for this area.
7. FBI - HRT - The EPA inspector observed one full 55 gallon drum
of gun cleaning waste in a satellite accumulation area. This
drum should be, dated and removed within 72 hours.
8. FBI -Forensic Research Lab - The EPA inspector observed a one
gallon container of an unknown liquid in a laboratory hood.
According to the lab operator, this container has been in the
hood for some time (several months). The contents should be
determined and either used or disposed of accordingly.
9. TBS Armory - The EPA inspector observed used cleaning pads
(D008) in a trash can. The operator is aware of this
situation and. does remove them. The facility personnel should
update the SOP to include checking the trash cans for the
cleaning pads.
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10.. HMX-1 - The EPA inspector observed a 30 gallon accumulation
drum in a mixing room. The sides of the drum were covered
with paint which had apparently spilled when adding waste
paint, to the drum. Facility- personnel need to clean up this
material and ensure that it does not occur in the future.
11. Facilities Maintenance - Batteries, emptied of their contents
(DO08), were disposed of as a non hazardous waste through
Interstate Battery. Any battery no longer intact or empty is
considered a hazardous waste and must be handled as a
hazardous waste. This operation also had a 30 gallon
container of battery, acid. The Environmental Affairs
personnel were not aware of this practice.
12.' Building 2008 - This satellite storage held a 30 gallon
container of hazardous waste. It was located next to a drain.
The EPA inspector recommended placing this container into
secondary containment.
13. Hazardous waste storage - 27401 - The epoxy sealant and floor
should be repaired. The facility is aware of this situation
and a work-order has been submitted<
14.. The facility needs to conduct and maintain records of daily
inspections for the loading and unloading area at the
hazardous waste storage building (27401).
UST
The facility currently has nine regulated tanks. The EPA and
state inspector observed all nine tanks as well as reviewed the
leak detection methods for those tanks. They also reviewed the
closure records for the underground tanks removed from the
facility. No apparent problems were found.
Clean Air Act
Combustion Emissions
1. The initial performance test results were not submitted to the
EPA, and the quarterly excess emissions reports are not being
provided to the EPA as required by the NSPS Subparts Db and
Dc, codified at 40 CFR §60.49b, and 40 CFR §60.48c,
respectively.
2. With regard to tne notirication ot installation and
construction for the boilers, it was discovered that the
initial performance test conducted for Boiler #3 was done on
January 3, 1995. Boiler #3 failed the performance test
relative to. NOx and opacity emission limits. The second
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performance test for Boiler #3 was conducted on June 5, 1997
in which the boiler's operations passed for NO., and opacity
emission limits. NSPS Subpart Db, cited in 40 CFR §60.44b(f),
allows' for a facility tp take up to 180 days to conduct an
initial performance, test to establish compliance relative to
NOx and opacity .emissions. ¦ The Marine Corps Combat
Development Command (MCCDC) was in violation- of 40 CFR
§60 .44b (f) since it exceeded the allowable time frame for the
initial performance test.
3. A minor issue concerned the submittal of a proposal for NOx
Reasonably Available Control Technology (RACT).' The Base did
not submit a proposal to the EPA due to guidance provided by
the State in an internal VADEQ memorandum dated May 10, 1993.
The memo cited Appendix T of the VA DEQ regulations in which
exemptions are provided to combustion units less than
100,000,000 Btu/hr. This matter needs to be reported to EPA
as soon as it is convenient.
Although the aforementioned violations were noted during the
inspection, the Base should be commended.for the outstanding air
emissions reduction initiative undertaken since. 1993 during its
overhaul of all the boilers and combustion units that also included
conversion/retrofitting capability to use natural gas. The
estimated air emission reduction exceeded 150 tons for SOx, NO,.,
PM10, and CO. - . 1 '
VOC Emissions
SPRAY BOOTHS
1. With regard to the surface coating operations at the Base,
i.e., spray painting, verification of the total annual usages
was not provided in order to determine the applicability of
the VADEQ Surface Coating Regulation. A complete material
mass balance (or usage assessment) is needed to certify that
the Base falls under the limit in the State regulation.
However, based on the testimony of the different area
supervisors, the Base seems to fall under the usage limit and
is probably not subject to the VADEQ surface coating
regulation. Nonetheless., the Base should incorporate the use
of a database program that can easily track the use of each
type of paint at each affected facility and/or area.
2. The majority of the paints inspected consisted of VOC content
greater than 3.0 lbs/gal.. The EPA encourages facilities to
use paints that contain VOC contents less than 3.0 lbs/gal. in
order to fall under the limit in the State regulation.
Although.the use of these paints at the Base does not trigger
the State regulation, the Base should make a strong effort to
switch to paints that contain less than 3.0 lb/gal. of VOCs.
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This is typically known as conversion from high solvent-base
paints to low-solvent, high solids paints. Also, current and
appropriate Material Safety Data Sheet (MSDS) must be present
in the different affected areas of operation to facilitate
inspections.
3. The- Base should improve and better monitor its preventive
maintenance (PM) program in the different spray booths by
increasing the frequency of replacing the spray booth filter,
and keeping logs of such periodic replacements and any
periodic cleaning that would improve the capture efficiency of
the spray booth. Although this is not required by any
regulation, EPA makes this recommendation in order to improve
work practices.
GASOLINE DISPENSING STATIONS
1. The Base gasoline dispensing station at the Marine Exchange
Service Facility, with an approximate daily throughput of
8,000 gals, had the proper Stage II vapor recovery equipment.
The required recordkeeping and reporting was adequate and made
available. However, the daily checklist should include a
column for crimped hoses and flattened areas of hoses which
may restrict the vapor recovery capability of the Stage
system. The Base should begin to replace the Huskey nozzles
that are currently in place with the new improved nozzles that
can service brand new vehicles. This problem originates with
smaller orifices, made in new ¦ cars in which the old Huskey
nozzles do not. fit. This is not a requirement by the Stage II
State regulation, but it is merely a recommendation.
The Base should be commended for the initiative it took to
install Stage II Vapor Recovery Systems at low-volume gasoline
dispensing stations that did not require such air pollution control
equipment.
GASOLINE AND FUEL STORAGE TANKS
1. , The fuel storage areas 'were in proper working condition, but
the State and the facility should incorporate the use of VOC
detecting equipment, i.e., Portable flame ionization de,tectors
should be used to ensure that the seal around the gasoline
storage tanks are not leaking gasoline vapors, into the
atmosphere. Stage I is not required at the area because the
maximum storage of the tanks is below 40,000 gallons."
CFC Emissions
MOTOR VEHICLE REPAIR SHOPS
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. 1. While most .motor vehicle repair shops had, certified
technicians who were instructed in the proper' use of the
refrigerant recovery and recycling equipment, certification of
such equipment showing proper notification to the EPA was
never done. Also, such notification of the purchase of such
equipment would determine whether or not it is EPA-approve'd
•equipment. This is a violation of .4 0 CFR §82.42(a)(1). -
2. Although most of the motor vehicle repair shops had
refrigerant recovery and recycling equipment, such equipment
was approximately a year old, or the activities could not
provide purchase invoices. The lack of such documents does
not allow for the verification of purchase dates and implies
that the Base may be in violation of servicing motor vehicles
between the effective date of .the regulation, November 15,
1992, and the estimated purchase date , in 1996. This is a
violation of 40 CFR §82.34 and 40 CFR §82-42.
PROCESS REFRIGERATION AND REFRIGERATION DISPOSAL
1. While most of the chiller station and process refrigeration
repair shops had refrigerant recovery and recycling equipment,
such equipment was approximately a year old, or the activities
could not provide purchase invoices. The lack of such
documents does not allow for the verification of purchase
dates and implies that the Base was in violation of servicing
motor vehicles between the effective date of the regulation,
November 15, 1992, and the estimated purchase date in 1996.
This is a violation of 40 CFR §82.154 and 40 CFR §82.162.
2. Although some process refrigeration technicians had been
certified, certifications of all technicians could not be
verified. Copies of the .certifications for iall technicians is
needed to show compliance with 40 CFR §82.1611 " This
requirement became effective November 14, 1994.
3. While most of the affected areas maintained some degree of
documentation, the recordkeeping was deficient and did not
comply with the recordkeeping and reporting requirements cited
in 40. CFR §82.166. This is a violation of 40. CFR §82.166.
4. Throughout the Base, there were several activities, i.e.,
Facilities Maintenance and Defense Reutilization & Marketing
Office Annex (DRMO), that were, involved in the disposal
process of refrigerant-containing equipment.. However, the
proper verification of. refrigerant recovery and accountability
was not done. Each.time a refrigerant-containing piece of
equipment was put forth in waste stream, it yielded a
violation of 40 CFR §82.156(f).
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5. Throughout the Base, there were numerous process chillers that
.were constantly serviced due to frequent leaks. Although
Facilities Maintenance keeps documentation of all leak
repairs, the high rates of repair of the same units resulted
in the following amounts of refrigerants released, .to the
atmosphere due to leaks:
Year R-12(lbs.) R-22(lbs.)
1995 . 2,730 3,348
1996 1,600 2,090
1997 610 2,770 < (a/o 8/97)
While the Base has fixed leaks in all types of chiller
equipment in prompt fashion, the current service documentation
does not permit verification of compliance with 40 CFR
§82.156.(1) (1) - (4) . To decrease such large amounts of
refrigerants from being released into the atmosphere in the
future, the EPA strongly encourages the Base to invest in a
chiller retrofitting program as cited in 40 CFR §82.156 (I) (3).
6. A Navy study, dated September 3, 1996, was conducted at the
Base, for the replacement of ozone depletion substances. The
Base should begin to implement the findings and intentions of
this study in conjunction with an effective retrofitting
program of the chillers..
Clean Water Act
The NPDES component included inspections of the Mainside STP,
Camp Upshur plant and the industrial/stormwater outfalls. The
Mainside plant appeared to be operating well despite all of the
construction associated with the plant upgrade. The inspector even
commented on the clarity of the final discharge from the plant.
1. Although .no discrepancies were found in the DMR records
reviewed for either the Mainside STP (VA0028363) or Camp
Upshur STP (VA0028371), a misunderstanding in the DMR
reporting procedure was clarified. It was pointed out that all
weekly averages during a month that exceeded the maximum
weekly average limit are to be reported as excursions rather
than just reporting 1 excursion for only the maximum weekly
average.
2. The Camp Upshur STP (VA0028371) effluent samples have not been
refrigerated or kept on ice from the time of collection and
during transit to the Mainside STP nor have the NH3-N samples
been preserved (w/H2S04) upon collection. Also, the NEU-N
method (number) has not been indicated in the analytical
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records (eg. on bench sheet).
3. The Camp Upshur STP treatment units' gratings which were
generally- rusted and warped, presented a structural safety
hazard.
¦4. Industrial Discharges (VA0002151) sample preservation should
be documented (eg. on chain of custody). '
5. Essentially, Quantico's continuing, wastewater compliance
problems which have been well documented with DEQ are as
follows:
- failure to meet the TSS.effluent limits at Outfalls 071
(Guad Maintenance Shop Vehicle Wash) and 005 (Camp Barrett
Tank Wash) which are included in Quantico's Industrial
Discharges permit (VA0002151). The high clay content of the
soil in the wash water hasn't readily been removed at these
facilities.
- overflows in their sewer systems. These are generally
frequent, minor spills which are attributed to incidental
blockages that occur in flat, remote residential areas where
the sewers accumulate grease, etc. The sewer system
rehabilitation is not expected to significantly correct these
blockages, most of which occur in the Aquia Wastewater
Treatment Plant's (Stafford County) service area on base.
Quantico has been reporting all of the overflow incidents to
DEQ although there was some question a& to whether Stafford
County should report the incidents in their respective service
%rea.
UIC
This component of the inspection included visits to eleven:
areas at the facility to observe sixteen Class V wells. All were
identified as septic systems.' There were no endangering discharges'
to any of the wells which might effect public water systems on the
base .and surrounding communities.
Two other observations made by the inspector, not related to
UIC, were (1) the facilities tank farm and the potential for a fuel
spill to the stormwater system and (2) a fuel oil spill from a tank
at the Quadalcanal Maintenance facility which occurred over a year
ago, but has not yet been cleaned up (as stated by a facility
employee).
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TSCA/PCB
1. The annual records for 1991 - 1994 do not.contain the total
numbers and the total weights for PCB Articles, PCB Article
Containers and PCB Containers.
2. For PCBs and PCB Items remaining in 'service at the end of the
calendar year, the annual records do not contain the total
number of PCB Transformers and the total weight of the PCBs in
the transformers, the. total number of large high and low
voltage PCB Capacitors, and the total weight of PCB. Items in
PCB Containers.
3. There was no confirmation of receipt from a TSD facility for
two PCB waste shipments by an independent transporter in 1995
(manifest nos. 50565 & 50154).
4. The manifest (50565) for a PCB waste shipment in August 1995
indicated 130 kg. This figure was changed to 450 kg.'by the
TSD facility. This is not a problem, as long as the
discrepancy is resolved within 15 days after the waste was
received at the TSD facility. If the. discrepancy is not
resolved, a letter must be sent to EPA regarding the
. situation.
5. Documentation regarding the contaminated soil removed from the
old DRMO scrapyard needs to be maintained as part of the
annual records including total weights 'for the amount of
contaminated soil removed from the site.
6. Thirty large capacitors observed during the inspection were
later identified by facility personnel as non-PCB, according
to nameplate information.
Although these discrepancies regarding the annual records are
after the fact, these same discrepancies were addressed in a Notice
of Noncompliance issued.to the facility in Dec. 1990 and they were
not corrected subsequent to receiving the NON.
EPCRA. Section 313
The Quantico Marine Base has submitted Form R's under Section
313 of SARA Title III for the reporting years, 1994, 1995, and
1996. The records show that the facility had greater than 10
employees and is a Federal Facility. In addition, the records
showed that the facility exceeded the threshold for the following
listed Section 313 chemical:
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Reporting
Year
Amount
Manufactured (M)
Processed (P.)
Form R
Chemical
Otherwise Used (0) Due
Chlorine
Chlorine
Chlorine
94
95
96
61,255 (0)
41,184 (0)
44,962 (0)
Y
Y
Y
All uses and releases were well documented.
In addition, a determination should be made as to whether the
amount of lead from bullets which are periodically dug up and
disposed of and copper from the casings of used shells are
reportable under section 313.
Material Safety Data Sheets should be updated. The one obtained
from the. Main Side Waste Water treatment Plant, Attachment B9,
lists caustic (NaOH) as being-a Section 313 reportable chemical, it
is not.
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Technical Reports
Resource Conservation and Recovery Act
Permit Status
Quantico is a large quantity generator and an interim status
storage facility, storing for greater than 90 days. A- Part B
permit application, originally submitted about ten years ago, was
resubmitted¦ by Quantico - in July of 1997 at the request of the
Virginia Department- of. Environmental ' Quality. The permit
application is for storage of waste for greater than 90 days.
Treatment or disposal are not part of the application. In
addition, the facility has ten <90 day accumulation sites and
numerous satellite accumulation locations.
Inspection Observations
General
Quantico has a number of tenants that generate ' hazardous
waste. Some of these tenant's are- small generators and only have a
satellite accumulation site while others have a less than 90 day
accumulation area in addition to satellite accumulation. The
number of satellite and less than 90 day facilities are decreasing
through waste minimization and the changing mission for Quantico.
Storage is in containers up to 55 gallons in size. In all cases
the waste is transported to the Quantico hazardous waste >90 day
storage building (Building number 27401) by the generator. Since
all the waste is generated on site and no . waste travels over
publicly owned roads, none of the waste is manifested to the
storage facility. No additional storage devices, treatment methods
or disposal of hazardous waste were observed during this
.inspection.
All waste must be pre-approved through, the Environmental
Affairs office before being accepted at the greater than .90. day
storage facility. Typically, waste remains at the <90 day
accumulation sites for 45 to 60 days before transfer to Bldg. 27401
by the generator. The waste is identified through the generator
knowledge and MSDS information. The .1997 waste profile list is
provided as an attachment to this report. If there is any doubt as
to whether a particular waste is hazardous or non-hazardous,
Quantico arranges for a chemical analysis; The staff at the
generator locations are trained by the Environmental Affairs office
in the proper documentation, inspection and handling of the waste
generated, as well as Quantico's own procedures for waste handling
and disposal.
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As part of the . inspection all of the <90 day accumulation
sites and a number of satellite generation facilities were observed
fo'r compliance with those regulations. Some of the latter
coincided with the .less than'90 day accumulation locations.
In addition.to the. satellite and the <90 day accumulation
areas, Quantico has 106 Safety-Kleen parts washing stations on the
base. Safety- Kleen collects the -used solvents from these
locations, prepares the manifests and transports them off-site.
This waste does not pass through Bldg. 27401. The sites were not
specifically inspected but some were observed if located in or near
a satellite generation location or'.a less than 90 day location. No
item of concern was observed at any of the Safety -Kleen wash
stations.
Generators (less than 90 day and satellite accumulation areas)
Facility Support Branch-Motor T.Maintenance (Blda. 2013)
As the name suggests this facility is for vehicle maintenance.
Hazardous waste generation consists of a waste paint related
material. At the spray booth (satellite), this inspector observed
a closed 5-gallon container labeled flammable waste. Filters from
the paint spray booth'are disposed at the Quantico landfill as non
hazardous. The operator should check these filters for hazardous
constituents if not already accomplished. Other waste includes
waste petroleum products that are not regulated by RCRA. Only non-
regulated waste was observed in the <9,0 day storage structure at
the time of the inspection. A review ' of the training and
inspection records revealed no problems. The emergency plan for
this facility is currently undergoing revision because of changes
at this location.
Communication Officer School (Blda. 3185)
Waste generated at this location includes fuel which is not
regulated by RCRA and batteries that are regulated by RCRA as
universal waste. Two batteries were observed, both were closed and
intact. In addition, the facility uses and disposes of lithium
batteries. According to facility personnel, after the "pin" is
removed, the battery is allowed to discharge for a 2 to 3 day
period. The discharge area, outside the main building, is marked
to alert others-in the area. While discharging, the batteries are
covered to keep them dry. A temporary discharge area has been
established (photo 8). The old discharge facility has been retired
(photo 9). Photo 10 is a view inside the old discharge structure,
(note the batteries on the shelf). During the discharge phase, the
battery emits hydrogen gas. After discharge, the battery is
disposed of as a non-hazardous waste. This building does have a
<90 day accumulation area, but no RCRA waste was observed in that
structure during this inspection. The drain valve for the
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structure was observed to be partially open. The weekly (Tuesday)
inspections are documented; however, the' inspection form has no
line item for the drain valve.
Building 2118 - PCS Armory
This satellite facility has two containers, one inside and one.
outside (photo 11) us'ed to hold "Q-tips" and patches, from gun
cleaning. The hazard class is D008 for lead. Both were closed and
labeled.
Building 2043 - Security Battalion
This location has a satellite drum used" to hold "Q-tips" and
patches from gun cleaning. According to the operator, filling the
drum takes about six months. A Safety^-Kleen wash station, is also
located here. No RCRA related issues were noted.
Federal Bureau of Investigation
¦ p
The FBI is perhaps the largest single hazardous waste
generator at Quantico. The majority of their waste is derived from
gun cleaning, shooting range and laboratory analysis.
The gun-cleaning room (satellite) had one drum that held waste
from the gun cleaning procedure. It was' labeled as a hazardous
waste and the hazard constituent was lead (D008). The facility
had modified the container lid (photo 12) to help prevent non-
regulated waste from entering the container. According to the
operator of this location, the hazardous waste originates not from
the cleaning solvent, but from the "Q-tips" and patches that
contain residual lead from the gun powder. The Bureau, as well as
Quantico, had previously changed from a gun cleaning solvent that-
was regulated by RCRA when disposed to a non-regulated solvent.
According to the operator, ensuring that all the patches' and."Q-
tips" are placed in the waste container requires constant
vigilance. The operator removes the contents of the container
about once per week although this varies depending on use.
The gunsmith shop (satellite) has a similar operation,in that
it generates, as part of the gun cleaning procedure, "Q-tips" and
patches that fail TCLP for lead. The gun-cleaning residuals are
placed iil plastic lined red metal cans with a foot treadle to
operate the lid. This inspector counted six cans in the shop
(photo 13 & 14). Each night the cans are emptied into the
container located in the gun cleaning room. This shop is
restricted.to the gunsmiths and not open to others in the building.
The HRT building held one 55 gallon container in a cage area.
This container was closed and labeled as containing a hazardous
17
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waste. The container was almost full (photo 15). The operator of
this area indicated that the container had been there for about one
and a half years. It contained waste similar to that observed in
the gun-cleaning room. Some patches were observed in a trash can
in this same area. Whether these patches resulted from a gun
cleaning operation is unknown. The facility was told to remove the
drum and replace it with a new empty drum.
The forensic lab also generated waste from its analytical
procedures. It is the policy of the lab to remove hazardous waste
streams to a storage room (Room 117) at the end of each shift.
This room is equipped with storage cabinets and dry sumps to
capture spills. Inspections are documented weekly. No RCRA issues
were noted. In addition to Room 117, four additional generation
points were observed. The amount of waste was minimal and
consisted of one gallon and smaller containers. The containers
were closed and labeled with their contents. Photo 16 shows a
typical laboratory accumulation point (Room 306). In Room 310 a
container of unknown material was observed. The facility is in the
process of identifying its contents.
HMX-l
This area repairs and maintains the presidential helicopter
fleet. Its hazardous waste generation results from painting.. The
less than 90 day storage area building (photo f17) is typical of the
hazardous waste storage buildings used at Quantico. The building
has three sides with a fence and lockable gates on the fourth side.
The floor is sloped to the rear of the structure and there 'is a
drain valve leading to the ground surface to remove liquid. This
valve was closed at the time of the inspection.. One drum of waste
paint related material was observed and it was properly labeled,
dated and closed. In another area, the paint booth filters were
reported to be non hazardous and, as a result, disposal is through
municipal' trash. In the paint mix room (satellite) one container,
approximately 30 gallons in size, was observed. It was closed,
labeled (ignitible & toxic) and not leaking. The drum was observed
to be contaminated on the outside with a substantial amount of
spilled paint. Facility personnel should ensure that waste paint
is not spilled while adding it to this container. The EPA
inspector recommended that the existing contamination be cleaned
from the side of the container.
All hazardous waste inspection records for HMX-l are
maintained on a computer with disk-backup, there is no paper copy.
The computer is pass-word protected. The recorded information was
appropriate for the facility.
18
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Facility Maintenance (Blda. 3252)
This operation maintains buildings and grounds at Quantico.
One 30 gallon drum was observed in the <90 day storage building.
It was used to hold waste sulfuric acid from batteries. The exact
reason why the battery acid was drained to the cpntainer was not
explained (photo 18). According to facility personnel at the
scene, batteries are typically shipped off site intact with the
acid regaining in the battery. Interstate Battery recycles old,
batteries and. supplies new one's, a - one for one exchange.
Reportedly, batteries removed by Interstate, were drained of acid
(source of the waste acid) . Both the batteries that have been
drained of acid and the acid itself must be stored, labeled and
transported as a hazardous waste. The environmental office was
unaware that some - batteries were handled in this manner. Five
additional containers were observed in the storage building. They
.were properly marked and closed. The acid container was not dated.-
Records Branch (Bldcr. 2 008)
This operation generated a waste ammonium hydroxide and waste
petroleum distillate. No storage problems we're observed in this
area. Inspection records are documented and available tor review.
In a satellite area, one 30 gallon container was observed. It
contained a petroleum distillate with a hazard waste label stating
D001. This container was stored in the vicinity of a floor drain.
The facility representative was advised to provide secondary
containment to ensure that none of the waste, if spilled or leaked,
could enter the floor drain.
Museum (Blda. 2112)
This operation generates waste paint related material. One 30
gallon container,was observed in a satellite area. Its storage
procedures were consistent with the regulations-. No hazardous
waste was stored in the <90 days storage building.
Hobby Shop (Blda. 4)
!
Private vehicles are maintained, rebuilt-and repaired by their
owners in this area. Wastes are limited to used motor oil, oil
filters, etc. There,is a paint booth but the vehicle owner is
responsible for the waste paint and solvents. The Hobby Shop's <90
day storage shed did not contain any hazardous waste.
.Naval Clinic (Bldq. 2200)
According- to the Clinic's representative, the facility
generates lab chemicals, paint waste and solvents. The storage
building (photo 19) held three containers of waste, all were
dated, closed, labeled and not leaking. Inspections records were
19
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satisfactory.
• Weapons Training Battalion (Blda. 27241)
This facility trains the soldiers on how to repair their
weapons^ The less than 90 day storage building held a container
(approximately 3 0 gallons) that was labeled nitric/phosphoric acid.
It was full, labeled and dated. No leaks were observed. Another
container was labeled kerosene. It was also labeled as a hazardous
waste. According to the facility representative, this container
was left by person or persons unknown and it is in the process of
having the waste removed. The satellite area for this building
held two containers. Each was properly labeled and closed.
Storage (>90 day storage building 27401)
The storage building was constructed as a. waste storage
building and was first used in 1989. In general, this inspector
observed that the building was in good condition and did not note
any regulatory concerns. The building is located across the road
from the base fire department (photo 20). There are no occupied-
buildings in close proximity other than the fire department.
The storage building is surrounded by a fence with a lockable
gate (photo 21). and appropriate signage on the gate. The garage
door is used for the waste deliveries and pickups with an office to
the side (photo 22). Around the inside, perimeter, seven bays hold
the different types of hazardous waste (photos 23 to 34). Each bay
has a separate dry sump used to capture any spillage. The center,
area is below grade and is used to store waste and stage waste.
Additional photographs with narrative are, attached to this feport.
No drains were observed in the building. The floor was coated with
an epoxy material. No floor cracks were observed, although the
facility is looking into recoating the floor. The building is
equipped with explosion proof electric, fire call station, fire
sensors and telephone. There is no air-conditioning although there
is ventilation and some of the ventilation runs continuously. The
drums and other containers observed were in good condition. No
odors, leaks or deteriorated containers were observed. Labels on
the containers stated the contents and that it was a hazardous
waste. Based on the dates observed, no containers were stored for-
greater than 90 days. This inspector did not find any incident
where storage of incompatible materials had occurred.
Inspections are documented weekly and monthly. Waste is
received about twice per week. The inspector did not observe any
inspection records for the load-in or load-out area of the facility
for days it was in use.
20
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During the inspection, the EPA inspector did review-a number
of the records related to the facility's hazardous waste management
program. The findings of the- record rev.iew are documented in' the
inspection checklists "included¦as part of this report.
21
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TSD CHECKLIST - VA FACILITIES
Name of Facility: QUANTICO MARINE BASE .
Address of Facility: _MARINE CORPSE COMBAT DEVELOPMENT COMMAND
QUANTICO, VA
I. General
1. Does the facility generate hazardous waste? YES
2. Does the facility manage (i.e. treat, store -or dispose) any
hazardous waste that is:
a. generated on-site? YES
b. generated off-site at facility(s) having different
ownership? NO
c. generated off-site by facility(s) having common
ownership? NO
3. Does the facility perform the following on-site:
a. storage of hazardous waste? YES
b. treatment of hazardous waste? NO
c. disposal of hazardous waste? NO
4. Is the facility subject to any exclusions for its hazardous
waste? NO
5. Does the facility contemplate any changes in. its operation
insofar as the management of hazardous waste, is concerned? NO
6. Does the facility transport hazardous waste off-site for
. further management? YES THE ANNUAL DOCUMENT DATED 28JAN97
LISTS THE OFF-SITE FACILITIES (BY RCRA ID NUMBER) THAT RECEIVE
WASTE FROM QUANTICO. ALL SHIPMENTS ARE COORDINATED BY DRMO.
OUANTirO MARINE BASE "
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7. Has the facility' submitted:
a. Part A permit application? YES
If yes, approximately when? RESUBMITTED 7/25/97
b. Part B permit application? YES VA DEQ REQUESTED AND
WAS PROVIDED AN UPDATED COPY IN JULY 1997 OF THE PART B
APPLICATION
General Facility Standards
9.1.D.1
1. Has the facility obtained a detailed chemical and physical
analysis of a representative sample of each waste it receives
prior to its treatment, storage or disposal? YES - ATTACHED
IS A LIST OF THE WASTE CURRENTLY GENERATED AND SELECTED WASTE
PROFILE INFORMATION
9.1.D.3
2. Is the analysis repeated as necessary to ensure that it is
accurate and up to date? YES A PROCEDURE IS IN PLACE TO
ENSURE ALL THE WASTE IS PROPERLY IDENTIFIED
9.1.D.4
3. If the facility receives off-site shipments of hazardous
waste, does it adequately inspect and, if necessary analyze
each shipment to determine whether it matches the identity
specified on the accompanying manifest? NO OFF-SITE WASTE
RECEIVED
9.1.D.5
4. Has the facility developed a written waste analysis plan
and, if so, is the plan kept at the facility? YES AND YES;
ALSO USES GENERATOR KNOWLEDGE TO IDENTIFY WASTE THE PLAN IS IN
THE PART B APPLICATION. THE PLAN IS ATTACHED
If yes, does the waste analysis plan contain the following:
a. List of wastes to be. sampled? YES •
b. Location of sampling? TYPICALLY -ANALYSIS IS AVOIDED
DUE TO COST THE PRIMARY METHOD OF WASTE CHARACTERIZATION.
IS BY THE GENERATOR KNOWLEDGE AND THE MSDS. THE
QUANTITIES OF UNKNOWNS THAT NEED ANALYSIS ARE SMALL.
9 .1. D. 5 . a
c. List of parameters and why they were selected? YES BY
REFERENCE OF SECTIONS IN VA REGULATIONS
0 MARINE BASE
1
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9.1.D.5.b
d. Test methods? YES ALTHOUGH NO SPECIFIC PARAMETERS ARE
LISTED,' THE PLAN DOES REFERENCE SW-846
9.l.D.5.c
e'. ¦ Sampling method toj ensure collection of a
representative sample? YES BUT THE PLAN IS GENERAL AND
DOES NOT HAVE SPECIFICS FOR THE ACTUAL SAMPLING. THE PLAN
USES STATEMENTS SUCH AS: "CARE MUST BE TAKEN TO OBTAIN A
REPRESENTATIVE SAMPLE, ENSURE SAMPLING DEVICE-IS CLEAN,
FILL SAMPLE CONTAINER". ' THE PLAN SHOULD REFLECT
CONDITIONS AT QUANTICO AND BE . MORE, SPECIFIC ON HOW TO
COLLECT THE SAMPLE. SEE ATTACHMENT 11 PAGE 8
9.l.D.5.d
f. Frequency of sampling? YES
9.1.D.5.e
g. Waste analyses that off-site generators have agreed to
supply? N/A
9.l.D.5.f
h. Additional waste analysis requirements associated with
specific -waste management methods? N/A
265.13(b)(6) & 268.7 (40 CPR)
i. Required updates for LDR (see LDR checklists for more
details)? YES LDR IS MENTIONED IN THE PART B '
261.24 (40 CPR)
j. Replacement of EP Tox with TCLP? TC IS IN THE PLAN
265.13 (b)(7) (40 CFR)
k. The testing of contents/residues from LDR exempted
surface impoundments (268.4(a)) and the procedures for
the annual removal of those residues which do not meet
applicable treatment, standards? N/A NO SURFACE
IMPOUNDMENTS '
9.1.D.6
1. Procedures that will' be used by off-site facilities to
inspect and, if necessary, sample and analyze each
shipment of hazardous waste' to ensure that it matches its
identity on the accompanying manifest? N/A OFFSITE
WASTE NOT ACCEPTED BY QUANTICO
The inspector should obtain a copy of the waste analysis plan
o:jant:co marike base
3
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if any problems are found. COPY IS ATTACHED
9.1.D.5
5. Does it appear.that the facility follows its waste analysis
plan? YES ' BASED ON CONVERSATIONS WITH THE FACILITY
REPRESENTATIVES, THE FACILITY IS ABLE TO CHARACTER THEIR WASTE
PRIOR TO DISPOSAL. THE FACILITY MANAGES THE ORDERING OF
MATERIAL IN ORDER TO MINIMIZE . THE NECESSITY FOR WASTE
ANALYSIS.
9 • 1 • E • 2 • E
6. Does the facility have a 24 hour surveillance system which
continually monitors and controls entry to the active portion
of the facility? YES THROUGH ROAMING PATROLS
If no:
9.I.E.2.a.(1)
a. Does the facility have an artificial or natural
boundary which completely surrounds the active portion of
the facility? YES A FENCE WITH A LOCKABLE GATE
9.,I.E.2.a. (2)
b. Does the facility have a means to control entry at all
times, i.e., attendants, locked entrances, gates,
television monitors, controlled roadway access, etc.
YES THE FACILITY IS LOCKED EXCEPT WHEN ENVIRONMENTAL IS
PRESENT T,0 ACCEPT, INSPECT, SHIP, ETC. WASTE
9.I.E.3
7. Does the facility have a restricted access sign posted at
each entrance to the active portion of the facility, i.e.,
."Danger - Unauthorized Personnel Keep Out"? YES
9.1.F.2.a & b
8. Does the facility have a written inspection schedule and,-
if so, is it kept at the facility? . YES BOTH WEEKLY AND
MONTHLY DOCUMENTED INSPECTIONS
If yes, does it address inspecting: ATTACHED
9.1.F.2.a
a. Monitoring equipment? YES
QUANT I CO MARINE BASE
4
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b. A written job description for each position? YES
9.1.G.4.C
c. A written description of the type and amount of
training that will be given- to each person? -YES
9 .1. G. 4 . d
d. Records that- document that the training or job
experience required by facility personnel to effective iy
respond to emergencies and otherwise manage; hazardous
waste in a proper, manner has been successfully completed?.
YES
9.1.6.2
14. Have facility personnel successfully completed the
required training or job experience within six months after
occupying the position? YES
9.1.G.3
15. Do facility personnel take part in an annual review of the
initial training requirements and update them as necessary?,
YES
Answer the following questions if the facility manages either
ignitable or reactive waste.
9.1.H.1
16. Are ignitable or reactive wastes separated and protected
from sources of ignition or reaction? YES STORAGE BLDG HAS
EXPLOSION PROOF FIXTURES
17. Are there "No Smoking" signs posted wherever a hazard from
ignitable or reactive waste exists? YES
9.1.H.2
18. Are ignitable or reactive wastes managed in what appears
to be a safe manner (i.e. no generation of extreme heat,
pressure, fire or explosion, violent reactions, toxic fumes,
etc. or damage to devices holding such wastes)? YES
Answer the following question if the facility manages
incompatible wastes. . NO INCOMPATIBILITY PROBLEMS WERE
OBSERVED DURING THIS INSPECTION. THE FACILITY DOES MANAGE
WASTE, IF COMMINGLED, WOULD CAUSE A PROBLEM BUT.THESE WASTE
ARE KEPT APART
•4
9 .l.H.2.
19. Is the mixture or commingling of incompatible wastes, or
vaj:t:co marine base
£
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incompatible wastes and materials conducted in a safe manner?•
. YES
III. Preparedness and Prevention
1. Does the facility have the following equipment:
9.2.B.1
a. Internal communications or alarm system? YES
9.2.B.2
b. Telephone or hand-held two-way radio? YES CELL PHONE
9.2.B.3
c. Portable fire extinguishers or other fire control
equipment, spill control equipment and decontamination
equipment? YES FIRE STATION IS ACROSS THE- STREET
9.2.B.4
d. Adequate volume of water? YES
9.2.C
2. Does the. facility test and maintain the above equipment to
assure its proper operation? YES
9.2.E
3. Is there sufficient aisle space to allow the unobstructed
movement of personnel and equipment to.areas where hazardous
waste are located in the event of an emergency? YES
9.2.F.l.a
4. Has the facility made arrangements witn local authorities
to familiarize them with the layout of the facility and the
nature/hazards of the hazardous waste handled at the facility?
YES THE FACILITY HAS ITS OWN FIRE DEPARTMENT AND THE
COMMANDER HAS AGREED WITH THE PART B WHERE IT TALKS ABOUT THE
FIRE DEPARTMENT AND EMERGENCY RESPONSE. ARRANGEMENTS, IN
WRITING, WITH THE SURROUNDING FIRE DEPARTMENTS
IV. Contingency Plan
9.3.A.1 & C.l
1. Has the facility prepared a contingency plan and is it
maintained at the facility? YES THERE IS ONE MANUAL WITH 9
ADDITIONAL SECTIONS-ONE FOR EACH OF THE <90 GENERATORS LOCATED
AT QUANTICO
If yes, does it contain the following:
O.UANTirO MARINE 3ASE
7
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2. Does the facility note any significant discrepancies in the
manifest (significant discrepancies in,quantity are variations
greater than 10 %• for bulk waste or any variation in-piece
count- for batch waste)? N/A
5.5.C.2 .e
3. Does the facility send a copy of the manifest back to the
generator within 30 days after the waste was received? N/A
5.5.C.2.f
4. Does the facility retain a copy of the manifest for at
least 3 years? N/A
5.6.B
5. Does the facility. attempt to reconcile any significant
discrepancies in the manifest when they are discovered?
N/A
•6. If the discrepancy is not resolved within 15 days after
receiving the waste, does the facility notify the appropriate
state agency in writing? N/A
9.4.B.1
7. Does the facility keep a written operating record?
YES
If yes, does it contain the following:
9 .4 . B. 2 . a
a. Description and quantity of each hazardous waste
received? YES
b. Method(s) and date(s) of treatment, .storage or
disposal? YES NO TREATMENT AT THIS FACILITY
9.4.B.2.b
c. Location of each hazardous waste within the facility
and the quantity at each location? YES A LIST IS FAXed
¦TO THE FIRE CHIEF ROUTINELY DESCRIBING THE WASTE AND ITS
¦ LOCATION (SAMPLE ATTACHED)'AND A COMPLETE INVENTORY IS
MAINTAINED (ATTACHED)
9.4.B.2.c
d. Records and results of waste analysis? IF' THERE IS AN
ANALYSIS, IT IS ON RECORD OTHERWISE THE FACILITY' USES
MSDS AND GENERATOR KNOWLEDGE
9.4.B.2.d
e. Details of all incidents that require implementing the
QUANT:CO 'MARINE BASE
9
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contingency plan? N/A
9.4.B.2.e
f. Records and results of inspections? YES
9.4.B.2.f
g. Monitoring, testing or analytical data? YES
9.4.B.2.g
h. Closure/post-closure cost estimates? YES
265.73(b)(8) (40 CFR)
i. Records of quantities and dates of placement of
hazardous waste into land disposal units? N/A,NO LAND
DISPOSAL UNITS FOR HAZARDOUS WASTE AT QUANTICO THE
MANIFESTS INCLUDE THE LDR NOTIFICATIONS FOR DISPOSED
WASTES
265.73(b)(9) - (14) (40 CFR)
j. Copies of notifications,
demonstrations, if applicable,
program? N/A
9.4.D
8. Does the facility prepare, and submit to the appropriate
state agency by March 1 of each even numbered year, a annual
report using the correct form (Form 8700-13)? YES COVER PAGE
ATTACHED
If yes, does it contain the following:
9.4.D.1
a. EPA I.D. number, name and address of the facility?
YES
9 .4 . D. 2
b. Calendar year covered by the report? YES
9.4.D.3
c. EPA .I.D. number of each generator from which the
facility received a hazardous waste shipment during the
year? YES
9.4.D.4
d. Description and the quantity of each hazardous waste
received .during the year (for off-site facilities, this
information must be listed by EPA I.D. number of each
0 MARINE 3ASE
10
certifications and
required by the LDR
-------
generator)? YES
9.4.D.5
e. Method of treatment," storage or disposal of each
hazardous waste? NO
9.4.D.6
f. Required monitoring data? ' N/A
9.4.D.7
g. Most recent closure/post-closure cost estimates?
N/A
9.4.E
9. Has the facility received any hazardous waste from an off-
site generator without an accompanying manifest? OFF-SITE
WASTE NOT RECEIVED
VI. Ground Water Monitoring
N/A THE FACILITY. HAS NO ACTIVE NO GROUND DISPOSAL UNITS
CONSEQUENTLY THERE ARE NO GROUND WATER MONITORING
VII. Closure/Post-Closure/Financial Assurance
9.6.C.1
1. Does the facility have a written closure plan? YES
If yes, answer the following,:
a. Has the plan been approved by the State? UNDER REVIEW
AS A SECTION OF THE PART B PERMIT APPLICATION.
9.6.C.3
b. Has the closure plan been amended as necessary in
order to keep it up-to-date? PLAN FINALIZED IN JULY 1997
9.7.B.1
c. Is there a detailed and up-to-date written estimate of
closure cost? US GOV EXEMPT FROM FINANCIAL ASSURANCE
9 .7 . B. 4
d. Is the latest closure cost, estimate kept : at the.
facility? YES .
QUANTICO MARINE' BASE
11
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9.6.1.1
2. Does the facility have a written post-closure plan? IT IS
THE FACILITY'S OPINION THAT POST-CLOSURE WILL NOT BE NEEDED
SINCE THE ELDG 27401 WILL DECONTAMINATED WHEN RETIRED:
If yes, answer the following:
a. Has the plan been approved by the State? UNDER REVIEW
AS A SECTION IN THE PART B
9.6.1.4
b. Has the post-closure plan been amended as necessary in
order to keep it up-to-date?•N/A
9.7.D.1
c. Is there a detailed and up-to-date written estimate of
post-closure cost? FINANCIAL ASSURANCE EXEMPT US GOV
264.140(c)
9.7.D.4
d. Is the latest post-closure cost estimate kept at the
facility? N/A
9.7.C & 9.7.E
3. Does the facility have a means to satisfy its financial
assurance requirements? EXEMPT US GOV
VIII. Containers
Answer the following questions if the facility stores
hazardous waste in containers.
9.8.B
1. Are container(s) in good condition? YES
9.8.C
2. Are container(s) made of or lined with materials which will
not react with or be incompatible with the waste they are
storing? YES ¦
9.8.D.1
3. Are container(s)"kept closed? YES
9.8.B
4. Are any container(s) leaking? NO
9.8.E
5. Are container,storage area(s) inspected at least weekly and
C!jAN?:ro kar:::£ base
12
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is an adequate inspection record/log maintained? YES SAMPLE
INSPECTION FORM ATTACHED ' '
9.8.F
6. Are container (s) holding igni.table or reactive waste
located at least 15 meters (50 feet) from' the facility's
property line? YES
7'.- Are ' incompatible wastes "placed in the same container (s) ?
NO NONE OBSERVED
9.8.G.1
a. Is there any evidence1 that conditions of extreme heat -
or pressure, fire or explosion, violent reactions or
toxic emissions occurred? NO.
9.8.G.3
8. Are container(s) holding incompatible hazardous waste
properly separated or protected from one another while in
storage? YES SEPARATE STORAGE BAYS ARE PROVIDED'SEE PHOTOS
MARINE BASE
12
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GENERATOR CHECKLIST - VA FACILITIES
(12-92)
Date of Inspection AUG 19 97
Name of Facility: . QUANTICO:MARINE BASE
Address of Facility: MARINE CORPS COMBAT DEVELOPMENT COMMAND
EPA I.D. Number: VA1170024722 '
I. General THE- FACILITY HAS SUBMITTED A PART / B PERMIT
APPLICATION FOR THE HAZARDOUS WASTE STORAGE
BUILDING AND THE FACILITY IS USING BUILDING 27401
FOR >90 DAY STORAGE. THE FACILITY MAINTAINS 10 <90
DAY ACCUMULATION SITES AND SATELLITE STORAGE
LOCATIONS (SEE ATTACHED LISTS).
1. Provide a brief description of the type of operation(s)
that produces hazardous waste at this facility:
US MARINE BASE FOR TRAINING AND ADMINISTRATIVE ACTIVITIES, FBI
ACADEMY, AIRCRAFT MAINTENANCE, SHOOTING RANGES
2. Does the facility perform the following on-site:
a; storage (>90 day or . >180 day for SQG) of hazardous
waste? YES
b. treatment of hazardous waste? NO
. c. disposal of hazardous waste? NO
(if yes; complete appropriate TSD checklists)
3.1
3. Is the facility subject to any exclusions for its hazardous
waste? NO
6.1.C
4. Has the ,facility properly determined whether all of its
waste exhibits any of the characteristics of hazardous waste?
YES THROUGH TESTING, USER KNOWLEDGE AND MSDS INFORMATION
5. Has the' facility failed to notify the State of any of its
hazardous waste management activities, including locations of
all hazardous waste accumulation areas? NONE OBSERVED
O'JANTICO MAR I NT. 3ASE
1
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Manifest
Complete this section.only if facility ships hazardous waste
off-site.
5.2. A
1. Does the facility use the Uniform Hazardous Waste'Manifest
whenever transporting hazardous waste? YES
If yes, review a representative .number of manifests and
indicate whether they contain: THREE MANIFESTS ARE ATTACHED
FOR YOUR INFORMATION
5.3.B
a. Generator's name, mailing address, telephone number
and EPA ID number? YES -
b. Unique five digit manifest number? YES
c. Total number of pages-used.to complete this manifest?
YES
d. Transporter's name and EPA ID number? YES
e. DOT waste description, including proper shipping name,
hazardous waste class and I.D. Number as identified in Va
Regulations? YES
f. Number and type of containers (if applicable)? YES
g. Quantity of each waste transported? YES SAFETY KLEEN
MANIFEST HAVE STAND WEIGHTS FOR THE WASTE COLLECTED. THE
NUMBERS ON THE MANIFEST DO NOT ALWAYS REFLECT THE EXACT
AMOUNT OF WASTE BEING TRANSPORTED (TWO MANIFESTS ARE
ATTACHED).
h. Name, EPA ID number and site address of facility
designated to receive the waste? YES
5.3.C
i. The following certification? YES
"I hereby declare that the contents of this consignment are
fully and accurately described above by proper shipping name
and are classified, packaged, marked, and labelled, and are in
all respects in proper condition for transport by highway
according to applicable international and national government
regulations.
If I am a- large quantity generator, I certify that I have a
program in place to reduce, the volume and toxicity of waste
MARINE BASE
2
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generated to a degree I have determined to be economically-
practicable and that I' have selected the. practicable method of
treatment, storage or disposal currently available to me which
minimizes the present and future threat to human health and.
environment; OR, if I am a small quantity generator, I.have
made a good faith effort to minimize my waste generation and
select the best waste management method that is available to
me and that I can afford."
2. Did the generator:'
5.4.A
a. Sign and date the manifest? YES
5.4.B
b. Obtain the handwritten signature and date of
acceptance from the initial transporter? YES
5.4.D
c. Ensure that return copies of the manifest from the
designated.TSD facility were properly signed and dated?.
YES
5.4.E
d.. Retain a copy of the signed manifest for at least
three years? YES
The inspector should obtain copies of any manifests that are
found to have problems.
III. Pre-Transport Requirements
Complete this section only if the facility ships hazardous
waste off site.
1. Is there any indication that the facility is:
6.4. A
a. Not packaging its waste in accordance with Va
Regulations Governing Transportation of Hazardous
Materials? NO
6.4.B
b. Not labelling each package in accordance with Va
Regulations Governing Transportation of Hazardous
Materials? NO
6.4.C.2
QUANT
CO MARINE
3ASE
3
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c.. Not marking each container of 110 gallo'ns or less with
the words "Hazardous Waste-Federal Law Prohibits
Improper Disposal? • NO
6.4.D
2. Does the.facility placard'or offer the transporter placards
for its hazardous waste. shipments'? QUESTION NOT ASKED.
IV. Waste Accumulation
1. Does the facility utilize the following types of hazardous
waste accumulation:
a. Satellite accumulation? YES'
b. Less than.90 day storage? YES
Answer the following questions if the generator has satellite
accumulation area(s).
6.4. E. 4. a
.2.- Is satellite accumulation area(s) near the point of waste
generation and under the control of the operator of the
process actually generating the waste? YES
6.4.E.4.a
3. Are there multiple satellite accumulation areas for any one
process that generates hazardous waste? YES
If yes, describe: SEE REPORT FOR THE FBI GUNSMITH SHOP
6.4.E.4.a
4. Is the waste stored in container(s)? YES
9.8.B
5. Are container(s) in.good condition? YES
6.4.E.4.a.(2)
6. Are container(s) marked with the words "hazardous waste" or
the actual contents of the container(s)? YES
9.8.D.1
7. Are container(s) kept closed? YES
9.8.B
8. Are any container(s) leaking? NO
6 .4 . E. 4 .,a
C-'-'A-'-'TICO MARINE BASE
4
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9. Has the facility accumulated more than 55 gallons of
hazardous waste or more than 1 quart of acutely hazardous
waste in a satellite accumulation area? . ONE CONTAINER AT THE
FBI/HRT WAS ALL BUT FULL OF Q-TIPS AND PATCHES RESULTING FROM
GUN'CLEANING
6.4.E.4.b
a. Are the container(s) holding excess waste dated as to
when accumulation began? N/A
b. Does the excess waste comply with the less than 90 day
storage 'requirements (6.4.E.2) within three days of the
time when accumulation of such excess waste began? N/A
Answer the following questions if the facility has less than
90 day storage.
6.4. E. 2. d
10. Does the facility record inspections of its storage area
in an inspection log or summary? YES
If yes, describe what information is shown on the log
or summary: SAMPLE COPY ATTACHED TO REPORT; OPERATOR DOES A
WEEKLY AND A MONTHLY INSPECTION WHILE ENVIRONMENTAL OFFICE
DOES A QUARTERLY INSPECTION
6 .4 . E. 2 . d
11. Does the facility maintain personnel training and other
records required in 9.i.G? YES.
If yes, do these records include:.
9.1.G.4.a
a. Job title for each position related to hazardous waste
management and1 the employee filling each job? YES
9.1.G.4.b
b. A written job description for each position? YES
9 • 1. G. 4 . c
c. A written description of the type and amount of
training; that will be given to each person? YES
9 .1. G. 4 . d
d. Records that document that the training or job
experience required- by facility personnel to effectively
respond to 'emergencies and otherwise manage hazardous
waste in a proper manner has been successfully completed?
0 MARINE BASE
5
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YES
9.1.G.2
12. Have facility personnel successfully completed the
required training or job experience within six months after
occupying the position? YES
9.1.G.3
13. Do facility personnel take part in an annual review of the.
initial training requirements and update them as necessary?
YES
6.4 . E. 2 . d
14. Does the facility maintain an adequate preparedness and
prevention program as required in 9.2? YES
Is the facility equipped with:
9.2.B.1
a. Internal communications or alarm system? YES
9.2.B.2
b. Telephone or hand-held two-way radio? YES TYPICALLY
THERE ARE NO PHONES AT, THE <90 DAY STORAGE AREAS BUT
ADJACENT BUILDINGS DO HAVE PHONES
9.2.B.3
c. Portable fire extinguishers or other fire control
equipment, spill control equipment and decontamination
equipment? YES THE FACILITY ALSO HAS ITS OWN FIRE
. DEPARTMENT
9.2.B.4
d. Adequate volume of water? YES PUBLIC HYDRANT SYSTEM
9.2.C
15. Does.the facility test and maintain theabove equipment to
assure its proper operation? YES FIRE DEPARTMENT ACTIVITY
9.2 .E
16. Is there sufficient aisle space to allow the unobstructed
movement of personnel and equipment to areas where hazardous
waste are located in the event of an emergency? YES ''
9 .2 . F. 1. a
17.. Has the facility made¦ arrangements with local authorities
to familiarize them with the layout of the facility and the
nature/hazards of the hazardous waste handled at the facility?
o marine: base
6
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YES FACILITY HAS OWN FIRE DEPARTMENT ALSO THERE IS AN
AGREEMENT WITH OTHER FIRE DEPARTMENTS IN THE AREA, AGREEMENTS
IS DOCUMENTED IN PART B APPLICATION.
6.4.E.2.d
18. Has the facility prepared a contingency plan and is it
maintained at the facility? YES
If yes, does it contain:the following:
9.3.B.1
a. Description of the actions that are to be taken in
case of an emergency (all potential types of emergencies
should be identified)? YES
9.3.B.3
b. Description of , arrangements made with local
authorities? YES COPIES ARE IN THE PART B APPLICATION
9.3.B.4
c. Current list of emergency coordinators' names,
addresses and phone numbers (office and home)?
YES SOME UPDATES FOR PHONE NUMBERS AND PERSONS NEEDED
BUT THESE CHANGES ARE MINIMAL AND ARE BEING CHANGED.
9.3.B.5
d. List of all emergency equipment at the facility,
including locations, descriptions and relevant
. capabilities? YES ALTHOUGH THE RELEVANT CAPABILITIES
ARE NOT DESCRIBED
9.3.B.6
e. evacuation, plan for facility personnel? YES
The inspector should obtain a copy of the facility's
contingency plan if any problems are found.
9.3.C.2
19. Were copies of the contingency plan submitted to. local'
authorities that may provide emergency services? YES
20. Has the facility's contingency plan ever failed in an
emergency? N/A
9.3.F.10
21. If the contingency'plan is implemented, does the facility
record'the incident in its operating log and submit a -written
report of the incident to the appropriate state agency within
0 MARINE BASE
7
-------
15 days? N/A '
6 .4 . E. 2 . a
22. What is the' method of waste storage:
Containers? YES
Tanks? NO
Containment Buildings? - NO
Other? NO
Answer the following -questions if the facility uses container
storage.
6 .4 . E. 2 . b & c
23. Are the container(s) marked with the words "Hazardous
Waste" and the date that waste accumulation in that container
begins? YES
6.4.E.2
24. Based upon accumulation dates, have any container(s) been
in storage for more than 90 days? ¦ NONE OBSERVED BUT THE
FACILITY DOES HAVE A SEPARATE >90 STORAGE FACILITY
If yes, the inspector should complete the appropriate TSD
checklists. INCLUDED WITH REPORT
9.8.B
25. Are container(s) in good condition? YES ALTHOUGH THE'MIX
ROOM AT HMX-1 HAD WASTE PAINT SPILL ON THE CONTAINER AND
FLOOR,
9.8.C
26. Are container (s) made of or lined with materials which
will not react with or be incompatible with the waste they are
storing? YES
9.8.D.1
27. Are container(s.) kept closed? YES
9.8.B
28. Are any container(s) leaking?" NO
9.8.E
¦2 9. Are container storage area(s).inspected at least weekly?
YES AND THESE INSPECTIONS ARE. DOCUMENTED
o marine: base
8
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9.8.F
30. Are container (s) holding ignitable or reactive waste
„ located at least *15 meters (50 feet) from the facility's
property line? YES
31. Are incompatible.wastes placed in the same container(s)?
NONE OBSERVED
9.8.G.1
a. Is there an;" evidence that .conditions of extreme heat
or pressure, fire or explosion, violent reactions, or
toxic emissions'occurred? NO
9.8.G.3
32. Are container(s) holding incompatible hazardous waste
properly separated or protected from one, another while in
storage? YES
TANKS ARE NOT USED BY QUANTICO FOR STORAGE OF HAZARDOUS WASTE
CONTAINMENT BUILDINGS ARE NOT USED BY QUANTICO FOR THE
STORAGE OF HAZARDOUS WASTE
Recordkeeping and Reports
6.5.C.2
65. Does the facility prepare an Exception Report and submit
it to the state regulatory agency if a signed copy of the
manifest is not received within 45 days of the date the waste
was accepted by the initial transporter? N/A NO EXCEPTION
REPORTS WERE NOTED IN THE FACILITY FILES .
6.5.B.1
66. If the facility ships any hazardous waste off-site, does
it prepare, a Annual Report using the required forms and submit
it to the state regulatory agency by March 1 for the preceding
calendar year? YES BIENNIAL REPORTS ARE NOW REQUIRED BY
VEDEQ, COVER PAGE TO THE REPORT IS ATTACHED, THE FACILITY ALSO
SUBMITS GENERATION REPORTS TO DOD IN A DOD FORMAT
6.5.A.2 & 3/9.1.F.4
67. Does the facility retain copies of Annual (biennial)
Reports, Exception Reports and test results/waste .analyses for
a minimum of 3 years from the date that the waste was last
:o marine: base
9
-------
sent to on-site or off-site treatment, storage or disposal and
inspection records for at least 3 years after the inspection?"
YES
o marine: base
10
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Underground Storage Tanks
Quantico Marine Base has implemented the following leak
detection procedures for its underground storage tanks:
1. Tank tightness, tests are performed annually on all tanks.
2. The facility utilizes inventory control procedures for all
tanks.
3 . Ground water monitoring is in place as a back up on all tanks~.
In addition, the facility has installed an interstitial
monitoring system on the following tanks:
2056D, 2056E, 2056F,- 24142A,. 26156A, . & 27002C
The facility has also installed automatic tank gauging systems
on the following tanks:
3500B, 3500C, &3500D
During the subject inspection, the EPA inspector, completed
leak detection inspection checklists for all of the facility's
regulated tanks. The completed checklists are provided as part of
this report.
Also included as attachments to this report are a number of
documents requested by the EPA inspector at the time of the
inspection. These documents are as follows:
Attachment No. UST-1 Site characterization report for tank no.
27940C, FBI Service Station
Attachment No. UST-2 Underground tank system characteristic
reports
Attachment No. UST-3 Example of tank leak detection reports
22
-------
i aumiy iw ivuitiuoi ju i / u*t/
Leak Detection Inspection Checklist
1. Ownership of Tank(s)
II. Location of Tank(s)
MARINE CORPS COMBAT DEVELOPMENT COMMAND
,
Owner Name (Corporation, Individual. Public Agency or other entity):
3040 McCAWLEY AVENUE
Facilitv Name or ComDanv Site Identifier, if different from left
Street Address
QUANTICO VIRGINIA 22134-5053
Street Address or State Road, as applicable
City State Zip Code
703 784 4030
City (nearest) State Zip Code
Area Code Phone Number
CAMILO K. COBILE
Area Code Phone Number
Number of Tanks at This Location: 9
Contact Person At UST Location
lit. Tank Information Complete tot «acfc tank. If faciBty has more tlwi 4 tank#, photocopy page and complete information for additional tanis.
Tank presently in use (circle)
Tank 2056D
Tank 2056E
Tank 2056F
Tank 24142A
If not. date last used
If emptied, verify 1" or less of product in tank
Month and Year Tank Installed
08/01/91
08/01/91
08/01/91
09/01/91
Material of Construction
FIBERGLASS
FIBERGLASS
FIBERGLASS
FIBERGLASS
Capacity of Tank (in gallons)
10,000
10,000
6,000
4,000
Substance Stored
GASOLINE
GASOLINE
DIESEL
GASOLINE
IV.A. Release Detection For Tanks <%«<* the reiem dmetsw «wth«ife*»for wf* ot wa h
Manual Tank Gauging (tanks under 1,000 gal.)
Manual Tank Gauging and Tank Tightness Testing
(tanks under 2,000 gal.)
Tank Tightness Testing and Inventory Control
~
~
~
~
Automatic Tank Gauging
~
~
~
~
Vapor, Groundwater or Interstitial Monitoring
~
~
~
~
Other approved method
IV.B. Release Detection For Piping Check lh# retease detection method!*} used (or piping.
Check Pressurized (P) or Suction (S) Piping for
each tank
S
S
S
S
Automatic Line Leak Detectors, and check one
'
Vapor or Groundwater Monitoring
~
~
~
~
Secondary Containment with Monitoring
~
~
~
~
Line Tightness Testing
~
~
~
~
I Gerard R. Donovan. Jr. certifv tha
I have inspected the above named faci
itvon 08/11.12/97
(print name)
Inspector's Signature:
'month/day/year
. Date: 08/11.12/97
: . ' '•
-------
1A Facility ID Number 3017647
Leak Detection Inspection Checklist
!. Ownership of Tank(s}
II. Location of Tank(s)
MARINE CORPS COMBAT DEVELOPMENT COMMAND
'
Owner Name (Corporation, Individual. Public Agency or other entity):
3040 McCAWLEY AVENUE
Facility Name or ComDanv Site Identifier, if different from left
Street Address
QUANTICO VIRGINIA 22134-5053
Street Address or State Road, as applicable
City State Zip Code
703 784 4030
City (nearest) State Zip Code
Area Code Phone Number
CAMILO K. COBILE
Area Code Phone Number
Number of Tanks at This Location: ¦ 9
Contact Person At UST Location
II f. Tank Information Complete for each wr*. It facifity has more than 4 tanks, photocopy page and complete information for additional tBnfe.
Tank presently in use (circle)
Tank 26156A
Tank 27002C
Tank 3500B
Tank 3500C
If not, date last used
If emptied, verify 1" or less of product in tank
J
Month and Year Tank Installed
01/01/92
01/01/91
01/01/86
01/01/86
Material of Construction
FIBERGLASS
FIBERGLASS
FIBERGLASS
FIBERGLASS
Capacity of Tank (in gallons)
4,000
10,000
12,000
12,000
Substance Stored
DIESEL
DIESEL
GASOLINE
GASOLINE
1V.A. Release Detection For Tanks Check tlte r«Je»sa detection fnethodfs) used for sseh tank or tifA if none required.
Manual Tank Gauging (tanks under 1,000 gal.)
Manual Tank Gauging and Tank Tightness Testing
(tanks under 2,000 gal.)
.
Tank Tightness Testing and Inventory Control
~
~
~
~
Automatic Tank Gauging
~
~
~
~
Vapor, Groundwater.or Interstitial Monitoring
~
~
~
~
Other approved method
IV.B. 'Release Detection For Piping Check the releasedetection methodls) used lot piping.
Check Pressurized (P) or Suction (S) Piping for
each tank
,S
S
s
S
Automatic Line Leak Detectors, and check one
Vapor or Groundwater Monitoring -
~
~
~
~
Secondary Containment with Monitoring
~
~
~
~
Line Tightness Testing
V
~
~
~
I Gerard R. Donovan. Jr. certify tha
11 have inspected the above named faci
itvon 08/11.12/97
(print name)
Inspector's Signature:
month/day/year
• Date: 08/11.12/97
-------
id Facility >D Number 3017647
Leak Detection Inspection Checklist
I. Ownership of Tank{s)
11. Location of Tank(s)
MARINE CORPS COMBAT DEVELOPMENT COMMAND
r
Owner Name (Corporation, Individual. Public Agency or other entity):
3040 McCAWLEY AVENUE
Facility Name or ComDanv Site Identifier, if different from left
Street Address
QUANTICO VIRGINIA 22134-5053
Street Address or State Road, as applicable
City State Zip Code
703 784 4030
City (nearest) State Zip Code
Area Code Phone Number
CAMILO K. COBILE
Area Code Phone Number
Number of Tanks at This Location: 9
Contact Person At UST Location
lit. Tank Information Complete far each tar*. If ieciBty has more than A tanks, photocopy page and complete information far additional tBn&s.
Tank presently in use (circle)
Tank 3500D
Tank
Tank
Tank
If not, date last used
If emptied, verify 1" or less of product in tank
1
Month and Year Tank Installed
01/01/86
Material of Construction
FIBERGLASS
1 ;
Capacity of Tank (in gallons)
12,000
Substance Stored
GASOLINE
IVkA. Release Detection For Tanks Cfcaek the reieass detection mathixlfs} used for each Jarflt or WA if nan* required.
Manual Tank Gauging (tanks under 1,000 gal.)
Manual Tank Gauging and Tank Tightness Testing
(tanks under 2,000 gal.)
-
Tank Tightness Testing and Inventory Control
~
i
Automatic Tank Gauging
~
Vapor, Groundwater or Interstitial Monitoring
~
Other approved method
IV
-------
2 Facility ID Number 3017647
Leak Detection for PiDina
Pressurized Piping A method must be selected from each set. Where applicable indicate date of last test. If this facility
more than 4 tanks, please photocopy this page and complete information for aft additional piping.
las
Set 1
Tank 20560
Tank 2056E
Tank 2056F
Tank24142A
Automatic Flow Restrictor
Automatic Shut-off Device
Continuous Alarm System
,
and
Set 2
Annual Line Tightness Testing
Interstitial Monitoring
If Interstitial Monitoring, documentation of monthly monitoring is
available
Ground-Water or Vapor Monitoring
If Ground-Water or Vapor Monitoring, documentation of monthly
monitoring is available
Other Approved Method (specify in comments section)
Suction Piping * indicate date of most recent test.
Line Tightness Testing (required every 3 years)
YEARLY
YEARLY
YEARLY
YEARLY
Secondary Containment with Interstitial Monitoring
~
~
~
~
Ground-Water or Vapor Monitoring
BACK UP
BACK UP
BACK UP
BACK UP
Other Approved Method (specify in comments section)
4 No Leak Detection Required
(must answer yes to all of the following questions)
Operates at less than atmospheric pressure
" .
,
Has only one check valve, which is located directly under pump
Slope of piping allows product to drain back into tank when suction
released
All above information on suction piping is verifiable
On die back of this sheet, please sketch the sitej noting all piping rims, tanks {Including size and substances stored) and location of
wells and their distance from tanks and piping.
Comments:
Inspector's Sianature: Date: 08/11.12/97
-------
t-acnity iu Number 3U17647
Leak Detection for Pioino
Pressurized Piping A method must be selected from each set. Where applicable indicate date of fast test. If
more than 4 tanks, please photocopy this page and complete information for all additional p
is facility has
ping.
Set 1
Tank26156A
Tank27002C
Tank3500B
Tank3500C
Automatic Flow Restrictor
~
~
Automatic Shut-off Device
, ~
~
Continuous Alarm System
-
~
~
and
Set 2
Annual Line Tightness Testing
~
~
Interstitial Monitoring
If Interstitial Monitoring, documentation of monthly monitoring is
available
Ground-Water or Vapor Monitoring
BACK UP
BACK UP
If Ground-Water or Vapor Monitoring, documentation of monthly
monitoring is available
Other Approved Method (specify in comments section)
Suction Piping * indicate date of most recent test.
Line Tightness Testing (required every 3 years)
YEARLY
YEARLY
Secondary Containment with Interstitial Monitoring
~
~
Ground-Water or Vapor Monitoring
BACK UP
BACK UP
Other Approved Method (specify in comments section)
I
No Leak Detection Required
(must answer yes to all of the following questions)
Operates at less than atmospheric pressure
Has only one check valve, which is located directly under pump
Slope of piping allows product to drain back into tank when suction
released \ .
All above information on suction piping is verifiable
On the back oi this sheet, please sketch the site, noting alt piping runs, tanks {Including size and substances stored) and location of
wells and their distance from tanks and piping.
Comments:
¦
Inspector's Sianature: ~ Date: 08/11.12/97
-------
- hactUty ID Number 3017647
Leak Detection for PiDina
Pressurized Piping A method must be selected from each set. Where applicable indicate date of last test. If this facility has
more than 4 tanks; please photocopy this page and complete information for all additional piping.
Set 1
Tank 3500D
Tank
Tank
Tank
Automatic FlowRestrictor
~
Automatic Shut-off Device
~
Continuous Alarm System \ -
~
and
Set 2
Annual Line Tightness Testing
~
Interstitial Monitoring
If Interstitial Monitoring, documentation of monthly monitoring is
available
Ground-Water or Vapor Monitoring
If Ground-Water- or Vapor Monitoring, documentation of monthly
monitoring is available
Other Approved Method (specify in comments section)
Suction Piping. indicate date of most recent test.
Line Tightness Testing (required every 3 years)
Secondary Containment with Interstitial Monitoring
,
Ground-Water or Vapor Monitoring
Other Approved Method (specify in comments section)
No Leak Detection Required
(must answer yes to all of the following questions)
Operates at less than atmospheric pressure
Has only one check valve, which is located directly under pump
Slope of piping allows product to drain back into tank when suction
released
All above information on suction piping is verifiable
On the back of this sheet, please sketch the site, noting all piping rims, tanks {including size and substances stored) and location of
wells and their distance from tanks and piping.
Comments:
/ - , "
Inspector's Signature:
Date:
08/11.12/97
-------
Facility )U Number 3U17S47
Inventory Control and Tank Tightness Testing
Method of tank tiqhtness testing: VACUTECT
Name and address of tank tiqhtness tester: TANKNOLOGY ENVIRONMENTAL INC. 201 NORTH FAIRFAX STREET; ALEX. Va
Please complete alt information for each tank If this facility has more than 4 tanks, please photocopy this page and complete the
information for all additional tanks.
Tank 2056D
Tank 2056E
Tank 2056F
Tank 24142A
Date of last tank tightness test. YEARLY
07/31/96
07/31/96
07/31/96
07/31/96
Did tank pass ,test? Indicate yes or no. If no, specify in
comments section below the status of the tank or what
actions have been taken (e.g., has state been notified?)
YES
YES
YES
YES
Documentation of deliveries and sales balances with daily
measurements of liquid volume in tank are maintained and
available.
YES
YES
YES
YES
Overages or shortages are less than 1 % + 130 gals of
tank's flow-through volume.
YES
YES
YES
YES
If no, which months were not?
Please answer yes or no for each question
Owner/operator can explain inventory control methods and figures used and recorded.
Yes ~
No
Records include monthly water monitoring.
Yes ~
No
Tank inventory reconciled before and after fuel delivery.
Yes ~
No
Books are reconciled monthly.
Yes ~
No
Appropriate calibration chart is used for calculating volume.
Yes ~
No
Dispenser pumps are calibrated to within 6 cubic inches per five gallons.
Yes ~
No
The drop tube in, the fill pipe extends to within one foot of tank bottom.
Yes ~
No
Owner can demonstrate consistency in dipsticking techniques.
Yes ~
No
The dipstick is long enough to reach.the bottom of the tank.
Yes ~
No
The ends of the gauge stick are flat and not worn down.
Yes ~
No
i The dipstick is marked legibly & the product level can be determined to the nearest 1 /8th inch.
Yes ~
No
The tank has beeri tested within the year & has passed the tightness test (if necessary).
Yes ~
No!
A third-party certification of the tank tightness test method is available.
Yes ~
No
Tank tester complied with all certification requirements.
Yes ~
No
1 Monitoring and testing are maintained and available for the past 12 months.
Yes ~
No
Comments:
' ' "
Inspector's Siqnature: Date: - 08/11.12/97
¦
-------
o« , Facility ID Number 3017647
Inventory Control and Tank Tightness Testing
Method of tank tiqhtness testinq: VAQI.JTECT
Name and address of tank tightness tester: TANKNOLOGY ENVIRONMENTAL. INC. 201 NORTH FAIRFAX STREET. ALEX. Va
. ¦ .
Please complete all information for each tank If this facility has more than 4 tanks, please photocopy this page and complete the
information for all additional tanks.
Tank 26156A
Tank 27002C
Tank 3500B
Tank 3500C
Date of last tank tightness test. YEARLY
. 07/31/96
07/31/96
07/31/96
07/31/96
Did tank pass test? indicate yes or no. If no, specify in
comments section below the status of the tank or what
actions have been taken (e.g., has state been notified?)
YES
YES
YES
YES
Documentation of deliveries and sales balances with daily
measurements of liquid volume in tank are maintained and
available.
YES
YES
YES
YES
Overages or shortages are less than 1 % + 130 gals of
tank's flow-through volume.
YES
YES
YES
YES
If no, which months were not?
Please answer yes or no for each question
Owner/operatOr can explain inventory control methods and figures used and recorded.
Yes ~
No
Records include monthly water monitoring.
Yes ~
No
Tank inventory reconciled before and after fuel delivery.
Yes ~
No
Books are reconciled monthly.
Yes ~
No
Appropriate calibration chart is used for calculating volume.
Yes ~
No
Dispenser pumps are calibrated to within 6 cubic inches per five gallons.
Yes ~
No
The drop tube in the fill pipe extends to within one foot of tank bottom.
Yes ~
No
Owner can demonstrate consistency in dipsticking techniques.
Yes ~
No
The dipstick is long enough to reach the bottom of the tank.
Yes ~
No
The ends of the gauge stick are flat and not worn down.
Yes ~
No
The dipstick is marked legibly & the product level can be determined to the nearest 1 /8th inch.
Yes ~
No
The tank has been tested within the year & has passed the tightness test (if necessary).
Yes ~
No
A third-party certification of the tank tightness test method is available.
Yes ~
No
Tank tester complied with all certification requirements.
Yes ~
No
Monitoring and testing are maintained and available for the past 12 months.
Yes ~
No
Comments:
Inspfirtnr's Signature: Date: 08/11.12/97
-------
Facility ID Number 3017647
Inventory Control and Tank Tightness Testing
Method of tank tightness testinq: VAQUTECT
Name and address of tank tiahtness tester: TANKNOLOGY ENVIRONMENTAL. INC. 201 NORTH FAIRFAX STREET. ALEX. Va
Please complete all information for each tank If this facility has more than 4 tanks, pfease photocopy this page and complete the
information for all additional tanks.
'
Tank 3500D
Tank
Tank
Tank
, Date of last tank tightness test. YEARLY
07/31/96
Did tank pass test? Indicate yes or no. If no, specify in
comments section below the status of the tank or what
actions have been taken (e.g., has state been notified?)
YES
Documentation of deliveries and sales balances with daily
measurements of liquid volume in tank are maintained and
available.
YES
Overages or shortages are less than 1 % + 130 gals of
tank's flow-through volume.
YES
If no, which months were not?
Please answer yes or ikj for each question
Owner/operator can explain inventory control methods and figures used and recorded.
Yes ~
No
Records include monthly water monitoring.
Yes ~
No
Tank inventory reconciled before and after fuel delivery.
Yes ~
No
Books are reconciled monthly.
Yes ~
No
Appropriate calibration chart is used for calculating volume.
Yes ~
No
Dispenser pumps are calibrated to within 6 cubic inches per five gallons.
Yes ~
No
The drop tube in the fill pipe extends to within one foot of tank bottom.
Yes ~
No
Owner can demonstrate consistency in dipsticking techniques.
Yes ~
No
The dipstick is long enough to reach the bottom of the tank.
Yes ~
No
The ends of the gauge stick are flat and not worn down.
Yes ~
No
i The dipstick is marked legibly & the product level can be determined to the nearest 1 /8th inch.
Yes V
No
The tank has been tested within the year & has passed the tightness test (if necessary).
Yes ~
No
A third-party certification of the tank tightness test method is available.
Yes ~
- No.
Tank tester complied with all certification requirements.
Yes ~
No
'Monitoring and testing are maintained and available for the past 12 months.
Yes ~
No
Comments:
i ¦ ¦
Inspector's Siqnature: Date: 08/11.12/97
; .. 1
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racnuy lu iMumoer ju i /to4/
Vapor Monitoring
Name of monitorina device:
Date svstem installed . Number of monitorinq wells
Distance of monitorina well(s) from tank(s) (1) 12) (3) (4)
Site assessment was conducted by:
Location of site assessment documentation:
Please indicate yes or no for each tank Please complete all information for each tank. if facility ht
please photocopy this page and complete the information
i$ more than 4 tanks,
or additional tanks.
Tank 1
Tank 2
Tank 3
Tank 4-
Well is clearly marked and secured.
Well caps are tight.
Well is constructed so that monitoring device is not rendered inoperative by
moisture or other interferences.
Well is free of debris or has other indications that it has been recently checked.
Piease answer yes or no for each q
uestfon
UST excavation zone was assessed prior to vapor monitoring system installation.
Yes
No
One or more USTs is/are included in system.
Yes
No
If the system is automatic, check the following:
Power box is accessible and power light is on.
Yes
No
Documentation of monthly readings is available for last 12 months.
Yes
No
Equipment used to take readings is accessible and functional.
Yes
No
Vapor monitoring equipment has been calibrated within the last year.
Yes
No
If the system Is manual, check the following:
Documentation of monthly readings is available for last 12 months.
Yes
No
Equipment used to take readings is accessible and functional.
Yes
No
Vapor monitoring equipment has been calibrated within the last year.
Yes
No
Porous material was used for backfill.
Yes
No
Wells are placed within the excavation zone.
Yes
No
Level of background contamination is known.
If so - what is level? '
Yes
No
On the back of this sheet, please sketch the site, noting alt piping runs, tanks (including site and substances stored) and location of
wells;and their:distance from tanks and piping.
Comments: NOT USED FOR TANK TIGHTNESS IS A BACKUP CHECK
Inspector's Signature: Date: 08/11.12/97
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5 Facility ID Number 3017647
R ' ' :¦¦¦¦ —|
Manual Tank Gauqinq
Manual tank gauging may be used as the sole method of leak detection only for tanks of 1,000 gal. or fewer or in combination with
tank tightness testing for tanks of up to 2,000 gal.
I Please indicate the number of the tank or tanks for which manual tank gauging is used as the main leak detection method (e.g.;
tanks 1 & 4):
Please answer yes Or no for each question
Records show liquid level measurements are taken at beginning and end of
period of at least ([Circle one] 36, 44, 58) hours during which no liquid is
I added to or removed from the tank.
Yes
No
Level measurements are based on average of two consecutive stick readings
at both beginning and end of period.
Yes
No
Monthly average of variation between beginning and end measurements is less
than standard shown below for corresponding size and dimensions of tank and
| waiting time.
Yes
No .
Gauge stick is long enough to reach bottom of the tank. Ends of gauge stick
are flat and not worn down.
Yes
No
Gauge stick is marked legibly and product level can be determined to the
nearest one-eighth of an inch.
Yes
No
M T G is used as sole method of leak detection for tank.
Yes
No
M T G is used in conjunction with tank tightness testing.
Yes
No
Are all tanks for which MTG is used under 2,000 gallons in capacity?
Yes
No
Are monitoring records available for the last 12 month period?
Yes
No
Check One:
Nominal Tank Capacity
[in gallons*
Tank Dimensions
Monthly Standard
{in gallons)
Minimum Test
Dwation
( )
550
N/A
5
36 hours
< »
551 -1,000
N/A
7
36 hours
( )
1,000
64" diameter x 73"
length
4
44 hours
( )
< >
1.000
48" diameter x 128"
length
6
58 hours
1.001 -
2.000*
N/A
13
36 hours
* Manual tank gauging must be used in combination with tank tightness testing for tanks over 1,0G0 gaf< and less than 2,000 gal,
l
Comments:
NONE
... ' >
1
Inspector's Signature:
Date: 08/11.12/97
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• uwnit) iw i«Ulnubi ww • i W"T i
Ground Water Monitoring
Date Svstem Installed:
Distance of well from tank(s) (1) (2)
(3)
(4)
Distance of well from DiDina (1) (2)
(3)
(4)
Site assessment was conducted by:
Location of site assessment documentation:
Please answer each question of each well if there are more than 4 welts, please photocopy this page end complete
the information far all additional wells.
Well 1
Well 2
Well 3
Well 4
Well is clearly marked and secured to avoid unauthorized
access or tampering.
Well was opened and presence of water was observed in
well at depth of ft.
Please answer yes or no for each question
Wells are used to monitor piping.
Yes
No
Site assessment was performed prior to installation of wells;
Yes
No
Documentation of monthly readings is available.
Yes
No
Specific gravity of product is less than one.
Yes
No
Hydraujic conductivity of soil between UST system and monitoring wells is not less than 0.01
cm/sec. According to:
Yes
No
Groundwater is not more than 20 feet from ground surface.
Yes
No
Wells are seaied from the ground surface to top of filter pack.
Yes
No
Continuous monitoring device or manual bailing method used can detect the presence of at
least one-eighth of an inch of the product on top of groundwater in well.
Yes
No
Groundwater is monitored: ( ) Manually on a monthly basis.
() Automatically (continuously or monthly basis [Circle one)).
Check the followina if aroundwater is monitored manuallv:
functional.
Bailer used is accessible and
Yes
No
Check the followinq if qrofjnd water is monitored agtomatically: Monitorinq box is operational.
Yes
No
Checked for presence of sensor in monitoring well.
Yes 1
No
On the back of tWs sheet please sketch the site, noting all piping runs, tanks (including size and substances stored) and location of
wells and their distance from tanks end piping.
Comments: NOT USED FOR TANK TIGHTNESS IS A BACKUP CHECK
InsDector's Sianature:
Date: 08/11.12/97
-------
rduijiy iu muiituei ou i /oh/
Interstitial Monitoring
Manufacturer and name of system: RED JACKET 1401
Date svstem installed: 1991. & 1997
Materials used for secondary barrier: FIBERGLASS
Materials used for internal lininp: FIBERGLASS
Interstitial space is monitored (Circle one): automatically, coptfnuoysly. monthly basis.
Please answer yes or no for each question
All tanks in system are fitted with secondary containment and interstitial monitoring.
Yes ~
No
N/A
System is designed to detect release from any portion of UST system that routinely contains
product.
Yes ~
No
N/A
Monitoring method is documented as capable of detecting a leak as small as .1 gal./hr. with at least
a 95% probability of detection and a probability of false alarm of no more than 5%.
Yes ~
No
N/A
Documentation of monthly readings is available for last 12 months.
Yes ~
No
N/A
Maintenance and calibration documents and records are available and indicate appropriate
maintenance procedures for system have been implemented.
Yes ~
No
N/A
Monitoring box, if present, is operational.
Yes ~
No
N/A
If monitoring wells are part of leak detection system, monitoring wells are clearly marked and
secured to avoid unauthorized access and tampering.
Yes
No
N/A ~
Interstitial space is monitored manually on monthly basis (answer the following question).
Yes
No
N/A
Equipment used to take readings is accessible and functional.
Yes
No
N/A
Tank is double-walled
Yes
No
N/A
•)
Tank is fitted with internal bladder to achieve secondary containment
(answer the following question).
Yes
No
N/A
Bladder is compatible with substance stored and will not deteriorate in the presence of that
substance.
Yes
No
N/A
Excavation is lined with impervious artificial material to achieve secondary containment
(answer the following questions).
Yes
No
N/A
Secondary barrier is always above groundwater.
Yes
No
N/A
If secondary barrier is not alvyays above groundwater, secondary barrier and monitoring designs
are for use under such conditions.
Yes
No
N/A
Secondary barrier is constructed from artificially constructed material, with permeability to
substance < 106 cm/sec.
Yes
No
N/A
Secondary barrier is compatible with the regulated substances stored and will not deteriorate in
1 presence of that substance.
Yes
No
N/A
Secondary barrier does not interfere with operation of cathodic protection system.
Yes
No
N/A
Comments:
-
Inspector's Signature: Date: 08/11.12/97
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facility ID Number 3017647
Automatic Tank Gauging
Manufacturer, name and model number of system: VEEDER ROOT 250
Tank # 3500B. 3500C & 3500D
Please answer yes or no for each question
Device documentation is available at site (e.g., manufacturer's brochures,
owner's manual).
Yes ~
No
Device can measure height of product to nearest one-eighth of an inch.
Yes ~
No
Documentation shows that water in bottom of tank is checked monthly to
nearest one-eighth of an inch.
Yes ~
No
Documentation is available that the ATG was in test mode a minimum of once a
month.
Yes ~
No
Checked for presence of gauge in tanks. -
Yes ~
No
Checked for presence of monitoring box and evidence that device is working
(i.e., device is equipped with roll of paper for results documentation).
Yes
No
Owner/operator has documentation on file verifying method meets minimum
performance standards of .20 gph with probability of detection of 95% and
probability of false alarm of 5% for automatic tank gauging (e.g., results sheets
under EPA's "Standard Test Procedures for Evaluating Leak Detection
Methods").
Yes ~
No
Checked documentation that system was installed, calibrated, and maintained
according to manufacturer's instructions.
Yes ~
No
Maintenance records are available upon request.
Yes t/
No
Monthly testing records are available for the past 12 months.
Yes ~
No
Daily monitoring records are available for the past 12 months (if applicable).
Yes ~
No
Comments:
Inspector's Signature: _____ Date: ~ 08/11.12/97
-------
raumy iu ivuinoer ou i / oh/
Statistical Inventory Reconciliation
Please complete ail information for each tank If this facility has more than 4 tanks, please photocopy tNs page and
complete the information far all additional tanks.
Documentation of deliveries and sales balances with daily
measurements of liquid volume in tank are maintained and
available.
Please answer yes or no for each question
Records include monthly water monitoring.
Yes
No
Tank inventory reconciled before and after fuel delivery.
Yes .
No
Appropriate calibration chart is used for calculating volume.
x Yes
. No
Dispenser pumps are calibrated to within 6 cubic inches per five gallons.
Yes
No
The drop tube in the fill pipe extends to within one foot of tank bottom.
Yes
No
of the following three;
1) Owner can demonstrate consistency in dipsticking techniques.
Yes
No
a) The dipstick is long enough to reach the bottom of the tank.
Yes
No
b) The end of the gauge stick is flat and not worn down.
Yes
No
c) The dipstick is legible & the product level can be determined to the nearest 1 /8th inch.
Yes
No
fiB
2) Automatic tank gauge is used for readings.
Yes
No
QB
3) Other method is used for readings (explain in comment section below).
Yes
No
A third-party certification of the SIR method is available.
Yes
No
Monitoring and testing records are maintained and available for the past 12 months.
Yes
No
' Comments: NOT USED
)
InsDector's Sianature:
Date: 08/11.12/97
1 =========== ==^====r'
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10 Facility ID Number 3017647
Spill/Overfill Prevention
X Tank 2056D
Tank 2056E
Tank 2056F
Tank 24142A
Are all tank transfers less than 25 gallons?
Yes No ~
Yes No ~
Yes No ~
Yes No ~
Sp8l Prevention
Is there a spill bucket (at least 5 gallons) or another
device that will prevent release of product to the
environment (such as a dry disconnect coupling)?
Yes»^ No
Yes ~ No
Yes ~ No
Yes ~ No
Overfill Prevention
What device is used to prevent tank from being
overfilled?
Ball float valve
Yes No
Yes No
Yes No
Yes No
Butterfly valve (in fill pipe) ,
Yes ~ No
Yes ~ No
Yes ~ No
Yes ~ No
Automatic alarm monitoring is used
Yes No
Yes No
Yes No
Yes No
Other alarm system
Yes No
Yes No
Yes No
Yes No
Cathodip Protection
Tank 1
Tank 2
Tank 3
Tank 4
Sacrificial Anode System
Test results show a negative voltage of at least 0.85
Volts (using the tank and a copper/copper sulfate cell)?
Yes No
Yes
No
Yes
No
Yes
No
The last two test results are available. (Tests are
required every three years.)
Yes No
Yes
No
Yes
No
Yes
No
Impressed Current
Rectifier is on 24 hours a day?
Yes No
Yes
No
Yes
No
Yes
No
The last two test results are available? (Tests are
required every 60 days.)
Yes No
Yes
No
Yes
No
Yes
No
Test results show a negative voltage of at least 0.85
Volts (using the tank and a copper/copper sulfate cell)?
Yes No
Yes
No
Yes
No
Yes
No
Comments: ~ '
1
Inspector's Signature:
Date:
08/11.12/97
-------
10A Facility ID Number 3017647
Spill/Overfill Prevention
Tank 26156A
Tank 27002C
Tank 3500B
Tank 3500C
Are all tank transfers less than 25 gallons?
Yes No ~
Yes No*'
Yes
No ~
Yes
No ~
Spftl Prevention
Is there a spill bucket (at least 5 gallons) or another
device that will prevent release of product to the
environment (such as a dry disconnect coupling)?
Yes ~ No
Yes ~ No
Yes ~
No
Yes ~
No
Overfill Prevention
What device is used to prevent tank from being
overfilled?
Ball float valve
Yes No
Yes No
Yes
No
Yes
No
Butterfly valve (in fill pipe)
Yes ~ No
Yes ~ No
Yes ~
No
Yes ~
No
Automatic alarm monitoring is used
Yes No
Yes No
Yes
No
Yes
No
Other alarm system
Yes No
Yes No,
Yes
No
Yes
No
Tank 1
Tank 2
Tank 3
Tank 4
Sacrificial Anode System
Test results show a negative voltage of at least 0.85
Volts (using the tank and a copper/copper sulfate cell)?
Yes No
Yes
No
Yes
No
Yes
No
The last two test results are available. (Tests are
required every three years.)
Yes No
Yes
No
Yes
No
Yes
No
Impressed Current
Rectifier is on 24 hours a day?
Yes No
Yes
No
Yes
No
Yes
No
The last two test results are available? (Tests are
required every 60 days.)
Yes No
Yes
No
Yes
No
Yes
No
Test results show a negative voltage of at least 0.85
Volts (using the tank and a copper/copper sulfate cell)?
Yes No
Yes
No
Yes
No
Yes
No
Comments:
Inspector's Signature:
Date:
08/11.12/97
-------
TOB Facility ID Number 3017647
Spill/Overfill Prevention
Tank 3500D
Tank
Tank
Tank
Are all tank transfers less than 25 gallons?
Yes No ~
Yes
No
Yes
No
Yes
No
Spftl Prevention
Is there a spill bucket (at least 5 gallons) or another
device that will prevent release of product to the
environment (such as a dry disconnect coupling)?
Yes ~ No
Yes
No
Yes
No
Yes
No
Overall Prevention
What device is used to prevent tank from being .
overfilled?
Ball float valve
Yes No
Yes
No
Yes
No
Yes
No
Butterfly valve (in fill pipe)
Yes ~ No
Yes
No
Yes
No
Yes
No
Automatic alarm monitoring is used
Yes No
Yes
No
Yes
No
Yes
No
Other alarm system
Yes No
Yes
No
Yes
No
Yes
No
Cathpdic Protection
'
Tank 1
Tank 2
Tank 3
Tank 4
Sacrificial Anode System
Test results show a negative voltage of at least 0.85
Volts (using the tank and a copper/copper sulfate cell)?
Yes No .
Yes
No
Yes
No
Yes
No
I
The last two test results are available. (Tests are
required every three years.)
Yes No
Ves
No
Yes
No
Yes
No
Impressed Current
Rectifier is on 24 hours a day?
Yes No
Yes
No
Yes
No
Yes
No
The last two test results are available? (Tests are
required every 60 days.)
Yes No
Yes
No .
Yes
No
Yes
No
Test results show a negative voltage of at least 0.85
Volts (using the tank and a copper/copper sulfate cell)?
Yes No
Yes
No
Yes
No
Yes
No
Comments:
Inspector's Siqnature:
Date:
08/11.12/97
-------
Clean Air Act
The purpose of this was to determine the .facility1s compliance
with standards for VOC air contaminants and standards for visible
and fugitive emissions. The Virginia SIP codified at §120-04-0403,
§120-04-0404, §120-04-0409, and §120-04-0410,the . federal
requirements under New Source Performance Standards (NSPS), cited
in 40 CPR §§ 60.1 - 60.759, and Prevention of Significant
Deterioration and New Source Review, cited in 40 CFR §52.21 and 40
CFR §52.10.
Additional attention was given to NOx and S02 emissions
particularly from combustion operations as cited in the Virginia
SIP in §120-04-0408 and §120-04-0405. VOC emissions from coating
operations and from petroleum storage operations were also targeted
as cited in the Virginia SIP in §120-04-0407 and §120-04-3703.
A detailed review of the facility's operating permits as a
stationary source was conducted as cited in the Virginia SIP in
§120-08-01. Solvent metal' cleaning operations were also inspected
as cited in the Virginia SIP in §120-04-2401.
Furthermore, operations that handled and/or used
chlorofluorocarbons (CFCs) were specifically targeted because of.
the size of the facility(coveting over 60,000, acres) as cited in 40
CFR §82.34, §82.154. As a federal facility, the Marine Corps Combat
Development Command (The Base) is required to adopt procurement
regulations which conform to the policies and requirements of Title
VI of the Clean Air Act as cited in 40 CFR §82.80.
At the outset of the inspection, the EPA inspector, Humberto
Monsalvo met with the facility representative, Mark Branca, Air
Compliance Manager and a representative from the FBI Academy. Mr.
Branca described different areas of the Base such as the central
heating plant and the locations of spray booths and some of the
•tenant organizations such as the FBI Academy, The Marine Corps
Basic School, and Camp Barrett.
Mr. Branca, also stated that he was, completing the Title V
application for the Base to submit shortly thereafter to the VADEQ
pursuant to the Clean,Air Act Amendment requirements of 1990.
He stated that there were 6 spray booths throughout the base
and 2 spray booths at the FBI Academy. The EPA inspector
requested a description of boilers at the base's central heating
plant and Camp Barrett to which Mr. Branca provided the following
list :
a) Boiler #1 had-a design - capacity of 61 MMBtu/hr and was' fired
with distillate oil (fuel oil with a maximum sulfur content of 0.5%
23
-------
tjy . wt. )
b) Boiler #2 had a design capacity of 61 MMBtu/hr and was fired
with distillate oil (fuel oil with a maximum sulfur content'of 0.5%
by wt. )¦
c) Boiler #3 had a design capacity of 84 MMBtu/hr and was fired
with distillate oil (fuel-oil with a maximum sulfur content of 0 .5%
by wt.)
4
d) Boiler #4 had a design capacity of 114 MMBtu/hr and was fired
with distillate oil (fuel oil with a maximum sulfur content "of 0.5%
by wt.)
E) Boiler #5 had a. capacity of 114 MMBtu/hr and was fired with
natural gas with the a back-up capability of using distillate oil
(fuel oil with a maximum sulfur content of 0.5% by wt.)
F) Boiler #6 had a capacity of 114 MMBtu/hr and was fired with
natural gas with the back-up capability of using distillate oil
(fuel oil with a maximum sulfur content of 0.5% by wt.)
The Base also has thirteen distillate oil-fired and four
residual oil-fired boilers with design capacities under 2 5
MMBtu/hr. These boilers are as follows:
a) two 22 MMBtu/hr residual oil-fired boilers
b) one 6 MMBtu/hr distillate oiL-fired boiler
c) one 5 MMBtu/hr distillate oil-fired boiler
d) two 3 MMBtu/hr distillate oil-fired boilers
e) three 2 MMBtu/hr distillate oil-fired boilers
f) three 1 MMBtu/hr distillate oil-fired boilers
g) one 825 kw diesel-fired standby generator
Additional sources of emissions were those for VOCs which will
be described later in this section.
At the FBI Academy, there were seven boilers that used
distillate oil (fuel oil with a maximum sulfur content of 0.5% by
wt.) all of which ranged from 11.6 MMBtu/hr to 2.6 MMBtu/hr, and
four diesel-fired stand-by generators that ranged in capacity from
1,500 kw to 425 kw.. These boilers are as follows:
a) three 11.6 MMBtu/hr distillate oil-fired boilers
b) three 8.4 MMBtu/hr-distillate oil-fired boilers
24
-------
c) one 2.6 MMBtu/hr'distillate oil-fired boiler
d) two 1,500 kw diesel-fired standby ' generators
e). one 800 kw diesel-fired standby generator
f) one 425 kw diesel fired- standby generator
In addition, there were other sources of air emissions at the
FBI Academy that included: a) a paint booth; b) ah underground
storage tank (UST) balanced submerged filling station; c) UST
breathing losses; and d) gasoline dispensing without containment.
Following the initial interview, the EPA inspector accompanied
by Mri Branca went to the Environmental Affairs Office to review
the facility's files for the aforementioned sources of emissions.
At the office, the EPA inspector also met with Mr. William Fennell,
Director of Environmental Engineering Section.
The first set of files reviewed were those for the Central
Heating Plant(CHP). According-to the files provided, the Central
Heating Plant, had a maximum capacity of 455.66 MMBtu/hr. Mr."
Branca provided a copy of the CHP air permit which indicated that
all the boilers, #1, #2, #3, #4, and #5 were subject to the New
Sources Performance Standards (NSPS). This permit indicated that
these boilers were modified and/or constructed in 1993. In
particular, this NSPS permit specified that the equipment that was
constructed in 1993 were Boilers #3, #4, #5, and the equipment
modified in 1993 were Boilers #1, and #2.
The permit contained several conditions that included' the
following:
a) the approved types or tuei tor ail boilers along with the'
definition of distillate oil to meet the specifications of fuel oil
#1 Sc #2; .
b) combined(Tons/yr) and individual(lb/hr) emissions from each
boiler (using fuel oil, distillate oil, & natural' gas) that
consisted of rates of total' suspended particulate matter (TSP),
particulate matter less than 10 microns(PM-10), sulfur
dioxide(SO,) , nitrogen oxides (NOx), carbon monoxide (CO), volatile
organic compounds (VOC) , beryllium, copper, formaldehyde, a:nd
vanadium;
c) the type of control for S02 to exist in the maximum sulfur
content (0'. 5%) of fuel and/or distillate oil for each boiler;
d) the applicability of 40 CFR §60 Subpart Dc for boilers #1, #2,
#3 along with the applicability of 4 0 CFR §60 Subpart Db for
Boilers #4 & #5;
25
-------
e) the type of control for NOx for Boilers #3, #4, & #5 to be in
the use of low NOx burners and flue gas re-circulation;
f) visible emissions limit of 10% for all normal operation;
g) an initial performance test, concurrent with a Method 9 visible
emission test, for each boiler stack to be conducted no later than
180 days after the start-up of .each boiler and test results to be*
submitted to the VADEQ and EPA;
h) the installation of continuous emissions monitors (CEMs) for
each boiler to , measure and record opacity and such CEMs to be
installed and operated prior to the initial performance tests,-.
i) the maximum sulfur content of 0.5% by weight of each boiler's
fuel oil shipment along with certificates of analyses with each
shipment of distillate oil;
j) each boiler's emissions are .to b.e controlled by the proper
maintenance and operation with the appropriate boiler training for
all operators;
k) written notification to VADEQ and EPA of the actual date of
construction and modification of each boiler within 10 days after
such date, the anticipated start-up date of the boilers no more
than 60 days, nor less than 3 0 days prior to such date, the actual
start-up date of the. boilers within 10 days after such date, and
the anticipated date of visible emissions evaluation and
performance tests of each boiler at least 30 days prior to such
date;
1) the maintenance of records for all emission data and operating
parameters necessary to demonstrate compliance with this permit
which includes the throughput of natural gas and fuel oil for each
boiler and their respective fuel certifications;
m) the submission of fuel quality reports to VADEQ within 3 0 days
after the end of each calendar quarter;
n) revocation of this permit based on violation(s) of any permit
condition with the requirement of prior notice of all changes;
o) notification to VADEQ of any malfunctions of more than one hour.
The facility's air permit for the, Central Heating Plant
contains fuel consumption limits for each of the boilers.
According to the permit boilers #1 & #2 each have a maximum- fuel
consumption limit of 1.814 x 106 gallons of distillate oil per
year. Boiler #3 has a fuel consumption limit of 387.2 x 106 cubic
feet of natural gas, and.1.10 x 106 gallons of distillate oil per
year, and boilers #4 & #5 have a combined maximum fuel consumption
limit of 572.1 x 10" cubic feet of natural- gas per year. In
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addition, boilers #1, #2, #4, & #5 have a maximum fuel1 consumption
limit of 2.842 x 10c gallons of distillate oil per year..
Mr...Branca provided a copy of a fuel consumption table for
each boiler. The EPA inspector reviewed this table and found that
the fuel consumption limits had not been exceeded for any of the
boilers.
The following profile shows the! fuel consumption for each boiler:
Boiler #
1
2
3
4
5
After'completing a thorough review of the fuel consumption
records for 1995 and 1996, the EPA inspector concluded that the air
permit's fuel consumptions limits had not been exceeded for either
natural gas or fuel oil. Therefore, the emission limits dictated by
the air permit for S02, NO « CO, -VOC, beryllium, copper,
formaldehyde, and vanadium were apparently not exceeded; however,
it should be noted that only a stack test would satisfy any EPA
suspicion, that the limits for TSP, PM-10, S02, and NOx were
exceeded. Notwithstanding, a thorough review of the CEMs data and
records was conducted and yielded no problems with respect to
exceedances and/or calibration of the CEMs equipment.
Following the record review, the EPA inspector asked Mr.
Branca to,describe the other types of operations at the Base such
as the VOC surface coating operations in spray booths and metal
decreasing tanks. Mr. Branca explained that the base had surface
coating operations in spray booths at several locations and that
there were some degreasing tanks at some of these locations. The
degreasing tanks were mainly used for degreasing brake parts for
automobiles.
The EPA inspecto'r also asked about the operations that handled
refrigerants and all areas that contained refrigerants. According
to Mr. Branca, the base had 2 refrigerant recovery machines that
serviced a 600 vehicle, fleet. Apparently, 10-15% of the vehicles
used refrigerant R134 and the rest (about 500 vehicles) used
refrigerant R12. There were 10 technicians that were authorized to
service refrigerant systems in motor vehicles.
The EPA inspector, accompanied by Mr. Branca, visited a nearby
building that contained the two (2) refrigerant recovery machines.
At the building, the inspector met with one of the technicians,
Gunnery Sgt. Darren Coulombe, maintenance bay, that serviced
refrigeration systems in motor vehicles(MVACs). The EPA inspector
1996 Fuel Consumption
(gals.)
191,659
245,922
140,253
72,.112
64,064
Fuel Type
¦ distillate oil
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interviewed Sgt. Coulombe . and asked to see his MVAC pocket
certification card. The card indicated that.Sgt. Coulombe had been
certified by MACS (Mobile Air Conditioning Society, (215) 541-4500)
and the certificate number was 89228..
The EPA inspector next observed the .two recycle/recovery
machines. The machines were manufactured by RTI 1 Refrigerant
Management,' Inc.. The units had both, recycle, and recovery
capabilities. The EPA inspector asked Sgt. Coulombe to demonstrate
his experience with the machines by conducting a mock servicing
job: Sgt. Coulombe performed a mock service job which demonstrated
that he was familiar with the proper use of the machines.
The EPA inspector questioned Mr. Branca and Sgt. Coulombe
regarding the certification of the machines with the EPA. Sgt.
Coulombe stated that he did not know if a certification was made
with the EPA. The EPA inspector also asked about the purchase date
of the machines, to which.Mr. Branca replied that he would have to
check, with another individual at the base that would know the
purchase dates. The inspector explained to Mr. Branca that this
information was important for determining compliance with equipment
certification regulations.
In another area of the same building, the EPA inspector
observed a number of degreasing tanks. Mr. Branca and Sgt.
Coulombe showed the inspector a bio-degradable degreasing tank that
contained filters which were changed every six weeks. All
together, there were a total of five degreasing tanks in the
building.
In the same Dunaing, tne inspector observed a third
recycle/recovery machine; Model - RRC 750 with a maximum capacity
of 10 lb., which Sgt. Coulombe indicated was strictly used for
refrigerant R12.
- The EPA inspector, accompanied by Mr. Branca and Sgt. Coulombe
visited building #2013 to observe a spray booth in the building.
The spray booth filters were not changed on a regular basis'. They
were only changed on an as-needed basis determined by the booth's
operators.( The EPA inspector climbed' on top of the spray booth,
but did not observe any detectable VOC emissions or odors from the
operation. At the time of ,the inspection, a spray had recently
been completed, but there were no.operators in the booth.
There was an old spray booth that, according to Mr. Branca,
had not been in service for over five years. The operations in
this building included the complete servicing of the base motor
vehicles. According to Mr. Branca, used oil filters from this
operation were picked up once a month by Safety Kleen Corp.
While at the spray booth, the EPA inspector obsejrved that the
typical paint was a DuPont black paint; i.e., 1 gallon (3.785
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liters) 99A pitch black. The EPA inspector reviewed the MSDS'
(Material Safety Data Sheet) for this paint and it described the
paint as a'Centari Acrylic Enamel with a VOC content of, 32-84% by
volume. .This information is important because most State VOC
surface coating regulations require VOC contents to be below 3.0
lb(solids)/gal(paint) by weight. The indicator that would reveal
the actual VOC emissions from these spray coating operations would
be the usage volume of such a coating.
Outside of this building there is a gasoline pumping station
that serviced all motor vehicles for the base. This gasoline
pumping station contained Stage II Vapor Recovery equipment. This
system was a retrofitted vacuum-assist system with OPW nozzles
which appeared in good shape and did not have any tears nor any
holes. This gasoline station's throughput was approximately
180,000, gallons. .
According to Mr. Branca, an annual pressure to K test for all
Stage II Vapor Recovery systems at the base was scheduled for the
near future.
Adjacent to this gasoline pumping station,- there was a
compressor station for natural gas. This compressor station was
manufactured^ by Kraus Refueling Technologies of Winnipeg, Canada
and was about 2 to 2.5,years old. The compressor was a 1994 Model
3304, manufactured by Caterpillar with a 102 KW or equivalent
generator. .According to Mr. Branca, this natural gas compressor
station was operated by the local gas company, Commonwealth Gas,
who contracted with Air Technologies to come in and service this
station.' The maximum pressure on the compressor's plate was 3000
psia; @ 100 O F = 4125 psi.
¦ The inspect and facility, personnel next went to building #
2101 to inspect the surface coating operations. This"facility was
called the maintenance bay operations. . The supervisor of this
area, Sgt. Coulombe and an assistant, Corporal Dash described the
operation.
The surface coating operations in this facility were strictly
for aircraft. The EPA inspector observed that the spray booth was
green inside, indicating the color, of the previous job. According
to Cpl. Dash,; the booth's filters were changed once per week. The
booth had an exhaust stack which formed an elbow prior to exiting
through the side of the building. I observed that the manufacturer
of the green paint was U.S. Paint Manufacturing Co. of St. Louis,
MO. The MSDS sheet for the paint, indicated it had a VOC content of
3.96 - 4.69 lb/gallon. , The EPA inspector also inspected the spray
guns used in the booth. The spray, guns were manufactured by GEO
Manufacturing Co. and had an efficiency rating of 7,7%.
In another area of the building, the EPA inspector observed a
sandblasting operation which used a blasting medium that was
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comprised of plastic (70%) and glass (30%). The EPA inspector did
not observe any particulate matter fugitive emissions while
sandblasting..occurred. The sandblasting system contained a recycle
hose that dumped all material back to a 55-gallon drum. The EPA
inspector observed another 55-gallon drum that contained
sandblasting medium fines and chromium waste. The EPA inspector
questioned Corporal Dash about this drum and he explained that they
were in the process of disposing of the drum via a disposal
contractor.
The EPA inspector observed another spray booth in building
2103 which was one year old. This spray booth was white inside and
was equipped with infra-red curing capability that typically
operated at 90°F. The booth's paint usage was approximately 1
gallon per month. 1' The booth was only used to paint small
parts/pieces. According to Corporal Dash, the booth's filters,
both fiberglass and paper were changed on a weekly basis.
Adjacent to this spray booth was a mixing room that contained
cleaning solvents(from Safety Kleen) that were used to clean
painting equipment such as spray guns,. Inside the mixing room, the
inspector observed two drums containing waste paint. Neither of
the drums was marked with any form of identification. Corporal
Dash stated that Safety Kleen typically came in to pick up such a
drum and properly dispose of it. , The EPA inspector did not
observe any visible emissions from this spray booth's stack; this
spray booth was apparently constructed of sheet metal.
Near the booth, the EPA inspector observed a fire extinguisher
that contained 150 lb. of Halon 1211, fire-suppressing agent
(bromochlorodifluoromethane). Another fire extinguishing tank,
#121, was not used in testing,' according to Cpl. Dash. He also
informed me that the C02 fire extinguishers were used in mock fire
drills for firefighting testing.
The last items observed in this building were two refrigerant
recycle/recovery machines, Robinair -134s, that were purchased two
months prior' to the inspection. One of machines, which was the
series 34700, was for handling R-134a refrigerant. The other
Robinair-134 was for handling refrigerant R-12. Corporal Dash
indicated that the machines may not have been certified with the
EPA at.the time of the inspection. He also stated that there were
four to five MVAC certified technicians1 that were authorized to
service motor vehicle air conditioning (MVAC) systems in this
building, but was not sure whether the technicians' certificates
.were available in their personnel files.
August 12,1997
The EPA inspevi-u-i., cnj^umpcuixeu. Jjy nr. cranca, went uo Dunaing
# 3300 in which the first item observed was a 825 KW generator.'
Mr. Branca indicated that he came in every six months.to check the
3 0
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number of operating hours on the generator. The name plate of this
generatpr revealed the following information:
a) manufacturer - Caterpillar;
b) generator set - 3512;
c) rating - 1031, cos o= 0.8;
d) KVA - 825, 60 Hertz;
e) Standby mode;
f) maximum temperature.by resistance,^ 130°C;^
g) the current operation hours = 78 (2 years old).
According to Mr. Branca, the generator was permitted in 1994
after its installation in the same year.. Testing for this
generator was done every month by service contractors and such
testing is called, fire mop.
In building # 3300, the EPA inspector observed a 2.4 MMBtu/hr
(Input) steam boiler that was not operating. It was a small
package boiler that ran on natural gas. The inspector reviewed the
boiler's operating log of daily checks for pressure and
temperature. All the information in the log was.dated, signed and
legible. Most of the pressures and the temperatures were in the
same range indicating that operation of the boiler was consistent
without any upsets. Aside from'this boiler, the inspector observed
another boiler which was a hot water boiler with a design maximum"
capacity of 0.7 MMBtu/hr. The EPA inspector reviewed the operating
log for pressure and temperature checks. No opacity (visible
emissions) were observed from the stacks of these boilers.
The EPA inspector ' and Mr. Branca next visited the largest
gasoline station . on the base. This gasoline station had a
throughput of 2.6 million gallons in 1996.
According to the stations -manager, Ms.. Vickie Thacker, an
independent contractor (Omega-Goode), came in on a weekly basis to
check each gasoline dispensing pump for cracks,leaks in hoses,
boots, holes and also lubricated each pump handle to make sure that
they operated properly. Omega-Goode also checked for adjustments,
vapor caps, and fill caps' to ensure that everything was operating
properly. The inspector reviewed a copy of a daily checklist for
the gas station's equipment in addition to obtaining a blank copy
of the checklist. The most recent copies of the checklist were #1
and #3.
The EPA inspector reviewed the Stage II Facility Registration
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and Compliance Form provided by Omega-Goode as of 3/31/94. The
inspector requested from Ms. Thacker, a photocopy of a typical form
for the week of the inspection. The form indicated that the gas
station used Healy .400 nozzles which Ms. Thacker indicated did not
function properly and were going to be changed. Ms. Thacker also
showed me the Site Stage II Vapor Recovery Training Certificate
from Precision Testing Company. Ms. Thacker indicated that the gas
station received 8,200 gallons, of gasoline every day, seven days,
per week.
The EPA inspector then walked outside to.inspect each pumping
island; At each island the inspector reviewed service tags that
indicated that a representative (B. Minthorne) from Virginia's
Department of Agriculture, Measure Consumer Services had la.st
inspected the, entire gasoline station on 8/4/97.
The EPA inspector also reviewed the MSDS sheets for all liquid
products sold and dispensed. These MSDS sheets were on-site and
looked complete.
With regard to all the underground storage tanks (USTs), the
inspector reviewed the Veeder-Root Sensor receipts which indicated
gallons of fuel used as well as inches of water in the tanks and
the temperature of the gasoline. According to Ms. Thacker, these
checks are done every night. As an example, the EPA inspector
reviewed.the fuel usage figures for 8/8/97 which indicated that
7,793 gallons of fuel was pumped on that day. The gas station also
had on-site procedures for proper operations of the Stage I & II
vapor recovery systems. These instructions required that a station
operator be outside with each tank truck shipment to ensure that
Stage I & II vapor recovery controls were being used properly. The
EPA inspector observed several signs that stated, ^No Topping Off,
nor Over spillage.§ These signs also had instructions on how to
prevent topping off and over spillage and provided a telephone
number for the VADEQ (703) 583-3900.
The. EPA inspector also observed a motorist in the process of
pumping gasoline. The inspector heard the clicking sound which
indicated that the Stage II Vapor Recovery system had been
activated, and the inspector did not detect any gasoline fumes
emanating from the car's gas tank. Following' this, the inspector
walked around the station and inspected each island and its
equipment. The inspector observed that all hoses and nozzles were
in good shape without any cracks, slits, or any flattened portions.
The EPA inspector and Mr. Branca next visited building # 3252.
The inspector observed a spray painting operation in this building
which consisted of one spray booth that was only used one or two
times per week. According to Mr. Branca, approximately 95% of
spray painting is sent -off-site to be done.
A typical paint used in this booth.had a VOC content of 1.74
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lb./gallon. This spray booth was mainly used for painting small
cabinets. The spray booth was not operating at the time of the
inspection.
The booth- has a waterfall curtain and the .water is. changed
every three to four months. Water removed from this operation is
sent off-site for proper disposal. The inspector took several
photographs of the spray booth area. The inspector requested that
facility personnel turn on the water curtain so the inspector
could observe the- flow and circulation of the water. The spray
booth did not have a plastic curtain in front of it similar to the
ones used in-other spray booth operations to increase the booth's
capture efficiency. The spray booth had a blower on top that was
used to pull the air to the booth's' stack located building's roof.
The EPA inspector did not observe any opacity (visible emissions)
or any odors from the stack. According to Mr. Branca, by having
95% of the spray painting done off-site, the base has reduced its
VOC emissions from bulk spray paining by 8 tons per year. The Base
was also in the process changing from solvent-base paints to latex
paints which they hoped to accomplish by the end of 1997.
In the spray booth itself, the actual paint usage was
approximately 2 gallons per month. New paint that, was recently
purchased included: Duron acrylic; Sherwin-Williams semi-gloss; and
Sampson Coatings. The spray guns used in the booth were Binks
Devil guns, model 8155 with an estimated.transfer efficiency of
about 60-70%. '
This facility also paints the traffic lines on the roadways
throughout the base. This painting typically occurs between April
and November. The typical VOC content of the traffic line paint
was 0%, but contained about 60-70% volatility by volume.
The EPA inspector observed a paint spray in one of the
buildings at the FBI Academy. According to the spray painting
supervisor, paint usage varied from one to three gallons per month
in this booth. Similar to the spray painting operations at
building 3252 on the base, about 90-95% of the bulk spray painting1
occurs off-site.
This booth's filters are changed on an as-needed basis
according to a monthly P/M schedule. The typical paint used in the
booth is Sherwin-Williams vinyl sealer(T67F3) which contains about
24% solids and most of the clear paint used in the booth is
lacquer.
The spray guns used at this booth were the same type as the
oneis used in building #3252; Binks Devil, model 8155 with an
estimated transfer efficiency of about 60-70%.
This facility also paints traffic lines on roadways within the
FBI Academy compound and the paint most commonly used contains
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3.51% VOC content by weight. The EPA inspector photographed,the
spray booth.
The EPA inspector, questioned facility personnel about
refrigerant servicing at the Academy and was informed that there
are no R-134a recycle/recovery machines in the automobile service
• garage at the Academy. In the car, garage, there is an R-12
refrigerant recycle/recovery machine(serial # 0993A0437) that was
purchased three years prior to the inspection. This machine is a
Snap-On ACT 4100 recycle/recovery refrigerant system with a 30 lb.
cylinder used to recover old refrigerant from MVACs and recycle
virgin refrigerant back into them. . In addition to this
recycle/recovery machine, there was another machine that is brand
new and has never been used. This other recycle/recovery machine
is a Robinair model 17700 with serial # 11220 and date code of,
0493. This machine was purchased as a back-up refrigerant recovery
and recycling and re-charging station. According to the. garage
manager, the Academy was trying to get someone from Robinair to
come in to show them how to use the machine.
. The EPA inspector interviewed a technician, Mr. D.C. Mills,
that was authorized to service MVACs. The EPA inspector reviewed
Mr. Mill's refrigerant servicing certification card which indicated
that Mr. Mills' technician certification had been provided by IMACA
(the International Mobile Air Conditioning Association) and the
certification number on the card was the ' technician's social
security number. Mr. Mills had certification for Type I & II
refrigerant servicing, in addition to confined space certification.
The EPA inspector requested information regarding the
certification and purchase invoices of the recycle/recovery
machines at the FBI Academy and was informed that it would be
provided before the end of the inspection. This information is
necessary for determining compliance, with the equipment
certification requirements.
The EPA inspector next visited the FBI Academy's gasoline
storage tank area which, was not. operating at the time of the
inspection. Although it is not required, the FBI Academy had
voluntarily decided to have a Stage II Vapor Recovery System
installed at this station. The gasoline storage tank area's
throughput was . 105,000 gallon in 1996. The EPA inspector
photographed the storage area.
The EPA inspector next inspected the FBI Academy's heating
plant which contained boilers and chillers. There was a
refrigerant recycle/recovery machine that was Robinair system with
serial #04290 and had a 45 lb. cylinder used only for servicing the
chillers in the heating plant. The first chillers inspected were
two 1100 ton chillers that were pulling 79% of their maximum design
capacity. The chillers' evaporator temperature was 38°F with a
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head pressure of ,9.5 psi and an evaporator pressure of 18 psi. The
chillers' heads are pulled every year and cleaned.
The EPA inspector next inspected the facility's boilers. Each
boiler had a separate stack (~3. ft. height) .The boilers were
¦installed on July 28, 1970 which1 made them grand fathered with
respect to the NSPS (New Source Performance Standards). For Boiler
#1 (I.D. #L415145), it was off and not running. Boile:r #2 was also
not running because it was getting P/M (preventive maintenance).
According to the Maintenance Supervisor, the Boilers cycled on and
off on an as-needed demand basis. This maintenance department uses
a portable emissions analyzer once a month to check for C02 and
Particulate Matter (PM) . The Academy changed fuels usage from fuel
oil #6 to fuel oil #2. At the time of the inspection, the FBI
Academy was burning approximately 600,000 gallons of fuel oil #2.
The boilers alternated every week, as far as operation.
Outside this area, the EPA inspector observed the water
cooling towers for the FBI Academy.' According to the maintenance
supervisor, two pumps needed to be on whenever both chillers were
on. The pumps had variable speed motors on fans. The water tower
was treated with caustic alkali liquids using two 55-gallon drums
that contain sodium hydroxide. The inspector did not detect any
odors on top of the cooling tower; however, there was algae growth
visible around the fans on all four of the cooling towers.
Adjacent to¦the cooling towers, there were two small chillers
manufactured by Trane Manufacturing Company which used R-22
refrigerant with a volume capacity of 105 lbs. These small
chillers, model no. CG50C, had a capacity of 400 lbs./in.2 on the
high side and 300 lbs./in.2 on the low side.
In an adjacent building, there was a 800 KW Emergency
Generator made by Caterpillar that was fueled with #2 fuel oil and
not diesel fuel. According to the Academy maintenance supervisor,
#2 fuel oil contained'more sulfur than diesel oil. This generator
was tested every week.
In the same building, there was a portable, refrigerant
recovery/recycle machine, ThermoFlo QZ Saver 4000, model 4000,
serial no.9330152. The EPA inspector requested the purchase
invoice for this machine and inquired if the machine was certified
with EPA. The supervisor believed that it was certified but stated
that he would provide documentation prior . the end of the
inspection. The inspector also inquired as to the number of
technicians that performed refrigerant work at' the FBI Academy and
whether or not they were certified to do such work. The supervisor,
said that he would provide documentation of the technician's
certification prior to the end of the inspection.
The EPA inspector then went to the FBI Academy's Engineering
Research Building to inspect the chillers. There were four
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Carrier, model 19DK73313CM, chillers with a refrigerant charge
capacity of 1010 lbs in this building. These chillers used R-ll.
refrigerant. At the time of the inspection, three of the chillers
were running, each with a chilling design capacity of 370 tons.
Within the same building, there was a sizeable refrigerant
recovery/recycle machine whose model and serial numbers were,
19QA040-104 and 2592J04714, respectively. This machine's had a
volume capacity of 40.6 ft.3 and used refrigerant R-ll with a
maximum charge capacity of 3,300 lbs.. Its maximum operating and
design pressures were 10 psi. and 15 psi., respectively. The
inspector requested the purchase invoice for this machine and asked
if the machine had been certified with the EPA. The area
supervisor was not sure, but indicated that he would provide that
information before the end of the inspection.
Outside the chiller room, there were two small emergency 1500
KW generators. The generators, manufactured by Caterpillar, model
no. 3500. The operating meters indicated 1,376 hours of operation.
According to the Academy maintenance supervisor, these generators
were tested under load conditions once per week.
The EPA inspector accompanied by Mr. Branca returned to
building no. 2013 and met ,with Mr. George Caswell, maintenance
department supervisor, to review CFC documents. Mr. Caswell
provided a copy of the CFC technician certificates and a list of
their refrigerant recycle/recovery machines. This department had
three refrigerant recycle/recovery machines that serviced two
shops. There were nine (9) certified technicians. The EPA
inspector obtained photocopies of the certification cairds for seven
of the technicians. The other two technicians were on vacation at
the time of the inspection. The inspector interviewed one.of the
technicians, Tim Dickerson, who, explained the standard procedure
for conducting a recovery/recycle job on a refrigerant-containing
unit. Mr. Dickerson properly explained the procedure, indicating
each component of the machine. The machine had a 50 lb.(22.7 kg.)
tank that used Arcton 12 (refrigerant R-12).
The EPA inspector next visited building no. 2112, Larson
Gymnasium, and met with Mr. Garner, Safety and Environmental
Coordinator. The EPA inspector observed a paint room that
contained mainly interior latex semi-gloss paint (Pro-Mart 400 and
Enamel Pure White, Base X). The inspector noted that all the paint
containers were closed and no VOC odors were detected. In the
adjacent paint shop, paint usage was 10 gal./month, but varied a
bit depending on the jobs. The MSDS sheet for a typical paint used
by this shop did not contain a % VOC amount. The EPA inspector
suggested to the, paint shop's supervisor that the MSDS sheet should
be updated.
The EPA inspector visited the refrigeration room where the
facility stored refrigerant. The inspector observed that the
department used R-502, type Genetron MP 39, and Genetron AZ-50(a,
mixture of HFC 125/1439 refrigerants. The MWR Department owned
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approximately ,12 ice machines, 12 refrigerators, 15 window, units,
¦6 walk-in refrigerators, and 6 freezers. MWR had retrofitted most
of these units from, R-12 to R-502s and other refrigerants. The
inspector requested a list of all the units that still used R-12
and was told;that a list would be provided.
The MWR Department had two (2) refrigerant recycle/recovery
machine's, a PreCooler^by Copeland Co., model PC-1, purchased in
1994, and a Sercan 5000 Recovery System, model 5000A, purchased in
1992. Both machines were used for R-12, R-22, R-500 and R-502.
The inspector inquired as to the total number of technicians that
were authorized to service refrigerant-containing units and
requested copies of their certification cards as well as
photocopies of the purchase invoice for all the recovery/recycle
machines used at the MWR Department. Mr. Garner promised to
provide this information at the end of.the inspection.
The inspector spoke to one of the certified technicians, Mr.
William H.. Noel. Mr. Noel's certification was from The
Refrigeration Service Engineers Society and it was good for Type I
& II as of 10/13/94. The EPA inspector photographed the two
recycle/recovery machines.
In this same: area, the inspector also observed several window
units to be disposed of. The inspector did not see any
identification tags on ,the units to indicate the" removal of
refrigerant. Depicted in photo no. 4 is a unit that was not
identified and had a tap in its line. The EPA inspector inquired
as to the procedures for disposing of such units. Mr. Garner
stated that his department would1 first set a unit out after
removing it from service and assess whether such units are
repairable. Afterward, the units would be shipped to another
facility(Defense Re-utilization Marketing Office (DRMO)) on the
base for disposal.
The EPA inspector next visited building no.3252 and met with
Mr. Gary Cooper, Facilitieis Maintenance (FM) supervisor. Facilities
Maintenance serviced over 240 separate air conditioning systems
throughout the base. Mr. Cooper stated that FM had recently
purchased a new recycle/recovery machine. He.also indicated that
aside from servicing air conditioning /refrigerant-containing
systems, they also disposed of them. According to Mr. Cooper, the
technicians would.recover all refrigerants from the units to be
disposed of and store the refrigerant in 50 lb. cylinders that
would be picked up by a contractor, EMS Consultants, Crofton, MD,
for reclamation. . The last pick-up, prior to this inspection,
totaled 270.6 lbs. of recovered refrigerant for reclamation. Mr.
Cooper stated that FM had four portable recycle/recovery machines
that were older ones. They also hadi three larger capacity ones and
had recently purchased four portable machines and two larger
capacities ones (2000 series)1. Air conditioning units that were • to
be disposed of were sent to the DRMO facility on the base. Mr.
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Cooper stated that there was .no paperwork- that accompanied the
units to be disposed of. The EPA inspector suggested to Mr. Cooper
that they might want to start maintaining a log of all activities
related to the units that were allocated for disposal.
Mr. Cooper informed the inspector that there were 14 certified,
technicians. The inspector questioned Mr. Cooper about the EPA CFC
regulations to which he replied that he was not aware of the
requirements. He "also stated that they had not sent any
certification notices to the EPA for the recycle/recovery machines
that were used. The inspector requested copies of the purchase
invoices for all the refrigerant recycle/recovery machines at FM
and photographed some of the units that were set aside for disposal
by DRMO.
The inspector next asked Mr. Cooper for any operations log
that would indicate the amounts of refrigerant recovered and the
number of units that were set aside for disposal. While searching
for these records, Mr. Cooper came across a loose-leaf binder from
the Department of the Navy that contained a complete and detailed
report of the CFC regulations promulgated in 1992 and took effect
in 1993. This report explained the tasks the base should implement
to comply with the CFC regulations and covered all aspects of CFC-
containing systems which included everything from refrigerant ,
servicing to disposal. Both Mr. Cooper and Mr. Branca were
surprised to find this document and that no one had ever
implemented a CFC program at FM or anywhere else in the base. Mr.
Cooper provided the inspector with the operations records that
contained the amounts of refrigerant recovered and the type of
service for each job.
Following the records review, the inspector observed the new
portable machines that had been recently purchased. These units,
manufactured by Therma Flo Corp. were type OZ Saver models 600 and
2000a; there were four type 600 a:nd two type 2000a. Apparently, FM
had sent several other recycle/recovery machines back for repair.
The EPA inspector next observed the air conditioning units that had
been set aside for disposal by DRMO. One unit inspected was a
comfort cooling system made by Carrier Manufacturing Co. And marked
with the with the following data: model # 38EN060.530; manufacture
date, 9/87; serial # 4087E-13998; UL tested; and a design .maximum
charge capacity of 12.70 lbs. (5.76 kg.) of R-22. Mr. Cooper
confirmed that FM did recover refrigerant, for eventual
reclamation, from all the refrigeration systems designated .for
disposal.
The EPA inspector walked around the outside of this building
and observed empty cyclinders- that had punctures and cut lines
indicating that the refrigerant once contained in these cylinders
was presumably released into the atmosphere. The inspector asked
Mr. Cooper who had punctured the cylinders to which he replied that
he was not sure, but he could confirm the origin of the cylinders.
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He did say that some were probably from FM and its operations.
The EPA inspector next went to another building where a 150'
ton chiller was being repaired. According to the service records
for this repair, the chiller had 50 lbs. of R-22 added to it two
days prior to the inspection, and 80 lbs. of R-22 added to it one
month prior to inspection. According to the technician on the.job,
these amounts were necessary because of leaks in the system. The
EPA inspector requested information regarding the leak rates for
this chiller and Mr. Cooper said that he would provide the
information prior to the end of the inspection.
The auto hobby shop contained a paint spray booth and some
refrigerant recycle/recovery equipment. There was one refrigerant
recycle/recovery machine in this shop. The machine, a one-month
Robin Air, Type. - Enviro Charge, was designed to handle only R134a
with a capacity for recovery, recycling and recharging. The
machine was a model no. 34700, serial number 18170', manufactured in
July 1996 arid was UL-tested.
The EPA inspector also observed the spray booth in the shop.
This spray booth had a stack which exited through the side of the
building and according to the shop supervisor, the booth|s filters
were changed only once per year. According to the shop supervisor,
the next scheduled change was coming .up soon. All types of spray
painting take place.in this spray booth. According to the shop'
supervisor, the.average paint usage is about two gallons per month.
The shop supervisor provided copies of the MSDS sheets for the
typical paints used in the. booth. After reviewing these MSDS
sheets, the inspector noted that they, did not contain the % VOC
content of the paint.. The EPA inspector recommended that they
contact the paint manufacturer and obtain updated MSDS sheets for
the paint (e.g. ones listing the % VOC content) . The shop
supervisor stated that he would obtain updated. MSDS sheets for the
paint. The typical paint used in the spray booth is a Deltron
Acrylic 2000 Basecoat manufactured by PPG, with a % solid by weight
of 14-66 (as of 5/18/93) . The EPA inspector observed that the
interior walls of the booth were quite dirty and the filters were
clogged. The inspector, asked the shop supervisor why the dirty
filters had hot been changed, and he said that they were waiting for
new filters to be delivered, but the shipment had been delayed
because of a UPS strike.
The inspector checked capture efficiency in the spray booth by
taking a small piece of writing paper arid throwing it against the
filters to see if.it would stick to the filters. The inspector
conducted this test on several areas of the filters and the results
indicated a poor capture efficiency in the booth. Thorough capture
efficiency on all levels of filters is necessary for adequate
emissions capture and control. The inspector photographed the
outside of the booth, still within the building and the stack on
the outside of the building. No 'painting was being done at the
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time of the inspection, so no opacity was observed emanating from
the stack.
The EPA inspector and Mr. Branca returned to building no. 3252
and met with the Facilities Management and met with Mr. Gary Cooper
to review all of the refrigerant purchase records since 1995. Th
following is a profile of the refrigerant purchases:
YEAR
REFRIGERANT TYPE
AMOUNT (lbs.)
PURCHASED
1995.
R-12
2, 730
1995
R-22
3,348
1996
R-12
1,600
1996
R-22
2, 090
1997
R-12
610
(up to
August "97)
1997
R-22
2, 770
(up to
August "97)
Following the record review, the Facilities Management
Supervisor, Gary Cooper, discussed plans that the base has for
replacing all R-12 refrigeration units and improving the preventive
maintenance(P/M) program for the units. The plans include removing
the old refrigeration units that were.installed before 1960 and run
mostly on R-12 and replacing these with new units that use
alternate refrigerants.
While discussing this replacement' program, the facility
personnel said that there was a chiller job that was being done in
building no. 2085 a;djacent to the Marine Corps University. The EPA
inspector accompanied by Mr. Branca went to this building to
observe the job. At the site of the repair job, the EPA inspector
observed that a 75-ton Carrier (model 5H60-200) chiller was being
repaired. According to the technician doing the job, only 5 lb. of
refrigerant R-12 was recovered before starting the repair job.
Unfortunately, the rest of the charge had leaked out. The problem
with this chiller was a crack on the low pressure side for
lubricating one of two compressors. Both of the chiller
compressors were running off a double shaft. The inspector
requested the leak rate of the chiller and all the operations data
that was available to review the repair history. Mr. Branca said
that he would, provide this information prior to the end of the
inspection.
The-, inspector asked to see the. refrigeration certification
card of the technician on the repair job. The technician produced
his card and Mr. Cooper said that he could provide copies of
certifications for all the technicians that worked on the base.
The technician explained to the inspector that the chiller needed
to be charged with about 75-100 lbs. of R-12 using the portable
refrigerant recycling/recovery machine on site with vacuum of 3 5
lb. at about 34-36°F(the chiller operating temperature). The
.4 0
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portable refrigerant recycling/recovery machine that was being used
on this job was'a green-colored, Therma-Flo, Model OZ Saver Light
-#600. The EPA inspector requested from Mr. Cooper and Mr. Branca
the purchase invoices for that machine,. and all the other
refrigerant recycle/recovery machines that were used on the base.
Mr. Cooper said that he would provide'this information prior to the
end of the inspection. The technician further explained that the
5 lbs. of R-12 that were recovered were put in a 25 lb. compressed
cylinder for storage and subsequent recycling back .'into the
chiller.
The EPA inspector accompanied by Mr. Branca next visited
building no . 2012, the central heating plant (CHP) for the base.
Mr. Branca explained that the three operable boilers(#3, #4, &
#5) in the CHE were retrofitted in 1994 and that the retrofit
project cost more than 50% of the original cost of the boilers.
These- boilers are subject to the NSPS. The inspector requested
copies of all the correspondence and information related to the
retrofitting project for the boilers at the CHP. Mr. Branca said
that he would obtain this information before the end of the
inspection.
Mr. Branca asked the CHP supervisor on duty for a tour of the
plant. The supervisor explained that the continuous emission
monitor (CEM) manufacturer (Rosemount) came in that day to check out
the CEM equipment and to conduct a RATA, (relative accuracy test
analysis) for all gaseous CEMS at the heating plant. ¦ According to
the supervisor, there were gaseous CEMs for NOx/ C02, and 02 on
Boilers #3, #4, & #5.
Inside the plant control room, the inspector observed the
control readings. They are as follows:
a) C02 = 7.9%
b) 0, =6.04%(this,was raw # and was corrected an equivalent of n
5.55%)
c) ,N0X =34 .1 ppm.(corrected to equivalent = . 35ppm)
d) opacity =0.3 - 0.4%
According to Mr. Branca, the last six months' average opacity
was 0.3%. The EPA inspector noted that these readings were all
below the CHP's operating air permit limits. The only boiler
operating was boiler #5 which was burning natural gas. According
to the CHP's. air permit, boiler #5 is subject to the NSPS, Subpart
Db and its Nox limit is 0.1 lb./MMBtu. In the quality control
manual, the limit was seen as, 0.1 lb*./MMBtu. According to Mr.
Branca, the typical NOx reading for boiler #5 is 0.067 lb./MMBtu
with natural gas on low. summer loads. Similarly, the N0X reading
for boiler #5 is 0.095 lb./MMBtu for natural gas during high winter
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loads all day.
According to the supervisor's explanation, these boilers did
not operate consecutively for days. Also, the CO limit on the DEQ
permit for boiler #3 (for burning.distillate fuel oil) was 13.48
lbs.-/hr (11.2 tpy), and the limit for burning natural gas was 14.19
lbs /hr (31. 5 tpy). All boilers were stack tested in January 1995
for.most criteria pollutants, and all the boilers passed except for
CO. According to Mr. Branca, the initial stack test CO failed in
1994. Another stack test was conducted in September 1995 for CO
and N0:< to obtain mass emission rates. The EPA inspector requested
all information relative to these initial performance tests that
were conducted for all the boilers, in 1994 and 1995; in
particularly, all stack test results. Mr. Branca indicated that he
would provide this information upon returning to his office.
The inspector explained to Mr. Branca that there is a 180-day
limit in which EPA requires a facility to conduct and pass initial
performance tests for fossil fuel-burning boilers. The CHP' s
supervisor stated that the last time that VADEQ had been there was
in July 1997 represented by inspector, James McFadden. Also, Mr.
Branca indicated that the base had never stack tested.for PM-10 or
formaldehyde. The inspector asked why the CHP air permit had
limits for such pollutants as formaldehyde. Neither Mr. Branca or
the plant supervisor could answer the question and suggested.that
the inspector ask the State of Virginia. They also did not know
how the CHP could show compliance with the other pollutants such as
VOCs, formaldehyde, copper, vanadium, and beryllium.
Mr. Branca stated that the, in-house combustion engineer uses
a portable analyzer to check all operable boilers annually for CO
and ,NOx. Mr. Branca demonstrated a sample calibration for CO by
using Boiler #4. Mr. Branca stated that' CHP usually experiences
approximately twelve hourly exceedances and that the they were
trying to decrease these exceedances by learning more about the
equipment and adjusting the controls. They burn 80% natural gas
and 20% no.2 fuel oil.
The EPA Inspector asked Mr. Branca to provide copies of .the
quarterly excess emission reports for 1995, 1996, & 1997. The
inspector explained that he needed to see the percentage of time
that exceedances occurred. Mr. Branca provided the reports and the
inspector explained that there were instances in the reports which
would have to be "referred'to the EPA Region III CEM expert, Angela
McFadden for evaluation.
From the on-site review, the inspector documented ' the
following information: For the last quarter(Sept. - Dec.) for 1996
and the first quarter for 1997(Jan. - Mar.), the down time of the
CEM was about 0.5%. The inspector explained' to Mr. Branca that
typically, the EPA focuses on sources whose down time is greater
than 10%. Mr. Branca stated that the CHP voluntarily Q/Cs the fuel
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used in the boilers either in the fuel , loop (in operation) or
straight from the trucks to ensure that .the sulfur content is less
than 0.5%. The inspector noticed that a.typical sulfur content was
0.103 %S as indicated in a certificate of analysis provided by Mr.
Branca. The inspector asked Mr. Branca if the results from the
RATAs were sent to the EPA. Mr. Branca replied that the results
are sent to VaDEQ, but he was not sure if they forwarded them to
EPA. The inspector explained to Mr. Branca that the NSPS required
that the RATA results be.sent to the EPA for all subject sources.
The EPA inspector and Mr. Branca went to the facility's sewage
treatment plant(STP)and met with the plant supervisor.
According to the supervisor, the plant was undergoing a $20 million
renovation that would increase plant capacity by 10%.
The plant currently uses anaerobic digestion to treat the
sludge which produces methane gas. There is no meter at the plant
to monitor production of the gas. The facility burns the methane
gas and at the time, of the inspection, the burner was operating;
however," the EPA inspector did not observe any opacity from the
burner or any fugitive emissions at the STP.
The EPA inspector and Mr. Branca returned to the central
heating plant to inspect the boilers and to conduct spot checks of
the boiler controls.
The readings on boiler no'. 5, rated at 114 MMBtu/hr., were as
follows: 02 =5.3%; CO =9.2%; and NOx =35.2 ppm. Boiler no. 5 had
low NOx burners installed as part of the retrofitting program.
Boilers no.3 & no. 4, each rated at. 84 MMBtu/hr.(NSPS Subpart Dc
boilers), were both off at the time of the inspection.
Boilers no.l & no.2, retrofitted from residual oil to
distillate oil and rated at 64 MMBtu/hr. each, were not operating.
The EPA inspector went up to the roof to observe the stack on
boiler no. 5; however, no opacity was observed from the stack.
The EPA inspector accompanied by Mr. Branca visited the fuel
farm loca:ted on the west side of the base. There was a total of
ten tanks at the fuel farm.
/
Two tanks on the left side of the fuel farm, with a combined
capacity of 250,000 gallons, are used for storing no. 2 heating
oil. According to the fuel farm supervisor, one of these tanks was
full (95,000 gallons) and the other was almost empty (4.5" of
fuel). In the center of the fuel farm, there were two horizontal
tanks; one with a capacity of 12,500 gallons, was,empty. This tank
is used to hold kerosene. The other tank contained road diesel
fuel and had a capacity of 25,000 gallons.
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Of the six other tanks on-site, two were 25,000 gallon tanks
used storing reformulated gasoline (one tank was empty and the
other was full); two 75,000 gallon tanks were used for storing JP5
aviation fuel (both tanks were almost full); and the last two were
75,000 gallon tanks used for storing reformulated gasoline (both of-
these were empty) . These two tanks had not been used to store
gasoline in almost 5-6 years.
According .to the supervisor, the fuel farm has a throughput of
140,000 gallons and he indicated that the empty tanks were going to
be renovated within the next 18 months. Gasoline would be moved to
a 25,000 gallon fixed-roof tank with a 12,500 gallon tank as a
back-up.
The fuel farm did not have Stage I & II Vapor Recovery based
on the minimal annual throughput, which was -under the State
regulation that required such controls.
The EPA inspector climbed on top of the tank (D tank) that
contained 25,000 gallons of reformulated gasoline. The temperature
of the tank was 720F. The inspector did not observe any visible
or fugitive emissions. The inspector did detect odors from the
roof vents. These vents allow air from inside the tank to escape
into the atmosphere. This air lies between the floating cap and
the roof of the tank. All the tanks in the fuel farm had fixed
metal roofs and internal floating caps. The inspector opened the
vents and immediately detected odors emanating from them. This
tank was grounded. The inspector did not detect any odors from the
valve at the bottom of the tank.
A tank truck adjacent to this ta,nk did not have Stage I Vapor
Recovery Controls. According to the fuel farm supervisor, the lack
of Stage I is based on the minimal annual throughput. This truck,
used for gasoline, had a capacity of 2,400 gallons.s Gasoline
vapors are vented directly into the atmosphere due to the fuel farm
falling under the vapor recovery controls limits in the State
regulations. The gasoline in the tanks is purchased from Citgo or
Crown Petroleum Companies.
The EPA inspectorvnext inspected the Defense Reutilization
Marketing Office's (DRMO) surplus yard, which is a tenant activity
at the base. The yard, managed by Mr. Tony Webb, is used to store
refrigerant containing equipment that is to be either sold to the
public or disposed of by scrap metal recyclers.
.The yard is separated into areas that contained 3$white goods$£
and 3$brown goods.$ White goods were primarily equipment that
contained refrigerant such as refrigerator, window and roof-top air
conditioners, and commercial and industrial freezers. Brown goods
consisted primarily of stove ranges, laundry washers & driers, and
other, household items that normally do not contain refrigerants.
Also, there was equipment in separate piles and refrigerant
44
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containers.
The inspector questioned Mr. Webb about the internal
procedures for receiving materials at the yard, regardless of
whether or not .they contained'refrigerant. Mr. Webb explained that
all equipment coming into the yard was by appointment only and
everyone entering the yard had to sign in at the office. Mr. Webb
would then visually inspect the incoming equipment for leaks of"
refrigerant and oil. If he did not detect any leaks, then he would
place the shipment in its respective area in the storage yard.
DRMO conducts their sales using sealed bids at public
auctions; the minimum bid is $20.00 for a whole lot. Wherever
possible, Mr. Webb explained that whole lots of like items were
sold together instead of individual items. The sales contract is
the only paperwork that is generated from the office of this DRMO
surplus, yard.
Initially, Mr. Webb could not locate any written procedures
for tracking the accountability of refrigerants in the white goods;
however, later during the inspection, Mr. Webb did locate a
Department of Defense document (#60.50.1) which described these
procedures.
All refrigerant-containing equipment is sold as CFC-containing;
equipment. The surplus yard personnel assume that the refrigerant
is still in these units. This DRMO surplus yard did not have a
refrigerant recycle/recovery, machine and does not recover
refrigerant from any of the refrigerant-containing goods.
During the inspection, the EPA inspector aiso met with Mr.
Webb's supervisor, Mr. Thomas Esker. Mr. Esker, Store Manager for
the Mid-Atlantic Zone, is stationed at Fort Belvoir. . Mr. Esker
explained that if no refrigerants' were found in the white goods,
they required a certificate from vendor that states that the unit
did not. contain refrigerant. At this DRMO surplus yard, these
statements are internally referred to as clear take statements.
According to Mr. Esker, the yard does not keep copies of these
statements. The copies are sent to the accounting people for DRMO
at a separate location on the base.
The yard accepts, goods from other military bases and other
federal government facilities. The EPA inspector went out to the
back portion of the facility to observe the scrap piles. While
observing the scrap piles, the EPA inspector found several
refrigerant, cylinders that had been .punctured .and their flow valves
had been snapped off. Mr. Webb and Mr. Esker did not know who. had
punctured the cylinders or why they had been punctured. The
inspector explained that the overall intent of the CFC regulations
was to maintain accountability of refrigerants throughout the
disposal chain; particularly at the tail end. Mr. Esker asked if.
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there would be any correspondence sent to this DRMO surplus yard
regarding to the inspection. The inspector explained to him that
an inspection report would be generated and provided to the*base.
Subsequent correspondence would be dictated by the need to pursue
enforcement based on violations found.
In the pile of punctured refrigerant cylinders, the EPA
inspector also observed water fire extinguishers.
The EPA inspector next visited the base landfill to inspect
for goods containing CFCs. Upon arriving at the landfill, the
inspector met with the landfill supervisor who explained that they
had a very strict policy of not accepting any goods at the landfill'
that contained- CFCs. If CFC-containing goods were;found in the
landfill, they would be returned to its originator. The supervisor-
pointed out the large sign at the entrance that was conspicuously
displayed informing everyone that, no CFC-containing goods were
accepted in the landfill. The EPA inspector did not observe
anything of concern at the landfill.
Following the visit to the landfill, the EPA inspector went to
Camp Barrett which is a training facility, for new recruits.- At
Camp Barrett, there is' a gasoline dispensing station with a
throughput of 25,000 - 40,000 gallons per year. This falls under
under the VADEQ regulation limit -that calls for a minimum
throughput of 100,000 gallons per year. Nonetheless, the station
had installed Stage II Vapor Recovery Controls.
The EPA inspector next went to Camp Barrett's heating plant
which contained two 22 MMBtu/hr boilers (boilers #1 & #2). The
maintenance supervisor explained that they send out.for S2 analysis
of their #6 fuel oil. A typical analysis of S2 =.1%. These
boilers feed the chillers at Camp Barrett to supply heat and hot
water. At the time of the inspection, boiler #1 was operating and
boiler #2 was shut down. These boilers were installed in 1988/89
and contained new burners for more efficient combustion and better
emissions controls-. The EPA inspector did not observe any visible
emissions from the stack on boiler #1. The heating plant has a
continuous opacity emission monitor, but it was not certified and
was only calibrated annually. This monitor was not required by any
regulation,- it was simply an internal compliance indicator for Camp
Barrett's maintenance department. There was one such monitor for
each of the two boilers. Upon calibration, the monitor read the
opacity at 3%. Typically, the opacity was well, under 10%,
according to the heating plant's supervisor.
The inspector's record review focused on the installation of
these boilers which replaced the old' ones. The heating plant's
supervisor indicated the contract for the replacement took place
around October,1987 (on 10/5/87, the actual work bid was made to
the base). In early 1980's, the boilers' burners were replaced.
46
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There was a combustion efficiency test that was conducted annually
as required by the ASME boiler certification. Additionally, boiler
inspectors check for: a) safety operation parameters; b) opacity
with density unit for operating and safety limits; c) for stains;,
d) and all internal.burners, tubes, etc... This, testing was done
for the heating plant1s boilers and all other satellite units. The
heating plant maintains a daily log of opacity readings; i.e., 10%
for ¦ 8/15/97. There was a separate log for all operational
parameters.
The inspector then went over to boiler #2 to check the name
plate. The name plate revealed the following information: a) model
TJWC-20; b) serial number, L-277; c) order number, W^20025; d) year
of construction, 1988; e) rate capacity = 22 MMBtu/hr.;. f) 'heating
surface .= 1767 ft2; g) rated flow, 452 GPM; and h) the
manufacturer, The International Boiler Works, Co. Of East
Stroudsburg> PA - a subsidiary of Volcano, Inc.. Likewise for
Boiler #1, the name plate indicated the following: a) model - TJVJC-
20; b) order number, W20025; c) design operating pressure, 340
psia; d) serial number, L276; e) maximum water pressure, 300 psi. ;.
f) heating surface, 1676 ft2; rate - capacity = 22 MMBtu/hr.; g)
rated flow, 452 GPM; h) year ..of construction, 1988; and i) the
manufacturer, The International Boiler Works, Co. Of East
Stroud.sburg, PA - a subsidiary of Volcano, Inc.. Looking at boiler
#l's controls, the inspector noticed that the opacity reading was
15% for which the supervisor explained was erroneous; it was just
that the calibrating contractor could only zero up to the 15% mark
which in reality represented a 0% opacity. The EPA inspector
again observed that the opacity from Boiler #l's stack, whose stack,
length was 10 ft., was" 5-10%. •
At the conclusion of the inspection, the EPA inspector met
with facility personnel and explained that he would provide a brief
analysis of the initial, findings and•observations. The inspector
also explained that a complete review of all information requested
during the inspection would be required prior to providing an
initial air compliance assessment:.. Mr. Branca then explained the
entire chronology of the problem with the initial stack test in
1994 an 1995 for Boilers #3, #4, & #5 and indicated that he would
provide the inspector with all information regarding this problem
as well as all othei information requested during the inspection.
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Clean Water Act
Mainside STP (VA0028363)
Facility Description
The^Mainside STP serves the base area east of 1-95 or- the main
portion of the base (Mainside) and the Town of Quantico. At the
time of the subject inspection, the plant was, being upgraded from
a 2.0 mgd trickling filter/nitrification plant to a 2.2 mgd
biological nutrient removal (BNR) plant. Sketches of the old and
proposed plant are included with the subject report (Attachments
CWA-1 and CWA-2, respectively).
With construction having been underway-for almost 2 years, the
plant is presently operating with the following treatment units:
head works-2 barminutors, 2- grit removal swirl separators, 1-
3 00,000 gal. aerated equalization basin, 4 primary settling tanks,
2 nitrification basins, . 1 denitrification basin, 2 final
clarifiers, 2 dual media polishing filters and 1 chlorine contact
tank. For phosphorus removal, alum is normally added at the
nitrification basin effluent and the primary settling tanks but at
the time of the inspection, alum was only being added at the
nitrification basin effluent due to repairs to the alum feed line
at the primary settling tanks. Operable sludge processing units
included: 1 floatation thickener, 1 anaerobic digester and 2
centrifuges. '
Plant effluent discharges to the Potomac River via outfall
001. Sludge is land applied on base by a contractor.
The plant essentially treats domestic wastewater as there are
no known significant industrial type wastes discharged to its sewer
system. The plant's sewer system,.also being upgraded, included 3
main pump stations and 18 lift stations at this,time. Except for
the remote Camp Upshur, the remaining portion of the base is served
by a municipal facility, Stafford County's Aquia Wastewater.
Treatment Plant. The Quantico base discharges no known industrial
wastewater to the Aquia system.
Permit Status
Quantico is operating under an expired permit (6/18/86 -
6/18/91) for its Mainside STP until VA DEQ establishes their
Potomac Embayment' Standards. Interim effluent limits from Appendix
D of a Special Order Amendment- (12/7/88) applied at this time.
As a result of- a Consent Order (3/91-9/93) with the Natural
Resources Defense Council- (NRDC), Quantico has undertaken a list of
improvements which essentially include the ongoing plant and sewer
system upgrades. Plant construction began 11/95 and was originally
48
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scheduled for completion by 2/99 but has been several months behind
schedule with completion now expected 10/1/99. Quantico has no
compliance schedule for these improvements.
'Construction Status
At the time of the subject inspection, some of the plant
improvements had been completed, and were on line. Reference may be
made to the Consent Order fact sheet (Attachment CWA-3) which lists
the required improvements. Their status, at the time of the subject
inspection, was noted as follows:.
Liquids Processes
-The pump stations' work had not yet begun. There will be no new
pump stations. One of the 3 existing main pump stations will be
demolished and another will be upgraded.
-The flow equalization tank modification had not yet begun.
-The second nitrification tank had been completed and had been in
operation for over a month.
-The trickling filters had essentially been demolished as would
soon be the secondary settling tanks.
-The construction of a third secondary clarifier was underway and
associated sludge pumping system work would follow its
completion.
-A new post aeration tank has been completed but pipeline work
remained. The chlorine contact tank will also be converted to a
post aeration tank.
-Other effluent related construction which was ongoing included
installation of an ultraviolet disinfection system, a Parshall
flume and a hydropneumatic process water pump.
Solids Processes
-Two centrifuges replaced the vacuum filters in 1995. A third
centrifuge will be installed. .
-A new digester will be built and the existing digester will be
refurbished.
The sewer system rehabilitation was nearing completion at this
time. Only sections of sewer near Lejeune Hall and the town of
Quantico remained but were expected to meet the scheduled
completion date (2/99) .
Operation and Maintenance
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Mr. Sinclair, the plant supervisor, is responsible' for its
operation and maintenance program. The plant is Class II and manned
24 hours per day/7,days per week. All operators have at least a
Class II license including 10 (out of 18 operators). Class I.
licenses. Although the upgrade construction activities were
ongoing, ' the plant appeared to be operating adequately at this
time. All necessary treatment units were in operation and the
effluent was clear.
The plant staff includes a preventive maintenance mechanic who
coordinates all maintenance activities and performs the routine
maintenance duties. The maintenance management system uses a
computer program (Operator110)'to identify each piece of equipment
and its preventive maintenance frequency. Generally, plant
equipment appeared to be operable and adequately maintained. Spare
parts availability can sometimes be a problem due to delays,
inherent of the base's requisition process, but equipment
redundancy has usually prevented any major problems. Also, the
base's maintenance trade shops are readily available to the plant
•for various repairs and services.
Sewer Overflows
Although the plant has essentially been 'in compliance with the
interim effluent limits, Quantico has a chronic problem with
overflows in their sewer systems. Some are due to electrical
problems at pump stations but most are the result of incidental
blockages, particularly in the Aquia WWTP's (Stafford County)
service area on base. Generally, the spills are minor and occur in
flat, remote residential areas where the sewers accumulate grease,
etc. The sewer system rehabilitation is not expected to
significantly correct these blockages.
Quantico has been reporting all of the overflow incidents to
DEQ although there was some question as to whether- Stafford County
should report the incidents in their respective service area.
Self-Monitoring
Plant personnel collect all samples except for Fecal Coliform
which is collected by the contract lab at the time when the
samples are picked up for delivery. Until upgraded; the samples are
collected at the chlorine contact tank's rectangular weir either as
grab or composite samples. A monitoring shed here includes a Sigma
900 refrigerated automatic sampler which is connected for flow
proportioning to a Honeywell Truline flow recorder which senses the
flow.level at the weir. Operators measure pH, DO and Cl2 residual,
on site using, respectively, the following instruments': Orion SA
520, YSI 50B and Hach DR/2000 DPD and record these results on daily
log sheets. Universal Laboratories, the contract lab, initially
faxes the lab results to the plant within 24 hours of analysis, in
addition to submitting the lab report about 10-12 days later. These
50
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analyses include BOD5, TSS, TKN, TP and Fecal Coliform.
Recordkeeping arid DMR reporting procedures were ! reviewed
during the. subject, inspection. A computer program (Operator 10)
performs the DMR calculations which were checked for the month of
July 1997 and found to be correct. Although no'discrepancies were
noted for the records reviewed, a misunderstanding in reporting
procedures was clarified. It wa? pointed out that all weekly
averages during a month that exceeded the maximum weekly average
limit are to be reported as excursions rather than just reporting
1. excursion for only the maximum weekly average. Otherwise, the
reporting procedures were correct and no data inconsistencies were
noted. Also, daily calibration records were maintained for the pH
and DO meters. It should also be noted that the July 1997 DMR
submittal also included copies of letters to DEQ addressing
accidental or unauthorized discharges resulting from 2 separate
overflow incidents at one of the plant's main pump stations and at
a pump station on base in the collection system which discharges to
the Aquia WWTP. As noted below, Quantico often reports sewer system
overflows to DEQ.
EPA Form 3560-3, NPDES Compliance Inspection Report, is
included as part of the subject inspection report.
51
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Camp Upshur STP (VA00283 71)
Facility Description
The Camp Upshur STP is a minor NPDES facility, located in a
remote area in the northwest portion of;the base, roughly 20 miles
from the Mainside area of the base. It had a 3 tier design system
of .04, .07 and .'140: mgd but is now only operated at the .04 mgd
tier since daily tenant- activities generate influent flow well
below design and occasional flow increases from Reserve training
and Boy Scout activities remain below .04 mgd. As a result, the
plant normally operates by discharging an intermittent effluent by
holding or accumulating the wastewater within the plant over a few
days before finally treating. In past years, increased activity at
Camp Upshur generated more flow which necessitated operating at the
higher tiers. Only domestic wastewater is generated at Camp Upshur.
Essentially, the plant operates as an activated sludge plant
with a sand filter followed by chlorination/dechlorination before
discharging to Ceda.r Run via outfall 001. It has chemical treatment
capabilities which are not normally used - or needed. The minimal
amount of generated sludge is aerobically digested, dewatered on
sludge drying beds and land applied on base by a contractor. A
sketch of the plant is included with the subject report (Attachment
CWA-4). :
'Permit Status
Quantico is operating under a current permit (2/26/95 -
2/26/00) for its Camp Upshur STP.. In addition to the conventional
parameters," the permit requires the outfall 001 effluent to be
monitored for metals (every 6 months) and cyanide (annually),
effective as of March 1997.
The permit also includes Compliance Schedules for Dissolved
Oxygen and Ammonia-Nitrogen. Essentially,, the plant can meet the DO
limit (5.0 mg/1) which became effective June 1996. Pending further
monitoring, the plant may not be capable of meeting the final NH3-N
limits (2.90 mg/i / .44 kg/day) which become effective 2/26/99. A
new plant may be required.
At this time, it was noted that a feasibility study to replace
the plant with a constructed wetlands type facility . had. been
completed.
Operation and Maintenance
As with the Mainside STP, Mr. Sinclair,, the plant supervisor,
is responsible for the Camp Upshur STP1s operation and maintenance.
The plant is Class III and manned 8 hours per day/7 days per week
by 1 operator on a rotational basis from the Mainside STP staff,
52
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'each of whom have at least a Class II license. At the time of' the
subject inspection, the plant was not in full operation as there
was no effluent being discharged that day. Although some redundant'
units were . not operable (secondary clarifier) or permanently
removed from, service (sand filter), all necessary treatment units
were operable for adequately treating the minimal wastewater flow
normally received.
The plant's maintenance program is essentially the same as -
noted above for the Mainside STP. Generally, the plant equipment
appeared to be old but maintained as necessary to provide adequate
treatment. Structurally, however, the treatment units' gratings
which were rusted and warped presented a safety hazard,
particularly, since only 1 operator is normally onsite.
Self-Monitoring
The operator collects the effluent samples at the
dechlorination chamber which discharges to outfall 001. All samples
are grab samples as required by the permit. The operator measures
pH, DO and Cl2 residual on site using, respectively, the following
instruments: Orion SA 250, YSI 57 and Hach DR100 Colorimeter and
records these results on daily log sheets. Daily calibrations were
logged on separate sheets for each instrument.
The samples for lab analyses are delivered by the operator to
the Mainside STP for NH3-N analysis and contract lab pickup for BOD,
and TSS analyses". The samples, however, have not normally been
refrigerated or kept on ice from the time of collection and during
transit to the Mainside STP. Also, the NH3-N sample has not been
preserved, (w/H2S04) upon collection.
Flow is measured at the chlorine contact tank's V-notch weir
by an ultrasonic level detector which signals a recorder.(Quality
Control Equipment Co.) located inside the plant's building.
Recordkeeping and DMR reporting procedures were essentially
the same as those reviewed for the Mainside STP. As was noted for
the Mainside STP analyses, Universal' Laboratories, the contract
lab, similarly reports the Camp Upshur STP lab results to Quantico. .
Again, the month of July 1997 was checked for DMR calculations and
found to be correct with no data inconsistencies. Although the
correct method of analysis for NH3-N. is performed, the method
(number) has not been indicated in the analytical records (eg. on
bench sheet).
As an example of the low flow from Camp Upshur, there were
only 8 days that the plant discharged during July 1997. The, Monthly
Average flow was ~ 3500 gpd for 31 days and "13,000 gpd if only the
8 days of actual discharge were averaged.
53
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EPA Form 3560-3, NPDES Compliance Inspection Report, is
included as part of the subject inspection- report.
Industrial Discharge (VA0002151)
Quantico Marine Base
Facility Description
Quantico has 31 outfalls on their existing industrial permit.
These discharges include: process wastewater from water treatment
plants; vehicle maintenance and washing activities; steam heating
and air conditioning condensate; swimming pool filter backwash and
stormwater runoff from industrial type facilities. • Six of the
outfalls have been eliminated since the permit was issued, 2 of
which were associated with the power plant's coal, pile runoff
lagoons (066-treated effluent and 067- leachate).
Most of the existing discharges are untreated but some require
at least sedimentation basins (lagoons, etc.) and/or oil water
separators. Reference may be made to the discharge' description
copied from the DEQ's Permit Program Fact Sheet which includes each
outfall's discharge source, treatment and flow estimate (Attachment
CWA-5). '
Permit Status
Quantico is operating under a current permit (12/19/94
12/19/99) for its industrial discharges. In addition to the routine
monitoring requirements at each outfall, the permit requires bio
and chemical monitoring at certaih outfalls.
The permit also included a compliance schedule for total
residual chlorine (TRC) at Outfalls 001, 002, 003 and 004 (water
treatment plant filter backwash) and Outfalls 009, 012, and 040
(swimming pool filter backwash) which has been met.
Inspection Observations
The following outfalls were toured during the subject
inspection: 001, 002, 003, 004, 005, 009, 010, 013, 014, 015, 016,
022, 027, 030, 035, 071, 072, 073, 074. Since the weather was
essentially dry, there was generally, little or no flow being
discharged at this time from most of the observed outfalls. For
effluent observations, reference may be made to page 4 of EPA Form
3560-3, the NPDES inspection checklist completed for this permit.
Other,inspection comments are as follows:
The HMX-1 Hangars & Maintenance facility, which discharges
54
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stormwater as well as non-contact cooling water and steam
condensate through outfall 014, uses deicer on only the helicopter
apron, not the rest of-the runway, in the winter. Since the outfall
discharges to an unnamed tributary close to the' river, sampling is
actually performed on the facility site at the nearest upstream
manhole, in an effort to lessen the tidal effects on representative
sampling. The storm sewer within the facility is also tidally
influenced..
Outfalls 010 and 016 are the 2 major stormwater outfalls which
serve the base's Mainside north and south drainage areas,
respectively. Both outfalls are tidally' influenced as they
discharge to unnamed tributaries near the river. Sampling for
outfall 010 is actually performed at a nearby upstream manhole,
generally, not affected by the.tide as the river level partially
submerges the outfall. At this time, the water level submerged
about 2/3 of the pipe. Outfall 016 is not as significantly affected
by the tide. At this time, the water level submerged about 1/3 of
.the pipe and a slow flow discharging from it was noticeable. (Ref.
Photographs 36, 37 "(010); 38, 39 (016)).
Outfall 015 which discharges stormwater from the Airfield
Refueling Area1s holding lagoon is a submerged outfall. Sampling is
conducted at the lagoon when it is discharging.
Although not affected at this time, other outfalls observed
that can be subject to submergence during high river levels
included minimal flow outfalls 013 and 022 associated with the MWR
.Hobby Shop.
The Mainside Water Treatment Plant's (WTP) filter backwash is
normally pumped to the. Mainside STP from holding tanks, to avoid
dechlorination of its sedimentation lagoon's effluent which
discharges to outfall. 003 (Ref. Photographs 40 (003), 41 (lagoon)).
Excess backwash flows to the lagoon which will discharge if the
level' is high enough. The most recent discharge, at this time, had
been in June 1997 during an emergency which occurred about a year
after the previous discharge.
The Camp Upshur WTP's filter backwash lagoons had not
discharged to outfall 001 in over 2 1/2. years due to Camp Barrett's
minimal water usage.
The Camp Barrett WTP's filter backwash lagoons which are
operated in parallel discharge through outfalls 002 and 004. There
is generally no flow through outfall 002. Outfall 004 normally
requires dechlorination before discharging.
Outfalls 073 and 074 serve as the cfuantico landfill's south
and north stormwater runoff discharges, respectively. Outfall 073
discharges from a pond whereas outfall 074 discharges from a marsh
(Ref. Photographs 42. (073) ; 43 (074)) . There was no apparent stream
55
-------
in the immediate vicinity of either outfall as each discharge
essentially forms an unnamed tributary when there is stormwater
runoff. At this time, the landfill was expected to be closed within'
a year.
Outfall 072 is an oil/water separator discharge which serves
Quantico's Fuel Farm.'Onsite drains flow to the o/w separator which
can be bypassed. (Ref. Photographs 44 (072-far swale, bypass-near
swale) , 45 (draiin within berm) ) "
Generally, Quantico has been in compliance with the effluent
limits at all outfalls except outfalls 071 (Guad Maintenance Shop
Vehicle Wash) and 0 05 (Camp Barrett Tank Wash), which have
chronically exceeded TSS limits. Essentially, the high clay content
of the soil washed from trucks, track vehicles, etc. hasn't readily
been removed from the wash water before discharge. Outfall 071's
wash rack drains to a holding tank followed by an o/w separator
before discharging. Outfall 005's" wash area drains to concrete
sedimentation basins followed by an o/w separator before
discharging. Although not totally successful • up to this time,
Quantico has been making efforts, to eliminate the TSS violations .
which have included installation of filter, cloth at each outfall
and reducing the flow volume (high pressure, low flow) used in the
washing operations. (Ref. Photographs 46, 47 (071); 48 (005), 49
(005, o/w separator beyond 005 in hill, sedimentation, basins.beyond -
fence))
Self-Monitoring
The Natural Resources and Environmental Affairs Branch (NREAB)
staff collect the effluent samples at the outfalls. Samples are
collected as required by the permit.. All are grab samples except
for the 24-hr biomonitoring composite samples. As noted above,
some outfall sampling is performed slightly upstream from,, the
outfall discharge to collect better representative samples due to
tidal effects on submerged outfalls.
NREAB measures pH, temperature and Cl2 residual, at the
required outfalls using, respectively, the following instruments:
Orion 23.0A, Fisher Scientific Digital Thermometer (NIST) and Hach;
Pocket Colorimeter. NREAB also performs some lab analyses for TSS
and O&G at the Mainside WTP lab and were planning to begin TPH
analysis. Otherwise, their contract lab, Central Virginia
Laboratories & Consultants, Inc., does most of the lab analyses
which include TSS, O&G, Metals, PCB, TOC and TPH.
Again reviewing the month of July 1997, the DMR reporting
procedures and DMR calculations were found to be correct, with no.
data inconsistencies noted. Otherwise, calibration 'records were
logged on separate sheets for the various analytical equipment
including the pH meter, analytical balance,and various thermometer
(pH meter, drying oven, water bath, refrigerators) temperature
56
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cheeks using the NIST thermometer as the standard. There was,
however, no documentation of sample preservation which could be
indicated on the chain of custody forms.
EPA Form 3560-3, NPDES Compliance Inspection Report, is
included as part of the subject inspection:
57
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&EPA
United U^vc'rienia ^roieciton Agen'.y
V\as'"ng'of 1) I 204bC '
NPDES Compliance Inspection Report
' o'" A^p'over
0MB No 2>10-0003
Approval Eves 7-3' -8t
Section A: National Data Syttem Coding
Transaction Code NPQES yr/mo/day Inspects Type Inspector
i£j H INITIO!Si, If 1,7 tefci ' _isi3j
Remarks
Fac Type
2o4'
i I M l I I I :1 1 I 1 1 i n 1 [ I ! I M I I 1 -! ! i ! ! 1 j !' ! | i !
67
Reserved Facility Evaluation Ra:mg
i 69 ¦ 70 j
Bl OA
?'U ¦
Reseryed-
73 ! I 74 ' 7Si I i
ec
Na me and Location of - Fdciiity inspected
AlairtJicie- S ~Cf
MCcpC
C?jg,iTi co. VA '3.2.1.3 *4
Narneis; of On-Site^Representative^sj
£5j,]c
ftlcKAHe*
Section B Facility Data
Entry Time r^AM P] pw.
Hco
Exit Time Da:e
Uoo Birz/fi
Permit Effective Date
Permit Expiation Dot&
(t/ishi
Titie(sj
S OjO lit' V / S 0 r"
AsSijturff ''
L,a b T
-------
Form Approved
OMl) No. ISS • RQ073
'us F tiiru'L: Complete on all inspections, as appropriate. N/A
= Not Applicable
PE RMIT NO,
VA co 2 8 j
6 3
SECTION F - Facility and Permit Background
ADDRESS OF PERMITTEE IF DIFFERENT F.ROM FACILITY
(Including City. County and/IP code)
DATE OF LAST PREVIOUS INVESTIGATION
(In If i
BY EPA/STATE
FINDINGS J* ±
Sa il Tike ,
— Cij_ Rocia. fa vi /) eeJ-X To ,C-\nJ
SECTION G • Records and Reports
RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT;
DETAILS:
S^YES ~"NO ~ N/A 'Further
explanation attached
ia) ADEQUATE RECORDS MAINTAINED OF:
!ij SAMPLING DATE, TIME, EXACT LOCATION
¦Sf Y£S
l_i NO
|_J N • A
. ANALYSES DATES TIMES
E^Ves
~ NO
~ N/A
(iii) . INDIVIDUAL PERFORMING ANALYSIS
B^yes
~ NO
~ N/A
(iv) ANALYTICAL METHODS/TECHNIQUES USED
£ES
~ NO
~ N/A
(v) analytical RESULTS (e.g., consistent with self-monitoring report data)
B'yes
~ NO
~ N/A
(b) MONITORING RECORDS (e.g..flow, pll, D.O., etc.) MAINTAINED FOR A MINIMUM OF THREE YEARS
INCLUDING all ORIGINAL STRIP CHART RECORDINGS (e.g. continuous monitoring instrumentation,
calibration and maintenance records).
E^es
~ NO
~ N/A
(c) LAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT.
DB-"Ygs
~ NO
' ~ N/A
(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT'UNIT
QKyes
~ NO
~ N/A
(a) QUALITYASSURANCE RECORDS KEPT. i-d b '
ET YES Ci
tf^NO
~ N/A
(f)* RE CORDS maintained of major contributing industries (and their compliance status) USING
PUBLICLY OWNED TREATMENT WORKS.
~
YES
~ NO
B^/A
SECTION H - Permit Verification
INSPECTION OBSERVATIONS VERIFY THE PERMIT. SVes ~ no ~ n/a (Further explanation attached
DETAILS:
¦
(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE.
Q^yes
~ NO
~ n/a
(b) FACILITY IS AS DESCRIBED IN PERMIT.
BKyes
~ NO
~ n/a
(c) PRINCIPAL PRODUCT(S) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN PERMIT
APPLICATION.
~
YES
~ NO
E'n/a
1 AO icnQifkfpA
i C "Kj ly C.
YES
~ N/A
¦ o) any(hvdrauli"c«nd;or ORGANIC OVERLOADS EXPERIENCED.
YES
. i NO ¦
~ N/A
i tv/\,' f Jr -tcji{(. £ Ci" 'J? ft
EPA FORM JbbU-J (9
£.*t
PAGE 2 OF 4
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/• onn A ppravi
()\1H /Vo. 15X - KOOTJ1
• IT RM.iT No
0 02.
iM
O
SECTION J - Compliance Schedules
IT- RV'TTC E IS MEETING COMPLIANCE SCHEDULE.
CMhCK APPHOPHlATE PHAi)£.lSt:
~ yes Lino
N/A (hurvicr explanation attached
LJ
-------
/¦'omi Approved
OMR No. 15.8-R 00 73
SECTION L - Effluent/Receiving Water Observations ! r exp'unuunn at fuelled
OUTFALL NO.
PL R'.*! 1
OIL SHEEN
O 0 j
jREASE
TURBIDITY
VISIBLE
FOAM
VISIBLE
FLOAT SOL
COLOR
OTHER
cl
e ay
(Sections M and N: Complete as appropriate for sampling inspections!
SECTION M - Sampling inspection Procedures and Observations (Further explanation attached
M
!J GRAB SAMPLES OBTAINED
~ COMPOSITE OBTAINED
~ FLOW PROPORTIONED SAMPLE
~ AUTOMATIC SAMPLER USED
/*
~ SAMPLE split with permittee
~ CHAIN OF CUSTODY EMPLOYED
~ SAMPLE OBTAINED FBOM FACILITY SAMPLING DEVICE
COMPOSITING FREQUENCY ' :
PRESERVATION
SAMPLE REFRIGERATED DURING COMPOSITING: ~ YES ~ NO
SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE _
SECTION N - Analytical Results (Attach report ij necessary)
/s/A
EPA Form 3560-3 (9 77)
PAGE 4 OF 4
-------
A®J'- ngtor. Li L 204t»C
NPDES Compliance Inspection Report
SEPA
> 0"T Approves
OMB No 20O-00G3
Approval Evres 7-3'. Bi
Section A National D»t« Syttsm Coding
Transaction Code NPDES
T •'
£-0 ti I €.CL{A ,-C.iQ/i
.Phone Not
Phone No
7 03- 7 84 - J>~/ oz.
Contacted
D Yes&Ne
Section C: Areas Evaluated During Inspection
(S = Satisfactory. M = Marginal. U = Unsatisfactory. N - Not Evaluated)
f
s
S-
Z
Permit
Records/Reports
Facility Site Review
| Flow Measurement
5" I Laboratory
/^' Effluent/Receiving Waters
J"
Pretreatment
Compliance Schedules
Self-Monitoring Program
Operations & Maintenance
Sludge Disposal
Other:
Section D: Summary of Findings -'Comments IAttach additional sheets H necessary!
Nameisl and Signature^! of Inspector(s)
C c Hor,,(
Agency/Off ice/T elephone
EPA j F!P/ 4/ o -sis - 27 7S
Date
e/o/n
Agency/Office / ¦. T~
f • r ,/F i P
Date /
H A
Regulatory Office Use Only
i at-en
La-
.i." 1 • 3'' CI' To!.. ¦
CD Noncompliance
CD Compi a''Cf
F Pi r.-.r— -( 3 P:f>> ro'! :>on5 J'f r^so'e'.?
-------
Form Approved
OMli No. 15S-R0073
SECTION F - Facility and Permit Background
v\:turns F thru L: Complete on all inspections, as appropriate. N7A = Not- Applicable
PERMIT NO.
\IAfiOXfs3 7/
ADDRESS OF PERMITTEE IF DIFFERENT FROM FACILITY
/Including City, County and ZIP codej
DATE OF LAST PREVIOUS INVESTIGATION BY ,EPA/STATE\
FINDINGS ST
— t *'fj ' :— V'
j f'-t-tT Cyc ( <¦ i or/n; n c I'~S
SECTION G • Records arid Reports
RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT.
DETAILS:
Bye
YES ~ NO ~ N/A !Further explanation attached .
(a) ADEQUATE RECORDS MAINTAINED OF:
¦jsK,
SAMPLING DATE, TIME, EXACT LOCATION
sy>
YES,
U NO
J N/A
ANALYSES DATES. TIMES
ES
NO
(tii V
INDIVIDUAL PERFORMING ANALYSIS
USED<3f /Jrlj-A' A ct lk\ Jit* fid
with self-monitoring report data!'
ES
NO
~ N/A
~ N/A
(iv)
ANALYTICAL METHODS/TECHNIQUES
My
Iv
ES
~ NO
~ n/a
(v)
analytical RESULTS (e.g., consistent with self-mohitoring report dataj
ES
~ NO
~ N/A
(b) MONITORING RECORDS (e.g..flow, pH, D.O., etc.) MAINTAINED FOR A MINIMUM OF THREE YEARS
INCLUDING ALL ORIGINAL STRIP CHART RECORDINGS (e.g. continuous. monitoring instrumentation,
calibration and maintenance recordsj. ES
~ NO
~ N/
(c) LAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT.
C tV;
rite
S?yes
no
JDING OPERATING LO^fOR EA£H J^JiTMENT^UNIT. YES UNO U N/A
La hj^ffLlabTA'/h^j b*ves ~ no dnm
~ N/A
(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LO
~ N/7
(o) QUALITY ASSURANCE RECORDS KEPT.
(f) RECORDS MAINTAINED OF MAJOR CONTRIBUTING INDUSTRIES (and their COmpliancYstatUS) USING
PUBLICLY OWNED TREATMENT WORKS.
"INQ i NDUSTRIES (and their compliancrstah
Ah jriJvS Ir, a I U/U fT-
~ YES
~ NO
&ft/A
SECTION H • Permit Verification.
ffl^YES
~ NO Dn/a (Further explanation attached 7
NSPECTION OBSERVATIONS VERIFY THE PERMfT.
DETAILS:
B^YES
Q-^es
(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE.
~ NO
~ n/a
(b) FACILITY IS AS DESCRIBED IN PERMIT.
~ NO
~ n/a
(c) PRINCIPAL PRODUCTIS) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN PERMIT
APPLICATION. . ~ ~ YES
D NO
Ej-tf/A
Id) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION.
B- ^ h.-rfda,
f-
'RO'
£Ky:
(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIDED.
Mailable. C'L
YES
~ NO
~ N/A
(b) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES A
ic) REPORTS ON ALTERNATE SOURCE OF POWER SENT TO EPA^TATE AS REQUIRED BY^g^MIT
~ n/a
S-lfl/A
(d) SLUDGES AND SOLIDS ADEQUATELY DISPOSED.
EpYES . ~ NO
~ n/a
(e) ALL TREATMENT UNITS IN SERVICE.
~ YES
S^NO
~ N/A
(f) CONSULTING ENGINEER RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION AND
MAIN+ENANCE PROBLEMS.
~ YES
DB^NO '
~ N/A
(9) QUALIFIED OPERATING STAFF PROVIDED.
EKyes
S^YES
~ NO
~ n/a
(h) ESTABLISHED PROCEDURES AVAILABLE FOR TRAINING NEW OPERATORS.
NO
~ N/A
(i) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, AND
PARTS AND EQUIPMENT SUPPLIERS.
B^YE
YES
~ n6 Dn/a
(j) INSTRUCTIONS FILES KEPT FOR OPERATION AND MAINTENANCE OF EACH ITEM OF MAJOR
EQUIPMENT.
S^YES
~ NO
(k) OPERATION AND MAINTENANCE MANUAL MAINTAINED.
EO'ES ¦ ~ NO
(I) SPCC PLAN AVAILABLE.
E^yes
(m) REGULATORY AGENCY NOTIFIED OF BY PASSING. (Dates .
'~ YES
ANY BY-PASSING SINCE LAST INSPECTION.
~ YES
o) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED, ck! fit /> ^ If S i tj h ' G'.rotf' X.!-L ~ YES
_~ _NO
L NO
c.
NO
J N/A
~ n/a
~ n/a
' B^/A
Srf/A
J N/A
EPA FORM 3560-3 (9-77)
PAGE 2 OF 4
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/• orrn Af){)rovi ^
OMH /Vo. 158-H0073
PF.RMiT NO.
i VA002-S37/
SECTION J - Compliance Schedules
PERMITTEE 15 MEETING COMPLIANCE SCHEDULE. Dv ES D NO (Further explanation attached
CHECK APPROPRIATE PHASEIS): fa'ft .V*A/ tc b f- A sWa! .1 *j f rC/WlL faL"
~ (a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE _ ' 7 1
AUTHORITIES TO BEGIN CONSTRUCTION.
n (hi PROPER ARRANGEMENT HAS BEEN MADE FOR FINANCING' "Hort^Q^C COIIWlitnh'HtS. VUlltS. etc.).
D CONTRACTS FOR ENGINEERING SERVICES HAVEB^EN EXECUTED.
~ <:lj DESIGN PLANS AND SPECIFICATIONS HAVE'BEEN COMPLETED.
~ iej CONSTRUCTION HAS COMMENCED.
~ '-•) CONSTRUCTION AND/OR EQUIPMENT. ACQUISITION IS ON SCHEDULE.
~ (gl CONSTRUCTION HAS BEEN COMPLETED. '
~ in) START-UP HAS COMMENCED.
G til THE PERMITTEE HAS REQUESTED AN EXTENSION OF TIME.
SECTION K - Self-Monitoring Program
Part 1 - Flow measurement (Further explanation attached - ^ j
PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. B^YES ~ NO ~ N/A
DETAILS:. •' .
a) PRIMARY MEASURING DEW^E^P^Qftj^R L Y INSTALLED. V*/\}\\r*S C \c 11, v I A n YES ~ NO , ~ N/A
TYPE OF DEVICE: jVWEIR, ~PARSHALLFLUME DmaGMETER ~ VENTURI METER PoTHER (Specify
fa) CALIBRATION FREQUENCY ADEQUATE. (Date of last calibration . a.nA\,'ij ! ly ) B^ES ~ NO 1 Dn/a
c) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED. S^YES ~ NO ~ N/A
uilSECONDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED. B^YSS ~ NO Dn/a
(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW RATES
. B*YES ~ NO Dn/a
Part 2 — Sampling (Further explanation attached j
PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS: ,
QKyes ~ no Dn/a
I
a) LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES. •¦ • ffKYES ~ NO Dn/A
(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT. ~ H^YES ~ NO Dn/A
(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT. ~~ ipYES~ NO ~ N/A
IF NO. DgRAB ~ MANUAL COMPOSITE DaUTOMATIC COMPOSITE FREQUENCY
(d) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE. . B^YES ~ NO ~ N/A
n* !U ~ YES ~ NO R r> * Jy
PROPER PRESERVATION TECHNIQUES USED /'c 'A uPenet!Lf,aB^nq Dn/a
FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMI^ }~ yES DnQ Bi^7a
tii) . PROPER PRESERVATION TECHNIQUES USED /lfiTi' r/J uDa n PARAMETERS OTHER THAN THOSE REQUIRED BY THE PERMIT ARE ANALYZED. " ' ~ YES 0NO ~ N/A
d) SATIS FACTO RV_CA_L IB R AT I ON AND MAINTENANCE OF INSTRUMENTS AND EQUIPM ENT. B^YES ~ no"
e) QUALITY CONTROL PROCEDURES USED. SKyES ~ NO ~ N-A
Li N.'A
t) DUPLICATE SAMPLES AR.Ej
q) SPI KED SAMPLES ARE US EC
REANALYZED. JJOLQ. .% OF TIME.! ¦ ' E'YES ' U NO ~ N/A
Wb**:/ "'Aof tiive. r ' " " e^y
YES ~ NO
hi COMMERCIAL LABORATORY USED. , _ CT ETyES ~ NO pM/A
) COMMERCIAL LABORATORY STATE CERTIFIED. ~ YES ~ NO • 3K" A
LAB NAME
LAB ADDRESS
t^n.1 v. crj?i J fart
ck D>'i 1Ha.-*/?.X3>kitJt,..
1S-1- Rkr-nZZO
EPA FORM 3560-3'9 77) ' PAGE 3 OF 4
-------
Form Approved
0M13 No. 158-R0073
SECTION L - Effluent/Receiving Water Observations •'/•//*?
: •-£ ••
a1 * 0 /' / /> Sf-
VISIBLE
FOAM
C~t.'_
VISIBLE
' FLOAT SOL
COLOR
OTHER
I
(Sections M and N: Complete as appropriate for sampling inspections)
SECTION M - Sampling Inspection Procedures and Observations (Further explanation attached ,<
A'/A
Li GRAB SAMPLES OBTAINED
~ COMPOSITE OBTAINED
' ~ FLOW PROPORTIONED SAMPLE
~ AUTOMATIC SAMPLER USED
~ SAMPLE SPLIT WITH PERMITTEE
~ CHAIN OF CUSTODY EMPLOYED
~ SAMPLE OBTAINED FROM FACILITY SAMPLING DEVICE
COMPOSITING FREQUENCY ' !
PRESERVATION
SAMPLE REFRIGERATED DURING COMPOSITING: DyES ~ NO
SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE-
SECTION N - Analytical Results (Attach report if necessary)
M
EPA Form 3560-3 I9-77!
/PAGE 4 OF 4
-------
O EPA NPDE
'Jnif»d [ri*i'Or,'r»erH9 »-fciteT*Ay#n*.r
AaiK.'P3!or. 1) C 204 t>C
S Compliance Inspection Report
V^'TT A^pfove-r
OMB No 204D-OOG3
Approval Exs»res 7:jh -8"b
Section A Nations! Data System Coding
Transaction Code NPDES yr/mo/day , Inspection Type Inspector Fee Type
\Al *5 iV\Alo]^o\z\/\^i\u . ig7l7ifllg!/frli7 ¦ ia£ ,<£] 2v±
Remarks
I^'li>j^bTr!lgl| IAIlI 1P! i lS\C\H]A llC'krlfrl^ i 1 .1 i 1 M I M l M ii 1 i ! i M M
Reserved Facility Evaluation Rating
67* M 1 69 . 70_J.
Bl OA
71 I . 72_;
73! j I 74
-Reserv«a nf>c c A'd ,-t»t Ans ^
aoCMfico/VA -
NaneiS; o' On-Site Representatives;
j^« iffi A
Krilrtfi « Sr*.
A'rCol*l, / I
entry T,me ^MQ pM
ofQO
Exit Time. Date
Permit Effective Date
Permit Expiration. Date
D-hliW
/"fZ-txA j l>'lv'C-r'y"\ feVi ft* / 7'<
C £/Vj i j ~r~
£~-"> *' 'Hit A fd ( ft-a Tltr Tim; SsiCm {/S f
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L
Phone No's
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i l
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Name. Aaaress of Responsible Official
(5 j- u C K" t <2-/ j
Hzud Aft £ A dm AC ii
Phone Nc/
7 a 3-7\
Agency/Oflice/Telephone
j£~PA /F I ft / Ho - S"73 -2 7 7S~~
Date
.&//+! f 7
Agency/Otlice
Date
pi p
Regulatory Office Use Only
ctijn ia».en
~ Noncompliance
CD Comp'-arrr
-------
Form Approved
OMli No. 158 ¦ R0073
Si.viinns F tinu L: Complete on all inspections, as appropriate. N/'A
= Not Applicable
PERMIT NO
VA&OO
SECTION F - Facility arid Permit Background
ADDRESS OF PERMITTEE IF DIFFERENT FROM FACILITY
(Including dry, County and 7.IP code)
DATE OF LAST PREVIOUS INVESTIGATION BY
B/9/n
fcPA/ST AT £
F1N 01N GS_ „ ) '
c. c i'i t . "k\ o; .-i ^ prib le-M
/ @ o OS')
0 71
SECTION G - Records and Reports
RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT. '
S^YES Dno On/a 'Further
exnlanatior.
ttacf
ed
DETAILS: ,
iai ADEQUATE RECORDS MAINTAINED OF: '
-SAMPLING DATE, 71 WE, EXACT LOCATION
l2Tyes
¦ ~
NO
. I_J N/A
(iil ANALYSES DATES TIMES
s^yes
n
NO
~ N/A
(iii) INDIVIDUAL PERFORMING ANALYSIS
YES
C
NO
~ N/A
(iv) ANALYTICAL METHODS/TECHNIQUES USED
B^es
~
NO
~ N/A
. (v) analytical RESULTS [e.g., consistent with self-monitoring report data) .
~''yes
~
NO
~ N/A
(0) MONITORING.RECORDS (e.g.,flow, pH, D.O., etc.) MAINTAINED FOR A MINIMUM OF THREE YEARS
INCLUDING all original STRIP CHART RECORDINGS (e.g. continuous monitoring instrumentation,
calibration and maintenance records). .
Q^yes
~
NO
n n/a
(c) LAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT. ¦. + «,
Ci'l i (
yes
~
NO
~ N/A
Id) FACILITY.OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT UNIT.
~
YES
~
NO
Bfw/A
(o) QUALITY ASSURANCE RECORDS KEPT. ¦ C ,f Ln b
ffl^YES
~
NO
~ n/a
(f) RECORDS MAINTAINED OF major CONTRI buting industries (and'their compliance status) USING
PUBLICLY OWNED TREATMENT WORKS.
~
YES
~
NO
S^/A
SECTION H - Permit Verification
INSPECTION OBSERVATIONS VERIFY THE PERMIT. EK-ES ~ no ~ n/a (Further explanation attached
DETAILS: -
)
(a) CORRECT NAME AND MAILING ADORESS OF PERMITTEE.
E"yes
~
NO
~ N/A
(b) FACILITY IS AS DESCRIBED IN PERMIT.
B^yes
~
NO
~ n/a
(c) PRINCIPAL PRODUCTIS) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH |N PERMIT
APPLICATION.
~
YES
~
NO
S-rf/A
(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION. ,,
E^yes
• ~
NO
~ n/a
(e) NOTIFICATION GIVEN TO EPA/STATE OF NEW, DIFFERENT OR INCREASED DISCHARGES.
IF'yes
~
NO
~ n/a
(f) ACCURATE RECORDS OF RAW WATER VOLUME MAINTAINED.
~
YES
~
NO
~W/A
(g) NUMBER AND LOCATION OF DISCHARGE POINTS ARE AS DESCRIBED IN PERMIT.
ISTves
~
NO
~ n/a
'?7'&CLn±/\Tr>/A n "fa*. 4.- 6 llj I'iiL't ScJiM r /tt*
(a) STANDBY POWER.OR OTHER EQUIVALENT PROVISIONS PROVIDED.
~
YES
~
f
NO
e^A
(b) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE.
~
YES
~
NO
Btf/A
(c) REPORTS ON ALTERNATE SOURCE OF POWER SENT TO EPA/feTATE AS REQUIRED BY PERMIT.
~
YES
- ~
NO
3
-------
/• orrrj
OMIi /Vo. /5« - wnor:?.
• I'F RMH Nf.
VA oooziyi
SECTION J • Compliance Schedules
PERMITTEE IS MEETING COMPLIANCE"SCHEDULE.
CMtCK AFP K OP R I ATE PHAbL-iS)': . .
0YES Lino D n/a (l-unh'-r explanation attached ~ / .
~ (a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE
' AUTHORITIES TO BEGIN CONSTRUCTION.
0 lb) PROPER ARRANGEMENT HAS BEEN MADE FOR FINANCING .'Wnrtnaife cfCj.
'• ' CONTRACTS FG»! ENGINEERING SERVICES HAVE BEEN EXECUTED.
H (-J) DESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED.
~ ie) CONSTRUCTION HAS COMMENCED.-
~ CONSTRUCTION AND 'OR EQUIPMENT ACQUISITION IS ON SCHEDULE.
~ 'Uji CONSTRUCTION HAS'BEENl COMPLETED.
-Z: -:h) START-UP HAS COMMENCED.
~ ii) THE PERMITTEE HAS REQUESTED AN EXTENSION OF TIME.
SECTION K - Selt-Monitoring'Program
Part I — Flow measurement (Further explanation attached
PERMITTEE FLOW MEASUREMENT MEETS THE
oil <
DETAI LS:
a) PRIMARY MEASURING DEVICE PROP-ERLY INSTALLED.
EETS THE REQUIREMENTS AND INTENT QF THE PERMIT.
sit iA HA 4 d c ^ Tf-sTcp t
E'v
YES ~ NO
~ YES
~ NO
_TY_PE OF DEVICE: [JWEIR ~ PARSHALL FLUME DmaGMETER ~ VENTURI METE R ~ OTHER /Sp.
eci! r.
b) CALIBRATION FREQUENCY ADEQUATE. (Date of last calibration .
~ YES
~ NO
~ •N/A
B"n/*
™5n/a
IC) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED.
~ YES
~
NO
'0^/A
iaiSECOiyDARY INSTRUMENTS (totalizers, recorders, ete.j PROPERLY OPERATED,AND MAINTAINED.
~ YES
~
NO
B^/a
(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW RATES.
~ YES
. ~
NO
B^/a
Pari *> — Sampling (Further explanation nrtarhn! I
PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS:
Oa^YES
~
NO
~ n/a
(a! LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES.
[B^YES
~
NO
~ n/a
(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT.
E^yes
~
NO
~ n/a
(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT.
IF NO. DgRAB ~ MANUAL COMPOSITE ~ AUTOMATIC COMPOSITE FREQUENCY
CD^yes
~
NO
~ N/A
Id) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE.
H'yes
~
NO
~ n/a
(i) SAMPLES REFRIGERATED DURING COMPOSITING h'ibfl.i iilit C
B'yes
~
NO
~ n/a
(ii) PROPER PRESERVATION TECHNIQUES USED
GJ'yes
~ NO
~ n/a
(Hi) FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMIT biOCLUULfl
CB^yes
~
NO
~ n/a
SAMPLE HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3
CQ^yes
~
NO
~ n/a
le) MONITORING AND ANALYSES BEING PERFORMED MORE FREQUENTLY THAN REQUIRED BY
' PERMIT. .-ppr-clrifH
B^yes
~
NO
~ N/A
&Fy
If) IF (e) IS YES, RESULTS ARE REPORTED IN PERMITTEE'S SELF-MONITORING REPORT.
Part 3 — Laboratory (Further explanation attached _
ERMITTEE LABORATORY PROCEDURES MEET THE REQUIREMENTS AND INTENT OF THE PERMIT
DtTAI LS; CQi'a eCtlc. t
YES ~ NO
Y ES ¦ ~ NO
~ n/a
PA APPROVED ANALYTICAL TESTING PROCEDURES USED. (40 CFR 136.3)
y Muc
3_i0l Odd RcjL (f O,Ac£lcH3£) L-jrlchb^j r VA
804- 84-l~2fiS2 . Soo-Wi;-I+-7 0- FA X 604-847-2
"ie^A
'Ob
B3D
fc'PA FORM 3560-3 (0 771
PAGE 3 OF 4
-------
Form Approved
OMR No. J58-R007J
SECTION
OUTFALL NO.
Or* OiiOX~f
j /
O* O, C
J\ 6-~f v.P i/c U ao e.„D^SL:trj'
TION L - Effluent/Recfeiving Water Obs<
01 l sheen-
cka c. a jt—^ .^L4
Observations Tt-wth- r ,-xplj>wifm alhiclu J
¦ WA ~S\)
PCRV.lT NO.
i VM OOO.XjSj
GREASE
TURBIDITY
1 c le-*r
•* w' j ^ • >> _ 1 ¦ | j^ I ' -
> ! o I si .¦ a J »¦ a, F L0 ^jrt J
;(p.jL^.TnoJ mJMiMJ JV 2./A ^
VISIBLE
FOAM
VISIBLE
FLOAT SOL
COLOR
! T/c
.--nut-Jit!(*-. A, o /Vo A- 7tat,Uf
» to tide- '
OIL
j S* icv-' >/oAj¦ y\,
! ° Si (Ty gyp Ccuxc »1 e
!mJc i-\ u.-t s ^ —/ -rW-Ut >L^g^/to t"ide . j »
¦TiCeaC>i^(5- arrLi,Xt£ fyy T.'^e Tivhui
c -t:-. Jg.n ^eTj-Vn'v Z-^jro'dtwMSfi
! / / ' A. .
OOZj 0~7j | SliTe.'iTia.i ly /ȣ r Io\diT~ff i*J Pr'ily
£'£¦4 ; c 6J- ei>Jvvve-&ly, la j so.~i c/i I u \
„ £> ^ °'-1' d A / 1^t/c u.1. dugftc Ti'Jal i
Ov! OCrj^oW} . /7 1
^7^,£/_!
PAGE 4 OF 4
-------
Underground Injection .Control
There are eleven facilities utilizing a total of 16 Class V
Wells. All Class V Wells were identified as septic systems. All'
facilities are connected to Public Water Systems located both on
base and in surrounding communities. There were no obvious
endangering discharges taking, place to'any of the Class V Wells.
The only potential endangering discharges were at the fire station
(floor drains) and the two water plants (chemical sinks). Non-UIC
concerns include the potential for a fuel spill to the base storm
water system at the Fuel Farm and a fuel oil spill which occurred
one year ago at the Guadalcanal Maintenance Facility and has not
yet been remediated.
MAIN SIDE WATER PLANT
Utilities Section B041-7
Three bathrooms discharge to a Class V Well (septic system).
One chemical sink also discharges to the septic system. The
chemicals being discharged are those associated with drinking water
analysis and are believed to be in such small concentrations as to
not pose an endangerment to the ground water. There are no other
non-domestic discharges to the septic tank. A chemical drain under
a chemical hood is present for the discharge of endangering
chemicals. This drain discharges to a self-contained chemical tank
which is.pumped out by the Marine Corps (USMC) and disposed of by
the Hazardous Waste Storage Facility ,(HWSF) . There was a
remediation project approximately two years ago involving the
removal of oil contaminated soil. The source of the original
contamination was a leaking, oil storage tank utilized in past
operations. Oil is no longer utilized as a power source at the
plant'.
Hazardous waste storage facility (HWSFY
This facility has no bathrooms and no injection wells are
believed to exist at this facility. Hazardous wastes are disposed
of through a DRMO contract. There were no environmental problems
observed at the facility.
QUANTICO SECURITY BATTALION FIRE DEPARTMENT
This typical firehouse facility consists of several truck bays
and living facilities for the firemen. It also has two bathrooms
and kitchen facilities which discharge to a Class V Well (septic
tank). The facility has at least two floor drains (l1 x 1') which
are believed to discharge to the septic tank. Both drains are
subject to automotive wastewater discharge in the eivent of a
contaminant spill. No automotive service, other than basic
automotive fluid additions, is conducted at the facility. The;
58
-------
facility appears . clean and the drains' do - not exhibit any
endangering contaminant discharge. The EPA inspector recommended
that an emergency response plan be prepared to deal with any
inadvertent contaminant(oil/anti-freeze) discharge to the floor,
drains. •
NATURAL RESOURCE SATELLITE OFFICE
The administration- facility has two bathrooms and a kitchen
sink discharging to a Class V Well (septic system) . The Game
Office has a single bathroom discharging to a separate (2nd) septic
system. No floor drains or other potentially endangering
discharges were observed at this site. The inspection did reveal
that monitoring wells are present in this area as a result of a
pesticide dump (55 gallon drums).
AMMUNITION SUPPLY POINT (ASP)
The old administration facility has one bathroom discharging
to a (Class V Well) septic system. No endangering discharges were
observed. This facility is to be permanently abandoned in the near
future. The new administration facility is reported to have two
bathrooms discharging t° a separate (2nd) septic system. There is
one floor drain in each of the bathrooms and no other floor drains
were reported anywhere else within the new facility. No personal
inspection was made of new facility because of security reasons.
No endangering discharges are believed to exist in either facility.
The EPA inspector recommended that the septic system serving
the old administration facility be pumped out and permanently
abandoned when it is no longer required.
OUANTICO SUPPLY POINT
The facility consists of a small office building which has one
bathroom discharging to a Class V Well (septic ,system) . There is
also one floor drain discharging to the septic system in both the
bathroom and the fire house. Neither floor drain is believed to
represent an endangerment.
An inspection of the facility revealed that all fuel tanks are
enclosed in containment ponds that have storm water drains which
are only opened to discharge storm water from the containment pond.
These drains discharge to what was described as a fuel water
separator, which has the ability to completely eliminate fuel from
storm water discharged. The facility recently had a fuel spill
when line containment failed. The spill required removal of some
soil. The area of the spill also had cutoff storm drains
discharging to the fuel separator system. In areas below the above
ground fuel piping1 leading to the distribution point there are
multiple storm drains which cannot be closed and discharge directly
59
-------
to the storm sewer system. In the event that a pipe's integrity-
fails ,in this area, a large quantity of fuel could be discharged
directly to the storm water sewer system. The present system has
no type of alarm which would warn the operators in the event a pipe
were to fail.
DEFENSE UTILIZATION MARKETING OFFICE (DRMO)
This facility is utilized for the storage of previously used
appliances etc., so that they can be reutilized. The facility has
one bathroom discharging to a Class V Well (septic system)! This
facility does not generate any hazardous wastes and the septic
system is being utilized for domestic waste only.
EXPLOSIVE ORDINANCE DISPOSAL (EOD)
The upper facility has one bathroom and a shower which
discharge to a Class V Well (septic system). The lower, facility
has four bathrooms and one shower discharging to a second septic
system. There are three floor drains in the duty hut and no other
potentially endangering discharges. They use small amounts of
petroleum products and solvents which are disposed of by NREA
Disposal.
GUADALCANAL MAINTENANCE FACILITY
The facility has two bathrooms which were reported to
discharge to two separate septic systems. This facility probably
has no septic systems and is probably connected to the municipal
sewer system. The facility had a fuel oil containment tank fail
approximately one year ago. The tank was enclosed in containment
wall which was unable to prevent some spillage onto the surrounding
soil. This soil has not been excavated or properly evaluated for
remediation.
The EPA inspector recommended that the site of.the oil spill
be evaluated.
CAMP UPSHUR WATER PLANT
This small water treatment plant has one bathroom discharging
to a Class V Well (septic system),. One chemical sink also
discharges to the septic system. The chemicals being discharged are
those-associated with drinking water analysis and are believed to
be in such small concentrations as to not pose an endangerment to
the ground water. There are no other non-domestic discharges to
the septic tank. The facility has floor drains in a pump room
which discharges to the on-site water storage ponds.
60
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ENGINEER SUPPORT AREA
. This facility consists of two compounds. The upper and lower
compounds.have been utilized for many different types of operations
throughout the years but mainly as a research & development site
for different types of military equipment. Presently, that
facility is almost entirely shut down but plans are in the works to
re-open the facility for use by ' reserve nits. There is one
bathroom in each cf the two compounds discharging to separate
septic tanks. The septic system in the upper building has been
backing up for the .past few months. There is one wash bay that
discharges to an oil water separator then to an unknown location.
The oil/water separator was installed approximately two years ago.
There were no floor drains observed in any of the buildings. There
was evidence of some dumping in the woods surrounding the lower
compound. Information was gathered that indicates that
contamination may be present on this site. Information further
indicates that the ground in the forest below the lower compound
leaches a red substance during periods of high ground water. vBase
environmental management is supposed to be aware of the
contamination, but military personnel on site were very reluctant
to talk about any problem which might exist.,
The EPA inspector recommended that the potential contamination
on the site be investigated to determine an appropriate course of
action.
CONSTRUCTION EQUIPMENT REPAIR FACILITY
This facility is utilized for they maintenance of heavy
equipment and has several floor drains and a wash rack which
discharge to an oil/water separator then to a municipal sewer
system. Several monitoring wells were observed on site. These
wells were reportedly a result of a battery disposal site which has
been remediated. There are no UIC discharges at this site.
MEDAL OF HONOR GOLF COURSE
Typical golf course facility with four bathrooms discharging
to a Class V Well (septic system). There were'no floor drains in
any maintenance area. Used batteries are disposed of by Quantico
HWS.
61
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Toxic Substances Control Act
Quantico Marine Base owns and operates an electrical
distribution system to supply electric power to the base. The
facility does not have electrical generation capability, but
purchases electricity from the Virginia Power Co. The distribution
system contains equipment common to the distribution of electrical
power, such as transformers and capacitors.
EPA conducted a TSCA/PCB inspection at the Quantico Marine
Base in March, 1990. At that time, the facility had sixteen PCB
Transformers in their distribution system. During that inspection,
a number of discrepancies were noted involving the PCB equipment at
the facility, including, but not limited to leaks on PCB
Transformers, missing quarterly inspections, and recordkeeping
deficiencies. As a result of that inspection, EPA issued a Notice
of Violation to the facility in December, 1990 addressing all of
the deficiencies noted during the inspection.
Subsequent to that, the- facility hired a contractor to
identify and test for PCB content, all oil filled transformers in
the facility's distribution system. This was accomplished during
the 1991/1992 time frame. , At the same time, the facility also
awarded a contract to begin removal and disposal of all PCB
equipment in the distribution system.
From 1991 to 1995, all known PCB and PCB Contaminated
Transformers were removed from service and shipped off-site for
disposal. All of this equipment was replaced with non-PCB
equipment.
During 1995, the facility began another program to identify
all other oil filled equipment located at the facility (e.g.
forklifts, hydraulic machinery, etc,-) . Once identified, the oil in
this equipment was sampled and tested for PCB content. Part of
this program included the testing of hydraulically operated machine
shop equipment at various locations throughout the base. The
results of this testing identified one piece of equipment which was
contaminated with PCBs. This equipment, a Milwaukee milling
machine located in the facility's central heating plant, was
contaminated with PCBs at a concentration of 1950 PPM (see
attachment no. PCB-15). This piece of equipment was subsequently
removed from service and shipped off site for disposal.
At the time of the subject.inspection, there were no known PCB
or PCB Contaminated Transformers at the facility either in.service
or in storage for re-use or disposal.
' There are thirty large power capacitors in use at the
facility; however, at the time of the subject inspection the
facility personnel did not know if the caDanit.nrR rnnfainaH Dm
S2
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fluids.
There are several areas at the facility which either had
previously or are currently undergoing remediation for PCB
contamination. These sites are as follows:
• An old eight acre landfill located along the Potomac
River wheire, among other hazardous materials, 1.20 gallons
of PCB transformer oil was disposed of (See Photo Nos. 1,
2, & 3) .
• DRMO-Scrapyard, although it is located on the old
landfill site, it is considered a separate site because
it was a fenced in area used to store electrical
transformers. About 10 PCB contaminated transformers
were stored there for a period.of time and before they
were removed, the oil in six of the transformers leaked
onto the ground (See Photo Nos. 1, 2, & 3).
• Old Batch Plant - this site was used for about six to
nine years for the open storage of unserviceable
electrical transformers. Of the 34 transformers.stored
at this site, two contained PCB fluids at concentrations
greater than 500 PPM and twelve contained fluids with PCB
concentrations between 3 and 240 PPM. Some of the fluids
leaked from these transformers while in storage.
A more detailed description of these sites was obtained from
the facility's site management plan (see attachment no. PCB-1).
Facility Tour
During the subject inspection, the EPA inspector accompanied
by facility personnel, visited two locations at the facility that
were previously used by.the facility's contractor to stage PCB. and
PCB contaminated transformers prior to shipment of site. The
facility did not have a designated PCB storage area. These areas,
one near the base fire station and the other behind the base's
headquarters building are both asphalt paved areas. The EPA
inspector observed both areas during the inspection and there was
no evidence of. leaks or spills (e.g. visible stains) from PCB
equipment which had been stored there in the past.
The other areas visited during ' the inspection, were two
electrical substations that contained the thirty, in service
capacitors previously mentioned in this report.
The stadium substation, located on McCawley Avenue near the
base environmental office contained a bank of twenty-one capacitors
(see photo no. 4) . Each of the capacitors- was marked with a
manufacturer's nameplate, but there were no markings to indicate.if
the capacitors were PCB or non-PCB. The capacitors were mounted on
63
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a metal, rack and the information on the nameplates was too small to
be read from ground level. The EPA inspector noted that two of the
capacitors were stained (see photo nos. 5 & 6) indicating that they
may have leaked at some time; however, there were no stains on- the
ground under the capacitor bank. According to the electrical shop
supervisor, Dale Triplett, the capacitors-were included in a survey
of oil filled equipment to identify PCB containing equipment. He
said that the,information from the capacitor nameplates might be
contained in files maintained at the public works office. The EPA
inspector accompanied by the facility representative, Ralph Phipps,
went to the public works office to check on this information;
however, the person who. might have the information was not in the
office the week o'f the inspection. Ralph Phipps stated that he
would check with this person the following week.
The other substation containing capacitors is located in the
Camp Barrett area of the base. : This, substation contained nine
large capacitors mounted;in a metal rack (see photo no. 7). These
capacitors also were marked with manufacturer's nameplates, but
there were no markings to indicate if they were PCB or non-PCB.
There were no visible stains or leaks on these capacitors.
Subsequent to the inspection, Ralph Phipps, stated that they
checked the information on the capacitor nameplates and each of the
thirty capacitors was marked as containing non-PCB fluid.
Recordkeeping
All of the records regarding PCBs and PCB Items are maintained
in the facility's environmental office. During the subject
inspection, the EPA inspector reviewed all of the records dating
from 1991 to the present. These records included the facility's
annual document logs (electrical equipment inventories) , PCB
shipment manifests and attached documents (e.g. continuation sheets
and certificates of disposal) and records regarding the removal of
contaminated PCB soils from art old landfill site.
From 1991 to 1994, the facility's annual documents'consisted
of electrical equipment inventories for each calendar year as well
as manifest and 'associated documents for any PCB shipments made
during the calendar year. Although these documents listed each
piece of electrical equipment (transformers) including serial
numbers, gallons of oil, weight of oil and PCB concentrations, the
documents did not contain the total number and total weights in
kilograms for PCB Articles, PCB Article Containers and PCB
Containers removed from service and shipped off site (See
Attachment No. PCB-2). These documents also did not contain the
following information: for items remaining in service at the end of
the calendar year, the total number of PCB Transformers and the
total weight of the PCBs in the transformers, the total number of
large high and low voltage PCB Capacitors, and the total weight of
PCB Items in PCB Containers.r
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Beginning in 1995,, the facility personnel utilized a different
format for their annual documents.. (See Attachment No. PCB-7) . The
1995 annual document contained only four items (three transformers
and one hydraulically operated milling machine). The three
transformers were removed from service and disposed of ..in 1995 and
the hydraulic milling machine was placed into storage for disposal
in 1995.
The 1996 annual document contained only the hydraulically
operated milling machine and the document' indicated that the
machine, contaminated with PCBs, was shipped off-site for disposal
in 1996. The, facility had tested all of the hydraulically operated
machinery at the base and the milling machine was the only piece of
equipment,which contained any concentration of PCBs (See Attachment
No. PCB-15)
While reviewing the manifest for shipments of PGBs off-site,
the EPA inspector noted that for two shipments of PCBs in 1995 by
independent transporters (See Attachment Nos. PCB-8 & PCB-9), the
facility had no confirmation of receipt of the PCB shipments by the
TSD facility (e.g. phone log).
The EPA inspector told facility personnel that their annual
documents also needed to include documentation of all the PCB
contaminated materials (soils) removed from the old landfill site.
During the subject inspection, the EPA inspector completed
copies of two inspection checklists, Recordkeeping Checklist and
Subpart K - PCB Waste Disposal Records and Reports Checklist. The
completed checklists are included as part of this report
65
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Recordkeeping
Checklist
'(40 CFR 761.180)
Facility NamePin-it _Inspection Date: &/r7
761.180(a)
1. . Does the facility have in use, or in storage for future use
or disposal, the following:
a. 99.4 lbs. (45 kg.) or more of PCBs in PCB Container(s)?
Yes V No J
b. One or more PCB Transformers? Yes V _N°
c. 50 or more large high or low voltage PCB, capacitors?
Yes , y NO
2. Has the facility developed and maintained all annual records
and the annual document l.og as of July 1,1991 and each year
thereafter? ^ Yes _No ,
a. Are the annual records and the annual document log
prepared on a calendar year basis?
V' Yes No
b. Has the facility retained the annual records and the
annual document logs for at least three (3) years after
it no longer used or stored PCBs or PCB Items? ,
V Yes No
' ¦ '
3. Where are the records maintained?
^ 0 Lj'O
r4 1
How are the records compiled and by whom7A£C&4i£lc1L
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761.180(a)(1)(i) & (ii)
4. Does the facility's annual records contain the following:
a. All signed manifests generated by the facility during
the calendar year? y Yes No
b. All Certificates of Disposal that have been received by
the facility during the calendar year?
's/ Yes ' No
761.180(a)(2) fiV & (ii)
5. Does the written annual document log contain the following:
a. The name, address, and EPA identification number of the
facility? y Yes . No
b. The calendar year covered by the annual document log?
A/ Yes No
c. The; unique manifest number of every manifest generated
by the facility during the calendar year?
v/ Yes No
7^ . ¦'
761.180(a)(2) (ii)(A)
6. Does the written annual document log contain the following
information from each manifest and for unmanifested waste
that may be stored at-the facility:
Bulk PCB waste (e.g. in a tanker or truck)
a. Its weight in kilograms? y Yes _No
b. The first date'it was removed from service for
disposal? Yes No
c. The date it was placed into transport for off-site
storage or disposal? V Yes No
d. The date of disposal, if known? ^ Yes No
;ff6>.
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761. 180 fa). (2) (ii) (B)
PCB Articles (e.g. transformer or capacitor)
a.' The serial number .(if available) or other means of
identifying each PCB Article? Yes No
b. The weight in kilograms of the PCB waste in each PCB
Article? S/ ' Yes No
c. The date it was removed from service for disposal?
Yes No
d. The date it was placed in transport for off-site
storage or disposal? _Yes No
e. The date of disposal, if known? V Yes No
761.180(a)(2)(ii)(C)
PCB Containers
a. A unique number identifying each PCB Container?
y Yes No
b. A description of the contents of each PCB Container?
Sc Yes No
c. The total weight in kilograms of the material in each
PCB Container? V/ Yes No
11 1 •' '¦ 1 111 **
d. The first date material was placed in each PCB
Container? ^ Yes No
e. The date each container was placed in transport for
off-site storage or disposal? Yes No
f. The date of disposal, if known? \y Yes No
761.180(a)(2)(ii)(D)
PCB Article Containers
a. A unique number identifying each PCB Article Container?
y/ Yes _No
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b. A description of the contents of each PCB Article
Container? ^ Yes No
c. The total weight in kilograms of the contents of each
PCB Article Container? y Yes No
d. The first date a PCB Article was placed into each
container? ^ Yes No
e. The date the container was placed in transport for off-
site storage or disposal? ^ Yes No
f. The date of disposal, if known? Yes No
761.180(a)(2) (iii)
7. , Does the facility's annual document log contain the total
numbers and total weights (kg.) for the following items:
a. Total number of PCB Articles (by specific type)?
Yes y1 No
b. Total weight of PCBs in PCB Articles?
Yes \j/ No
¦¦¦
c Total number of PCB Article Containers?
Yes No
d Total weight of contents of PCB Article Containers?
Yes y/ No
e. Total number of PCB Containers?
Yes \y No
f. Total weight of contents of PCB Containers?
Yes \/ No
—;—: At" -
g. Total weight of bulk PCB waste that was placed into
storage for disposal or disposed during the calendar
year? Yes _No
761.180(a) (2) (iv) . (v) & (vi)
8. For PCBs and PCB Items remaining in service at the end of
the calendar year, do records indicate the. following:
a. Total number of PCB Transformers?
Yes V No
b. Total weight (kg) of PCBs in transformers?
Yes \y/ No
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c. Total number of large high or low voltage PCB
Capacitors? Yes ' No
d. Total weight (kg) of PCBs and PCB Items in PCB
Containers? Yes X. No
e. Identification of content-s of PCB containers (liquids,
capacitors, etc.)? Yes No
761.180(a)(2) (vii)"
9. For any PCBs or PCB Items received from or shipped to
another facility owned or operated by the same generator,
does the annual document log contain the same information as
asked in Question No. 6? Yes _No
761.180(a)(2)(viii)
10. Does the facility's annual document log contain a record of
each telephone call (or other means of verification) made to
each commercial storer or disposer to confirm receipt of- PCB
waste transported by an independent transporter?
Yes ^ No
11. Additional Commments:
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SUBPART K - PCB WASTE DISPOSAL RECORDS AND REPORTS CHECKLIST
(40 CFR Part 761.202 thru 761.218)
Note: This checklist should be used starting February 5, 1990 at
any facility which generates, stores, transports or disposes of PCB
waste. This would normally exclude only those facilities1which have
all of their PCB articles/items either in service or in storage for
reuse. PCB wastes are regulated herein if they contain greater than
50 ppm PCB or if they contain less than 50 ppm PCB as a result of
dilution.
Name of Facility; (p .iLfUtZflOcLAXiU!. "
Type: Gen ^Transporter Comm. Storer Disposer
1. Is the facility exempt from the EPA notification requirements
because it is only a generator of PCB waste through its use,
owning, servicing or processing of PCBs or PCB items but does not
own or operate a designated storage for disposal area subject to
the requirements of S761.65(b) or S761.65 (c) (7)?
yes no (761.205(c)(2))
If yes, skip to question 5c
2. Has the facility engaged in PCB waste handling activities on or
prior to February 5, 1990? yes no (761.202 (c))
.3. Has the facility applied for an EPA identification number?
yes no (761.202)
If yes, what was the date of the application.and has.the ID number
been officially issued?
If no, does the facility already have a RCRA identification number?
yes no
If the facility has- a RCRA ID number, did it notify EPA of its PCB
waste activities by April 4, 1990? y yes no
(761.205 (b)) £P/j 2*
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4. Has the generator submitted separate notifications to EPA for
each PGB storage area it owns or operates on different sites or
properties? yes no N/A (761.205 (c) (2) (iii))
5. If the facility did not engage in PCB waste activities until
after February 5, 1990 and has not yet received an EPA
identification number or if the facility engaged in PGB waste
activities on or before February 5, 1990 but has not applied for an
EPA identification number have any of the following occurred
a) The facility is a generator of PCB waste and processed,
stored, transported or offered for transport or disposed of such
PCB waste after June 4, 1990? yes no'
(761.202(b)(c)&(d))
b) The facility is not a generator of PCB waste but has engaged
in transporting, commercial storage or dispbsal of such PCB waste
after June 4, 1990? _yes no '
(761.202(b)(c)&(d))
c) The facility is a generator that offered PCB waste to
transporters, commercial storers, or disposers who_ have not
received an EPA identification number? yes X" no
(761.202 (b) (c)& (d) )
d) The facility is not a generator of PCB waste but has
delivered such waste to a transporter, commercial storer or a
disposer that have not received an EPA identification number?
. yes V no (761.202(b)(c)&(d))
6. Has the generator prepared a manifest whenever it ships PCB
waste off-site? yes _no N/A (761.207 (a))
If no or N/A skip to question 13
/
7. . Was the. manifest prepared on EPA Form 8700-22 with a
continuation sheet if necessary? yes no (761.207(a))
If no, describe ,what manifest was used.
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8. Was the following.information specified on the manifest
a) For each bulk load of PCBs, its identification, the earliest
date of removal from service for disposal and its weight
in kilograms? yes no (761.207(a)(1))
b) For each PCB container or article container, an
identification number, type of PCB waste, earliest date of removal
from service for disposal and its weight in kilograms? V yes
_no (761.207(a)(2))
c) For each PCB article, its serial number or- other
identification, date of removal from service for disposal and
weight in kilograms of its PCB waste? V yes no
(761.207(a)(3))
d) An approved off-site commercial storage or disposal facility
for PCB waste? V yes no (761.207 (g))
9. Did the generator of PCB waste, transporter or the storage or
disposal facility retain on file copies of the appropriate
manifests? yes no (761.209(a))
10. Were the manifests properly signed? V yes . no
(761.209(a))
11. Did the generator receive the hand signed manifest within 35
days after the PCB waste was accepted by the transporter?
X yes ; no N/A (761.208(a)(4))
If yes, did the generator confirm by telephone or other means,(if
shipped by an independent transporter) within a day after receiving
the hand-signed manifest that the commercial storer or disposer
actually received the manifested waste?
. yes V no N/A (761.208(a){4))
If no, did the generator telephone or communicate by other means
first with the commercial storer or disposer and then, if
necessary, with the transporter to determine the status of the PCB
waste? yes no N/A (761.208(a)(4))
12. If the generator has not received a hand-signed manifest from
an EPA approved facility within 10 days from the date of the
telephone call to the transporter, did it submit an exception
report to the EPA Regional Administrator?
_yes no y N/A (761.208(a)(4))
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13. Is there evidence to indicate that either a. transporter or a
commercial storer or disposer accepted a shipment of PCB waste
after April '4, 1990 without a properly signed manifest?
_yes no N/A (761.211(a))
If yes, describe and state whether an "Unmanifested Waste Report"
was submitted to the EPA Regional Administrator within 15 days
after the unmanifested PCB . waste was received (761.211(c))
MjA
14. Is there evidence to indicate that a significant discrepancy
regarding the amount of PCB waste stated on the manifest occurred?
V yes no _N/A (761.210 (a) )
If yes, discribe the discrepancy and attempts to reconcile it, and
state whether , a letter was submitted to the EPA Regional
Administrator if it is was not resolved within 15 days after the
PCB waste was. received (7$1-.210 (b)) _ ^
' 'JU*L
Answer questions 15. and 16. if the facility is a disposer of PCB
waste
15. Does the disposer submit to the EPA Regional Administer,a One-
year Exception Report if it receives PCB or PCB items more than 9
months after they were removed from service for disposal and, it
could not dispose of the affected PCBs or PCB items within 1 year
of the date of removal from service for disposal? . ji > i
yes no (761.215 (c) (1) & (2))
16. Does the disposer prepare a Certificate of Disposal for each
shipment of PCB waste that.it accepts and does it send a copy to
the generator identified on the manifest within 3 0 days of the date
that disposal of the PCB waste was completed?
yes no (761.218(a)&(b))
m
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Answer question 17. if the facility is a generator or commercial
storer of PCB waste
17. Does the generator or. commercial storer submit to the EPA
Regional Administrator a One-year Exception Report if it
transferred PCB or PCB items to. the disposer within 9 months after
they were removed from service for disposal and it either has not
received, within 13 months after removal from service for disposal,
a Certificate of .Disposal confirming, the disposal of the affected
PCBs or PCB items or it receives a Certificate of Disposal
confirming disposal more than 1 year after the date of removal from
service?
yes
Pertinent Comments
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Emergency Planning and Community Right-To-Know Act
This inspection was conducted to inspect, document, and verify
the facility's compliance with the reporting requirements stated ir
40 C.F:R. Part 372 under Section 313 of SARA Title III.
SARA Title III
The Emergency Planning and Community Right-to-Know Act (EPCRA)
was enacted as part of Title III of the Superfund Amendments and
Reauthorization Act of 1986. Executive order 12856 of October,'
1993 brought federal facilities under the requirements of this act
for the first time effective reporting year 1994.. The Executive
order defines a covered facility coming under the provisions of
Section 313 as one that meets all three of the following criteria;
1. If its a Federal facility. And
2. It has 10 or more full-time employees (or the equivalent
20,000 hours per year). And
3. It manufactures (including , imports) , or processes, or
otherwise uses a listed toxic chemical during any
calendar year in amounts greater than the threshold
quantities specified below.
Thresholds are specific amounts of toxic chemicals used during
the calendar year that triggers reporting requirements.
1. If a listed toxic chemical is manufactured, imported or
processed, the threshold quantity is 25,000 pounds per
toxic chemical or. category over the calendar year.
2. If a listed toxic chemical is otherwise used (without
incorporating it into any product or producing it at the
facility), the threshold quantity is 10,000 pounds per
toxic, chemical or category over.the calendar year.
Inspection Procedures and General Information
On August. 11 & 12, 1997, a Section 313 inspection was
conducted at the Quantico Marine Base in Quantico Virginia. The
inspection was conducted as part of'a multi-media inspection and
was limited to Section 313. The EPA inspector met with facility
personnel from the Natural Resources and Environmental Affairs
(NREA) Branch to review documentation and calculations for
compliance with Section 313. A tour of the water and waste water
treatment plants was also provided.
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Section 313 was the primary focus of,the inspection. The
inspection- involved determining if the Base manufactured,
processed, or otherwise used any one of the listed toxic chemicals
-in excess of the thresholds in calendar years 1994, and 1995.
Since the facility had filed its 1996 Form R report, that year was
also included in the review.
In 1994, the Department of Defense (DoD) sent a list of
chemicals to the Marine Corp Base (MCB) Quantico which were present
on the facility. A contractor was hired to determine which
chemicals on the list were present at the 75% of threshold level.
Those chemicals are listed below. As the MCB does manufacture,
process, or import chemicals, the otherwise use threshold of 10,000.
pounds was the guide line.
Summaries of usages of Section 313' chemicals for the years
being reviewed are as follows: .
CAS No.
Chemical Name
Usage in Pounds
1994
1995
1996
7782-50-5
chlorine
61,255
41,184
44,962
91-20-3
naphthalene
253'
135
142
.127-18-4
tetra
chloroethylene
3,488
< 2,633
0
108-88-3
toluene
524
524
524
1330-20-7
xylene
1,913
204
204
Chlorine was the only chemical used in quantities above the
EPCRA reporting threshold. It is used for disinfection purposes at
three swimming pools, two waste water treatment plants, and three
water treatment plants. The amounts of chlorine reported as
released on EPA Form R by the U. S. Marine Base Quantico are as
follows: .
Release in pounds
1994 1995 1996
Chlorine (includes both air & water) 42 42 42
The methodology used to determine the quantities of chlorine
used were obtained from the Standard Methods for the Examination of
Water and Wastewater, 17 th Edition, 1989 and Chemistry For
67
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Environmental engineering, Fourth Edition. A description of the
methodology can be found in Attachment B3, Release Calculations.
To facilitate the calculations, a Microsoft Excel•" spreadsheet has
been designed to perform the use calculations after the necessary
input of information is accomplished. Major Mock, Environmental
Engineer, and Branch Head of the NREA Branch, periodically checks
the calculations.
Appropriate documents were requested by the EPA inspector,
(Attachments A & B) and the SARA Title III Section 313
investigation was concluded.. A list of the documents taken was
provided to the NREA Branch representative completed (attachment B)
at the conclusion" of all inspection activities.
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Quantico Sanitary Landfill Permit #411
A representative from the Virginia Department of
Environmental Quality conducted an inspection of the Quantico.
Sanitary Landfill Solid Waste Permit #411. The following are the
issues and status of the issues that were discussed during the
inspection:
Unpermitted Operations
During an inspection conducted on March 24, 1997, the VaDEQ
inspector observed that the facility was not managing their wood
and metal piles, located outside the waste footprint, in
accordance with the VSWMR. A separate letter from the quarterly
inspection report,was written to distinguish these issues from
the landfill issues. The metal/debris pile was being managed as
an unpermitted Materials Recovery Facility.. The facility ceased
the management of the metal/debris recovery site before a June
24,1997 VaDEQ inspection.
The wood/debris site contained'clean wood, contaminated%
wood, construction/demolition debris and other solid wastes.
During the time period between the March 24 and June 24
inspections the facility mulched all the wood in this.pile,
including the contaminated wood. During the June 24 inspection,
the VaDEQ inspector explained to the facility that since the
contaminated wood was mulched with the clean wood then the whole
mulch pile was contaminated and should be disposed of in a
landfill. The facility had used some of the contaminated mulch
as alternate daily cover on the landfill. Contaminated wood
mulch has not been approved,as an alternate daily cover for
landfills. The contaminated mulch that was used on the landfill,
has now been covered with a minimum six inch daily cover of soil
as required.
During the EPA Multi-Media inspection on August 11, 1997,
the VaDEQ inspector discovered that the facility had not yet
begun to dispose of the contaminated mulch. . In addition, they
had-also started a size reducing operation at the same location
that was very similar to the metal/debris recovery site. A large
pile of furniture was being sized reduced on the ground, and then
placed in a truck to be. hauled to the Prince William County
Landfill. The VaDEQ inspector expressed again that this
operation was not in accordance with the VSWMR.
A week later, on August 18, 1997, VaDEQ representatives
(John Ely & Terry Gumbita) accompanied by Major Mock, of the
Natural Resources and Environmental Affairs Branch, and several
of his staff reins.pected the facility. . The size reducing
operation was cleaned up at that time.
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In a letter dated September 8, 1997, Quantico proposed that
they planned- to remove all of the contaminated mulch by December
1, 1997 and the only wood that would be stored is clean wood.
VaDEQ expressed that this proposal is satisfactory in a September
15, 1997 response letter to Colonel Costa as well as during the
quarterly inspection conducted on September 17, 1997.
Additional intermediate cover
The northern and western side slopes of the landfill lacked
adequate intermediate cover. At the time of the multi-media
inspection, waste was exposed and rill erosion was present. The
facility proposed to have ;the additional cover on these slopes
finished by December 1, 1997.. The VaDEQ inspector recommended
that the additional cover be finished by the end of September,
1997 and seeding be performed by the second week in October,
1997. This will allow some; vegetation to begin growing before
the winter and will help prevent erosion during these months.
This recommendation was suggested in the September 15th
letter 1^o Colonel Costa. By. the September 17th quarterly-
inspection, the facility had the additional cover almost
^completed and proposed to have the areas hydro-seeded in the next
several weeks. In addition,' during the August 18, 1997
inspection ;with Major Mock, the VaDEQ representatives questioned
the depth of intermediate cover on the eastern slope. During the
September 17, 1997 inspection the facility had bore holes open to '
demonstrate that the intermediate cover was adequate.
Groundwater
The facility has now implemented a final detection
groundwater, monitoring background schedule. During the review of
the facility's annual groundwater report by Mr. Larry Syverson,
' (VaDEQ1s Groundwater Corrective Action staff), a few deficiencies
including a contaminated upgradient well and either an inadequate
monitoring system or an inaccurate potentiometric map were
described. The facility is investigating these deficiencies and
has requested a reply extension to October 1, 1997..
Communications with Mr. Syverson indicate that the extension will
be granted.
Other Issues
During the September 17, 1997 quarterly inspection, gas
monitoring was discussed at the facility. The Quantico landfill
does not have a gas monitoring system. Therefore, the quarterly
inspection report will reflect this violation. The facility
staff expressed that they would begin the process of designing
the required gas monitoring system. This issue was not discussed
with the facility prior to the September 17, 1997 inspection.
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