Document 3EYjy191rLbooYRDmrO6Zmy6
RCRA Inspection Report
1) Inspector and Author of Report
(b) (6) Environmental Engineer RCRA Enforcement Section (b) (6) (b) (6)
U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch 61 Forsyth Street, S.W. Atlanta, Georgia 30303
2) Facility Information
Columbus Air Force Base (CAFB) (b) (6)
(b) (6)
Columbus, Mississippi 39710
EPA ID#: MS7570024060 NAICS #: 928110 - National Security
3) Responsible Official
(b) (6) (b) (6) 14 Civil Engineer Squadron (CES) (b) (6)
4) Inspection Participants
(b) (6) (b) (6) (b) (6)
Columbus Air Force Base P.E., Mississippi Department of Environmental Quality (MDEQ) P.E., U.S. EPA, Region 4
5) Date of Inspection
April 26, 2023
6) Applicable Regulations1
Mississippi Hazardous Waste Management Regulations (MHWMR), 11 Miss. Admin. Code Pt. 3, R. 1.1-1.24
Section 17-17-1 et seq. of the Mississippi Code of 1972, Miss. Code Ann. 17-17-1 et seq.
Section 17-17-27 of the Mississippi Code of 1972, Miss. Code Ann. 17-17-27
1 As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions will be to the authorized State program. However, for ease of reference, the federal citations will follow in brackets.
Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.10], a Large Quantity Generator (LQG) is a generator who generates greater than or equal to 1,000 kilograms (2200 lbs) of nonacute hazardous waste in a calendar month.
Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near the point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or without having interim status, as required by Section 17-17-27(4) of the Mississippi Code of 1972, Miss. Code Ann. 17-17-27(4), and without complying with 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption").
Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.17], a large quantity generator (LQG) may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 17-17-27 of the Mississippi Code of 1972, Miss. Code Ann. 17-17-27 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption").
7) Purpose of Inspection
The purpose of this inspection was to conduct an unannounced compliance evaluation inspection (CEI) to determine Columbus Air Force Base's compliance with the conditions of the applicable requirements of RCRA and the corresponding Mississippi regulations. This was an EPA led inspection supported by MDEQ.
8) Facility Description
Columbus Air Force Base (CAFB) is a United States Air Force (USAF) base located approximately 9 miles north of Columbus, Mississippi. The host unit at Columbus is the 14th Flying Training Wing assigned to the Air Education and Training Command. The facility is situated on approximately 5,000 acres in Lowndes County, Mississippi with approximately 3,500 personnel at the facility, military and civilian. CAFB was established on June 26, 1941. The mission of the CAFB is to train pilots. The CAFB functions as support for operating units of the 14th Flying Wing. The CAFB primarily supports training pilots for the USAF. The facility is also responsible for the repair and maintenance of approximately 238 training aircraft. Housing and other residential services are also included within the base complex.
Operations at the facility including parts cleaning, aircraft painting, aircraft maintenance, and aircraft washing/cleaning may generate hazardous waste; and healthcare operations at the facility may also generate other hazardous wastes, including pharmaceutical waste. The facility's waste, which includes hazardous waste and universal waste, is managed through the Defense Logistics Agency (DLA) Disposition Services. The DLA is a combat defense logistics agency that
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manages the global supply chain, from raw materials, to end user, to disposition, for the Department of Defense (DOD). All the hazardous waste generated onsite, including spent paint booth filters, used paint from aircraft painting operations, paint residue solids, waste aircraft sealants containing chromium, waste bead blast media and waste rags, are picked up by the DLA contractor and transported to a treatment storage and disposal (TSD) facility, AES Environmental LLC (EPA ID KYD985073196) located in Calvert City, Kentucky. The transporter of hazardous waste is Lamp Environmental Industries (EPA ID LAR000055467). The universal waste including fluorescent lamps and used batteries are also sent to AES Environmental LLC.
According to facility personnel, approximately ten parts washer machines, used for cleaning and degreasing, are located in the aircraft maintenance area. Heritage-Crystal Clean (EPA ID ILR000130062) picks up the spent parts washer solvent once a month, and manages it at their facility located in Memphis, Tennessee. The used oil pickups are scheduled once a quarter, or as needed, through Base Qualified Recycling Program contract, and Westside Oil Recovery Services (EPA ID LAD982552184) recycles CAFB's used oil at its facility located in Slidell, Louisiana.
The City of Columbus provides drinking water and there are no active wells onsite. The facility has its own fire department. According to the facility personnel, the fire department has an agreement with the local Columbus fire department for backup and assistance as required.
Columbus Air Force Base has notified as a Large Quantity Generator (LQG) of hazardous waste. The latest notification was submitted on February 24, 2023. The hazardous waste codes for hazardous waste generated at Columbus Air Force Base include D001 (Ignitability), D002 (Corrosivity), D006 (Cadmium), D007 (Chromium), D008 (Lead), D009 (Mercury), D018 (Benzene), D035 (Methyl Ethyl Ketone), and F005 (Spent Solvents). The facility, in the 2021 Biennial Report, reported that 67.6595 tons of hazardous waste was generated at the facility and the same amount was shipped. The facility operates under a minor air permit, MS0000002808700007.
9) Previous Inspection History
The US EPA and MDEQ have conducted three RCRA CEIs at the subject facility since 2010. The last prior inspection was conducted on May 3, 2018. Four violations were cited as a result of the 2018 CEI inspection.
10) Opening Conference
On Wednesday, April 26, 2023, U.S. Environmental Protection Agency (EPA), Region 4 (R4),
inspector (b) (6)
, accompanied by Mississippi Department of Environmental Quality
(MDEQ) inspector (b) (6) , arrived at Columbus Air Force Base at approximately 9:00 a.m.
at the base's entrance security building. After in-processing to receive guest passes, the
inspection team was met by (b) (6)
the Air/RCRA/Toxics/Recycling Manager and Spill
Response Advisor for the base. The inspectors were introduced to (b) (6)
(b) (6)
U.S. Air Force (USAF), the Base Civil Engineer, whose responsibilities include
overseeing the environmental program, before proceeding to the opening conference.
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An opening conference was held. The inspectors introduced themselves, showed their credentials to (b) (6) , and explained the purpose of the visit. It was explained that a RCRA hazardous waste inspection would be conducted.
The personnel present at the opening conference:
Name (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Affiliation Columbus Air Force Base Columbus Air Force Base Columbus Air Force Base MDEQ US EPA, R4
The inspectors described that the anticipated use of equipment was confined to using either a digital camera (EPA) and/or cell phone (MDEQ) to take pictures of waste management areas during the inspection. The EPA inspector explained that the Small Business Regulatory Enforcement Fairness Act's classification of a "small business" is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. A paper copy of the EPA information sheet for small businesses was provided to the facility. The EPA inspector also discussed a company's or organization's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. A paper copy of the EPA policy was provided to the facility. The company did not assert a business confidentiality claim. Base security was discussed and the inspection team noted that no photographs of the flight line, personnel, security measures, etc. would be taken, but that photographs would be confined solely to waste management and recycling issues.
The inspection team was briefed on waste management and recycling procedures on the base. It was briefed that the base is recycling paper, plastic, cans, glass, batteries, toner cartridges, crushed glass, scrap metal, newsprint, pallets, and tree waste.
11) Inspection Observations
Building 220: The inspectors began the walk-through portion of the inspection at Building 220. Building 220 is a machine shop with the capability to perform the custom repair of airplane parts for the facility's training aircraft. This repair can include the painting of the repaired parts. CAFB has two satellite accumulation areas (SAAs) near the paint booth for the shop (SAA A and B). Liquid paint waste, which contains methyl ethyl ketone (MEK), is generated in the paint booth and collected in SAA A (Photograph 1). The inspectors observed one container, which was labeled with the words "Hazardous Waste" and the hazard indicator label, in SAA A (Photograph 2). PPE and other solids that are generated in Building 220, are accumulated in SAA B (Photograph 3). The inspectors observed one 55-gallon container, which was labeled with the words "hazardous waste" and the hazard indicator label, in SAA B (Photograph 4). The area included an eye wash, fire extinguisher, and spill kit. The building also has a fire suppression sprinkler system.
Building 220 also included a SAA for hazardous waste (D007) generated from maintenance operations within the building. SAA C had a waste compactor. One (1) full 55-gallon drum was also in this area and was dated April 26, 2023. Both 55-gallon drums included the words
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"Hazardous Waste" however, it was observed that neither the drum in the compactor nor the full drum were labeled with an appropriate hazard indicator label or marking (Photographs 5 and 6).
Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)], A generator must mark or label its container with the following: (ii) An indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704).
MDEQ briefed CAFB on recent guidance from the EPA (February 2023), which states that the Class 9 DOT label, by itself, does not adequately indicate the hazard associated with the container's content. CAFB addressed this observation at the time of the inspection. CAFB addressed this observation by adding a Class 9 label to the containers and also adding the words "Toxic" and "Chromium D007" to the containers (Photographs 7 and 8). It is recommended that no writing be written on the DOT Class 9 label itself.
Universal Waste was also being accumulated in Building 220. CAFB is maintaining a spreadsheet on its universal waste containers and rotating the containers every six months.
The level of housekeeping in Building 220 was at a high level. No spills or releases were observed. This high level of housekeeping was present in all of the other waste management areas that were inspected during the inspection.
Building 218 - The inspectors then went to Building 218. The containers in Building 218 SAAs A, C, and D were properly labeled with the words "hazardous waste" and with the hazard indicator label (Photographs 9, 10, and 11). SAA B for the ultrasonic cleaner hazardous waste for this building is not operational but can be added, if needed. Universal waste was also being stored in this building in a closed and dated 5-gallon container (Photograph 12). CAFB also operates a parts washer in Building 218. This unit is serviced by contract. The sodium hydroxide tanks are cleaned out every two to three years. The spent solution is manifested as hazardous waste and is pumped into and transported by a disposal tanker truck. Building 218 also has a nonhazardous parts washer that is serviced by a contractor (Photographs 13 and 14).
Building 406 - SAA A and SAA B are for the operation of the large paint booth in Building 406 (Photograph 15). SAA A is for hazardous waste liquid paint waste generated specifically from painting operations (Photograph 16). The paint booths have three stages of air pollution control filters. The first stage is changed monthly, the second stage is changed every six months, and the third stage is changed annually. SAA B is for hazardous waste solid residues and PPE that are generated throughout the building and these wastes are placed in SAA B (Photograph 17). The containers in these areas were properly labeled and marked and were observed to be in good condition and closed.
Building 414 - The paint and surface of aircraft to be serviced are blasted to remove paint all the
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way down to the metal surface. Hazardous waste blast media is collected in the bag house collection system that feeds into 55-gallon drums (Photograph 18). The media is filtered through the system until it is finally collected in the blue drum for disposal. This hazardous waste blast media is hazardous due to its metal content. The metal related hazardous waste codes for this waste are D006, D007, and D008. Once full, the hazardous waste drum is removed, labeled as hazardous waste and dated. Approximately one drum of hazardous waste blast media is generated per hour during blasting shifts. The waste is subsequently moved to the 90-day area in Building 265.
Building 262 - This Corrosion Control Building has a large paint booth where aircraft are painted. The paint booth operates under negative pressure and is vented to the outside through three layers of air filters. SAA A is for liquid paint related waste generated in the paint booth. SAA B is for paint residue solids generated in the Corrosion Control Building. Two (2) drums of hazardous waste were located in the SAA B in this building (Photograph 19). One drum was full and dated April 26, 2023 (the date of the inspection) and the other drum was new (Photograph 20). SAA B is for paint residue solids that are hazardous for D006 and D007 and had a Class 4 DOT hazard label (Photograph 21). The containers were observed to be properly labeled and marked and appeared to be properly closed and in good condition. The container in SAA A is for liquid paint related waste and had hazardous waste codes D001, D035, and F005, on its label and had a Class 3 DOT hazard label (Photograph 21). This drum was observed to be properly labeled and marked and appeared to be properly closed and in good condition.
Building 265 - This building contains a 90-day Central Accumulation Area (CAA) (Photograph 22). This building is partially open to the environment. It is a separate building with a sign at the entrance indicating the building's use and with a fire extinguisher near the gate. The storage area is comprised of a concrete pad (with berm) and has a metal roof and concrete block walls (Photograph 23). The 90-day CAA at Building 265 was empty due to the hazardous waste pickup that morning. In addition to hazardous waste, CAFB stores nonhazardous waste - SCUM - oily based clean up materials, and nonregulated waste collected from plane deicing (Photographs 24 and 25) in the 90-day CAA. The 90-day CAA is equipped with a spill kit.
Building 410 - The inspectors next went to Building 410 which had used oil storage. Used oil was being accumulated in a 500-gallon double-walled tank. The tank was closed and labeled as "Used Oil" (Photograph 26).
Building 449 - The inspectors then went to Building 449 (Photograph 27). The hazardous waste in Building 449 is generated from aircraft maintenance repairs. Two SAAs were in Building 449, SAA A and SAA B. One 55-gallon container was observed to be in each SAA. It was observed that each of the two hazardous waste 55-gallon accumulation drums was missing the flammable hazard indicator label (Photographs 28 and 29). The building is equipped with a spill kit and fire extinguisher. It was recommended that a portable eye wash be included where applicable (11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)]).
Building 449 also contained a used oil accumulation container that was closed and labeled as "Used Oil" (Photograph 30). The remaining accumulation is for nonhazardous or nonregulated waste, such as used jet fuel.
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Building 460 - The inspectors next went to tour Building 460. This building had a SAA, SAA B for accumulating sealant hazardous waste. The container in SAA B was labeled and had a Class 9 DOT hazard label but was missing other hazard indicator information. This observation was immediately addressed as the container was supplemented with the words "Toxic Chromium D007" while the inspectors observed (Photograph 31) (11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)]).
Building 212 - CAFB manages a SAA in Building 212 for accumulating the contents of aerosol cans. The inspectors observed an AeroVent puncture unit on top of a 55-gallon hazardous waste accumulation container in this SAA. The AeroVent puncture unit is used to puncture aerosol cans and drain their contents into the 55-gallon container, which was labeled as hazardous waste and marked with a Class 3 DOT label. There was also a 55-gallon drum for scrap metal labeled as "Depleted Spray Cans" (Photograph 33).
Household Hazardous Waste - CAFB conducts household hazardous waste collection events for those living and working on the Air Force base. Household hazardous wastes are managed by a consultant for CAFB. CAFB was conducting a household hazardous waste collection event on the day of the inspection. The inspectors stopped at the collection event area and discussed the collection event with the consultant (Photographs 34 and 35).
Building 205 - The inspectors then went to the Security Forces Warehouse, Building 205. The waste collection area had a universal waste container of universal waste lamps dated January 6, 2023 (Photograph 36). Hazardous waste generated from security operations in the Building 205 area was being accumulated in a SAA. The 55-gallon hazardous waste accumulation drum at the SAA was labeled as hazardous waste but it was observed the hazard indicator label was missing (Photographs 37 and 38). It was noted that the hazard marking would include a DOT Class 9 label and also include the words "Toxic" added to the container (11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)]).
Building 926 - The inspectors then went to a second Security Forces Building. Hazardous waste generated from security operations in the Building 926 area were being accumulated in a SAA. The 55-gallon container in the SAA included the hazardous waste label but it was observed that the container was missing the hazard indictor marking (11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)]).
Building 384 - Building 384 included SAAs for maintenance and building operations. SAA A was specifically for liquid paint hazardous waste generated during maintenance operations. A second waste stream, for PPE and other debris generated in Building 384, was being accumulated in SAA B. The containers were closed, in good condition, had the hazardous waste labels, and the hazard indicators (Photographs 41 and 42).
Building 385 - The inspectors observed that universal waste was being collected in Building 385 (Photographs 43 and 44).
Building 304 - Two SAAs for hazardous waste were located in this building. SAA A had a 55gallon container being used to accumulate used gasoline and diesel fuel filters (Photographs 45 and 46) and SAA B had a 55-gallon container containing the contents from aerosol can
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puncturing (Photographs 47 and 48). Used Oil (Photograph 49) and universal wastes are also accumulated in Building 304 (Photograph 50).
Recycling Center - The inspectors next went to CAFB's recycling center. CAFB operates a recycling center for collecting recyclables such as plastic, glass, and aluminum cans. Wooden pallets, universal wastes, used oil, and other waste streams are also collected in this area. The recycling center has a 24-hour drop off area. The center also has equipment for crushing glass, crushing cans, and bailing paper (Photographs 51, 52, 53, and 54).
Wood Treatment - The inspectors then went to CAFB's wood processing site. CAFB operates a mulch yard for processing wooden wastes and agricultural debris (Photograph 55).
Building 267 - The inspectors final stop on the walk-through portion of the inspection was at the 90-day CAA located in Building 267 (Photograph 57 and 58). Most of the hazardous waste in 90-day CAA had been removed during CAFB's scheduled pick up earlier in the day. One 55gallon drum observed in this area had a Class 9 DOT miscellaneous label (Photograph 59) but did not have any additional hazard marking or labeling.
Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.17(a)(5)(i)], which is a condition of the LQG Permit Exemption, a large quantity generator must mark or label its container with the following: (B) An indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704).
The inspectors observed four containers of hazardous waste in the building. One 55-gallon container of hazardous waste contained hazardous waste solids (D006) and was dated March 10, 2023. A 5-gallon container of hazardous waste solids (D006) was dated March 24, 2023. One drum contained a toxic and flammable hazardous waste solid (D006 and D001) and was dated April 13, 2023, and included the hazard indicator label. The remaining hazardous waste drum contained an ignitable liquid hazardous waste (D001) and was dated April 5, 2023, and had the hazard indicator. Two containers of universal waste were also in Building 267 and those containers were dated January 6, 2023, and January 10, 2023.
12) Records Review
The following records were reviewed:
Waste Profiles - CAFB provided two binders of hazardous waste profiles for review with approximately 50 hazardous waste profiles in the current list.
Weekly Inspections - Weekly inspections for the 90-day CAAs in Buildings 265 and 267 were conducted and no missing inspections were identified. Each building had a unique checklist to record inspections, and different conditions were included on each list. The inspectors recommended that CAFB add the condition of the containers to one of the forms and consider
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harmonizing the forms to mirror the inspection form that was more comprehensive.
Hazardous Waste Manifests - Hazardous waste manifests for calendar years 2021, 2022, and 2023 were reviewed by the inspectors. The manifests included the LDR along with additional supplemental information used by the DOD. No discrepancies or missing records were identified.
Contingency Plan - A copy of the Contingency Plan and Quick Reference Guides for the Air Force Base were provided and reviewed by the inspectors. CAFB maintains QRGs for each of the buildings containing hazardous waste satellite accumulation areas and for the two 90-day central accumulation areas.
RCRA Training - Copies of RCRA training for CAFB personnel were provided to and reviewed by the inspectors. The record of training and classes taken were well organized and comprehensive. No issues were identified.
Annual Reporting - Annual reports for calendar years 2020 through 2022 were available when reviewed in RCRAInfo. No issues with annual reporting for CAFB were identified.
Waste Minimization - No issues with waste minimization reporting and pollution prevention program requirements for CAFB were identified. The inspectors noted that the CAFB had a comprehensive recycling program.
13) Closing Conference
The records review process was followed by a closing conference. The following personnel were in attendance for the exit meeting.
Name (b) (6) (b) (6) (b) (6) (b) (6) (b) (6)
Affiliation Columbus Air Force Base Columbus Air Force Base Columbus Air Force Base MDEQ US EPA, R4
The inspectors reviewed the preliminary findings of the inspection. The compliance observations of concern were solely confined to missing or incomplete hazard indication marking on some of the hazardous waste containers. The containers observed to have this issue were corrected during the inspection. No observations of other potential compliance issues in any other areas were identified. No releases, leaks, spills, or open containers were observed during the entire inspection.
14) List of Appendices
Appendix 1 - Photograph Log.
15) Signed
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Columbus Air Force Base (CAFB) (b) (6)
EPA ID#: MS7570024060
Appendix 1 - Photograph Log Photographs taken on: April 26, 2023 Photos taken by: (b) (6) Photos taken with: Kodak PixPro FZ53
EPA Property Tag: SX9091
Photograph 1: Liquid Hazardous Waste in Building 220, SAA A
Photograph 2: Labels on 55-gallon Container in Building 220, SAA A
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Photograph 3: 55-Gallon Container of Hazardous Waste Solids in Building 220, SAA B
Photograph 4: Labels on Hazardous Waste Solids Container in Building 220, SAA B
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Photograph 5: 55-Gallon Container Missing the Hazard Indicator
Photograph 6: 55-Gallon Container Missing the Hazard Indicator
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Photograph 7: Hazard indicator information added to container.
Photograph 8: Hazard indicator information added to container.
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Photograph 9: Building 218 SAA D
Photograph 10: Building 218 - SAA A
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Photograph 11: Building 218 SAA C
Photograph 12: Building 218 Universal Waste SAA
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Photograph 13: Parts Washer Unit.
Photograph 14: Parts Washer Unit.
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Photograph 15: Building 406 SAAs A and B
Photograph 16: Building 406 SAA A Container
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Photograph 17: Building 406 SAA B Container
Photograph 18: Building 414 - Blast media collection
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Photograph 19: Building 262 SAA B
Photograph 20: Hazardous Waste Label and Hazard Indicator on Solids Container
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Photograph 23: Empty Space in Building 265 CAA
Photograph 24: Non-Hazardous Waste in Building 265.
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Photograph 25: Non-Hazardous Waste in Building 265
Photograph 26: Building 410 Used Oil Container
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Photograph 29: Building 449, SAA B, Container Missing Hazard Indicator
Photograph 30: Building 449, Used Oil Container
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Photograph 37: SAA Container Missing Hazard Indicator
Photograph 38: SAA Container Missing Hazard Indicator
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Photograph 41: Building 384 SAA A
Photograph 42: Building 384 SAA B
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Photograph 43: Universal Waste Container
Photograph 44: Universal Waste Container
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Photograph 45: Building 304 SAA A
Photograph 46: Building 304 SAA A Container Labeling
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Photograph 47: Building 304 Aerosol Puncture Station SAA B
Photograph 48: Building 304 Aerosol Puncture Station SAA B
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Photograph 49: Building 304 Used Oil Collection
Photograph 50: Building 304 Universal Waste Collection
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Photograph 51: Recycling Center
Photograph 52: Recycling Center
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Photograph 53: Recycling Center
Photograph 54: Universal Waste in Recycling Center
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Photograph 57: Interior of Building 267 CAA
Photograph 58: Building 267, Hazardous Waste Container With Incomplete Hazard Indicator
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Photograph 58: Hazardous Waste Container
Photograph 59: Building 267, Hazardous Waste Container
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