Document jBvBZMYj4RD669Mk8KjzGw4aZ
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
07/25-27/2017 RCRA Hazardous Waste
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
Little Rock Air Force Little Rock Air Force Base 1255 Vandenberg Jacksonville, AR 72076 1255 Vandenberg Jacksonville, AR 72076 Pulaski Elizabeth K. Gamber Elizabeth.gamber@us.af.mil
19 CES / CEIEC
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
AR6571824808
Personnel participating in inspection:
Angela Hays
USEPA
Enforcement Officer
Joyce Johnson
USEPA
Enforcement Officer
John Sykes
ADEQ
Enforcement Officer
Chris Schmidt Ronnie Lynn Shaw
LRAFB LRAFB
19 CES / Chief Environmental Compliance 19 CES/ CEIEC
Mike Ramsey
LRAFB
19 CES/CEI
John Gahr
LRAFB
19 CES
Betty Gamber
LRAFB
19 CES/ CEIEC
Robby Weng
LRAFB
189 MXS
Alfred Cotter
LRAFB
19 MXS
Daniel Gorman
LRAFB
AFRC/MXMX
Charels Fletcher
LRAFB
ARC CRF/MXMX
214-665-2285 214-665-8548 501-682-0834 501-987-7700 501-987-8135 501-987-7698 501-987-5277 501-987-6800 501-987-7484 501-987-8586 501-987-4646 501-987-2980
6ENFORM-019-R7 (2/15/2017)
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Air Force / Little Rock AFB Inspection Date 07/25-27/2017
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Section I - INTRODUCTION
Air Force / Little Rock AFB Inspection Date 07/25-27/2017
PURPOSE OF THE INSPECTION
On July 25, 2017, EPA Region 6 inspectors Angela Hays and Joyce Johnson, along with ADEQ inspector; John Sykes, arrived at Little Rock Air Force Base at 10:00 a.m. for an unannounced Compliance Evaluation Inspection (CEI). We met with Chris Schmidt, 19 CES / Chief Environmental Compliance; Ronnie Lynn Shaw, 19 CES / CEIEC; Mike Ramsey, 19 CES/ CE;, John Gahr, 19 CES; and Betty Gamber, 19 CES / CEIEC of Little Rock Air Force Base (LRAFB) to conduct the Opening Conference (Appendix 2). Joyce Johnson presented her credentials to Schmidt, Shaw, Ramsey, Ghar, and Gamber; and we informed them that we were there to conduct an EPA inspection to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA). Ms. Johnson also explained EPA's federal facilities program where 10 federal facilities are inspected each year and that LRAFB is one of the facilities selected for inspection as part of the program. The scope of the inspection is to evaluate compliance with the RCRA regulations for generators of hazardous waste.
Each day of the inspection was attended by the representatives in attendance at the opening meeting. We were also joined at different times by specific leads for the particular production areas in the facility. This inspection included: walkthroughs of the facility's operations and waste management areas; interviews with facility personnel; and collection and review of facility records. We concluded the inspection on July 27, 2017, with a closeout meeting that included a discussion of the preliminary areas of concern.
This report serves as documentation of the onsite activities and observations as they pertain to the RCRA CEI. Photographs taken during the inspection to document onsite observations are included as Appendix 1.
FACILITY DESCRIPTION
Little Rock Air Force Base (LRAFB) is, located at 1255 Vandenburg in Jacksonville, Arkansas, Pulaski County. LRAFB covers 6,412 acres including one runway and one assault landing strip. The base population accounts for more than 8,000 active-duty military, civilian and 5,300 family members. As well as service approximately 53,000 retirees who reside in the local area. The LRAFB offers a variety of amenities, such as shops, recreation areas, schools, and emergency facilities (Appendix 3). Little Rock Air Force Base's total impact on the local economy in fiscal year 2015 totaled $511 million. It is the fourth-largest employer in Arkansas and created 2,835 indirect jobs in fiscal year 2015.
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LRAFB opened in October 1955 and is now home base to more than 70 C-130 H and J models. The base's host unit is the 19th Airlift Wing, in combination with the 314th Airlift Wing, 189th Airlift Wing, 913th Airlift Group and U.S. Air Force Mobility Weapons School.
The 19th Airlift Wing flies the world's largest fleet of C-130 aircraft and is responsible for providing worldwide deployable C-130 aircraft, aircrews, support personnel and equipment for Air Mobility Command and Air Expeditionary Force tasking including supplying humanitarian airlift relief to victims of disasters to airdropping supplies and troops into operation areas.
LRAFB registered as a Large Quantity Generator (LQG) of hazardous waste in 1992. The most recent notification listed hazardous waste codes D001, D002, D003, D005, D006, D007, D008, D009, D010, D011, D018, D035, D039, D040, F003, F035, P001, P075, and P081. The facility is also a Large Quantity Handler of Universal Waste accumulating - managing batteries and lamps.
Section II - OBSERVATIONS
This section documents the factual observations we made during this inspection and includes reference to photographs taken during the inspection (Appendix 1); descriptions of the satellite accumulation areas and waste storage areas; as well as the documents we reviewed and collected during the inspection.
During the inspection Ms. Johnson, Mr. Sykes, and Angela Hays, were escorted by Mr. Shaw and provided with a document titled "Satellite Accumulation Point (SAP's) by Shop Report" (Appendix 4). The report is a list of the facilities Satellite Accumulations Areas (SAA) and 90-day storage areas. The facility refers to SAA's as SAP's. The following write-ups use the waste stream and building numbers listed on the SAP's by shop report, to describe our observations during the inspection.
Building Number 1582 - 90 Day Storage Building number 1582 is one of the 90-day storage areas (photo # 399). The building has a concrete floor with a shelfing lining the walls. According to Mr. Shaw, the facility had recently shipped out all wastes (photo 403). The wastes stored in the unit at the time of inspection consisted of two cardboard boxes (photos 400 and 402) and two 55-gallon drums (photos 401, and 406). During the inspection Ms. Johnson, Ms. Hays, and Mr. Sykes, noticed liquid on the ground and inquired about what it consisted of and where it had originated. Mr. Shaw explained that it was run on from rain water (photos 404 and 405).
Building Number 1570 - Satellite Accumulation Area Building number 1570 is utilized for universal waste and "free issue" accumulation. The building was split into three rooms. The first room contained a "Free-Issue" area. This consisted of open products available for the base residents to use as needed. This area consists of items such as paint, paint thinner, pesticide, and adhesives (photos 417 and 418). The room also contained a 55-gallon drum for broken
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mercury lamps (photo 408 and 409), a covered 5-gallon bucket for NI-CAD batteries (photo 410, 411), a collection container for lithium batteries (photo 412 and 413), and a collection area for mercury thermostats (photos 414 and 415).
Ms. Johnson stepped into the second room where she observed several open boxes of lamps without operator present. Ms. Johnson retrieved Ms. Hays from room 1, and upon re-entry to the second room together an operator was present. The operator stated that he was consolidating the boxes of mercury lamps and that the boxes are not typically open (photo 407).
Building Number 213 - Satellite Accumulation Area Building number 213 is the sheet metal shop. This building generates waste stream LRK-SAP-043 (D006, D007) (Appendix 4) (Appendix 9, spent bead blast media (photo 422). The building contained a satellite accumulation area with 55-gallon drum containing spent blast media, labeled and marked with the hazardous waste codes D006 and D007 (photo 423). There were no other wastes present at the time of inspection in building 213. According to the SAP's by Shop Report, this building also generates waste streams LRK-WSN-40 (D001, D007, D035), LRK-WSN-41 (D007), LRK-WSN-42 (D006, D007, F005), LRKWSN-52 (D007, F005), LRK-WSN-69 (D001, D007, D035), and LRK-WSN-70 (D007) (Appendix 4).
Mr. Schmitt and Mr. Shaw explained that the bead blast is considered spent when it is too small for use as blasting material. The spent material is characterized as hazardous; exhibiting the characteristics of toxicity for cadmium and chromium (D006 and D007). After the spent material is collected it is shipped to US Technology Media Inc. for reuse / recycling. Ms. Hays requested further documentation of how the material is recycled and how the recycled material is utilized. The facility was able to produce the Lease and Recycle Program Overview of US Technology Media Inc.'s recycling process (Appendix 7). US Technology Media Inc. states that the recycle program utilizes the spent blast media in concrete block production. The facility was unable to provide documentation of how the blocks are used once produced.
Mr. Sykes produced a letter dated August 04, 2006. from Arkansas Department of Environmental Quality (ADEQ) to US Technology Corporation for the approval of Confirmation of Environmental Exemption Status for Spent Blast Media.
Building Number 207 - Satellite Accumulation Area Building number 207 is the Survival Equipment and Sortie Support building. The posted waste streams on the wall, are for LRK-SAP-042 (D006), LRK-SAP-069 (D001, D007, D035), and LRK-SAP-070 (D006, D007) (photo 424). An area within the building has a pallet with three 55-gallon drums, one for each of these waste streams collected (photo 425, 426, 427). One of the 55-gallon drums for collection was labeled with the waste profile number LRK-PRF-040 but this was crossed out and waste profile number LRK-PRF-069 (D001, D007, D035) was written (photo 425). Another 55-gallon drums labeled with the
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waste profile LRK-PRF-070 (D007) has a written note for building 207 (photo 427). The building wall does reflect that these waste streams are being generated in building 207 but according to the SAP's by shop report, LRK-PRF-070 is a waste that is generated in building 213 (Appendix 4).
The building also had a metal trash can with lid for empty aerosol can collection. The lid on the container has a 2-inch hole cut into the top (photo 428). It was not observed if the aerosol cans were punctured or not during the inspection. Non-punctured aerosol cans are generally considered D001 or D003 or both and collected in a labeled container with a lid.
Building Number 205 - Satellite Accumulation Area Building number 205 house, the paint booth. The building is not documented on the SAP's by Shop Report. The building has SAP# 040 (D001, D007, D035), SAP# 041 (D006, D007) and SAP# 052 (D006, F005) posted on the wall (photos 429, 430).
Building Number 356- Satellite Accumulation Area Building number 356 is the Contract Engine Shop / CRF. This building contained one large and two small parts washers as well as a "burrito machine" for wrapping waste. The large parts washer is closed loop (photo 435, 440) with sludge drainage into an open side bin (photo 432, 433, 434). Fluid from the small parts washers is accumulated in a 55-gallon drum (photo 441, 447). The sludge is collected in a 55-gallon drum and labeled as hazardous waste (photo 434, 440, 442, 444, 445, 446). The filters from the parts washers are wrapped in the "burrito machine" (photo 436) and collected in a 55-gallon drum, with waste profile number LRK-PRF-008 (D006) (Appendix 10) (photo 443, 444). Building 356 also has a fiber container with lid for adhesive / sealant (photo 437, 438).
Building Number 282 - Satellite Accumulation Area Building 282 is for Corrosion Control. The building houses blasting units used in order to strip paint from surfaces (photos 463 - 476). The waste streams in the drums are LRK-PRF-020 (D001, D07, D035), LRKPRF-062 (D007, D035), and LRK-PRF-030 (D007) (photo 453, 454, 455,456). There is no documentation of blast media waste from this building. The bead blast machine is housed in the building (photo 465, 466, 467) and the excess is collected under the bag house in a fenced area (photo 461, 462). Collection of the spent bead blast does not meet the requirements for SAA, due to the collection being out of control of the operator nor the requirements of a 90-day storage area due to not being dated or labeled. The wall posts purging procedures for the steel cabinet blaster (photo 468). Mr. Shaw was unable to answer how the filters for the bead blast unit are maintained (photo 477). Ms. Hays requested documentation of filter waste management. A small step can was observed at the entrance between the offices and shop of the bead blast area (photos 479 and 478). The can is for bootie collection as personnel exit the bead blast area. The can has a danger notice on the lid stating danger, contains cadmium, may cause cancer, cause damage to lungs and kidneys, avoid creating dust.
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Building Number 282 - 90 Day Storage Area Building 282 has an outdoor 90-day storage area for the Corrosion Control Accumulation Site. This the facility's second 90-day storage area. As stated before by Mr. Shaw, the facility had recently shipped all hazardous waste. During the inspection the facility had one 55-gallon drum labeled and one plastic bag (photo 448, 449, 450). This storage area is fenced in and on a concrete flooring (photo 451 and 452).
Building Number 1090- Satellite Accumulation Area Building 1090 is the Medical Clinic Pharmacy. This building consists of a main pharmacy and two laboratories. The facility had three closed lid containers for hazardous wastes D001, D002, P075, P081, P001, P042 (photos 479, 480, 481, 482). Only used medications are disposed of, unused medications are returned to Pharmalogistics. There was no waste in the containers during inspection. The facility does not do liquid chemotherapy treatment. A type of chemotherapy medication is given in tablet form only.
Building Number 232- Satellite Accumulation Area Building 232 is the Fuel Systems Repair. This building has an underground tank. The facility said the underground tank is empty and that it last held fire foam water. EPA requested documentation of waste determination and shipment of last clean out from Mr. Shaw. The building has three waste streams LRKPRF-18 (D001, D010, D035) (photo 459), LRK-PRF-38 (D006) (photo 458), and LRK-PRF-59 (D006, D003) (photo, 457, 460).
Document Review
The document review began on July 25, 2017. We reviewed a variety of documents to assess LRAFB compliance with RCRA LQG regulations. The documents reviewed were related to compliance with the RCRA regulations pertaining to Contingency Plans, emergency response procedures, training, record keeping requirements, waste determination and hazardous waste manifesting. The documents copied and received for review from LRAFB are listed below.
Waste manifests years 2014, 2015, 2016 and partial for 2017. Hazardous waste training certificates for Gamber, Shaw, Piacentini, Ghar, Henson, Graves,
Weng, Daniel. Johnson, Maguire, Barskile, Farppgi, Quade, Miller, Jones, Tingle, Hatton, Swister, Bickers, Stevens, Chisler, Hunter, Mattison, Mannion, Sauceda, Larocque, Kunckel, Chellberg,
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Reynolds, Digiovanni, Winston, Herrick, Matyiko, Wagers, Gorney, Gallardo, Babczak, Gross, Benton, Jordan, Dover, Price, McIntyre, Caravello, Pfleger, Jacob, Huggins, Jones, Miller, Harbor, Wilks, Styza, Bible, Martin, Daus,Casey and Bredwell List of SAP POC's and HAZMO inspection dates. Hazardous waste profiles - paper copies for buildings 205, 207, 213, 246, 250, 356 and complete list on two CD's HAZMO checklist from 5-12-2017 List of LRAFB hazardous waste medications and shipping labels Red Plan US Technology Media Inc. Lease &Recycle program Overview Map of Base SAP's by Shop Report LRAFB Introduction to RCRA hazardous waste training overview ADEQ letter of Recycling Exempt Status Confirmation Request ADEQ letter of Recycling Exempt Status Confirmation Approval Bill of Lading for Bead blast media from 11-12-15 to 5-10-2017 Analytical results on building 282 Bead blast purchase order LRAFB Bead blasting media & recycling services performance work statement Chain of command graph MART EQ Wastewater Processing System Operating Manual
Section III - AREAS OF CONCERN
Possible open and unlabeled container of non - punctured aerosol cans (photo 428). Updated contingency plan for Large Quantity Generator Requirements (Appendix 5).
-No documentation of emergency plan with local police and fire first responders or hospitals. - Outdated list of personnel - Does not include information of hazardous waste in 90-day storage area Shipping hazardous waste to unauthorized facility (Appendix 6). Not shipping hazardous waste on manifests. Spent bead blast not contained in SAA or 90-day storage (photos 461 and 462). No documentation of weekly inspections or details of inspections, for 90-day storage areas.
Section IV - FOLLOW UP Documents received by EPA from Mr. Schmidt after exiting the Facility on 7/27/2017,
E-mailed - request for 14-day extension for submitting documentation; received August 11,2017 at 2:40 p.m.
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Mailed - Underground storage tank wash out / pump/ disposal documents; received August 21, 2017 at 2:25 p.m.
Mailed - parts washer manuals Mailed - Bead blast filter replacement and disposal handling; received August 21, 2017 at 2:25
p.m. Mailed - record of movement and certificate of recycling from US Technologies for Bead Blast;
received August 21, 2017 at 2:25 p.m.
Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 82 photos, taken 7/25/2017 to 7/27/2017 Appendix 2 - Inspection Participants Sign in Sheet Appendix 3 - Little Rock Visitors Map Appendix 4 - SAP's by Shop Report Appendix 5 - Red Plan / Contingency Plan Appendix 6 - Bead Blasting Media & Recycling Services Performance Work Statement Appendix 7 - US Technology Media Inc. Lease &Recycle program Overview (CBI) Appendix 8 - Arkansas Department of Environmental Quality letter Appendix 9 - Hazardous waste profile sheet for LRK-PRF-043 (19 pages provided by LRAFB) Appendix 10 - Hazardous waste profile sheet for LRK-PRF-008 (15 pages provided by LRAFB)
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Appendix 1 Photo Log - 82 photos
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399 - HAZMO Building 90-day storage # 1582 - outside of building 11
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400 - Hazardous waste stored inside of building 1582
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401 - Hazardous waste stored inside of building 1582
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402 - Hazardous waste stored inside of building 1582
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403 - Hazardous waste stored inside of building 1582 and shelving unit
404 - Liquid on the ground inside building 1582 15
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405 - Liquid on the ground inside building 1582
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406 - Hazardous waste stored inside building 1582
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407 - Building 1570 - open boxes of lamps
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408 - Accumulation / Hazardous waste stream sign inside of building 1570
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409 - Hazardous waste drum of broke lamps in building 1570
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410 - Universal waste accumulation / waste stream sign for Ni- Cad batteries building 1570
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411 -Ni-Cad Battery container building 1570
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412- Universal waste accumulation sign for lithium batteries inside building 1570
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413 - Universal waste lithium battery container inside building 1570
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414 - Universal waste accumulation / waste stream for mercury thermostat sign inside building 1570
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415 - Container for mercury thermostats inside building 1570
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416 - Wide view of storage area for mercury thermostats, Ni- Cad batteries, and broken lamps inside building 1570
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417- Free issue area inside building 1570
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418 - Free issue area inside building 1570 29
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419 - Dented antifreeze drum with corrosion on the top building 1570
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420 - Dented antifreeze drum with corrosion on top building 1570 31
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421 -No lid on the aerosol can collection container with no label building 1570
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422 - Red plan and waste stream sign inside building inside building 213
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423 - Accumulation drum media vacuum inside building 213
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424 - Waste stream signs in building 207
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425 - Hazardous waste drums inside of building 207 - waste stream changed
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426 - Hazardous waste drum inside building 207
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427 - Hazardous waste drum inside building 207
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428 - Open aerosol Can collection inside building 207
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429 - Waste stream sign inside of building 205 40
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430- Waste stream sign inside of building 205 41
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431 - Drums inside of building 205 42
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432 - Sludge accumulation from parts washer in building 356
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433 - Sludge accumulation from parts washer in building 356
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434 - Satellite accumulation area and parts washer in building 356
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435- Parts washer in building 356
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436 - Burrito machine inside building 356
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437 - Paint waste in fiber container - building 356
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438 - Building 356 - fiber canister of paint waste
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439- Waste stream and accumulation area signs in building 356 50
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440 - Waste steam signs in building 356 51
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441- Hazardous waste accumulation drum in building 356
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442 - Hazardous waste drum inside of building 356
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443 - Hazardous waste drum inside of building 356
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444 - Satellite accumulation area in building 356
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445 - Sludge from small parts washer in building 356
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446- Sludge from small parts washer in building 356
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447 -small parts washer in building 356
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448- Hazardous waste in 90-day accumulation area outside building 282
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449 - Hazardous waste in 90 day accumulation area outside building 282
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450 - Hazardous waste in 90-day accumulation area outside building 282
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451 - Hazardous waste in 90-day accumulation area outside building 282
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452 - Hazardous waste in 90-day accumulation area outside building 282
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453 - Waste stream sign LRK-PRF-030 sign for SAA inside of building 282
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454 - Waste stream sign LRK-PRF-062 sign for SAA inside of building 282
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455- Waste stream sign LRK-PRF-020 sign for SAA inside of building 282
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456- Filter room for bead blast and SAA for building 282
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457 - SAA for waste stream LRK-PRF-059 in building 232
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458- SAA for waste stream LRK-PRF-038 in building 232
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459 - SAA for waste stream LRK-PRF-018 in building 232
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460- SAA in building 232
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461 - Outside collection of bead blast at building 282
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462 - Outside collection of bead blast at building 282
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463- Building 282 - Small blast units
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464 - Building 282 abrasive blast units
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465 - Building 282 blast units 76
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466 - Building 282 Sand blast unit 77
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467 - Glass media blast unit building 282 78
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468 - Purging procedures for steel cabinet blaster building 282 79
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469 - Plastic media blast machine building 282 80
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470 - Plastic media sign on blast unit building 282 81
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471 - Window on bead blast unit building 282 82
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472 - Window on bead blast unit building 282
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473 - Operation controls for walk in blaster building 282 84
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474 - Walk in blaster lines in building 282
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475 - Walk in blast unit building 282 86
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476 - Walk in blast unit building 282 87
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477 - Filters for walk in blast unit in building 282
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478 - PPE collection from blast area in building 282
479 - PPE collection from blast area in building 282 89
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480 - SAA in clinic / Refil Pharmacy building 1090
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481 - SAA in clinic / Refil Pharmacy building 1090 91
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482 - SAA in clinic / Refil Pharmacy building 1090
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Appendix 2 Inspection Participants Sign in Sheet
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Appendix 3 Little Rock Air Force Base Visitors Map
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Appendix 4 SAP's By Shop Report
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Appendix 5 Red Plan / Emergency Response Action Plan
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Appendix 6 Bead Blasting Media & Recycling Services
Performance Work Statement
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Appendix 7 US Technology Media Inc. Lease & Recycle
Program Overview Marked Confidential Business Information by US Technology. Available for review under CBI only.
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Appendix 8 Arkansas Department of Environmental Quality Letter
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Appendix 9 Hazardous Waste Profile Sheet
LRK-PRF-043
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Appendix 10 Hazardous Waste Profile Sheet
LRK-PRF-008
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