Document NE0v1EQNJbykJ5XRR69mk34y8

December , 2024 Mr. Brian Hendrickson Hazardous Waste Media Manager Naval Submarine Base New London RTE 12 Crystal Lake Road Groton, CT 06340 Re: U.S. EPA-Region 1 Inspection Report of Naval Submarine Base New London, September 25 - 26, 2024 Dear Mr. Hendrickson: In accordance with current policy, I am providing you with a copy of the final inspection report summarizing observations made during the September 25 - 26, 2024, inspection of your facility. This inspection was conducted under the authority of RCRA. Please contact me at 617-918-1163 or patel.hardik@epa.gov if you have any questions. Sincerely, Patel, Digitally signed by Patel, Hardik _H__a_r_d__ik______1_0_:2_4_:1_3_-0_5_'0_0_' __ Date: 2024.12.11 Hardik V. Patel Environmental Engineer cc: Joseph Schiavone, CT DEEP 1 Es/ZKEDEd> WZKdd/KE 'Ez Z'/KE Et E'>E WK^d K&&/ ^YhZ ^h/d K^dKE D^^,h^dd^ ZZ Z /Z Z E ^ E >ZZ Zd > ZZ 'ZZ d ^ Z /Z /Z ZZ Z /Z ZZ & Patel, Hardik Digitally signed by Patel, Hardik Date: 2024.12.11 10:24:02 -05'00' , s W Z t Z ^Z O'Donnell, Mary Mary Jane Digitally signed by O'Donnell, Jane Date: 2024.12.10 16:54:35 -05'00' D : KZ D t Z ^Z /Z ZZ d Z & h Z Z Z ZZ Z Z W Z Z Z Z Z Z Z ZZ Z Z W Z ZZ Z d Z Z ZZ Z ZZ Z Z d Z Z Z Z Z Z Z Z EZ Z W Z Z Z Z Z Z Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 RCRA HAZARDOUS WASTE INSPECTION REPORT I. GENERAL INFORMATION a. Facility Name: Naval Submarine Base New London (the "facility") b. Inspection Dates: September 25 - 26, 2024 c. Inspection Type: RCRA Compliance Evaluation Inspection (CEI) d. EPA Inspectors: Bryan Gonzalez, Biologist, EPA Headquarters Justin Young, Physical Scientist, EPA Headquarters Adam Plourde, Physical Scientist, EPA Region 1 Hardik Patel, Environmental Engineer, EPA Region 1 e. EPA ID Number: CT4170022020 f. NAICS: 928110 - National Security 336611 - Ship Building and Repairing g. Street Address: RTE 12 Crystal Lake Road, Groton, CT 06340 h. Mailing Address: P.O. Box 400, Pw Env HW Branch, Groton, CT 06349 i. Facility Contact(s): Brian Hendrickson, Hazardous Waste Media Manager Email: brian.g.hendrickson.civ@us.navy.mil j. Generator Status: Large Quantity Generator (LQG) Treatment, Storage, and Disposal (TSD) facility k. Date first notified as a generator (per RCRAInfo): 08/18/1980 l. Date of most recent notification in RCRAInfo: 03/01/2024 m. Current Property Owner: US Navy n. Current Operator: US Navy o. Wastes generated (per most recent RCRAInfo notifications): D001, D002, D003, D004, D005, D006, D007, D008, D009, D010, D011, D018, D019, D021, D022, D023, D025, D026, D027, D035, D039, D040, D043, F001, F002, F003, F005, P030, P042, P081, U002, U031, U044, U072, U075, U080, CR01, CR02, CR04, CR05 3 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 Report Attachments: ATTACHMENT 1 - Photo Log ATTACHMENT 2 - Map of Facility ATTACHMENT 3 - TSDF Inventory II. FACILITY DESCRIPTION The Naval Submarine Base New London is located on the Thames River in Groton, Connecticut. It is the oldest submarine base in the United States and has a robust history dating back over a century. Originally acquired by the U.S. Navy in 1868 as a coaling station for refueling ships, the site officially became a submarine base in 1915. The designation marked the Navy's recognition of submarines as a vital element of modern warfare, and it quickly transformed into a center for submarine activity. Today, Naval Submarine Base New London remains the primary east coast base for the U.S. Navy's submarine fleet. It houses a significant portion of the nation's nuclear-powered submarines and serves as the Navy's premier training location for new submarine crews. According to the facility's permit, Naval Submarine Base New London is a large quantity generator (LQG) of hazardous waste and a Treatment, Storage, and Disposal Facility (TSDF) for storage of hazardous waste (HW). The facility generates, treats, and stores waste, including, but not limited to ignitable solvents (D001), corrosives (D002), reactive (D003), toxicity characteristic waste (D004-D043), universal waste, precious metals, used oil and stateregulated wastes. III. INSPECTION OPENING CONFERENCE The facility was notified of the RCRA inspection on Thursday, September 19, 2024, via an email to Christopher Koproski, Installation Environmental Program Director. The inspection team arrived at the facility on Wednesday, September 25, 2024, at 08:00 AM. The EPA inspection team ("inspection team") consisted of Bryan Gonzalez (EPA HQ), Justin Young (EPA HQ), Adam Plourde (EPA Region 1), and Hardik Patel (EPA Region 1). The inspection team met with Brian Hendrickson, Hazardous Waste Branch Manager, at the Visitors Pass Office and was escorted to a conference room where Christopher Koproski was present and introduced himself to the inspection team. During the opening conference, facility staff and the inspection team members introduced themselves and signed in on the sign-in sheet provided by EPA. The inspection team then presented their EPA credentials. Inspector Gonzalez discussed inspection procedures, including the right to claim confidential business information (CBI) and the need to take photographs during the inspection. The inspection team provided an overview of the scope of the inspection 4 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 to the present personnel, including why the facility was selected for inspection. Inspector Gonzalez also let the facility know that a closing conference would be conducted at the end of the inspection to discuss any findings or areas of concern observed during the inspection. The following personnel were present for all or part of the opening conference: EPA: Bryan Gonzalez, Biologist, EPA Headquarters Justin Young, Physical Scientist, EPA Headquarters Adam Plourde, Physical Scientist, EPA Region 1 Hardik Patel, Environmental Engineer, EPA Region 1 The Facility: Brian Hendrickson, Hazardous Waste Media Manager Christopher Koproski, Installation Environmental Program Director Facility employees and EPA inspectors discussed the following information about the facility processes and operations during the opening conference and inspection walkthrough: Christopher Koproski has been in his current position for about 18 months but a total of twelve (12) years with the installation. Brian Hendrickson has spent thirteen (13) years in waste management but a total of fifteen (15) years with the installation. The base has many different buildings of which approximately thirty-eight (38) are related to the hazardous waste program. The facility operates one TSDF, thirteen (13) Central Accumulation Areas (CAAs), and sixty-five (65) Satellite Accumulation Areas (SAAs). There are more than 9,000 personnel on the facility. The base operates 24 hours a day, 7 days a week, but the TSDF operation hours are limited to 06:00 AM - 03:30 PM, Monday - Friday with no weekend operations. The inspection team inquired about the Facility's waste streams and waste production processes. The Facility relies on generator knowledge for the waste determinations. Wastes are generated at ship building locations, ship maintenance areas, auto hobby shop, hospitals, labs, powder coating shop, dental clinic, pharmacy, gas station, Navy exchange, veterinary office, indoor range, and armory. No wastes are stored in tanks. The facility does not conduct open burning/open detonation (OB/OD) activities. The facility does generate different types of mixed waste such as cadmium, chromium, and lead. There are no exempted wastes at this facility. Brian Hendrickson explained that there are three (3) processes for treatment of hazardous waste conducted at the TSDF: oil filter crushing, mercuric nitrate reclamation and aerosol can puncturing. Every waste profile is reviewed annually using generator knowledge. After the inspectors finished their interview, Christopher Koproski presented a safety briefing for the facility. The opening conference concluded at approximately 09:25 AM, and the team proceeded to the TSDF, building 562, to begin the inspection. At the TSDF, Brian Hendrickson provided the inspection team with a map of all facilities and locations where hazardous waste is stored (Attachment 2). The inspection team laid out a plan to see the several of the CAAs and SAAs after inspection of the TSDF was completed. Photos were allowed to be taken by the EPA 5 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 inspection team in accordance with security and safety requirements. Brian Hendrickson and David Carter, Lead Environmental Protection Specialist, accompanied the inspection team for the facility walkthrough portion of the inspection. IV. FACILITY TOUR The facility tour or walkthrough portion of the inspection began at approximately 09:35 AM on September 25, 2024. The following personnel were present for all or part of the tour: EPA: Bryan Gonzalez, Biologist, EPA Headquarters Justin Young, Physical Scientist, EPA Headquarters Adam Plourde, Physical Scientist, EPA Region 1 Hardik Patel, Environmental Engineer, EPA Region 1 The Facility: Brian Hendrickson, Hazardous Waste Media Manager David Carter, Lead Environmental Protection Specialist Inspector Gonzalez took photographs to document the inspection observations which are included in Attachment 1. DAY - 1, September 25, 2024 Building - 562: TSDF The building has an office space for administrative work and recordkeeping pertaining to the hazardous waste program. The building also contains a staging area, process room, 9 (nine) bays with roll up doors and blind sumps. Each bay was designated for a particular type of waste: acid; reactive; oxidizer; ignitable; universal; alkaline; 2 (two) bays for toxic; and state-regulated waste. The staging area is where waste is received and recorded into the Chemical Safety Environmental Management System (CM-EMS). Cory Cavanaugh, Environmental Protection Specialist, coordinates with David Carter to unload, stamp and weigh the received waste. The waste information is recorded on the facility's internal 1348 form. From here the waste is moved into one of the bays based on its waste profile designation. The Process Room is the location in which three types of treatment of hazardous waste occurs: 1. Oil Filter Crushing - A process used to reduce the size and volume of used oil filters which are classified as hazardous waste due to the residual oil they contain. The process extracts the remaining oil for proper recycling and disposal. There was oil waste stored in a 5-gallon container and crushed filters stored in a 55-gallon container in the area at 6 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 the time of the inspection. All containers were closed and labeled as state- regulated waste. 2. Mercuric Nitrate Reclamation - A process of recovering and reusing mercuric nitrate. A chemical and/or physical process is used to isolate the mercuric nitrate from other components. The waste mercuric nitrate solution passes by tubing through three (3) filters and into a 5-gallon waste container. Brian Hendrickson explained to the inspection team that all filters are disposed of as non-HW, and the liquid waste is disposed of as state-regulated waste. The tubing also gets managed as HW when changed. Daily inspections are done on the mercuric nitrate filters. Containers all had labels on them and were covered. 3. Aerosol Can Puncturing - A process used to manage and dispose of aerosol cans which are considered hazardous waste when not completely emptied. Brian Hendrickson explained that the process involves puncturing the cans to release any remaining contents and propellants making the cans easier to recycle as scrap metal. A 55-gallon drum is being used to store the aerosol residuals, labeled as HW liquid/flammable. A 55gallon plastic drum is used to store empty/punctured aerosol cans, labeled "empty aerosol cans". The inspection team then proceeded into a passageway with nine (9) individual bays, four (4) bays on each side of the passageway and one (1) at the end. Each of the nine (9) bays were designated for storage of a specified category of waste. Each bay had a rollup door, and a "blind sump", a trench in the floor designed to capture and hold spilled materials. The blind sump was covered by grating and had no valves, piping, or other outlet device. The inspection team proceeded to inspect all bays and document their contents. A current inventory list of all the stored waste to date was provided to the inspectors for reference (Attachment 3). All contents on inventory sheet matched what was observed by the inspectors. Universal Waste Bay - Contained one (1) 3-gallon box labeled Universal Waste (UW) Waste Lamps Fluorescent, four (4) 4 ft. lamp tube containers labeled waste lamps, two (2) 55-gallon drums labeled waste alkaline batteries dry, two buckets (5-gallon, 3-gallon) labeled waste batteries dry Nicad. All boxes and containers were against each wall, closed, and with the label visible. Alkaline Bay - Contained six (6) 3-gallon buckets labeled monoethanolamine and water, on one pallet, three (3) 55-gallon plastic drums each labeled Monoethanolamine and water, Ammonium hydroxide/zinc oxide, bulked alkaline waste. All drums were on a plastic pallet in the middle of the room. One (1) cubic yard box labeled HW bulked alkaline waste. One (1) corrosive locker that was closed, contained 50+ quart size bottles all labeled amonium oxide, zinc oxide, bottles all closed. All boxes and containers were closed inside the bay. 7 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 Toxics II Bay - Contained one (1) 55-gallon drum, closed, labeled HW SHT tiles (lead) and one (1) cubic yard box, closed, labeled HW SHT tiles (Lead). Both containers were on pallets in the middle of the room and in good condition. Toxics I Bay - Contained two (2) 55-gallon drums, closed, labeled Lead dust debris (Lead), One (1) 55-gallon drum, closed, labeled Weapons ranch maintenance debris (lead); one (1) 1.5-gallon recyclable waste box labeled Nicotine containing products; one (1) 55-gallon drum, closed, labeled HW Waste fluorescent lamps (broken)(mercury). Connecticut Regulated/PCB Waste Bay - Contained four (4) 55-gallon drums, closed, on a pallet stacked on top of another four (4) 55-gallon drums, closed, on a pallet each labeled used oil, ozzy juice/dirt, cleaner lubricants, and preservative debris. The four (4) bottom 55-gallon drums were labeled sand, water, trace metals, epoxy, teflon from water jet cutter (liquid); Eleven (11) 55-gallon drums labeled sand/water; eight (8) 55gallon drums, closed, labeled used oil; one (1) 55-gallon drum, closed, labeled Lithium hydroxide canisters, blankets, pillows; One (1) 55-gallon drum, closed, labeled monitoring well purge water; one (1) 1 cubic yard box, lined and closed, labeled waste latex paint; one (1) cubic yard box, lined and closed, labeled liquid medical/dental/pharmaceutical; one (1) cubic yard box, lined and closed, labeled filters from abrasive blasting booths; one (1) tote, closed and on containment, labeled bulked CR04 waste. All containers were in good condition and labeled properly. Flammable Bay - Contained one (1) 55-gallon drum, closed, labeled flammable and nonregulated aerosols; one (1) 55-gallon drum, closed, labeled NEX consumer cosmetics; one (1) 55-gallon drum, closed, labeled adhesive waste; one (1) 55-gallon drum, closed, labeled alcohol waste; one (1) 55-gallon drum, closed, labeled NEX cosmetics; one (1) 55-gallon drum, closed, labeled aerosol residuals; one (1) 10-gallon bucket labeled paint waste; two (2) 55-gallon drums, closed, labeled gasoline/oil/water. All containers were stored on pallets, in good condition and with sufficient spacing between them. Oxidizer Bay - Contained two (2) 3-gallon containers, closed, labeled silver nitrate waste; one (1) seven-gallon container, closed, labeled hydrogen peroxide; one (1) 5gallon bucket, closed, labeled bulked nitric acid; one (1) 7-gallon bucket, closed, labeled inorganic solid oxidizers; one (1) 1-gallon bucket, closed, labeled double junction inner solution; four (4) 1 cubic yard boxes , closed, labeled oxygen candles. Cubic yard boxes were stored in a line on pallets but there was no space in between each one for aisle space. Reactive Bay - Contained one (1) 30-gallon plastic drum, closed, labeled UW batteries (Li); four (4) 55-gallon drums, closed, labeled vermiculite; one (1) 1-gallon bucket stored in locker, closed, labeled Li batteries. Back of room also contained a pallet of new cubic yard boxes. 8 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 Acid Bay - Contained a pallet of lead acid batteries with only large batteries having a label on them; one (1) 7-gallon bucket, closed, labeled HW inorganic acid; one (1) 3gallon container, closed, labeled HW silica standard from water testing with no date; two (2) 3-gallon buckets, closed, labeled HW hydrochloric acid and HW fuji capsule. Warning signs were posted throughout the TSDF, and emergency pull stations were in accessible areas. A fire suppression system was installed, along with an emergency eye wash station. Evacuation routes were posted throughout the facility and inspections logs were kept in a binder. Building - 1: Site - A13, Port Services Waste stored in this location primarily comes from boats. Site contained one (1) 2-gallon pail, one (1) 7-gallon pail, one (1) bag (triple bagged) of state-regulated waste consisting of oily rags, and one (1) 55-gallon drum of used oil. All waste was stored on secondary containment pallets. CAA signage was hanging from the ceiling, Brian Hendrickson mentioned it was because the sign kept falling off the wall. Spill kit was present and complete. A binder was present and contained training slides, weekly inspections, and training certificates. Building - 38: Site - A02, Carpenter Shop This location is managed by Gavin Richardson. No smoking and CAA signage were present. Site was a metal pod and contained three (3) bags of boat tiles labeled state-regulated waste; eight (8) bags of sealants labeled state-regulated waste; one (1) empty 55-gallon drum; one (1) 55gallon drum labeled caulks, adhesives, and glue; one (1) bag of gloves labeled chromium gloves; and two (2) 1-litre universal waste containers for batteries. A binder was available and contained training slides, weekly inspections, and training certificates. A spill kit was also present and appeared to be complete. Building - 38: Site - TSPR, Spruce Barge This site was a metal pod directly adjacent to Site - A02, Carpenter Shop. The CAA contained two (2) 55-gallon drums with used painting brushes, rollers, and trays. labeled state-regulated waste. CAA and no smoking signage present. A binder was available and contained training slides, weekly inspections, and training certificates. A spill kit was present and appeared to be complete but did not have a cover on it. Pier - 13: Site - TAPN, Portsmouth Richard Bergeron and Camille St. Hilaire are the point of contact (POC's) for this site and were present. Richard explained that waste stored here consists of paint waste, SHT tile, rags, brushes, rollers, trays, gloves, respirators cartridges, Tyvek suits, used oil, grease light bulbs, 9 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 aerosols and batteries that come off boats. There was no hazardous waste at this location at the time of the inspection. CAA and no smoking signage were present. A binder was available and contained training slides, weekly inspections logs, and training certificates. Site also had a fire extinguisher present. In addition, a spill kit was present and appeared to be complete. Building - 174: Site - A44, R6 99C/E Powder Coat The site contained one (1) 55-gallon drum containing IPA/Mineral Spirit Rags, one (1) stateregulated waste 55-gallon drum containing solid paint waste (non-PCB), one (1) state-regulated waste 55-gallon drum containing solid paint debris, one (1) 1-gallon universal waste pail containing manganese dioxide batteries, one (1) 3-gallon pail containing respirator cartridges, one (1) 1-gallon pail containing plastisol stripped waste. CAA and no smoking signage were present. A binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher present. Spill kit was present and appeared to be complete. Building - 174: Site - S83, R6 99C/E Powder Coat This SAA site was located at the same building as Site - A44, but outside. This site had two (2) 55-gallon drums that were labeled as solid paint debris from blasting. A binder was available and contained training slides, weekly inspections logs, waste profiles and training certificates. SAA signage was present. Building - 174: Site - S81, R6 99C/E Powder Coat This SAA site was located at the same building as Site - A44 but was inside next to the paint ovens. The site had one (1) 55-gallon drums that contained powder paint waste. A binder was available and contained training slides, weekly inspections logs, waste profiles and training certificates. SAA signage was present. Building - 175: Site - A38, FSG This site was used for waste from maintenance of buildings (lightbulbs, oily rags, batteries). The site was empty when inspected. CAA and no smoking signage were present. Binder was available and contained training slides, weekly inspections logs, and training certificates. Additionally, site had a fire extinguisher present. Spill kit was present and appeared to be complete. Building - 83: Site - A04, Outside Machine Shop The site contained one (1) 5-gallon bucket labeled HW de-stainer/parts washer. A spill kit was present but was stored inside a plastic tub with no cover. CAA signage was present, no smoking 10 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 sign was present but severely faded. A binder was available and contained training slides, weekly inspections logs, and training certificates. This site also had a fire extinguisher present. Building - 456: Site - A19, R4 Electrical Division The site was empty when inspected. CAA signage was present, no smoking sign was on the ground. Brian Hendrickson reattached the sign during inspection. A binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher present. Building - 478: Site - S45, Hull Division The site contained one (1) 3-gallon universal waste pail labeled Li batteries, one (1) 2-gallon universal waste pail labeled alkaline batteries, one (1) 3-gallon universal waste pail labeled NiCd battery, one (1) 3-gallon pail labeled fluorescent bulbs mercury, one (1) 3-gallon stateregulated waste pail labeled greasy/oily rags, one (1) 30-gallon drum labeled hazardous waste adhesive debris (MEK) Toxic, one (1) 10-gallon drum state-regulated rags, one (1) 55-gallon drum with HW labeled leather rags/gloves (chromium toxic), one (1) 55-gallon drum stateregulated waste respirator cartridges. All drums were closed and labeled. A binder was available and contained training slides, weekly inspections logs, and training certificates. Site had a fire extinguisher present. SAA and no smoking signage were present. EPA inspector Justin Young questioned if the site was near or at the point of generation for some of the waste stored here; David Carter stated he would find out more about information on this. Building - 612: Site - A42, Small Arms Range This site was inside an indoor shooting range. The site contained one (1) 55-gallon drum labeled hazardous waste lead dust debris (toxic). A binder was available and contained training slides, weekly inspections logs, waste profiles and training certificates. CAA and no smoking signage were present. The site had a fire extinguisher present. Building - 612: Site - S125, Firing Range (Hopper) This site was located outside and behind the site - A42, Small Arms Range. The site contained one (1) 55-gallon drum labeled HW lead dust debris, one (1) 55-gallon drum labeled scrap metal for recycling. All drums were closed and labeled. A binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher and the presence of spill kit. SAA and no smoking signage were present. Building - 325: Site - A18, Weapons 91E This site contained two (2) bags of state-regulated waste labeled rags/wipes, one (1) bag labeled hazardous waste spent aerosol paint cans. A binder was available and contained 11 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher and spill kit at the time of the inspection. CAA and no smoking signage were present. The inspection team proceeded to the vehicle maintenance area of Building - 325. Inspector Gonzalez noticed used rags with unknown residue on them inside one of the trash bins. The inspection team also observed a puddle of oily fluid on the floor underneath one of the vehicles. Brian Hendrickson explained that the maintenance of the vehicles is performed by contractors. No secondary containment was present in the building where the vehicles were being worked. Photos were taken of the oily fluid on the ground and the rags inside of the trash can (Attachment 1, Photo 26 and 27). The inspection team concluded the walkthrough portion of the inspection for the first day at approximately 04:15 PM. DAY - 2, September 26, 2024 Building - 451: Site - A40, PWD Shop This site contained one (1) 55-gallon drum labeled universal waste lead acid batteries, one (1) 55-gallon drum labeled state-regulated waste non-PCD light ballast, one (1) 55-gallon drum labeled state-regulated waste fluorescent light bulbs (PCB), two (2) boxes of mercury lamps and LED lamps, one (1) 3-gallon pail with Ni-Cd batteries, one (1) 1-gallon pail with lithium batteries, two tube boxes with mercury and LED lamps. CAA and no smoking signage were present. Binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher present. Spill kit was present and appeared to be complete. Building - 449: Site - S131, Pharmacy The inspection team met with Ann Ricca, the safety coordinator at the Navy Health Clinic. This site contained expired or almost expired medication. Waste observed included: one (1) 1-litre bottle labeled hazardous waste, waste containing nitro reaction, one (1) 1-litre bottle labeled hazardous waste pharmaceutical debris, one (1) 2-gallon pail labeled state- regulated waste with waste code CR05 pharmaceutical waste, one (1) 2-gallon pail labeled state-regulated waste with waste code CR04 pharmaceutical waste, one (1) 3-gallon pail labeled flammable pharmaceutical, one (1) 3-gallon pail labeled bulk chemo drugs (flammable), one (1) 3-gallon pail labeled regulated aerosol (flammable), one (1) 3-gallon pail labeled D004-0043 (toxic) pharmaceutical. SAA and no smoking signage were present. A binder was available and contained training slides, weekly inspections logs, and training certificates. Spill kit was present and appeared to be complete. POC for this SAA no longer worked for the base and was still identified as the POC on the sign posted in the area. Building - 449: Site - S133, Laboratory 12 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 This site contained one (1) 1-gallon pail labeled state-regulated waste heel warmers, one (1) 100-ml container labeled spent slide stainer. A binder was available and contained training slides, weekly inspections logs, and training certificates. A spill kit was present and appeared to be complete. Building - S75: Site - S138, RI Orthopedics The site contained one (1) 2-litre container labeled state-regulated waste liquid plaster trap. Binder was available and contained training slides, weekly inspections logs, and training certificates. A spill kit was present and appeared to be complete. Building - 449: Site - A17, Naval Branch Health Clinic The site contained one (1) 10-gallon container labeled Dorl (flam) medical waste, one (1) 2gallon pail labeled universal waste batteries, one (1) 55-gallon container labeled stateregulated waste bulked med/dental waste, one (1) plastic bag with a spent aerosol can (lysol disinfectant), and one (1) fluorescent lamp box labeled universal waste. A binder was available and contained training slides, weekly inspections logs, and training certificates. A spill kit was present and appeared to be complete. Building - 575: Site - S108, Dental Clinic This site contained one (1) 1-gallon pail labeled hazardous waste dental amalgam for recycling toxic (mercury). A binder was available and contained training slides, weekly inspections logs, and training certificates. A spill kit was present and appeared to be complete. Building - 574: Site - S96, Coastal Riverine Co This site receives waste from boat and truck maintenance. Site has a self-contained sewer with an oil-water separator. State-regulated waste consisted of one (1) 55-gallon drum of diesel fuel, one (1) 5-gallon pail of rags, one (1) 5-gallon pail of used oil, one (1) 55-gallon drum of used oil. Hazardous waste consisted of one (1) 5-gallon pail of spent aerosols, and one (1) 55-gallon drum of grease and oil rags. EPA inspector Bryan Gonzalez observed a bin that contained mixed used chemical containers and spent rags near one of the storage racks in the building. The hazardous waste coordinator of this site immediately moved the contents of the bin to the SAA for disposal. A binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher and spill kit present. SAA and no smoking signage were present. Building - 535: Site - S75, Marina Waste here is generated from the boats at the marina. The site contained one (1) 55-gallon drum labeled state-regulated waste greasy/oily rags, one (1) 55-gallon drum labeled HW 13 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 gasoline/oil, one (1) 2-gallon pail labeled state-regulated waste antifreeze, one (1) 20-gallon red can with the word "rags" written on it. A binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher and spill kit present. SAA and no smoking signage were present. The inspection team walked down to the marina and observed a spill kit by the dock that was filled with water due to a crack on the top lid. Brian Hendrickson mentioned that the spill kit was not part of the SAA and did not know where it came from. While walking out on the marina dock the inspection team observed a bucket with used rags inside that was not labeled. The marina hazardous waste coordinator did not know where the bucket or its contents came from. Building - 176: Site - S71, Weapons Ranch This site contained one (1) 55-gallon container labeled weapons ranch maintenance debris (lead), one (1) 3-gallon pail labeled state-regulated waste rags for laundering, one (1) 3-gallon container labeled state-regulated waste used oil for recycling. A binder was available and contained training slides, weekly inspections logs, and training certificates. The site had a fire extinguisher and spill kit present. SAA and no smoking signage were present. At 11:00 AM, the inspection team concluded the walkthrough portion of the inspection and returned to the conference room at the TSDF, Building - 562 for the records review portion of the inspection. V. RECORDS REVIEW Contingency Plan and Quick Reference Guide The inspection team reviewed the contingency plan and quick reference guide for the facility. The contingency plan included emergency evacuation routes, emergency response procedures, a phone number for the SUBASELON Regional Dispatch Center, and a list of emergency response equipment. The quick reference guide included the evacuation and emergency response procedures, a map showing where hazardous waste is generated and accumulated on site, and another map showing the facility in relation to surrounding businesses, schools, and residential areas. Lastly, the guide included the information of an onsite notification systems or alarms, and the name and telephone number for the emergency contact for the area. Inspector Patel noted that an update was needed for the emergency contact person. No primary or secondary coordinator was listed. Waste Shipments Manifests and Land Disposal Restrictions The inspection team reviewed a sample of hazardous waste manifests and land disposal restriction notifications from the date of the last inspection. The manifests were signed by Brian 14 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 Hendrickson, David Carter and Eugenie Kelly who all had received hazardous waste management training to sign manifests. When reviewing the manifests, the inspector observed the waste was shipped to the following TSDFs: - Heritage Environmental Services - Veolia ES Technical Solutions, AZ - Veolia ES Technical Solutions, IL - Ross Incineration Services - Veolia ES Technical Solutions, TX - Veolia ES Technical Solutions, WI - Clean Harbors El Dorado - Clean Earth of Calvert City - Soring Grove Resource Recovery - Clean Harbors Reidsville - Clean Earth of Alabama - Safety-Kleen Systems - Norfolk Naval Shipyard - Northland Environmental - Envirite of Pennsylvania - Tradebe T&R of Stoughton The inspector noted no issues with the manifests and land disposal restriction forms that were reviewed at the time of the inspection. Training Records Training records were reviewed for hazardous waste handlers who managed hazardous waste and those the inspection team met during the facility tour, as well as employees that signed hazardous waste manifests on behalf of the facility. The records reviewed during the inspection contained the topics for which the waste handlers are trained, a job description, and the initial and annual retraining certification dates. Based on a review of the training records, the inspectors observed that the waste handlers did receive annual training. Inspector Patel noted that Brian Hendrickson, David Carter, Eugenie Kelly, and Cory Cavanagh were missing training records for 2021. Brian Hendrickson explained that the reason for the lapse in training was due to Covid-19. Biennial Reports Inspector Gonzalez reviewed the facility's last two (2) Biennial Reports, 2021 and 2023. The facility reported as a LQG of hazardous waste. Waste codes reported by the facility were, but not limited to: D001 D002 D003 D004 D005 D006 D007 D008 D009 D010 D011 D018 D019 D021 15 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 D022 D023 D025 D026 D027 D035 D039 D040 D043 F001 F002 F003 F005 P030 P042 P081 U002 U031 U044 U072 U075 U080. Weekly Inspection Logs The inspection team reviewed weekly inspections logs for all SAAs, CAAs and permitted storage areas. More information about the weekly inspections can be found in Section IV of this report under the facility tour write up for each CAA and permitted storage area. The inspection team noted no issues with the weekly inspections. VI. INSPECTION CLOSING CONFERENCE A closing conference was conducted on September 26, 2024, at approximately 03:25 PM, prior to leaving the facility. The following personnel were present for the closing conference: EPA: Bryan Gonzalez, Biologist, EPA Headquarters Justin Young, Physical Scientist, EPA Headquarters Adam Plourde, Physical Scientist, EPA Region 1 Hardik Patel, Environmental Engineer, EPA Region 1 The Facility: Brian Hendrickson, Hazardous Waste Media Manager Christopher Koproski, Installation Environmental Program Director Dawn Works-Dennis, DPWO-PWD, David Carter, Lead Environmental Protection Specialist The inspection team ensured the facility personnel understood that the comments and observations made during the closing conference may not be all inclusive and that any preliminary observations discussed were not compliance determinations. All preliminary observations shared were subject to further investigation by EPA staff upon the additional review of records and documentations. The facility representatives were reminded that they could make claims of CBI on the material gathered during the inspection. No such CBI claims were made. Areas of Concern: The presentation of areas of concern does not constitute a formal compliance determination or violation. 1. Container in Building - 574 near Site - S96 had spent mixed products (bottles/rags) in it instead of being placed in SAA. 16 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 2. The unknown fluid spill under vehicle in Building - 325 in an area with no secondary containment. Trash can next to vehicle had spent rags inside with unknown substance on them. 3. One (1) 55-gallon used oil drum near Site - A13 did not have state-regulated waste label on it. 4. Building - 83: Site - A04, had "No Smoking" sign that was severely faded. 5. Building - 478: Site - S45, had a 30-gallon drum with MEK that was not at or near the point of generation. 6. Building - 456: Site - A19, had a "No Smoking" sign that had fallen and was on the ground. 7. The Contingency Plan did not have update regarding the emergency contact since 2022. 8. David C., Brian H., Cory C., Eugenie K., did not receive RCRA training in calendar year 2021 while the base was still operating and generating hazardous waste. 9. The dock across the Marina had a 5-gallon bucket that contained spent rags inside of it. No label was on the bucket and no lid. After discussing the above areas of concerns, the inspection team explained the next steps in the inspection process, which included the inspection team writing an inspection report and providing a copy to the facility within 70 days of the inspection. The inspection team thanked facility personnels' for their time and cooperation with the inspection activities and left the premises at 03:45 PM, concluding the on-site portion of the inspection. 17 Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 ATTACHMENT 1 Photo Log RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 Note: EPA inspectors were permitted to take photographs with their smartphone. DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 1 SITE LOCATION: TSDF - TSDF (B-562) Staging Area COMMENTS: View of loading bay at TSDF with hopper containing state regulated waste. DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 2 COMMENTS: View of staging area at the TSDF Building 562. SITE LOCATION: TSDF (B-562) Staging Area 1 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 3 COMMENTS: View of Oil Filter Crusher and 50gallon drum for storage of crushed filters. SITE LOCATION: TSDF (B-562) Process Room DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 4 COMMENTS: View of Mercuric Nitrate Reclamation area with 5-gallon waste container. SITE LOCATION: TSDF (B-562) Process Room 2 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 5 COMMENTS: View of Aerosol Can Puncturing area. 55-gallon drum used to store aerosol residual and plastic drum used to store empty/punctured aerosol cans. SITE LOCATION: TSDF (B-562) Process Room DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 6 COMMENTS: View of inside Universal Waste storage room. SITE LOCATION: TSDF (B-562) Universal Waste Bay 3 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 7 COMMENTS: View of inside Alkaline Waste storage room. SITE LOCATION: TSDF (B-562) Alkaline Waste Bay DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 8 COMMENTS: View of inside Toxic II storage room. SITE LOCATION: TSDF (B-562) Toxic II Bay 4 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 9 COMMENTS: View of inside Toxic I storage room. SITE LOCATION: TSDF (B-562) Toxic I Bay DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 10 COMMENTS: View of inside the PCB waste storage room facing right. SITE LOCATION: TSDF (B-562) PCB Waste Bay 5 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 11 COMMENTS: View of inside the PCB waste storage room facing left. SITE LOCATION: TSDF (B-562) PCB Waste Bay DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 12 COMMENTS: View of inside Flammable Waste storage room. SITE LOCATION: TSDF (B-562) Flammable Waste Bay 6 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 13 COMMENTS: View of inside the Oxidizer Waste storage room. SITE LOCATION: TSDF (B-562) Oxidizer Waste Bay DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 14 COMMENTS: View of inside the Reactive Waste storage room. SITE LOCATION: TSDF (B-562) Reactive Waste Bay 7 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 15 COMMENTS: View of inside the Acid Waste storage room. SITE LOCATION: TSDF (B-562) Acid Waste Bay DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 16 COMMENTS: Pallet of waste received during inspection of TSDF. Waste had come off a submarine. SITE LOCATION: TSDF (B-562) Staging Area 8 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 17 COMMENTS: View of inside CAA A13, Port Services. SITE LOCATION: A13, Port Services (B-1) DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 18 COMMENTS: View of inside CAA A02, Carpenter Shop. SITE LOCATION: A02, Carpenter Shop (B-38) 9 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 19 COMMENTS: View of inside CAA TSPR, Spruce Barge. SITE LOCATION: TSPR, Spruce Barge (B-38) DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 20 COMMENTS: View of CAA for the Powder Coating Building. SITE LOCATION: A44, Powdercoating (B-174) 10 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 21 COMMENTS: View of CAA R9 Outside Machine Shop. SITE LOCATION: A04, Outside Machine Shop DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 22 COMMENTS: View of SAA S45 Hull Division. Site will be converted to a CAA after review of process and point of generation. SITE LOCATION: S45, Hull Division (B-478) 11 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 23 COMMENTS: View of CAA Small Arms Range. Spent rag was observed on top of spill kit. SITE LOCATION: A42, Small Arms Range (B-612) DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 24 COMMENTS: View of SAA Firing Range located outside of building B-612 SITE LOCATION: S125, Firing Range (Hopper) 12 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 25 COMMENTS: View of inside CAA Weapons 91E. SITE LOCATION: A18, Weapons 91E (B-325) DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 26 COMMENTS: Spent rags with unknown solvent observed inside a mix garbage bag. SITE LOCATION: B-325 Vehicle Maintenance Area 13 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/25/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 27 COMMENTS: Oily residue dripping from vehicle parked in the Vehicle Maintenance Area. No drip pan being used. SITE LOCATION: B-325 Vehicle Maintenance Area DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 28 COMMENTS: View of inside CAA PWD Shop. SITE LOCATION: A40, PWD Shops (B-451) 14 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 29 COMMENTS: View of SAA at the Naval Health Clinic Pharmacy. SITE LOCATION: S131, Pharmacy (B-449) DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 30 COMMENTS: View of inside SAA A17 Naval Branch Health Clinic. SITE LOCATION: A17, Naval Branch Health Clinic (B-449) 15 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 31 COMMENTS: View of the SAA at the Naval Health Clinic Laboratory. SITE LOCATION: S133, Laboratory (B-449) DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 32 COMMENTS: View of the SAA at the Naval Health Clinic Orthopedics Area. SITE LOCATION: S138, Orthopedics (B-449) 16 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 33 COMMENTS: View of SAA at the Coastal Riverine Building. SITE LOCATION: S96, Coastal Riverine (B-574) DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 34 COMMENTS: View of bin containing spent rags and used chemicals outside of SAA area. SITE LOCATION: S96, Coastal Riverine (B-574) 17 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 35 COMMENTS: View of SAA at the Marina. SITE LOCATION: S75, Marina (B-535) DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 36 COMMENTS: View of outside SAA. Site is located across the street from the actual Marina. SITE LOCATION: S75, Marina (B-535) 18 Controlled by U.S. Environmental Protection Agency RCRA Subtitle C Inspection Report Naval Submarine Base New London CUI//PHYS CT4170022020 September 25-26, 2024 DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 37 COMMENTS: Spill kit located at the marina dock. Spill kil was in disrepair and had water inside due to a crack in the cover. All contents had water damage and were unusable. SITE LOCATION: S75, Marina (B-535) DATE TAKEN: 09/26/2024 TAKEN BY: Bryan Gonzalez PHOTO #: 38 COMMENTS: 5-gallon bucket observed on the dock at the marina. Contents were spent rags, lubricants, and trash. SITE LOCATION: S75, Marina (B-535) 19 Controlled by U.S. Environmental Protection Agency Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 ATTACHMENT 2 Map of Facility (b) (3) (B), (b) (7)(E), (b) (7)(F) Naval Submarine Base New London RTE 12 Crystal Lake Road, Groton, CT 06340 Inspection Dates: 09/25-26/2024 ATTACHMENT 3 TSDF Inventory