Document Dg8kpobaJDaq4gVXoJg2NpQa

RCRA Inspection Report 1) Inspector and Author of Report (b)(6) Physical Scientist RCRA Enforcement Section (b)(6) U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch (b)(6) 2) Facility Information USAF Shaw Air Force Base SC7570024466 428 Chapin Street Shaw AFB, Sumter County, South Carolina 29152 3) Responsible Official (b)(6) Hazardous Waste Program Manager (b)(6) 4) Inspection Participants (b)(6) (b)(6) (b)(6) (b)(6) (b)(6) (b)(6) USAF Shaw Air Force Base (AFB) USAF Shaw AFB USAF Shaw AFB South Carolina Department of Health and Environmental Control South Carolina Department of Health and Environmental Control U. S. Environmental Protection Agency, Region 4 5) Date of Inspection January 31, 2023 6) Applicable Regulations' Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code -- Annotated U.S.C.A. 6925 and 6927), South Carolina Hazardous Waste Management Act, S.C. Code Ann. 44-56-10 et seq., and South Carolina Hazardous Waste Management Regulations (SCHWMR), S.C. Code Ann. Regs. 61-79.260-270, 61-79.273 and 61-79.279, and [40 Code of Federal Regulation (C.F.R.) Parts 260 - 270, 273, 278, & 279]. Pursuant to S.C. Code Ann. Regs. 61-79.262.15(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of 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 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. Section 44-56-60(a)(2) and (b) of the S.C. Code Ann. 44-56-60(a)(2) and (b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with S.C. Code Ann. Regs. 61-79.124, 264267, and 270, and S.C. Code Ann. Regs. 61-79.262.16(b) or R.61-79.262.17(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in S.C. Code Ann. Regs. 61-79.262.15(a)(7) and (8) [40 C.F.R. 262.15 (a)(7) and (8)], provided that the generator complies with the satellite accumulation area (SAA) conditions listed in S.C. Code Ann. Regs. 61-79.262.15(a) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to S.C. Code Ann. Regs. 61-79.262.17 [40 C.F.R. 262.17] a generator of 1,000 kilograms or greater of hazardous waste in a calendar month is a large quantity generator (LQG) and may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Sections 44-56-60(a)(2) and (b) of the S.C. Code Ann. 4456-60(a)(2) and (b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with S.C. Code Ann. Regs. 61-79.124, 264-267, and 270, provided that the generator complies with the conditions listed in S.C. Code Ann. Regs. 61-79.262.17 [40 C.F.R. 262.17], (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to S.C. Code Ann. Regs. 61-79.273.9 [40 C.F.R. 273.9], a large-quantity handler of universal waste (LQHUW) is a universal waste handler who accumulates 5,000 kilograms or more total of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. 7) Purpose of Inspection The purpose of this inspection was for the U.S. Environmental Protection Agency, Region 4, and the South Carolina Department of Health and Environmental Control to conduct a joint unannounced compliance evaluation inspection (CEI) at USAF Shaw Air Force Base (hereinafter, "Shaw AFB" or the "facility") to determine compliance with the applicable requirements of the Resource Conservation and Recovery Act (RCRA) and the corresponding South Carolina Department of Health and Environmental Control (SCDHEC) regulations. This was an EPA lead inspection. 8) Facility Description Shaw AFB is located at 428 Chapin Street, Sumter County, South Carolina, Latitude 33.965753 and Longitude -80.487327. The facility has been at its present location since 1941 and consists of approximately 16,143 acres. Shaw AFB is owned and operated by United States Department of Defense under the federal government's authority. The facility has approximately 7,110 active duty and 679 civilian personnel and operates 24 hours a day, seven days a week. The facility consists of numerous buildings. The City of Sumter provides potable water, and the sanitary sewer is connected to an on-site wastewater treatment plant with the discharge to surface water under a NPDES permit. The primary NAICS code for the facility is 928110, National Security. Shaw AFB is home to the U.S. Air Force's largest combat F-16 Wing, the 55th Fighter Squadron. EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 2 of 13 Shaw AFB is also home to the 20th Operations Support Squadron, 77`" Fighter Squadron, and the Fighter Squadron. Shaw AFB also serves as Headquarters of the le, Ninth Air Force, U.S. Air Forces Central, Third Army, U.S. Army Central and other tenant units. Hazardous wastes are generated from the maintenance of airplanes and other military equipment. The facility generates hazardous waste in approximately thirty different areas. The facility manages numerous hazardous waste satellite accumulation areas (SAAs) and one central accumulation area (90-day or less area). Hazardous waste is initially accumulated in SAAs within these generation areas. Full containers are transferred to the central accumulation area for 90-day or less storage. The facility prepares the hazardous waste for packaging and on-site management, prior to shipping the hazardous waste using the manifest system to an off-site treatment, storage, or disposal facility (TSDF). Shaw AFB's RCRA Subtitle C Site Identification Form, 8700-12, of its regulated waste activity, dated July 8, 2022, indicates the facility as a LQG of hazardous waste, a large quantity handler of universal waste (LQHUW), operating a healthcare facility under 40 C.F.R. 266, Subpart P and indicating generating EPA waste numbers D001, D002, D005, D006, D007, D008, D009, DO10, DO11, D018, D035, F002, F003, F005, P001, U133, U188 and U220. The facility generates hazardous waste consisting but not limited to waste unleaded fuel (D001/D008), waste paint (D001/D007 F003/F005), waste adhesion promoter (D001, D035), waste coumadin (P001), parts washer VAT filters (D006), waste sonic wash water (D006, D008), waste paint and sanding debris (D006, D007), waste paint rags (D001, D007, D035, F005), waste stripper debris (D007, F002, F005), waste paint and solvents (D001, D007, F003, F005), waste tech wipes (D005, D006, D008), waste CATM exhaust filter debris (D008), waste paint booth exhaust filter (D007), waste bead blast media (D006), waste absorbent with hydrazine (U133), waste aerosol cans (D001, universal waste lamps, universal waste batteries, and used oil. Shaw AFB has a RCRA permit for corrective action for the treatment of contaminated groundwater. 9) Previous Inspection History Shaw AFB was last inspected by the EPA and the SCDHEC on November 13, 2019. The CEI was an EPA lead inspection. The inspectors observed the facility failed to keep a container of universal waste lamps closed, accumulated two containers of universal waste lamps for more than one year, failed to mark or label containers with hazard indicator and failed to keep a container of hazardous waste closed. 10) Opening Conference On January 31, 2023, the EPA inspectoiL (b)(6) accompanied by SCDHEC inspectors EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 3 of 13 (b)(6) and (b)(6) arrived at Shaw AFB visitors center at approximately 9:15 a.m. The inspectors were received by (b)(6) Hazardous Waste Program Manager with the Shaw AFB Environmental Division. The EPA inspector showed his credentials to the visitor center staff and because the inspectors were bein escorted by (b)(6) a visitor pass was not needed. The inspectors were escorted by to a conference room for an openin conference. (b)(6) and the inspectors were joined by Shaw AFB representatives (b)(6) and (b)(6) I for an opening conference. The inspectors introduced themselves, showed their credentials and explained the purpose of the visit. The inspectors described the anticipated use of a digital camera during the inspection and provided a written list of the records needed for review. 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 copy of the EPA's information sheet for small businesses can be found at https://wwvv.epa.gov/sites/production/files/201706/documents/smallbusinessinfo.pdf. The EPA inspector also discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information provided to the EPA. Shaw AFB did not assert a business confidentiality claim. (b)(6) provided an overview of the facility's history and current operations during the opening conference. In addition, (b)(6) explained to the inspectors that the facility received a letter from the SCDHEC dated December 28, 2022 (Letter), granting an extension to the 90-day or less accumulation time to several containers of hazardous waste. The 90-day extension applied to one 5-gallon container of adhesion promoter (D001, D035), one 5-gallon container of coumadin (P001), one 5-gallon container of parts washer VAT filters (D006), six 55-gallon containers of sonic wash water (D006, D008), five containers of paint and sanding debris (D006, D007), one 55-gallon container of waste paint rags (D001, D007, D035, F005), one 55-gallon container of waste debris with R256 stripper (D007, F002, F005), two 55-gallon containers of waste paint and solvents (D001, D007, F003, F005), one 55-gallon container of tech wipes (D005, D006, D008), two containers of CATM exhaust filters non-HEPA with debris (D008), one container of waste paint booth exhaust filter (D007) and two 55-gallon containers of bead blast media (D006). The inspectors reviewed the Letter at the time of the opening conference. The inspection participants also discussed health and safe rotocols and required personal protective equipment before Shaw AFB representativ- (Shaw AFB representative) escorted the inspectors on a tour of the facility operations. 11) Inspection Observations 20 CES/CAA (Central Accumulation Area) -- Building 1986 The Shaw AFB central accumulation area (CAA) is in Building 1986. This area serves as the facility's 90-day or less accumulation for hazardous waste generated at the various base operations. The building is an enclosed brick, stone and metal structure with a concrete floor. The building has four separate bays for the accumulation of hazardous waste. The management of waste is conducted by the on-site sub-contractor. (b)(6) EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 4 of 13 (b)(6) and (b)(6) are the environmental technicians that work in the CAA. Inspectors observed a sign on the wall indicating the category of waste in each Bay. Inspectors observed Bay 1 designated for flammable hazardous waste. Inspectors observed one 30-gallon container of waste paint rags, one 55-gallon container of waste paint and solvent, one 55-gallon container of waste adhesion and one 55-gallon container of waste fuel in the Bay. The containers were closed, in good condition with aisle space, labeled with the words "hazardous waste," marked with a date indicating storage less than 90-days and labeled with hazard indicators. Inspectors observed the one 55-gallon container of waste adhesion in Bay 1, was marked with the date June 16, 2022, and a container granted an extension by SCDHEC to accumulate in the CAA for more than 90-days. The remaining hazardous waste containers granted an extension by SCDHEC were shipped to an off-site destination facility. Inspectors observed Bay 2 designated for toxic hazardous waste. Inspectors observed three 55gallon containers of waste solvents, one 35-gallon container of waste debris and one 5-gallon container of waste coumadin in the Bay. The container of waste coumadin was labeled with the words, "hazardous waste", but not "hazardous waste pharmaceutical" (Photograph 1). The word "pharmaceutical" was marked on the container of coumadin (Photograph 2). The containers were closed, in good condition with aisle space, labeled with the words "hazardous waste," marked with a date indicating storage less than 90-days and labeled with hazard indicators. Pursuant to S.C. Code Ann. Regs. 61-79.266.502(e) [40 C.F.R. 266.502(e)I, labeling containers used to accumulate non-creditable hazardous waste pharmaceuticals at healthcare facilities. A healthcare facility must label or clearly mark each container of noncreditable hazardous waste pharmaceuticals with the phrase "Hazardous Waste Pharmaceuticals." Inspectors observed the one 5-gallon container of coumadin in Bay 2, was marked with the date June 22, 2022, and a container granted an extension by SCDHEC to accumulate in the CAA for more than 90-days. The remaining hazardous waste containers granted an extension by SCDHEC were shipped to an off-site destination facility. Inspectors observed Bay 3 designated for toxic hazardous waste. Inspectors observed two onecubic yard containers of waste paint/sanding debris. The containers were closed, in good condition with aisle space, labeled with the words "hazardous waste," marked with a date indicating storage less than 90-days and labeled with hazard indicators. Inspectors observed Bay 4 designated for corrosive hazardous waste. Bay 4 was empty at the time of the inspection. 20 CES/CAA (SAA) - Building 1986 Inspectors observed two SAAs. One SAA was accumulating a 30-gallon container of waste paint and a second SAA was accumulating a 30-gallon container of waste insecticide. Inspectors EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 5 of 13 observed the containers were closed, labeled with the words "hazardous waste" and labeled with hazard indicators. Inspectors observed an overhead fire suppression system, eye wash and shower stations and spill and emergency equipment. The inspectors reviewed RCRA training records and position descriptions foil (b)(6) and (b)(6) Weekly container inspection records were reviewed from 2019 to 2023. Outdoor Storage Pad The outdoor pad is located near Building 1986. This area serves as the facility's accumulation area for universal waste lamps, used oil and non-hazardous waste generated at the various base operations. The open-walled concrete pad is constructed with a 10 to 20-feet-high metal roof. The inspectors observed one eight-feet box of universal waste lamps and one four-feet box of universal waste lamps. The containers were closed, labeled with words "universal waste" and dated March 28, 2022, and January 12, 2023. The inspectors observed approximately 70 lead acid batteries on pallets. Three batteries were not in good condition, either bulging or cracking (Photographs 3 and 4). The three batteries were overpacked in a plastic 5-gallon container and marked with the words "universal waste. Universal waste batteries. A large quantity handler of universal waste must manage universal waste batteries in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows: Pursuant to S.C. Code Ann. Regs. 61-79.273.33(a)(1) [40 C.F.R. 273.33(a)(1)], a large quantity handler of universal waste must contain any universal waste battery that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. The inspectors also observed twelve 55-gallon containers accumulating waste soil contaminated with lead generated from a clean-up activity. The containers were closed, in good condition with aisle space, labeled with the words "hazardous waste," all marked with the date January 18, 2023, and labeled with a hazard indicator. Metal Storage Shed - Universal Waste Batteries The inspectors observed one 30-gallon container accumulating universal waste lithium batteries. The container was closed, in good condition, labeled with the words "universal waste" and marked with the date August 22, 2022. Munitions Storage The inspectors, the Shaw AFB representative and (b)(6) Iwere greeted at EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 6 of 13 the security gate by Flight Line Manager (b)(6) andl (b)(6) The inspectors signed-in and proceeded with the inspection. 20 EMS/MXMW PC (PGM Maintenance) - Building 1816 Shaw AFB manages three SAAs in this area. The inspectors observed one 5-gallon container accumulating waste sempen paint in the first SAA, one 5-gallon container accumulating waste sempen in the second SAA and one 30-gallon container accumulating empty aerosol cans in the third SAA. The containers were closed, in good condition, labeled with the words "hazardous waste", and labeled with a hazard indicator. The inspectors observed a large part washer in this area that was in use. 20 EMS/MXMWPD (Trailer Maintenance) - Building 1815 Shaw AFB manages one SAA in this area. The inspectors observed one 55-gallon container accumulating waste brake fluid (D001, DO10) in the SAA. The container was closed, in good condition, labeled with the words "hazardous waste" and labeled with hazard indicators. The inspectors also observed one container of used oil absorbent, one container of used automotive grease and one container of empty aerosol cans. 77th FGS//MXABF (Gambler Maintenance Support) - Building 1629 The inspectors were greeted by (b)(6) The inspectors observed one five-gallon container accumulating universal waste lithium batteries and one five-gallon container accumulating alkaline batteries. The container of lithium batteries was closed, in good condition, labeled with words "universal waste" and marked with the date October 13, 2022. The inspectors were escorted outdoors to a locked metal storage locker. The inspectors observed one five-gallon container in the locker accumulating waste adhesion promoter. The container was closed, in good condition, labeled with the words "hazardous waste", and labeled with a hazard indicator. Several containers of used oil and used oil absorbent were observed in the locker. The containers were labeled with the words "used oil". 77th FGS//MXADF (Tiger Maintenance Support) - Building 1628 The inspectors observed one five-gallon container accumulating universal waste lithium batteries and one five-gallon container accumulating waste adhesion promoter in a yellow fire cabinet. The container of lithium batteries was closed, in good condition, labeled with the words "universal waste" and marked with the date June 17, 2022. The five-gallon container of waste adhesion promoter was closed, in good condition, labeled with the words "hazardous waste" and labeled with a hazard indicator. The inspectors were escorted outdoors to two locked storage lockers. The inspectors observed three 30-gallon containers in the first locker accumulating petroleum contaminated absorbent. The containers were closed, in good condition and labeled with the words "used petroleum contaminated absorbent" (Photograph 5). In the second locker the inspectors observed two 55- EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 7 of 13 gallon containers accumulating used oil. The containers were closed, in good condition and labeled with the words "used oil". Golf Course Maintenance - Building 1440 The inspectors were escorted to the golf maintenance building. The Shaw AFB representative contacted the maintenance staff. The Shaw AFB representative indicated to inspectors that the maintenance staff had left work for the day. This building was not inspected. 20 MDSS/SGSAP (Hospital Pharmacy) - Building 1042 Hospital Pharmacy personnel provide prescription medication to active duty and retired military personnel. Non-Credible Pharmaceutical Storage Area The inspectors observed one five-gallon container accumulating a bottle of coumadin. The container was closed, labeled with the words" hazardous waste pharmaceuticals", marked with the date January 1, 2023, and labeled with a hazard indicator. Credible Pharmaceutical Storage Area The inspectors observed two 20 to 30-gallon red containers accumulating pharmaceuticals to be shipped as credible pharmaceuticals for possible credit (Photograph 6). The creditable pharmaceuticals are shipped quarterly. Inspectors requested to review the records showing the harmaceuticals are shipped for credit (b)(6) and (b)(6) indicated they would contact logistic to retrieve the records for the inspectors to review. Logistic (b)(6) indicated that the pharmacy should have a copy of the records and that shipping records for the credible pharmaceuticals were locked in a cabinet and were not available at the time of the inspection. The person responsible for securing the cabinet was not at the facility at the time of this inspection. Pursuant to S.C. Code Ann. Regs. 61-79.266.503(e) [40 C.F.R. 266.503(e)], A healthcare facility that initiates a shipment of potentially creditable hazardous waste pharmaceuticals to a reverse distributor must keep the following records (paper or electronic) for each shipment of potentially creditable hazardous waste pharmaceuticals for three years from the date of shipment: All records must be readily available upon request by an inspector. Hospital Chemistry Laboratory Blood and urine specimens are cultured and analyzed using a "Vitros 5600" instrument (Vitros). Gram staining is also performed in the laboratory. It appears the lines and internal parts of the Vitros instrument are cleaned on a regular maintenance schedule. The inspectors observed a one-gallon bottle of "Universal Wash Reagent" and an unmarked 2.5-gallon container of waste liquid stored inside the Vitros (Photograph 7). When full the container of waste liquid is removed from the Vitros and the content discharge to EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 8 of 13 the laboratory sink. It appears waste generated from the gram staining operation is discharged to the laboratory sink. Pursuant to S.C. Code Ann. Regs. 61-79.262.11 [40 C.F.R. 262.11], a person who generates a solid waste, as defined in 25 S.C. Code Ann. Regs. 61-79.261.2 [40 C.F.R. 261.2], must use the steps articulated in S.C. Code Ann. Regs. 61-79.262.11 [40 C.F.R. 262.11] to make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. Waste Management Employees in process operations that generate hazardous waste accumulate it in containers at the point of generation. Full containers are transferred to the central accumulation area for 90-day or less storage. The facility offers its hazardous waste to the following transporters and TSDFs. Shaw AFB used the following transporters in 2019 through 2022 Freehold Cartage, Inc, NJD054126164 Ecoflo, Inc, NCD980842132 Shaw AFB used the following TSDFs in 2019 through 2022 Clean Earth of Calvert City, KYD985073196 Ecoflo, Inc, NCD980842132 Records Review The hazardous waste manifests, land disposal restriction notifications, and nonhazardous waste manifests for the calendar year 2019 through 2022 were reviewed. The EPA inspector reviewed two hazardous waste manifests from the EPA's E-Manifest Record System for calendar year 2022. Waste Determination/Profiles/Safety Data Sheets (SDS) The inspector reviewed waste determination records for the waste part washer solvent, waste part washer filter, waste part washer sludge, waste sealing compound, waste used POL filters, waste absorbent with POLs, waste adhesion promoter and waste adhesion/sealant debris. The inspector reviewed the SDSs for Quick Slide Stain Pack (Wright Giemsa Buffer and Wright Giemsa Stain) and Wright Giemsa Rinse used in the Chemistry Laboratory. The Wright Giemsa Stain SDS indicates it is composed of methanol and has a flash point of 52 to 58 degrees Fahrenheit. The Wright Giemsa Rinse SDS indicates it is composed of ethanol and has a flash point of 111 degrees Fahrenheit. Quick Reference Guide The inspectors observed the quick reference guide did not include the name of the emergency coordinator(s). EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 9 of 13 Pursuant to S.C. Code Ann. Regs. 61-79.262.17(a)(6)11 [40 C.F.R. 262.17(a)(6)], which incorporates S.C. Code Ann. Regs. 61-79.262.262(b)(8) [40 C.F.R. 262.262(b)(8)], and is a condition of the LQG Permit Exemption, a generator's quick reference guide to the contingency plan must include the following elements: the name of the emergency coordinator(s) and 7/24-hour emergency telephone number(s) or, in the case of a facility where an emergency coordinator is continuously on duty, the emergency telephone number for the emergency coordinator. Contingency Plan The contingency plan was revised on April 13, 2022. The Contingency Plan was not submitted to the hospital. Pursuant to S.C. Code Ann. Regs. 61-79.262.262(a) [40 C.F.R. 262.262(a)], which is a condition of the LQG Permit Exemption, the large quantity generator must submit a copy of the contingency plan and all revisions to all local emergency responders (i.e., police departments, fire departments, hospitals, and state and local emergency response teams that may be called upon to provide emergency services). This document may also be submitted to the Local Emergency Planning Committee, as appropriate. The inspectors reviewed weekly container inspection records from January 2019 to January 2023. The inspectors reviewed the contingency plan, arrangements with the local authorities, personnel training, job titles, position descriptions, and quarterly reports. 12) Closing Conference The inspectors conducted a closing conference with (b)(6) from USAF Shaw Air Force Base. During this meeting, the inspectors stated their preliminary conclusions of the inspection. 13) Sampling Overview Sampling was not conducted. 14) List of Appendices Appendix 1 -- Photograph Log: Photos taken on: January 31, 2023 Photos taken by: (b)(6) Samsung Camera (Model WB250F) EPA Property Tag# S75917 EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 10 of 13 15) Signed (b)(6) (b)(6) Physical Scientist Concurrence (b)(6) (b)(6) Chief RCRA Enforcement Section Date Date EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 11 of 13 USAF Shaw Air Force Base RCRA CEI Photographs (b)(6) US EPA zrezunizny.lnizzxxriref, HAZARDOUS \ry r cTFP--"- 20 CES/CAA (b)(6) I Observed one 5-gallon container of waste coumadin in Bay 2. The container of waste coumadin was labeled with the words, "hazardous waste", but not "hazardous waste pharmaceutical" Photograph 1 taken at 11:26 a.m. 20 CES/CAA (b)(6) bserved the facility mark the one 5-gallon container of waste coumadin in Bay 2 with the word "pharmaceutical" Photograph 2 taken at 11:29 a.m. . l ,I' 411lr,, -._ - ki -....`` ' -.-_--,it .._ , ._ -- -----,_ _ .'iktz,- ,. ---_,---- '...-es ,--...., ,' -,---- /, ---'---------._- ,e*- -zs, -------l-e,r,, 20 CES/CAA 1 (b)(6) Outdoor Storage Area. Observed three batteries were not in good condition, either bulging or cracking. Photograph 3 taken at 12:03 p.m. 20 CES/CAA -I (b)(6) Outdoor Storage Area. Observed three batteries were not in good condition, either bulging or cracking. Photograph 4 taken at 12:03 p.m. EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 12 of 13 USAF Shaw Air Force Base RCRA CEI Photographs (b)(6) US EPA 77th FGS//MXADF (Tiger Maintenance Support) (b)(6) Outdoor Storage Locker. Observed containers accumulating used oil related material. Photograph 5 taken at 1:36 p.m. 20 MDSS/SGSAP (Hospital Pharmacy) - (b)(6) Credible Pharmaceutical Storage Area. Observed two 20 to 30-gallon red containers accumulating pharmaceuticals to be shipped for possible credit. Photograph 6 taken at 2:14 p.m. Hospital - Chemistry Laboratory. Observed container of wash reagent in "Vitros 5600" instrument. The inspectors observed the larger container on the right is accumulating possible waste liquid from cleaning the instrument. Photograph 7 taken at 2:49 EPA-RCRA CEI Report USAF Shaw Air Force Base Shaw Air Force Base, South Carolina EPA ID No. SC7570024466 Page 13 of 13