Document mmLxdLmRdRvYY9GLQ9OQVQR04

D003, D005-D009, D011, D018, D026, D035, F001, F002, F003, F005 and U154. 9) Previous Inspection History On June 23, 2021, FDEP conducted a RCRA CEI at the facility and no RCRA deficiencies were discovered. 10) Inspection Findings Following the opening conference, the inspection team proceeded with the inspection. The inspectors inspected the following areas during the onsite inspection: Building 3580 Corrosion Control, Building 1853, Building 1854 Blue Angel Hangar, Building 2644 Fuel Farm, Building 38 Port Operations, Building 3460 Mega Building, Building 684-A 90-Day Storage Area, and Building 684. Below is a description of the observations made during the inspection. Unless noted otherwise, for the walkthrough inspection: All satellite accumulation area (SAA) containers were observed to be closed and marked with a description of the hazardous waste being handled and/or the words "Hazardous Waste." All containers of hazardous waste observed in 90-day accumulation areas were closed, marked with the words "Hazardous Waste," an indication of hazard of the waste, and accumulation start dates. All universal waste containers were observed to be closed, marked with a description of the universal waste being handled, the words "Universal Waste," and accumulation start dates. All containers of used oil were marked "Used Oil." On February 7, 2020, the EPA added hazardous waste aerosol cans to the universal wastes outlined in title 40 C.F.R. Part 273, thereby giving generators the opportunity to choose the management method that best suits its operations. The State of Florida adopted the requirements of 40 C.F.R. Part 273 into the Florida Administrative Code (FAC 62-730) on October 30, 2020. It can either be managed as a universal waste or hazardous waste. The inspectors observed that NAS Pensacola was storing spent aerosol cans as universal waste and, also as hazardous waste throughout the facility. The inspectors recommended that NAS Pensacola handle spent aerosol cans as universal waste for ease of regulatory burden. Building 3580-Corrosion Control Building 3580 Corrosion Control is primarily conducting work on ground support equipment and paint operations with paint booths run by a contractor. The building has a multi-waste stream SAAs. The inspectors observed thirteen hazardous waste containers (ranging from 5-gallons to 55-gallons) of paint waste (Photograph #1), media blast, oily rags contaminated with metal, fuel rags, acid rags, parts washer sludge, paint chips and paint booth filters; five non-hazardous waste containers of oil spill debris, antifreeze, used oil filters, and silica waste; and one 30-gallon container of universal waste aerosol cans with an accumulation start date of December 25, 2021. Outside the building in a fenced area were two baghouse hoppers connected to two 55-gallon containers (Photograph #2). The containers collect the spent plastic media blast (PMB) from a blasting media unit. The PMB waste (D006 and D007) containers were dated January 19, 2022. The containers were marked with a DOT class 9 diamond indicating a "Miscellaneous" hazard. US Naval Air Station RCRA Inspection Report EPA RCRA ID No. FL9170024567 March 2, 2022 Page 4 of 15 operator of the process generating the waste, without a permit or interim status and without complying with the requirements of parts 124, 264 through 267, and 270 of this chapter, provided that all of the conditions for exemption in this section are met. Building 1854 Blue Angel Hangar Building 1854 is designated for the servicing, maintenance, and repair of the Blue Angels aircraft. The west side of the hangar is designated for the servicing, maintenance, and repair of the Blue Angel aircrafts. The facility representative stated that Blue Angel Team is at their winter training location in California. At the time of inspection, there were no SAA containers on the west side of the hangar. The east side of the hangar is operated by a contractor for the maintenance/repair of aircraft. The inspectors observed three closed 55-gallon containers of hazardous fuel/alcohol rags, paint rags, and adhesive waste; a 55-gallon container of non-hazardous oily rags; and one 55-gallon container of universal waste aerosol cans. The aerosol can container had an accumulation start date of August 11, 2021. In an office/procurement area SAA, the inspectors observed one 5gallon bucket of universal waste alkaline batteries dated December 5, 2021, one 5-gallon bucket lithium batteries dated November 23, 2021, and a 5-gallon bucket of hazardous Alodine rags/waste. Building 2644 Fuel Farm The fuel farm area is operated by the fuel contractor who manages the bulk fuel farm. The fuel farm contractor distributes fuel to the fueling tanks located throughout the base and conducts maintenance/repair on their vehicles in this area. At the time of inspection, the inspectors observed three closed 55-gallon containers of hazardous fuel filters, fuel rags, and gas/oil/water mix. In addition, there was a 55-gallon container of used oil filters and a 30-gallon container of used oil. Building 38 Port Operations The Inspectors visited the Port Operations area is located immediately adjacent to the Pensacola Bay. The Port Operations staff indicated that work/repairs on marine vessels and equipment take place at the dock or inside Building 38. There are two SAA storage lockers managed by separate contractors (Photographs #4-5). One locker is maintained by the Port Operations. The Port Operation staff indicated that occasionally staff from another building or contractor may bring waste to the second SAA storage locker in Building 38. The inspectors indicated that SAA containers be established "at or near" the point of generation and must be "under the control of the operator." Consolidating or bringing hazardous waste into containers not located at or near the point of generation does not meet the SAA container requirements per 40 C.F.R. 262.15(a). At the time of inspection, Port Operations locker contained two 55-gallon containers of hazardous fuel filters and gas/oil/water mix; and two 55-gallon containers of non-hazardous antifreeze and used oil. The second locker contained one 5-gallon container of hazardous diesel fuel/fuel filters and two 55-gallon containers of non-hazardous antifreeze and used oil. Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.15(a)], and is a condition of the SAA Permit Exemption, a generator may accumulate as much as 55 gallons of non-acute hazardous waste and/or either one quart of liquid acute hazardous waste listed in 262.31 or 262.33(e) of this chapter or 1 kg (2.2 lbs) of solid acute hazardous waste listed 262.31 or 262.33(e) of this chapter in containers at or near any point of generation where wastes initially accumulate which is under the control of the US Naval Air Station RCRA Inspection Report EPA RCRA ID No. FL9170024567 March 2, 2022 Page 6 of 15 operator of the process generating the waste, without a permit or interim status and without complying with the requirements of parts 124, 264 through 267, and 270 of this chapter, provided that all of the conditions for exemption in this section are met. Building 3460 Mega Building Building 3460 is known as the Mega Building. It is a building encompassing classroom and lab facilities utilized by Navy, Marine, and Air Force personnel for education and training purposes. There are various SAAs are maintained throughout the building and the trainings are conducted in the labs. The labs varied with paint booths, bead blast media units, and maintenance equipment. The inspectors inspected the following SAAs in the building: Lab 2812-there were two small paint booths adjacent to the paint blast unit. There were two 55gallon containers of hazardous paint waste and paint rags; and two 5-gallon containers of Alodine rags and Alodine waste. The lab staff stated that paint booth filters are removed when the paint booth meter indicates a specified air resistance on the filters. The contractor removes the paint booth filters as hazardous waste and transport them directly to the 90-day storage area. Outside Building 3460, there was a baghouse hopper connected to a 55-gallon container of hazardous spent paint chips/plastic blast media. The baghouse hopper (Photograph # 6) is connected to a paint blast media unit in Lab 2812. Lab 2811-the inspectors observed two 55-gallon containers of hazardous paint waste and paint rags, one 5-gallon container of Alodine waste, and a 5-gallon container of Alodine rags. Lab 1612-the inspectors observed two 55-gallon containers of hazardous paint waste and paint/thinner rags. Lab 2651-the inspectors observed three 55-gallon containers of hazardous oil contaminated with metals, dielectric solvent waste, and test patches with metals; one 55-gallon container of nonhazardous oily rags; one 15-gallon container of hazardous aerosol cans; and a 5-gallon container of universal waste lithium batteries dated November 18, 2021 (Photograph #7). Lab 1420-the inspectors observed one 55-gallon container of hazardous fuel rags. Lab 1422-the inspectors observed two 55-gallon container of non-hazardous penetrant waste oil and penetrant waste oil rags; one 5-gallon container of hazardous aerosol cans; and one 35-gallon container of hazardous MagnaFlux waste. The inspectors waited approximately thirty minutes and were not able to enter a lab SAAs during the inspection because no one was able to find the key or get in touch with a point of contact. NAS Pensacola staff were aware of the EPA and FDEP inspection prior to the inspection date. Not able to access hazardous waste storage areas raises safety concerns in the event of an emergency and prevented inspection for the purpose of ascertaining compliance with applicable hazardous waste regulations. Pursuant to 42 U.S.C 6927(a), for purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, any person who generates, stores, treats, transports, disposes of, or otherwise handles or has handled hazardous wastes shall, upon request of any officer, employee or representative of the Environmental Protection Agency, duly designated by the Administrator, or upon request of any duly US Naval Air Station RCRA Inspection Report EPA RCRA ID No. FL9170024567 March 2, 2022 Page 7 of 15 Photograph #13 - (b) (3) (A) (b) (3) (A) Photograph #14 - (b) (3) (A) (b) (3) (A) US Naval Air Station RCRA Inspection Report EPA RCRA ID No. FL9170024567 March 2, 2022 Page 15 of 15