Hazardous Waste Questions and Answers.docx

Hazardous Waste Questions and Answers

Regarding the Parameters. Would you be able to provide analyte lists for the groups of Halogenated Volatile Organics, Non-Halogenated Volatile Organics, and Aromatic Volatile Organics? Depending on where and what is being sampled will determine what VOCs are being sampled. Aerial Spray is annual, in the past we spoke with the lab director and instructed what we were wanting to sample for, he also gave us input, & we agreed on the analytes before he left the base. What the most common method of sampling is TCLP.

Heavy Metals is sampled for every sample we have completed. We also have waste streams that may require Hexavalent Chromium sampling.

Our Aerial Spray waste streams (there’s 2- one is liquid waste and one is absorbent materials & PPE) are sampled annually for heavy metals, VOC’s, pesticides & PCBs.

Our industrial wastewater treatment plant is sampled quarterly for our NPDES permit. What’s ran quarterly are the following: BOD-5 day; cadmium; Chemical Oxygen Demand (COD); Chromium; Copper; Lead; Mercury; Nickel; Silver; Total Suspended Solids; Zinc; minimum pH & maximum pH; Cyanide, Total; Oil & Grease; Temperature; Chromium, Hexavalent.

Our TTO is performed annually, and samples for VOCs, SVOCs, heavy metals, Pesticides & PCBs, along with others to include pH, cyanide, and total phenols, among other items. It’s approximately 150 analytes that are sampled.

Are there allowances for substituting methods for the testing of parameters? The most current & approved EPA method must be used. Lab must be certified and accredited.

Sampling and Pick up Logistics. Based on the information provided, it looks like the sampling needs are more based on a Will-Call basis rather than a routine schedule. Is this the case? Or is there more of a regimented or routine schedule that the base plans on following? Wastewater Treatment Plant can be scheduled on a quarterly basis, and the annual TTO can be scheduled as well. Waste streams newly identified are usually Will-Call basis. However, all waste streams must be sampled every 3 years apart from Aerial Spray waste streams that must be sampled yearly (This one can also be scheduled). We try to have samples completed when lab comes for quarterly wastewater treatment samples.

For the composite sampling, will we have to provide and set samplers the day prior to collection? Or will the samplers be set by base staff? Composite sampling varies between base staff and lab employees.

Getting on the base, what is the protocol for getting on base to either pick up samples or sample collection? Will security clearances be needed for the company or the individuals that would be on base? The CEV office would send a form for the company to complete. The form will require driver license information, DOB, & SSAN for each employee who will possibly come on base. This will be returned to the CEV office, & once we receive it, the documentation is sent to SFS where they will complete background checks on each person listed. The first time coming on base, they will have to register at the visitor center. They will need to have their DL, vehicle registration information, and insurance information when they register there. This form will have to be updated yearly or when needed.

Regarding the 15-day turnaround time for report submission, is the turnaround time 15 business days or 15 calendar days? Business Days

What is the anticipated schedule or number of samples that will be collected per structure? This will help us estimate the number of samples collected per day. Overall, we’re attempting to estimate if we will need a courier service or shipping through FedEx. We have approximately 30 hazardous waste streams. Aerial Spray’s 2 waste streams require annual sampling. All other hazardous waste streams require sampling every 3 years. Any newly identified waste streams require initial sampling for classification, & then every 3 years (if it’s not from Aerial Spray). We’re currently trying to work out a yearly schedule for the waste streams so not everything is completed at once. We usually have samples obtained during our quarterly IWWTP samples, unless something is urgent or newly identified.

Our Industrial Wastewater Treatment Plant requires quarterly samplings (4/year) and an annual TTO.

We have a Level 2s CMMC certification. We will have subconsultants, who will be members of the team for laboratory analysis. Are they required to have CMMC certification? We noticed FAR 52.204-21 and DFARS 252.204-7021 are not included in the solicitation, so we wanted to confirm that it is not needed for the lab subs under this contract.

It is not needed.

Are equivalent/alternate analytical methods acceptable if they are technically equivalent to the methods listed in the RFQ/PWS (we can provide a method crosswalk if needed)?

Regulatory approved alternate standard methods are legally valid for compliance monitoring.

I’m thinking the question on alternate methods came about because a lab prefers, is equipped, or is more proficient, for example, to use a certain standard method(s) for a specific analyte(s) other than one or more that was indicated in the PWS. Equivalent/alternate standard methods are acceptable if they are approved via the approval process noted in 40 CFR 136, the governing rule for compliance analysis of water and wastewater or found in the Standard Methods for the Examination of Water and Wastewater and are incorporated by reference into 40 CFR Part 136 for wastewater, or approved under SDWA for drinking water. The CFR describes and defines acceptable lab methods, and discusses how to address alternate methods for approval that haven’t been approved. The Standard Methods document often provides many approved variations to conduct analysis for an analyte: each has its own method number.

Is DoD-specific lab certification required, or is NELAP/NELAC accreditation acceptable?

The DoD Environmental Laboratory Accreditation Program (ELAP) is only REQUIRED for Defense Environmental Restoration Program (DERP) activities. Accreditation by State or EPA accreditation agencies known as NELAP-recognized Accreditation Bodies is perfectly acceptable for compliance monitoring, however the preference is to have ELAP accreditation AND State or EPA accreditation, especially for PFAS monitoring1.

Note:

0. 4 Dec 2024, DoD Policy for PFAS Monitoring and Treatment in DoD-Owned Drinking Water Systems, See Attachment 1, Page 5, Analytical Laboratories. Link: https://www.airforcemedicine.af.mil/Portals/1/Documents/MCCS/01a.%202024%20and%202023%20PFAS%20Sampling%20Policy.pdf