Document NGxyrZ3jDVD01NmVe3bZbD2VE

Section I - INTRODUCTION US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 2 PURPOSE OF THE INSPECTION EPA Region 6 inspectors David Robertson, and Joyce Johnson accompanied by NMED inspectors Jaime Rodriguez, Aaron Coffman, and Alex Mora arrived at the White Sands Missile Range for an unannounced inspection on May 19, 2018. The team met with and all of the DPW-ENV department (See Appendix 3). I, David Robertson, presented my credentials to the White Sands Missile Range representatives and informed them that this was an EPA lead joint inspection to determine compliance with the Resource Conservation and Recovery Act. The scope of the inspection was a compliance evaluation inspection (CEI). Due to security and safety protocols, White Sands Missile Range personnel took all photos and developed the photo log (Appendix 1) and no requested document copies were provided during the inspection. White Sands Missile Range sent copies of the documents after the inspection and after following their declassification protocol (Appendix 2). FACILITY DESCRIPTION White Sands Missile Range (WSMR) has been an active federal military installation since 1945. The facility covers over 3,200 square miles. The installation currently conducts missile testing and range recovery, provides the Army, Navy, Air Force and DoD with services for experimentation, testing, research, and training. Section II - OBSERVATIONS During site tours the EPA team was accompanied by Other personnel accompanied the NMED teams visiting satellite accumulation areas. Satellite Accumulation The inspection team observed 75% of all satellite accumulation areas, 155 in total. No areas of concern were observed satellite accumulation areas. Less Than 90 Day Storage Areas The inspection team observed the two less than 90-day storage areas for hazardous waste on the facility. Access to these areas were managed with locked fences. The units were marked with appropriate signage (Appendix 1, Photographs 5 and 11). 2 US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 3 Hazardous waste was accumulated in drums in the 10K less than 90-day storage area. A double row of drums was separated by an aisle space of approximately 10" (Appendix 1, Photographs 7-9). Movement of emergency equipment would require at least 36" of aisle space. While inspectors were present, the facility moved drums in order to create adequate aisle space (Appendix 1, Photograph 10; AOC Resolved 1). The inspection team observed the weekly inspection log for this less than 90-day storage area. The inspection log noted that there was adequate aisle space between containers at the unit. The inspection team suggested updated training for the unit manager that completed the inspection log. According to the unit manager received new training on adequate aisle space before the inspection team completed the inspection. Both less than 90-day accumulation areas were equipped with appropriate emergency communication equipment (cell phone and radio in the case of the 10k less than 90-day area). The units had emergency evacuation maps posted as required by Annex L of the Hazmat Incident Control Plan. Those evacuation maps included phone numbers for emergency responders (Appendix 1, Photograph 12). However, those phone numbers did not include area codes, which are required for non-local cell phones to call the number. Updated maps with area codes were posted with area codes during the inspection (AOC Resolved 2). Other than the missing area codes on the evacuation maps which were added during the inspection, no areas of concern were noted at the second less than 90-day storage area. On-site Generators Personal Protective Equipment (PPE) from Stallion Range PPE generated from sampling wastewater at the Stallion Range was observed at the hazardous waste storage facility. The spent PPE was managed as F003 and F005, listed hazardous waste. The waste profile, PW 17 271 02 (Appendix 2, pp 113-118) stated that the waste PPE was generated from sampling a septic system, however, facility personnel stated that the PPE was actually generated when sampling the wastewater lagoon. According to facility personnel, the F003 and F005 listing was applied because the laboratory results indicated the presence of acetone. Facility personnel also stated that acetone is a common laboratory contaminant. Following the inspection, the facility provided an email indicating that a review of operations at the Stallion Range determined that only domestic sewage is discharged to the lagoon and a new profile indicating that the spent PPE is non-regulated was generated (PW 18 106 02; not provided). (AOC Resolved 3) 3 US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 4 GTO Wash Rack Sump The facility operates a vehicle/equipment wash bay at Ground Target Operations (GTO). The spent water from the wash bay drains via a trough to an in ground sump (Appendix 1, Photographs 29-37). According to waste profile #MT 18 030 01 (Appendix 2 pp 134-137), the spent wastewater meets the listing F003 and exhibits the hazardous waste characteristics D006 and D008. The sludge removed from the unit, profile #MT 18 029 07, was found only to meet the F003 listing (Appendix 2 pp 138-159). Spent wastewater from the sump is pumped to an adjacent RCRA exempt wastewater reclamation unit. The initial sump managing the spent hazardous wastewater does not meet the requirements of a RCRA subpart J tank (no secondary containment, no spill and overfill protection, no engineering certification, etc.). The wastewater reclamation occurs in a RCRA exempt recycling unit. (AOC 1) Raytheon The inspection team toured Raytheon facilities supporting the Patriot and Hawk missile programs. Waste generation was not observed due to safety and security protocols, but several satellite accumulation areas were observed. No areas of concern were noted in these areas. Following the tour of the Raytheon facilities, the inspection team randomly requested a tour of several buildings that were observed from the road. The fenced area the team requested to tour included Building 21785, 21780, a "Hawk" trailer, two empty mobile sheds, and one building that was inaccessible. All but one of the identified buildings are managed by Raytheon. The remaining building was unavailable to tour because on-site personnel could not gain access and were unaware of who controlled access. The toured buildings housed electronic equipment related to the Hawk program (Appendix 1, Photographs 24-28). Outside the buildings, electronic equipment, including a cathode ray tube (CRT) computer monitor, was stored exposed to the elements (Appendix 1, Photograph 25). In addition, a CRT was observed and visually confirmed by in one labeled box indoors (Appendix 1, Photograph 27). The second labeled monitor box was not opened. Finally, spent fluorescent bulbs were observed in the Hawk trailer (Appendix 1, Photograph 28). According to Raytheon personnel, this material has not been on any inventory for over 20 years. This material is considered disposed by storage in lieu of disposal. The inspection team was unable to access the third building. Environmental Officer, stated that he had previously requested a tour of this building and could not determine who controlled access and was unable to gain access. Both the CRTs and the florescent bulbs are generally considered to be hazardous waste when disposed (AOC 2). 4 US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 5 On-Site Landfill During the inspection, the inspection team observed the Construction and Demolition landfill at the main post. During that tour, the team observed two lamps, one of which was mercury containing hazardous waste. Facility removed both lamps and moved them to their Universal Waste Storage area for management as Universal Waste. In addition to the spent bulbs, the team observed concrete lined steel piping of unknown previous use. Subsequent sampling indicated that the piping exhibited no characteristics of hazardous waste (Profile # 18 101 01). The facility has corrected all OBSERVED areas of concern at the landfill, however, the inspection team is concerned that previous disposal was unobserved during the inspection. It is requested that the facility review and update their inspection process prior to disposal in on-site landfills and train personnel empowered to send waste to the landfill to recognize potential hazardous waste. (AOC 3) Universal Waste White Sands Missile Range is a Large Quantity Handler of Universal Waste. Appropriately packaged, labeled and dated universal waste was observed in Building 1870B. In addition to the universal waste, WSMR had accumulated approximately 40,000 lbs. of spent lead acid batteries managed under 40 CFR Part 266 regarding recyclable materials. The batteries were managed in a manner designed to prevent discharges (Appendix 1, Photographs 13-14). The inspectors provided verbal guidance regarding the requirement for a waste determination and LDR notice when shipping batteries managed under part 266 off-site. In addition to the waste batteries managed under Part 266, the facility generates and accumulates waste batteries in multiple locations throughout the base. During the inspection, the team observed spent "core" lead acid batteries at GTO (Appendix 1, Photograph 18) and the Logistics Readiness Center Supply Support Activity area (Appendix 1, Photographs 15-17) the battery storage did not meet the requirements for storage of universal waste and the batteries previously shipped under this "core" program did not meet the standards for management of recyclable materials under part 266 (there was no LDR provided to the receiver). confirmed via email on 4/26/18 that there was no LDR notice sent to waste (core) battery receivers. The inspection team explained the three methods the facility could choose from to manage their waste batteries: universal waste, recyclable material under Part 266, or hazardous waste. (AOC 4) Manifesting Requirements The inspection team reviewed three years of manifests for wastes shipped from the facility and found two errors. First, manifest 010663500 FLE incorrectly listed the DOT proper shipping 5 US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 6 name as warfarin, however, profile # AAF1705901 (for that waste stream) indicated that the waste was actually nicotine and the proper shipping name is nicotine. The appropriate waste code, P075, was used on the manifest. Second, manifest 008734253FLE incorrectly listed that date of the waste offering (1/29/17) three days after the date of pickup by the transporter (1/26/17). (AOC 5) Section III - AREAS OF CONCERN NOTED AND RESOLVED DURING THE INSPECTION 1 40 CFR 262.34 (a)(4) [ref 265.35] - REQUIRED AISLE SPACE During the inspection, it was noted that drums marked "hazardous waste" were accumulated in the 10k less than 90-day storage area without adequate aisle space. Facility personnel moved drums creating adequate aisle space during the inspection resolving this AOC. 2 40 CFR 262.34 (a)(4) [ref 265.52] - CONTINGENCY PLAN During the inspection, it was noted that the posted evacuation plans did not include area codes with the emergency responder phone numbers as required by Annex L of the Hazmat Incident Control plan. The documents were updated and reposted during the inspection resolving this AOC. 3 40 CFR 270.1 - PERMIT REQUIRED The facility waste determination for spent PPE used in sampling wastewater from the Stallion influent to the sewage lagoon indicated that the PPE was contaminated with F003 and F005 hazardous waste from contact with the F003 and F005 containing waste in the lagoon. Disposal of F listed hazardous waste in a lagoon requires a RCRA permit for the operation of a surface impoundment. Following the inspection, the facility provided documentation indicating that there were no F listed solvents discharged into this sewer system. It was suggested that the facility review their waste determinations to ensure they are accurate. Section IV - AREAS OF CONCERN 1 40 CFR 270.1 - PERMIT REQUIRED 6 US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 7 The facility operates a vehicle/equipment wash bay at Ground Target Operations (GTO). The spent water from the wash bay drains via a trough to an in ground sump. The spent wastewater exhibits the hazardous waste characteristics of D006, D008, F003 and F005. Spent wastewater from the sump is pumped to a RCRA exempt wastewater reclamation unit. The initial sump managing the spent hazardous wastewater does not meet the requirements of a RCRA subpart J tank (no secondary containment, no spill and overfill protection, no engineering certification...). It was requested that the facility evaluate techniques to keep hazardous waste out of this unit or upgrade the unit to meet RCRA requirements. 2 40 CFR 270.1 - PERMIT REQUIRED DISPOSAL During the inspection, the inspection team randomly requested to tour one specific fenced area containing several buildings. The area included Building 21785, 21780, a "Hawk" trailer, two empty mobile sheds, and one building that was inaccessible. The identified buildings are managed by Raytheon. The buildings housed electronic equipment related to the Hawk program. In addition, electronic equipment, including a cathode ray tube (CRT), was stored outdoors. CRTs were observed in one labeled box indoors, in addition, spent fluorescent bulbs were observed in the Hawk trailer. According to Raytheon personnel, this material has not been on any inventory for over 20 years. This material is considered disposed by storage in lieu of disposal. It was requested that the facility evaluate all material storage on site to determine whether hazardous materials are being properly stored. 3 40 CFR 270.1 - PERMIT REQUIRED DISPOSAL During the inspection, the inspection team observed the Construction and Demolition landfill at the main post. During that tour, the team observed two lamps one of which was mercury containing hazardous waste. Facility removed both lamps and moved them to their Universal Waste Storage area for management as Universal Waste. In addition to the spent bulbs, the team observed concrete lined steel piping of unknown previous use. Subsequent sampling indicated that the piping exhibited no characteristics of hazardous waste. The facility has corrected all OBSERVED areas of concern at the landfill, however, the inspection team is concerned that previous disposal was unobserved during the inspection. It is requested that the facility review and update their inspection process prior to 7 US Department of the Army /White Sands Missile Range Inspection Date March 19-22, 2018 Page 8 disposal in on-site landfills and train personnel empowered to send waste to the landfill to recognize potential hazardous waste. 4 40 CFR 270.1 - PERMIT REQUIRED STORAGE During the inspection, the team observed spent "core" lead acid batteries at GTO and SSA the battery storage did not meet the requirements for storage of universal waste and the batteries previously shipped under this program did not meet the standards for management of recyclable materials under part 266 (there was no LDR provided to the receiver). It was suggested that the facility either manage their used batteries as universal waste or provide a LDR notice to the receiver. 5 40 CFR 262.20 (a)(1) - MANIFESTING REQIREMENTS During the inspection, it was noted that two manifests had errors: - Manifest 010663500 FLE incorrectly listed the DOT proper shipping name as warfarin, however, profile # AAF1705901 (for that waste stream) indicated that the waste was actually nicotine and the proper shipping name is nicotine. The appropriate waste code, P075, was used on the manifest. - Manifest 008734253FLE incorrectly listed that date of the waste offering was on 1/29/17, three days prior to the date of pickup by the transporter on 1/26/17. It was requested, that the facility review training on proper completion of manifests. 6 40 CFR 262.34 (ref 265.52 a-f) - CONTINGENCY PLAN The Contingency Plan was not updated when changes were made to the permitted storage facility or when the primary and alternate emergency coordinators were replaced, neither were position descriptions and training certification for the Emergency Coordinators available for the inspectors. Documentation to show communication and coordination between the facility and local emergency response teams that may be called upon to provide emergency services did not exist. Local authorities had not agreed to the facility's arrangements for emergencies. (One plan had not been revised since 2009.) The plan failed to list where emergency equipment is located and how to operate in the event of an emergency. 8 APPENDIX 1 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 1/54 Photo inside building 22903(A) Showing broken lithium ion batteries container 20180007 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 2/54 Photo showing Spill, Evacuation and Emergency Plan without Area codes on the Phone numbers 3/54 Photo of the inside of building 22905 (C) Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 4/54 Sign at the Hazardous Waste Storage Facility building 22895 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 5/54 Sign at the 10-K 90 day Hazardous Waste Accumulation Site Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 6/54 Spill, Evacuation and Emergency Plan at the 10-K 90 day Hazardous Waste Accumulation Site Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 7/54 Photo showing inadequate aisle space at the 10-K 90 day Hazardous Waste Accumulation Site close up Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 8/54 Photo showing inadequate aisle space at the 10-K 90 day Hazardous Waste Accumulation Site overall view Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 9/54 Photo showing inadequate aisle space at the 10-K 90 day Hazardous Waste Accumulation Site clipboard used for scale approximately 10 inches Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 10/54 Photo showing adequate aisle space after corrective action at the 10-K 90 day Hazardous Waste Accumulation Site 11/54 Sign at the Hazardous Waste Management Center 90 Day Accumulation Site Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 12/54 Spill, Evacuation and Emergency Plan at the Hazardous Waste Management Center 90 Day Accumulation Site showing missing area codes. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 13/54 Lead acid batteries managed under 40 CFR 266 part G at the Hazardous Waste Management Center showing neatly stacked and shrink wrapped batteries. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 14/54 Lead acid batteries managed under 40 CFR 266 part G at the Hazardous Waste Management Center showing labeling Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 15/54 Lead acid batteries turned in as cores at the Logistics Readiness Center Supply Support Activity. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 16/54 Lead acid batteries turned in as cores at the Logistics Readiness Center Supply Support Activity. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 17/54 Lead acid batteries turned in as cores at the Logistics Readiness Center Supply Support Activity. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 18/54 Lead acid batteries turned in as cores at the Materiel Test Directorate Ground Target Operations. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 19/54 Used mercury vapor lamp found at the main post construction and demolition landfill. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 20/54 Used mercury vapor lamp found at the main post construction and demolition landfill close up. 21/54 Light fixture of after the lamp had been removed for turn-in as universal waste. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 22/54 Used halogen lamp found at the main post construction and demolition landfill. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 23/54 Large pipe found at the main post construction and demolition landfill. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 24/54 Used electronics stored outside of building 21780 by Raytheon. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 25/54 Used cathode ray tube monitor stored outside of building 21780 by Raytheon. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 26/54 Used electronics stored outside of building 21780 by Raytheon distant photo. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 27/54 Used electronics stored inside of building 21785 by Raytheon. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 28/54 Used fluorescent lamps stored inside of the Hawk Trailer north of building 21785 by Raytheon. 29/54 Wash rack at Material Test Directorate bldg. 2780 looking east. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 30/54 Wash rack at Material Test Directorate bldg. 2780 drainage trough. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 31/54 Wash rack at Material Test Directorate bldg. 2780 oily water sump. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 32/54 Wash rack at Material Test Directorate bldg. 2780 cyclone filter. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 33/54 Wash rack at Material Test Directorate bldg. 2780 cyclone filter solids removal drain. 34/54 Wash rack at Material Test Directorate bldg. 2780 sock filter. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 35/54 Wash rack at Material Test Directorate bldg. 2780 main filtering unit and tank #2. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 36/54 Wash rack at Material Test Directorate bldg. 2780 water heating unit and tank #3. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 37/54 Wash rack at Material Test Directorate bldg. 2780 overall equipment view. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 38/54 Drum of soil cuttings investigation derived waste from Solid Waste Management Unit 79. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 39/59 Label on drum of soil cuttings investigation derived waste from Solid Waste Management Unit 79. 40/54 Drums of investigation derived waste from solid Waste Management Unit 62. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 41/54 Label on drum of PPE trash acetate sleeves investigation derived waste from Solid Waste Management Unit 62. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 42/54 Label on drum of soil cuttings investigation derived waste from Solid Waste Management Unit 62. 43/54 In-use lithium manganese dioxide batteries at building 1678. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 44/54 Radiographic Test Facility photo developer machine building 21127. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 1/xx Drum of processor wash water from old Photo developer machine building 21127. Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 46/54 Label on drum of processor wash water from old photo developer machine building 21127. 47/54 Satellite Accumulation Points at Building 21127 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 48/54 Satellite Accumulation Points at Building 21127 with containment open Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 49/54 Photo showing path from the dark room to the satellite accumulation points at building 21127 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 50/54 Photo showing path from the dark room to the satellite accumulation points at building 21127 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 51/54 Photo showing path from the dark room to the satellite accumulation points at building 21127 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 52/54 Photo showing path from the dark room to the satellite accumulation points at building 21127 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 53/54 Photo showing path from the dark room to the satellite accumulation points at building 21127 Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 54/54 Photo showing path from the dark room to the satellite accumulation points at building 21127 APPENDIX 2 Facility Nam.e Certification of the Applicability of Substantial Harm Criteria U.S. Army, White Sands Missile Range Facility Address US Highway 70 White Sands Missile Range, NM 88002-5000 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes _____ No ./ 2. Does the facility ave a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack seconda1y containment that is sufficiently large to contain the capacity of the largest aboveground storage tank plus sufficient freeboard to allow for precipitation within any aboveground storage tank area? Yes _____ No ./ 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? Yes _____ No ./ 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake? Yes ----- No --.-/ -- 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a rep01table spill in an amount greater than or equal to 10,000 gallons within the last five years. Yes _____ No --.-/ -- Ifa facility answers "Yes" to any of the above questions, the facility 11111st prepare a "Facility Response Plan" (FRP) according to 40 CFR 112.20. Certification I certify under penalty of law that I have personally examined and am familiar with the infmmation submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted info1mation is true, accurate and complete. Signature Name (ptint or type) c=>:-:-:_ Jose A. Gallegos Title Chief, Environmental Division Date 3 o c, -z.__o I z_ Approved for public release, limited distribution to EPA/NMED, OPSEC Reviewed 3 APR 2018 Certification of the Applicability of the Substantial Harm Criteria APPENDIX 3 Redacted