Cannon_AFB_2017_Hazardous_Waste_Biennial_Report_Background_Documentation_033018.pdf

2017 HAZARDOUS WASTE REPORT

PROJECT BACKGROUND DOCUMENTATION

CANNON AIR FORCE BASE

Prepared by Mitch Haight, Cardno

March 30, 2018 For

Ms. Dana Gentry CES, Environmental Element Chief

49 CES/CEIE

Cannon Air Force Base, New Mexico

2017 Cannon AFB Biennial Hazardous Waste Report Background Documentation

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TABLE OF CONTENTS

Introduction General Information Scope of Reporting Effort Description of Facilities and Points of Contact RY 2017 Biennial Report Summary Project Schedule and Milestones Data Scoping Schedule Data Sources Other Data Considerations Data Filter Criteria Data Grouping for GM and WR Forms Data Quality Control (QC) Data Analysis RY 2017 Regulatory Changes Exemptions Lessons Learned Appendix I

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Introduction

Pursuant to Sections 3002 and 3004 of the Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA), hazardous waste (HW) generators are required to report the quantities, nature, and disposition of generated HW to the Environmental Protection Agency (EPA) or the authorized states at least every two years (Section 3002). The EPA requires reporting by treatment, storage, and disposal facilities for the wastes they receive (Section 3004).

This data collection is done on a two-year cycle as required by Sections 3002 and 3004 of RCRA. The information is collected via a mechanism known as the Hazardous Waste Report (HWR) (a.k.a. Biennial Report) for the required reporting year and is mandatory reporting by the respondents.

The respondents' submissions (reports) describe each generated HW, the activity by which they generated the waste, and the waste quantity; the reports also list the management method by which each waste is treated, recycled, or disposed and the quantity managed.

Collection, validation and verification of the Biennial Report data are the responsibility of RCRA authorized states. EPA does not modify the data reported by the states. Any questions regarding the information reported for a RCRA handler should be directed to the state agency responsible for the Biennial Report data collection. Biennial data is provided to the EPA by the State.

General Information The Biennial Report is completed in accordance with (IAW) the instructions set forth in the publication “RCRA Subtitle C Reporting Instructions and Forms, EPA Forms 8700-12, 8700-13 A/B, 8700-23 (OMB #2050-0024; Expires 05/31/2020)” and pursuant to the Performance Work Statement (PWS) for Fence-To-Fence Environmental Services at Cannon AFB, Curry County, New Mexico and Holloman Air Force Base, Otero County, New Mexico. The 2017 Biennial Report effort includes scoping, data-mining, quality control, and report preparation (physical documents as well as online data-entry). The 2017 Biennial Report was submitted by the 49

CES/CEIE.

A Generator is required to submit a Biennial Report if it meets the definition Large Quantity Generators (LQG) during the collection year (odd year). A RCRA LQG is a generator that, by site, generates any of the following amounts in a calendar month:

• Greater than or equal to 1,000 kilograms (kg; 2,200 pounds [lbs.]) of non-acute RCRA HW; or

• Greater than 1 kg (2.2 lbs.) of any acute HW listed in sections 261.31 or 261.33(e); or

• Greater than 100 kg (220 lbs.) of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute HWs listed in sections 261.31 or 261.33(e); or

• Amounts above the LQG threshold of either acute hazardous waste or residue or contaminated soil containing acute hazardous wastes...

A generator who treated, stored, recycled or disposed of RCRA hazardous wastes on-site or shipped hazardous waste off-site to a RCRA permitted treatment, storage, recycling and disposal facility, or received hazardous wastes from off-site hazardous waste generators without storing the wastes before recycling during the reporting year (odd years) must also complete and file a Biennial Report.

Based on a review of the New Mexico Environmental Division (NMED) website (https://www.env.nm.gov/HWB/guidance.html), it was determined that no special NMED requirements exist for preparing and reporting the Biennial Report; the state of New Mexico aligns with federal requirements outlined in the federal EPA forms and instructions. In short:

1. New Mexico’s Biennial Report preparation aligns with federal requirements; no state specific requirements; and

2. The Biennial Report is submitted online via the following website:

https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login

Scope of Reporting Effort Cannon AFB was evaluated against the given criteria (above) and existing quantity thresholds and was determined to be an LQG and subject to reporting requirements. Melrose Air Force Range training area and White Sands Missile Range are not LQGs and not subject to biennial reporting.

https://www.env.nm.gov/HWB/guidance.html https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login

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The PWS for Fence-To-Fence Environmental Services at Cannon AFB, Curry County, New Mexico and Cannon Air Force Base, Otero County, New Mexico describe the Biennial Report task as follows:

• 5.4.6 Reports, HW: The Contractor shall produce the US EPA/NMED Biennial Report that details HW activities required by the US EPA and the State. This includes tracking data on waste streams, disposal, HW transportation, weights, and amounts.

• 5.17.4 HW Contract Support (CAP/HAZMART), Biennial Report: Contractor shall collect and gather the required data to support development of the EPA/NMED Biennial Report. Contract shall assist with all aspects of report preparation.

Description of Facilities and Points of Contact Cannon AFB is home to the home of the 27th Special Operations Wing generating waste under the EPA ID NM7572124454. Key points of contact (POCs) for the Cannon AFB Hazardous Waste Report include:

• Ms. Dana Gentry, CES, Environmental Element Chief, dana.gentry@us.af.mil

• Mr. Teddy “Mark” Suggs, CES, HWPM (transitioned to Air/Tank PM), teddy.suggs.1@us.af.mil

• Ms. Anita M. Lafuente, CES, TSCA PM/HW Specialist/PPBE, anita.lafuente@us.af.mil

• Mrs. Lindsey Dunahee, CES, HWPM (effective 29 Mar 2018), lindsay.dunahee@us.af.mil

• Mr. Sean Wolfe, Cardno, HW Supervisor, sean.wolfe@cardno-gs.com

RY 2017 Biennial Report Summary

• Total weight of HW generated - during the reporting year decreased in RY15 increased from 13.2 tons to 16.9 tons in the current reporting year, RY17 (see Figure 1). See Appendix I for full submission documents generated from EPA RCRAInfo Industry Application (RIA) software.

Figure 1: Source: https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login mailto:dana.gentry@us.af.mil mailto:teddy.suggs.1@us.af.mil mailto:anita.lafuente@us.af.mil mailto:lindsay.dunahee@us.af.mil mailto:sean.wolfe@cardno-gs.com

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Note: Per conversation with Mr. Mark Suggs (Cannon AFB) and Mr. Sean Wolfe (Cardno), the primary reason for the increase in total weight reported in RY17 is:

1) CV-22 Helicopter mission

2) MQ1 mission retirement and Oc10 gas cylinder disposal

3) Filter change out at CATM

• Source codes - Describes the type of process or activity (i.e., source) from which a hazardous waste was generated.

New Source Codes (1) reported in RY17 not used RY15

RY17: G13

Source Codes (5) reported in RY15 not used RY17

RY15: G12, 12, 19, 21, 32

• Form codes - Describes the general physical and chemical characteristics of a hazardous waste.

New Form Codes (1) reported in RY17 not used RY15

RY17: W001

Form Codes (5) reported in RY15 not used RY17

RY15: W002, 105, 203, 204, 206

Project Schedule and Milestones Biennial Report kick-off Meeting, 5 Oct 2017 The internal Biennial Report kick-off meeting was held October 5, 2017 to discuss the strategy and planning of the for Cannon and Cannon AFB Biennial Report effort. Attendees included Mitch Haight, Tanya Woodfall, and Josh Gunter. The agenda for the kick-off meeting included:

• Identify key players for report preparation o Josh Gunter responsible EESOH-MIS data mining, data validation and QC, and completing the online Biennial

Report o Mitch Haight: responsible for project coordination and background documentation

• Review schedule for completion of report o Data cleanup will continue 9 Oct 2017 through 29 Dec 2017 o Tentative date for EESOH-MIS final data pull was set for 5 Jan 2018

• Review criteria for scoping HW mass and containers IAW

• Discuss regulatory changes for reporting year 2017

Cannon AFB Biennial Report Preliminary Data Review Meeting, 25 Jan 2018 On 25 Jan 2018 Mitch Haight met with Mr. Mark Suggs, Mr. Sean Wolfe, and Ms. Anita Lafuente, onsite at Cannon AFB to discuss the status of the Biennial Report. The agenda for the meeting included the following:

• Scope: main base Cannon, EPA ID NM7572124454, is subject to reporting requirements.

• Data-mining methodology and quality control for Preparation of the Final Dataset

• Form GMs grouping criteria

• Method for deriving Form Codes and Source Codes

• Method for deriving designated TSDF and Management Method Codes

• Tentative schedule

• Discussion: juxtaposition and analysis of preliminary RY17 data and RY15 data:

o Comparison of the total weight of hazardous waste for the respective reporting years o Total Form GMs o New Source Codes (1) reported in RY17 not used RY15 o Source Codes (5) reported in RY15, not used RY17 o New Form Codes (1) reported in RY17 not used RY15 in RY17 o Form Codes (5) reported in RY15, not used RY17

• In addition, the following questions were also posed (black font) and addressed (underscored) by the client.

- 6 -o Is the methodology described for scoping and grouping data described above for biennial reporting acceptable? Yes o Is WW/IWTP sludge characterized, managed, and tracked according to the resulting waste determination? Yes o It is assumed that UHWM was entered in EESOH, with all associated DTIDs, and a Ship Date for all shipments in the reporting year – correct? Yes o It is assumed that “shipped” is indicated by an EESOH container record being on a DTID and all DTIDs placed on a manifest with a Ship Date - correct? Yes o It will be assumed that “hazardous” is indicated by the presence of any EPA code being associated with a container.

Correct? Yes o Is all UW ultimately recycled or is any managed as UW and then disposed of as HW? If so, is this clear in EESOH? Yes o Does the installation receive waste from off-site (i.e. rockets, other, etc.))? No o Does the base manage any HW not in tracked in EESOH? No o Are there any data for sources other than EESOH (i.e. spreadsheets or logs)? No, all records reside in the EESOH-MIS

HW module.

o Any HW accumulated and then treated on base (Solvent, IWTP, etc.)? No, with the exception of Aerosol cans, a universal waste.

o Consider this year’s business practices; were there changes local business practice that may affect scoping query criteria (i.e. DLA-DS CLIN change)? Yes: CU22 Helicopter mission; MQ1 mission retirement and Oc10 gas cylinder disposal, and filter change out at CATM.

Cannon AFB Biennial Report Final Data Review Meeting, 14 Feb 2018 On 14 Feb 2018 Mitch Haight and Josh Gunter met with Mr. Mark Suggs and Mr. Sean Wolfe via conference call to discuss the status of the Biennial Report. The agenda for the meeting included following:

• Schedule update

• No change to data since the initial juxtaposition and analysis of preliminary RY17 data and RY15 data

• Discussed remaining effort:

o Complete review of Forms GM, WR, OI, and SI, with special attention to Form SI o The new EPA RCRAInfo website does not currently have print capability so review must be done online o Recommend a formal letter for routing to individuals selected by the base to review o Cardno is prepared to assist with getting individual’s access to RCRAInfo website o Cardno is planning to complete the Hill AFB certification process and gain real-world experience in order to be of greater assistance to Cannon AFB as they work through the certification process.

Data Scoping A Form GM must be completed and submitted for each generated RCRA HW. HW must be reported if it was:

• Generated and accumulated on-site and subsequently managed on-site or shipped off-site in 2017; or

• Generated and accumulated on-site in 2017 but not managed on-site or shipped off-site until after 2017; or

• Generated and accumulated on-site prior to 2017 but either managed on-site or shipped off-site in 2017; or

• Imported from a foreign country in 2017.

A Form WR must be completed and submitted if, during 2017, it received RCRA HW from off-site.

Figure 2: Scoping

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Schedule Biennial Report project schedule and milestones:

Table 1: Schedule / Milestones Status Date Task

12/18/17 Request supporting data from Defense Logistics Agency (DLA) 1/8/18 EESOH data pull 1/15/18 Begin internal review / quality control 1/22/18 Reality check – cross yr. comparison w/ Client (in-person/onsite week of 1/22/18) 1/26/18 Final QC of data set complete 2/9/18 Complete data-entry of biennial Forms GM /WR/OI/Site ID 2/14/18 Final review with client 2/14/18 Finalize online forms and begin routing / obtain electronic signatures from client 2/26/18 Submit deliverables to respective state agency 3/30/18 Complete and submit project background documentation

Data Sources

Data pulled for reporting purposes was obtained from multiple sources. The following were the primary data sources used in the preparation of the Cannon AFB Biennial Report:

1. The EESOH-MIS HW Module, now fully implemented at Cannon AFB, was the primary waste tracking system for cradle-to-grave tracking of HW. Data was queried from EESOH-MIS HW module using the Ad Hoc Reporting Tool (ART) using the scoping criteria in figure 2 (above). The EPA ID is the key field used to query data from EESOH-MIS HW identifying the specific facility on an installation where waste is generated. This is especially important at Cannon AFB since CESQG containers are being tracked in EESOH.

2. The Final TSDF, Management Method Code, and Transporter EPA ID were all obtained from EESOH-MIS HW Module.

Shipping information maintained in EEOSH-MIS HW is now considered the authoritative source. Availability of DLA information is limited. Where available, the data is used as a secondary source and used to QC EESOH data as necessary. In previous reporting years DLA has provided a final TSDF. However, with the implementation of the DLA EBS/RBI systems, only the designated TSDF that waste is shipped to is reported. In general, the default Method Management Code on the Form GM’s was reported as H141 (waste stored, bulked, and transferred) when otherwise unavailable.

3. The EESOH-MIS HW Regulatory Report was used, but not exclusively. This was not possible due to the fact that 1) it only includes waste shipped, excluding any HW in storage at the end of the year, and 2) container weights are given in a text format.

4. There were no Form WR for Cannon AFB.

Other Data Considerations Form Codes and Source Codes: significant effort has been expended by Cardno staff at the bases we support to update the biennial codes in their EESOH HW module. Where not available, they will be extrapolated using the following alternate approach:

• Form Codes were assigned based on the 1) Waste Profile description, 2) % liquid (liquid/solid), 3) physical composition, 4) chemical composition, 5) profile narratives and 6) other data that adds to the story.

• Source Codes were assigned primarily based on associated narratives, i.e. 1) “Waste Type” (recorded in EESOH HW Module) or 2) “Waste Description” (recorded in EESOH) and other data contributing to the story. Waste sites/streams are unique and need to be treated as such.

• Designated TSDF and Management Method Codes were requested and provided by DLA-DS, the authoritative source for this information. DLA-DS provides only the designated TSDF and Management Method Code, not the Final TSDF. Where the Management Method Code was not readily available via EESOH-MIS HW module the Method Management Code of H141 (waste stored, bulked, and transferred) was used by default.

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• Off-spec or Virgin Product: Some RCRA regulated waste is generated through the disposal of off-spec, virgin product. Such product is staged on base while an outlet (re-sourcing, etc.)is sought and is not counted in Biennial Report reporting. When re-sourcing is not an option and the material is designated as HW, this waste is containerized for disposal and entered into the waste tracking database where it is processed as any other container and is counted in biennial reporting.

• End of year inventory (EOYI) and Waste Accumulating: HW having a “Ship Date” was considered to be in the process of disposal, hence disposed. All such waste was included. Waste in storage at the 90 Day facility awaiting shipping, in “RS” status in EESOH-MIS was also included. Partially full containers accumulating on base, being logistically impossible to assess, were not considered in reporting.

Data Filter Criteria

• Data filtering consisted of three phases.

o Initial ART data pulls and QC o Data categorization and QC o Manual QC and re-categorization based on data incongruences

• Initial ART data pulls and QC:

o Data pulled 1/5/2018 COB.

o Shipped Containers: Containers with a shipped date >= 1/1/2017 o Managed Containers: Containers that are in RS status o A union query between the shipped and managed containers to create a master list of all possible containers.

o Containers with a Deleted Date were removed from the dataset o Containers filling in the field fall out based on the shipped and managed criteria

• Data categorization and QC:

o Potential containers were divided into two groups based on standardized EESOH bins.

Potential containers to exclude from the biennial Exclude containers with a deleted / abandoned date Exclude containers that were sample only Exclude containers were managed and disposed of as a recyclable material Exclude containers managed and disposed of as a universal waste Exclude containers managed and disposed of as a Non-Hazardous waste Exclude containers managed and disposed of as TSCA (non-hazardous) Exclude containers managed and disposed of as CERCLA (non-hazardous) Exclude containers managed and recycled as used oil.

Exclude any container created / initiated after 12/31/2017

Potential containers to include on the biennial All containers not specifically excluded.

• Manual QC and re-categorization based on data incongruences:

o Manually review each excluded container for incongruences that might indicate that the container could have been misclassified, as follows, and flag them for follow up:

Are there excluded containers that have EPA waste codes Are there excluded containers that have a HW label Are there excluded containers that have a hazardous CLIN Are there excluded containers that have a hazardous profile Does the waste description have any indications that it might be hazardous o Manually review each included container for incongruences that might indicate that the may have been misclassified, as follows, and flag them for follow up:

Are there included containers that do not have EPA waste codes Are there included containers that have a non-hazardous label Are there included containers that have a non-hazardous CLIN Are there included containers that have a non-hazardous profile Does the waste description have any indication that it may not be hazardous o Any container in question included / excluded are researched whether it is through the EESOH forms, SJES, or speaking with the HWCF manager (i.e. Cardno HW Supervisor) about the container in question. Depending on the outcome, the questionable container is adjusted to include or exclude.

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Data Grouping for GM and WR Forms

• GM Forms are inclusive of all records having EPA ID NM7572124454.

• The grouping criteria for Form GMs is represented by unique values of o Primary Grouping Waste Profile Description Source Code Source Code Comment Form Code Form Code Comment EPA waste codes.

o Secondary Grouping Management Method Code Designated TSDF

Note: In the prior reporting year the CLIN Description was used in the Form GM grouping criteria. In the current reporting year Waste Profile Description was used. This change was made because DLA-DS (Defense Logistics Agency – Disposition Services) moved to an entirely new pricing and CLIN structure; one based on profile and container instead weight and EPA codes. The new CLINs came with a new CLIN description which were different prior CLIN description.

This change occurred mid-year 2017. The effect of continuing to use the CLIN description would lead to greatly proliferating Forms GM; e.g. the same waste may appear twice, once for each associated CLIN. Mapping the two CLINs descriptions so that each waste type is only reported once was considered but was rejected due to time constraints and data quality concerns. Consequently, it was decided that the EESOH-MIS HW module Waste Profile Description should be used.

The resulting dataset was subjected to QC to reduce redundant data caused by the combinations and permutations of how the user chooses to describe the waste vis-à-vis the Waste Profile Description. A Waste Profile may exist having the same EPA Codes, Form Code, and Source Code but having slight differences in the Waste Profile Description. For example, as the same waste may be called “Virgin Nicotine Patches” once and “Nicotine Patches” another time. In such cases, using professional judgement a standardized name was applied resulting in a single Form GM (one or the other or a high bred of the two).

• Cannon AFB had no WR Form. No waste was received by Cannon AFB from off-site locations.

Data Quality Control (QC)

The following general QC checks were performed on the Cannon AFB Biennial Report data:

• Source Code and Form Code verification o Although Source Code and Form Codes were populated at the time or generation all source codes and form codes were manually reviewed for accuracy to validate that the codes were congruent with the other pieces of information o Corrections were made and then all Source Codes and Form Codes were reviewed with the HWCF manager.

• Designated TSDF, Transporter, and Management Method Code o Any container missing a Designated TSDF, Transporter or Management Method Code was presented to the HWCF manager to verify and provide.

o If the HWCF manager was unable to provide, the most recent Designated TSDF, Transporter and Management Method Code was used.

• Quality control (QC) checks performed on the Cannon AFB Biennial Report include the following:

o Checked for duplicate containers o Check ship dates, are there any outside of the expected >= 1/1/2017 o Check that containers are not initiated after 12/31/2017 o Use sorting to look for data deficiencies or items that are outside of the expected norm o Run queries for all P and U codes. Is the GM description, Source and Form Codes correct?

o Run queries for all Pharmaceuticals. Is the GM description, Source and Form Codes correct?

- 10 -o Are the Source and Form Codes congruent with the GM description?

o Peer review – peer spot checked containers and verified they expected to be in, or excluded from, the Biennial Report.

o Peer review methodology for pulling data.

• Containers not having disposal data where considered in process;

• Waste accumulating at sites on base were not included – there is no way to determine how much waste is in the container and a weight is not available.

The following Cannon specific QC was performed on the Cannon AFB dataset to identify duplicate records using the following methodology:

• Using a standard Microsoft Access Query to find duplicates datasets were checked at two different times during o Standard Microsoft Access query was run to find possible duplicates in container records prior to form GM roll-up.

The EESOH container number was the single data element that was checked for duplicity No duplicate records were discovered o Standard Microsoft Access query was run to find possible duplicates in form GM roll-up GM Description, Source Code, Source Code Comment, Form Code, Form Code Comment, Management Method

Code, Designated TSDF, and EPA codes were the data elements checked for duplicity

No duplicate records were discovered.

The dataset was searched for waste identified as solvents and not having an F-Listed EPA code using the following methodology:

Containers with a GM Description that indicated a solvent or contained an F listed code were checked for congruency with Source Codes and Form Codes. There were items where this occurred. In those cases secondary information was manually checked to verify if it was, or was not, a solvent. This involved checking the EESOH forms, SJES comments, analytical, and/or speaking with the HW site manager. There were no container issues requiring research associated to the Cannon containers. The following containers having zero/null weights or unreasonably large weights were researched and verified:

• No null weights

• No unusually heavy containers

The following containers having P & U EPA codes were researched and reviewed against expectations:

• 201600586, and 201700027 Acute Pharmaceutical Waste P001

• 201700421 Nicotine products P075

The following listing of Designated TSDFs and corresponding Management Method Codes were verified:

• Designated TSDF’s are auto generated via the RCRAInfo system. Please see form OI for a list of designated TSDF’s.

• Any missing Management Method Codes were first referred to the HW site manager. In cases where the Management

Method Code was unavailable, the Management Method Code H141 was used (the default).

Data Analysis

• HW accumulating on base or in storage in at the 90 Day facility was not considered unless the container was placed into

“RS” (Ready to Ship) status when EESOH data was pulled. This waste is considered in process; a final waste determination has not been made in most cases nor has a container final weight been determined.

• Virgin Product accumulated by DRMO was not considered in the Cannon AFB Biennial Report. This waste is considered in process; a final waste determination has not been made in most cases nor has a container final weight been determined.

Once characterized as hazardous, this waste is containerized and processed as any other HW container.

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RY 2017 Regulatory Changes There were several regulatory changes introduced for the 2017 Biennial Report. These changes are summarized below.

• Previously, there was an independent software used to prepare and submit the Biennial Report (form 8700-12). This year

(reports to be submitted in March 2018) the Biennial Report must be prepared and submitted using the EPA RCRAInfo Industry Application (RIA) software. RCRAInfo Industry Application (RIA) is the Environmental Protection Agency’s (EPA’s) solution to allow subject generators to submit the 8700-12 (RCRA Subtitle C Site Identification Form) electronically to their regulating agency

• The New Rule deleted from the federal regulations the list of information that must be included in the report and replaced the list of specific data elements with a reference to the EPA Form 8700-13 A/B itself, which specifies the information needed for the 2017 report. EPA Form 8700-13 A/B was the authoritative source used in the preparation of the RY 2017 Cannon AFB Biennial Report.

• Both permitted TSDFs that store hazardous waste before recycling it and facilities that recycle hazardous waste without first storing the waste (i.e., the facility does not have a RCRA Part B storage permit) must also report for calendar year 2017. In the preamble to the New Rule, the EPA emphasizes that the LQG must identify in the Biennial Report all hazardous waste generated in the calendar year and not just for the month in which the generator was an LQG. This revision has no impact on the generator status of Cannon AFB Biennial Report. The installation was evaluated against the given criteria and existing quantity thresholds and was determined to meet the LQG criteria.

• Changes have been made to all of the four reporting forms that comprise the Biennial Report. The Site Identification Form (Site ID Form) had the most changes. These included:

These items have been added to the Site ID Form for the 2017 Biennial Report:

o E-mail, telephone number and extension, fax, and notes to the section for the legal owners of the site (Item 9.A) o Address, e-mail, telephone number and extension, fax, and notes to the section for the operators of the site (Item 9.B) o Indication that you are an SQG or very small quantity generator (VSQG) generating hazardous waste from an episodic event (Item 13) o Indication that you are an LQG notifying of consolidating VSQG hazardous waste under the control of the same person, as per 40 CFR 262.17(f) (Item 14) o Indication that you are an LQG notifying of site closure of a central accumulation area or an entire facility (Item 15)

This information was provided by the installation as applicable.

• In addition, these addendums to the Site ID Form have been either revised or added:

o Addendum for notification of hazardous secondary material activity o Addendum for episodic generation (as now allowed under the New Rule and applicable to SQGs and VSQGs only) o Addendum for LQG consolidation of VSQG hazardous waste (as now allowed under the New Rule).

This revision has no impact on the generator status of Cannon AFB Biennial Report.

• Source and Management Method Codes changes included:

o For the 2017 Biennial Report, the EPA revised and/or added several Source and Management Method Codes that are used in completing the Biennial Report and were taken into consideration.

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Exemptions

Industrial Wastewater Treatment Plant

Waste water influent is exempt from biennial reporting IAW the 2005 Hazardous Waste Report Instructions and Forms (EPA Form 8700 13 A/B, OMB #2050-0024) and was not reported on the Biennial Report:

“Wastes managed immediately upon generation only in on-site elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities as defined in 40 CFR 260.10. (40 CFR 261.5(c)(2)) Any hazardous waste residues generated from these units, however, must be reported on Form GM.”

Pursuant to CFR 260.10, Wastewater treatment unit means a device which:

(1) Is part of a wastewater treatment facility that is subject to regulation under either section 402 or 307(b) of the Clean Water Act; and

(2) Receives and treats or stores an influent wastewater that is a hazardous waste as defined in §261.3 of this chapter, or that generates and accumulates a wastewater treatment sludge that is a hazardous waste as defined in §261.3 of this chapter, or treats or stores a wastewater treatment sludge which is a hazardous waste as defined in §261.3 of this Chapter;

and

(3) Meets the definition of tank or tank system in §260.10 of this chapter.

Tank means a stationary device designed to contain an accumulation of HW that is constructed primarily of non-earthen materials (e.g., wood, concrete, steel, and plastic), which provide structural support.

Tank system means a HW storage or treatment tank and its associated ancillary equipment and containment system.

• HW accumulating on base or in storage in the 90 Day facility was not considered in the Cannon AFB Biennial Report Form GM, unless the container was placed into “RS” (Ready to Ship) status. This waste is considered in process; a final waste determination has not been made in most cases nor has a container final weight been determined.

Waste Samples Cannon AFB Laboratory facilities are considered exempt from Biennial Reporting pursuant to 2003 Hazardous Waste Report Instructions and Forms (EPA Form 8700 13 A/B, OMB #2050-0024):

“Hazardous waste that has been collected as a sample(s) for the purpose of determining its characteristic or composition, as specified in 261.4(d). (40 CFR 261.5(c) (1))”

Lessons Learned

• The new EPA RCRAInfo Industry Application (see RY 2017 Regulatory Changes) remains a work in progress, with several features added just days before the RY 2017 deadline (i.e. print capability). A tutorial was authored and shared with Cannon AFB CE to assist them with registering in and using the application. This document will be revisited prior to the next RY.

• The RCRAInfo system required a designated TSDF and management method code even if the containers was managed during the reporting year, characterized but not shipped.

• Biennial Report Biennial Report codes are maintained on the Profile Biennial tab in EESOH-MIS HW (see figure 3). A concerted effort was made by the Cardno HW support team to populate missing information and update existing information in the time period since the last reporting year. For Cannon AFB this information was nearly 100% complete for the current reporting year, fulfilling the self-fulfilled deadline of 31 Dec 2016 to complete this task.

• The business practice of entering DTIDs on separate lines of the manifest in EESOH-MIS and enter Management Method Codes for each line item was implemented in the time period since the last reporting year, significantly facilitating the accuracy and efficiency of completing the Biennial Report in the current reporting year.

• Progress on the implementation of the DLA GENFILE / EESOH-MIS interface has been slow. Once complete, this interface will ensure EESOH-MIS is updated with the correct disposal information, from DLA DS, the authoritative source. The Cardno HW support team will continue to monitor, test, and implement this functionality as directed by the Cannon AFB.

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Figure 3: EESOH-MIS HW Module Waste Profile

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Appendix I

Cannon AFB 2017 Biennial Submission

SUGGS, TEDDY M GS-11 USAF AFSOC 27 SOCES/CEIE

From: rcrainfo.admin@epa.gov Sent: Tuesday, February 27, 2018 10:55 AM To: SUGGS, TEDDY M GS-11 USAF AFSOC 27 SOCES/CEIE Subject: [Non-DoD Source] Biennial Report Submitted

Dear Teddy M Suggs <TEDDYSUGGS>, Your Biennial Report for site NM7572124454 has been successfully submitted for review. You may view the status by going to the Biennial Report Dashboard <https://rcrainfo.epa.gov/rcrainfoprod/action/industry/secured/br/home/NM7572124454> .

Thank you!

RCRAInfo Team <mailto:rcrainfo.help@epa.gov>

Cycle Site Name Site ID

2017 27 SOW AFSOC USAF CANNON AFB NM NM7572124454

GM 1 Waste Characteristics

A. Description of hazardous waste

ABSORBENTS, RAGS, WIPES, FILTERS WITH AV GAS

B. EPA Hazardous Waste Code(s)

D001, D008, D018, F005

C. State Hazardous Waste Code(s)

D. Source Code

G16

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

89.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

89.0

Comments

GM 2 Waste Characteristics

A. Description of hazardous waste

ACUTE PHARMACEUTICAL WASTES

B. EPA Hazardous Waste Code(s)

P001

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W005

F. Waste Minimization Code

A

G. Quantity

2.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

2.0

Comments

GM 3 Waste Characteristics

A. Description of hazardous waste

AIRCRAFT RAGS, SEALANT KITS AND APPLICATORS

B. EPA Hazardous Waste Code(s)

D007, F003, F005, D006

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

150.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

150.0

Comments

GM 4 Waste Characteristics

A. Description of hazardous waste

AIRCRAFT WASH SCRUBBIES AND PADS

B. EPA Hazardous Waste Code(s)

D006

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

534.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

534.0

Comments

GM 5 Waste Characteristics

A. Description of hazardous waste

AVIATION AND MOTOR GASOLINE

B. EPA Hazardous Waste Code(s)

D018, D001

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W211

F. Waste Minimization Code

A

G. Quantity

627.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

401.0

Site 2 B. EPA ID of facility to which waste was shipped

TXD074196338

C. Management Method Code

H141

D. Total Quantity Shipped

226.0

Comments

GM 6 Waste Characteristics

A. Description of hazardous waste

CHEM WIPES, MASKING AND PREP MATERIAL, PPE WITH SPENT PAINT

B. EPA Hazardous Waste Code(s)

D007, D035

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

76.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

76.0

GM 7 Waste Characteristics

A. Description of hazardous waste

CHEM WIPES, NITRILE GLOVES AND SPENT SOLVENTS

B. EPA Hazardous Waste Code(s)

D001, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

7.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

7.0

Comments

GM 8 Waste Characteristics

A. Description of hazardous waste

CHEM WIPES, RAGS WITH OIL, GREASE, LUBRICANTS

B. EPA Hazardous Waste Code(s)

D006

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

108.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

108.0

Comments

GM 9 Waste Characteristics

A. Description of hazardous waste

CHEMICAL WIPES & APPLICATORS WITH GREASE, OILS AND BORE CLEANER

B. EPA Hazardous Waste Code(s)

D008

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

212.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

212.0

GM 10 Waste Characteristics

A. Description of hazardous waste

CHEMICAL WIPES WITH SOLVENT, OILS, GREASE AND SEALANTS

B. EPA Hazardous Waste Code(s)

D006

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

160.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

160.0

Comments

GM 11 Waste Characteristics

A. Description of hazardous waste

CHEMICAL WIPES, CLOTH RAGS, NITRILE GLOVES, APPLICATORS WITH SPENT SOLVENTS

B. EPA Hazardous Waste Code(s)

D005, D006, D007, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

102.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

102.0

Comments

GM 12 Waste Characteristics

A. Description of hazardous waste

CHEMICAL WIPES, CLOTH RAGS, PPE, MASKING MATERIAL, SPENT SEALANTS

B. EPA Hazardous Waste Code(s)

D006, D035

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

97.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

97.0

GM 13 Waste Characteristics

A. Description of hazardous waste

CLOTH RAGS AND CHEMICAL WIPES WITH SPENT SOLVENT

B. EPA Hazardous Waste Code(s)

D001, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

61.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

61.0

Comments

GM 14 Waste Characteristics

A. Description of hazardous waste

CONSOLIDATED PRODUCT CONTAMINATED MATERIALS

B. EPA Hazardous Waste Code(s)

D005, D006, D007, D008, D011, D018, D035, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

1674.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

1674.0

Comments

GM 15 Waste Characteristics

A. Description of hazardous waste

CONSOLIDATED PRODUCT CONTAMINATED MATERIALS

B. EPA Hazardous Waste Code(s)

D005, D006, D007, D008, D018, D035, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

2941.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

2941.0

GM 16 Waste Characteristics

A. Description of hazardous waste

CORROSIVE AND TOXIC

B. EPA Hazardous Waste Code(s)

D007, D002

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W001

F. Waste Minimization Code

A

G. Quantity

11.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

11.0

Comments

GM 17 Waste Characteristics

A. Description of hazardous waste

CORROSIVE OXIDIZER

B. EPA Hazardous Waste Code(s)

D001, D002

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W001

F. Waste Minimization Code

A

G. Quantity

35.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

35.0

Comments

GM 18 Waste Characteristics

A. Description of hazardous waste

CORROSIVES

B. EPA Hazardous Waste Code(s)

D002

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W001

F. Waste Minimization Code

A

G. Quantity

130.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

130.0

GM 19 Waste Characteristics

A. Description of hazardous waste

FILTER MEMBRANE, TEST PADS WITH ETHER, GASOLINE, AND JP8

B. EPA Hazardous Waste Code(s)

D018, D001

C. State Hazardous Waste Code(s)

D. Source Code

G13

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

378.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

275.0

Site 2 B. EPA ID of facility to which waste was shipped

TXD074196338

C. Management Method Code

H141

D. Total Quantity Shipped

103.0

Comments

GM 20 Waste Characteristics

A. Description of hazardous waste

FILTERS STAGE 2 BLANKET, STAGE 3 POCKET

B. EPA Hazardous Waste Code(s)

D007, D035

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

219.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

219.0

Comments

GM 21 Waste Characteristics

A. Description of hazardous waste

FLAMMABLE IGNITABLE

B. EPA Hazardous Waste Code(s)

D001

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W001

F. Waste Minimization Code

A

G. Quantity

1516.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

1371.0

Site 2 B. EPA ID of facility to which waste was shipped

TXD074196338

C. Management Method Code

H141

D. Total Quantity Shipped

145.0

GM 22 Waste Characteristics

A. Description of hazardous waste

PAINT BOOTH PREPARATION AND FILTRATION MATERIAL

B. EPA Hazardous Waste Code(s)

D005, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

110.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

110.0

Comments

GM 23 Waste Characteristics

A. Description of hazardous waste

B. EPA Hazardous Waste Code(s)

D007, D035

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

2768.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

2768.0

Comments

GM 24 Waste Characteristics

A. Description of hazardous waste

PAINT RELATED

B. EPA Hazardous Waste Code(s)

D001, D007

C. State Hazardous Waste Code(s)

D. Source Code

G11

Management Method Code E. Form Code

W001

F. Waste Minimization Code

A

G. Quantity

2918.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

1606.0

Site 2 B. EPA ID of facility to which waste was shipped

TXD074196338

C. Management Method Code

H141

D. Total Quantity Shipped

1312.0

GM 25 Waste Characteristics

A. Description of hazardous waste

PAINT RELATED LIQUID WASTE

B. EPA Hazardous Waste Code(s)

D001, D005, D007, D035, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W209

F. Waste Minimization Code

A

G. Quantity

455.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H061

D. Total Quantity Shipped

455.0

Comments

GM 26 Waste Characteristics

A. Description of hazardous waste

PARTS WASHER FLUID AND PRODUCT CONTAMINATED MATERIAL

B. EPA Hazardous Waste Code(s)

D006

C. State Hazardous Waste Code(s)

D. Source Code

G01

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

38.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

38.0

Comments

GM 27 Waste Characteristics

A. Description of hazardous waste

PRODUCT CONTAMINATED MATERIALS

B. EPA Hazardous Waste Code(s)

D005, D006, D007, D008, D018, D023, D035, F003

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

101.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

101.0

GM 28 Waste Characteristics

A. Description of hazardous waste

PRODUCT CONTAMINATED MATERIALS

B. EPA Hazardous Waste Code(s)

D005, D006, D007, D035, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G06

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

1243.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

1243.0

Comments

GM 29 Waste Characteristics

A. Description of hazardous waste

PRODUCT CONTAMINATED MATERIALS

B. EPA Hazardous Waste Code(s)

D005, D007, D008, D035, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G15

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A

G. Quantity

132.0

UOM

POUNDS

Density

On-site Generation and Management of Hazardous Waste

Off-site Shipment of Hazardous Waste

Site 1 B. EPA ID of facility to which waste was shipped

ALD981020894

C. Management Method Code

H141

D. Total Quantity Shipped

132.0

Comments

GM 30 Waste Characteristics

A. Description of hazardous waste

PRODUCT CONTAMINATED MATERIALS

B. EPA Hazardous Waste Code(s)

D007, D018, D005, D035, F003, F005

C. State Hazardous Waste Code(s)

D. Source Code

G09

Management Method Code E. Form Code

W002

F. Waste Minimization Code

A