FTQW072002 AF 813 RCS 20-111 Repair Fuel Cell Revised.pdf

1/20/2021 AF FORM 813

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REQUEST FOR ENVIRONMENTAL IMPACT ANALYSIS Report Control Symbol (RCS):

20-111

INSTRUCTIONS: Section I to be completed by Proponent; Sections II and III to be completed by Environmental Planning Function. Continue on separate sheets as necessary. Reference appropriate item number(s).

SECTION I - PROPONENT INFORMATION

1. TO (Environmental Planning Function)

354 CES/CEI

2. FROM (Proponent organization and functional address symbol) Air Force - 168 CES/BCE

2a. TELEPHONE NO.

377-8574

3. TITLE OF PROPOSED ACTION

UPDATE FTQW072002 Repair Fuel Cell B1171 (RCS 18-057)

4. PURPOSE AND NEED FOR ACTION (Identify decision to be made and need date)

1. What do you intend to accomplish and why is the action necessary?

Building 1171 was designed in 1992 and constructed in 1997-1998 as a Fuel Cell facility. There have been no renovations or substantial repairs completed since construction. A comprehensive investigative services report completed by a local A/E in 2015 indicates that the facility is currently in satisfactory condition. However the facility does possess some system deficiencies and deviations from current code requirements that warrant repair prior to the next comprehensive facility renovation, expected to be completed in 2037 in order to continue to support current and future mission efforts.

2. What is currently being done to meet the need?

Minor repairs are done as necessary until the entire project can be implemented.

3. Provide any additional details related to the Purpose and Need for Action.

Need Date: 01/15/2021

5. DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES (DOPAA) (Provide sufficient details for evaluation of the total action.)

1. What other alternatives have been considered (to include the no action alternative)?

The facility will not operate as safely and efficiently as is needed and expected in order to properly maintain KC-135 aircraft fuel systems and tanker delivery systems.

Deficiencies in fire detection and suppression systems pose an increasing danger to occupants, aircraft, and maintenance processes. especially considering the fire dangers inherent in fuel systems maintenance operations. Loss of personnel, aircraft and the facility all have a greater possibility of occurrence given the state of the facility systems and the use or antiquated technologies for lire suppression. If HVAC systems are not operated and maintained appropriately, rapid facility deterioration is possible in this Arctic climate. The facility will age prematurely, require replacement before its normally expected life, and inhibit aircraft maintenance operations, leading to loss of mission capability.

2. What alternatives were eliminated from consideration and why?

There are no logical alternatives to conducting these repairs. The building must be brought up to code to support life/safety and mission.

3. Please provide a description of the construction action and timing when it will occur.

HVAC, fire detection, and fire suppression are the primary building systems with significant deficiencies.

HVAC includes both facility components as well as additional exhaust equipment used for aircraft maintenance. Both facility and hangar fire detection and suppression systems are deficient. The current Aqueous Film Forming Foam (AFFF) hangar system will be replaced with a High Expansion Foam (HEF) system as part of this effort.

2/9 n addition to above, areas for repair/upgrade have been identified as, but not limited to:

• Minor roofing repairs

• Replacement of main heating system pumps

• Repair of hydronic heating pumps

• Addition of pipe insulation

• Exhaust fan repairs

• Replacement of heating supply fan three-way valves

• Repair or replacing ventilation fans

• Upgrading wet and dry pipe sprinkler systems to correct deficiencies and modernize to current code requirements

• Replacement of fire alarm panel

• Addition of water fountain with water bottle filler to the office area

Additional work not addressed in original AFF813

- New egress paths

- New underground electric service (to include transformer pads)

- New fire hydrants (included as a bid option)

4. Describe the project location. Attach map(s)/diagram(s) – make sure to include an overview map of where your requested project area is on the installation.

See attached map for the additional work locations.

5. Describe additional project requirements: 1) Construction and site preparation requirements (include approx. area of ground to be disturbed); 2) Does the project require a laydown yard or storage area? If so, describe the location and groundwork required.

6. Describe additional project requirements: 3) Will soil boring/sampling/potholing occur during a design phase? If so, a separate dig permit will be required; 4) Detailed operational activities; 5) Equipment/material lists.

7. Provide any additional details related to the Description of the Proposed Action and Alternatives.

Map Attachments:

AKANG Eielson B1171_Civil Drawings 65- - clouds.pdf

6. PROPONENT APPROVAL (Name and Grade) Lipyanic Debbie DOD -debbie.m.lipyanic

6a. SIGNATURE Submitted on behalf of: Simpson, David R. Maj (david.simpson.32@us.af.mil - 377- 8574) //Lipyanic Debbie DOD -debbie.m.lipyanic i:0e.t|fedvis|debbie.m.lipyanic//

6b. DATE 12/21/2020

SECTION II - PRELIMINARY ENVIRONMENTAL SURVEY (Check appropriate box and describe potential environmental effects including cumulative effects.) (+ = positive effect; 0 = no effect; - = adverse effect; U = unknown effect)

+ 0 - U

7. AIR INSTALLATION COMPATIBLE LAND USE/ZONE USE (Noise, accident potential, encroachment, etc.) X

8. AIR QUALITY (Emissions, Attainment status, state implementation plan, etc.) X

9. WATER RESOURCES (Drinking water, wastewater, quality, quantity, X https://intelshare.intelink.gov/sites/USAFNEPA/Attachments/1608589731373/AKANG%20Eielson%20B1171_Civil%20Drawings%2065-%20-%20clouds.pdf

3/9 source, water features, etc.)

10. SAFETY AND OCCUPATIONAL HEALTH (Asbestos/lead-based paint/radiation/chemical exposure, explosives safety quantity distance, bird/wildlife aircraft hazard, etc.)

X

11. HAZARDOUS MATERIALS/WASTE (Use/storage/generation, solid waste, toxic materials, etc.) X

12. BIOLOGICAL RESOURCES (Wetlands/floodplains, threatened or endangered species, etc.) X

13. CULTURAL RESOURCES (Burial sites, archaeological, historical, etc.) X

14. GEOLOGY AND SOILS (Topography, minerals, geothermal, Installation Restoration Program, seismicity, etc.) X

15. SOCIOECONOMIC (Employment/population projections, school and local fiscal impacts, etc.) X

16. OTHER (Potential impacts not addressed above, such as Host Nation considerations/concerns for non-US locations.) X

SECTION III - ENVIRONMENTAL ANALYSIS DETERMINATION

17. PROPOSED ACTION QUALIFIES FOR CATEGORICAL EXCLUSION (CATEX) #A2.3.10. ; OR

PROPOSED ACTION DOES NOT QUALIFY FOR A CATEX; FURTHER ENVIRONMENTAL

ANALYSIS IS REQUIRED.

18. REMARKS

Secondary CATEX selections: A2.3.8.

• Please reference below comments from the 354CES/CEIE Environmental Office. Compliance with the remarks/comments/requirements is mandatory. Substantial or significant changes in project scope will trigger the need for a new AF Form 813 to be submitted.

• Eielson AFB is not a non-attainment or maintenance area, therefore the Clean Air Act General Conformity Rule does not apply.

• The scope of this Preliminary Environmental Survey is based on the Description of Project Actions and Alternatives (DOPAA), as stated in Block 5 and the project is either o Eligible for this Categorical Exclusion (CATEX), as authorized under 32 CFR 989, provided that the proponent does not substantially change the scope of the project, follows the instructions listed in the remarks section, and any additional instructions, or o Ineligible for a CATEX, in which case either an Environmental Assessment (EA) or Environmental Impact Statement (EIS) is indicated as required (blocks 17/18).

• Project proponents are also required to abide by all other relevant environmental requirements even if not specifically listed. Please follow up with the relevant Program Mangers or Subject Matter Experts (SMEs) for comment clarification and/or further advice, if necessary.

• This Environmental Impact Analysis (AFF813) expires one year from the date in block 19b. If expired, a new Air Force form 813 will be submitted to 354 CES/CEIEA and 354 CES/CEIEA must complete the form 813 before project may commence.

• CATEX No. and description: This action qualifies for an exemption under CATEX A2.3.8. Performing interior and exterior construction within the 5-foot line of a building without changing the land use of the existing building. This action qualifies for an exemption under CATEX A2.3.10. Routine facility maintenance and repair that does not involve disturbing significant quantities of hazardous materials such as asbestos and lead-based paint.

• 354 CES/CEIEC AIR QUALITY PROGRAM MANAGER—Ms. Heidi Young; heidi.young.6@us.af.mil;

907-377-1815

• 354 CES/CEIEC HAZARDOUS MATERIALS PROGRAM MANAGER—Mr. Justin Hogrefe;

justin.hogrefe.1@us.af.mil; 907-377-5209 & Mrs. Lindsey McCord; lindsey.mccord.1@us.af.mil; 907-377-

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• 354 CES/CEIEC SOCIOECONOMIC IMPACTS— Mr. Justin Hogrefe; justin.hogrefe.1@us.af.mil; 907-377-

• 354 CES/CEIEC HAZARDOUS WASTE PROGRAM MANAGER (RCRA Program)—Mrs. Ariane Glover;

ariane.glover@us.af.mil; 907-377-1659 & J. Galen Kornowske; joseph.kornowske@us.af.mil; 907-377-4017

• 354 CES/CEIEC TOXICS/EPCRA PROGRAM—Mrs. Ariane Glover; ariane.glover@us.af.mil; 907-377- 1659; Mr. Justin Hogrefe; justin.hogrefe.1@us.af.mil; 907-377-5209

• 354 CES/CEIEC ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) COORDINATOR—Mrs. Ariane Glover; ariane.glover@us.af.mil; 907-377-1659

• 354 CES/CEIEC SOLID WASTE PROGRAM MANAGER—Mr. Lonnie Britton; lonnie.britton@us.af.mil;

907-377-3313

• 354 CES/CEIEC SPILLS PROGRAM MANAGER—Mrs. Sara Kline; sara.kline@us.af.mil; 907-377-3365

• 354 CES/CEIEC STORAGE TANKS (POL) PROGRAM MANAGER—Mrs. Sara Kline;

sara.kline@us.af.mil; 907-377-3365

• 354 CES/CEIEC WATER QUALITY PROGRAM MANAGER—Mr. John Conover;

john.conover@us.af.mil; 907-377-7725

• 354 CES/CEIEA NATURAL/BIOLOGICAL RESOURCES PROGRAM MANAGER— Mr. Ron Gunderson; ronald.gunderson@us.af.mil; 907-377-5182

• 354 CES/CEIEA CULTURAL RESOURCES PROGRAM MANAGER— Mr. Ron Gunderson;

ronald.gunderson@us.af.mil; 907-377-5182

• 354 CES/AFCEC/CZO GEOLOGY & SOILS—INSTALLATION RESTORATION PROGRAM (IRP) &

CERCLA Program— Mr. Joseph Price; joseph.price.17@us.af.mil; 907-377-3578 or Ms. Kris Smith; 907-377- 4299; kristina.smith.10@us.af.mil

• 354 CES/CENP COMMUNITY PLANNING PROGRAM MANAGER—Mr. Duane Hoskins;

duane.hoskins.1@us.af.mil; 907-377-4251or SrA Austin Folse; austin.folse@us.af.mil; 907-377-5159

• 354 CES/CEIAP REAL PROPERTY PROGRAM MANAGER—Mr. Brian Chacho; brian.chacho@us.af.mil;

907-377-3142

• 354 FW/SEG OCCUPATIONAL SAFETY PROGRAM MANAGER—MSgt Ashley Pascas;

ashley.pascas@us.af.mil; 907-377-4260 or TSgt Joseph Thomson; joseph.thomson.1@us.af.mil; 907-377-4260 or mishap@us.af.mil

• 354 MDOS/SGOJ OCCUPATIONAL HEALTH PROGRAM MANAGER—BIOENVIRONMENTAL

ENGINEERING: TSgt Ann Turner; ann.e.turner12@mail.mil or usaf.eielson.354-mdg.mbx.bioenvironmental@mail.mil; 907-377-6687

• Mrs. Amanda Gallagher, 354 CES/CEIE, Chief, Environmental Element; amanda.gallagher.5@us.af.mil;

907-377-5643

19. ENVIRONMENTAL PLANNING

FUNCTION CERTIFICATION (Name and Grade) Hogrefe, Justin GS-12

19a. SIGNATURE //Hogrefe Justin DOD - justin.l.hogrefe i:0e.t|fedvis|justin.l.hogrefe//

19b. DATE 01/19/2021

AF IMT 813, 199990901, V1 THIS FORM CONSOLIDATES AF FORMS 813 AND 814.

PREVIOUS EDITIONS OF BOTH FORMS ARE OBSOLETE.

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CONTINUATION SHEET

Review Comments:

AICUZ/Land Use (12/22/2020 - Folse Austin DOD MIL - austin.n.folse [User]) There is no impact to AICUZ or land use.

AFCEC Restoration (12/22/2020 - Price Joseph DOD - joseph.e.price1) Interior construction only. No comments or concerns.

Tanks (12/22/2020 - Kline Sara DOD - sara.d.kline)

• All POL and hazardous material leaks/spills must be reported to 911. Eielson Fire Dispatch will call the spill line (377-7745). Eielson Environmental will conduct all communication with the Alaska Department of Environmental Conservation and/or US Environmental Protection Agency and others, if required. Discovery of historical contamination must also be reported by calling the spill line.

• The addition or removal of ASTs, USTs, OWS, transformers, etc. greater than 55 gallons must be reflected in EAFB’s Oil Discharge Prevention and Contingency Plan. Coordinate with Tanks Program Manager and provide all applicable information regarding new or upgraded tanks/containers. All USTs/ASTs must comply with federal and state regulations.

Water Resources (12/22/2020 - Conover John DOD - john.e.conover1) no comment, dec 22

Air Quality (12/31/2020 - Young Heidi DOD - heidi.j.young) Contact 354 CES/CEOII to determine if the buildings and structures are included in the EAFB asbestos register and if asbestos is present in these areas.

Contact EAFB HVAC if refrigerants or refridgeration units are being removed or replaced to determine if they are tracked by EAFB.

ANG air emission units (stationary sources) are not part of the EAFB Title V Permit and are the responsibility of ANG.

Comply with the Eielson AFB Fugitive Dust Emission Plan by controlling fugitive dust emissions during the project unless prohibited by contaminated soil requirements. Fugitive dust includes airborne dust generated by construction, dust from vehicles operating on unpaved surfaces, transfer or transport of dust producing materials, soil, stockpiling, etc. and must be controlled at the construction site, along haul routes, and in and around staging areas. Water spraying shall be conducted as necessary, determined by contracting officer, to minimize fugitive dust generation. Spraying operations must also comply with the Stormwater Construction General Permit requirements as applicable. Limit traffic speeds on all unpaved road surfaces to 15 mph. Any uncontaminated dirt or mud, which is tracked onto paved roadways must be cleaned away that day. Depending on conditions, the roadway will be watered before cleaning. If a street sweeper is used, it will have a water system that controls dust around the sweeper during operation. For a copy of the Eielson AFB Fugitive Dust Emission Plan contact Air Quality Program Manager.

Hazardous Materials/Waste (01/05/2021 - Hogrefe Justin DOD - justin.l.hogrefe) All Hazardous Materials (HM) must be submitted, reviewed, approved, and tracked through Enterprise, Environmental, Safety, & Occupational Health Management Information System (EESOH-MIS) (unless exempted), in accordance with, and to maintain compliance with the following:

• Air Force Manual (AFMAN) 32-7002: Environmental Compliance & Pollution Prevention (4 February 2020);

• Eielson AFB Hazardous Materials Management Plan (November 2019);

• Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016;

• Executive Order 12856 (August 3, 1993);

• Pollution Prevention Act (PPA) of 1990;

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• Public Law 99-499 (Oct. 17, 1986); 42 U.S.C. 11001, Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986;

• 40 CFR Parts 350, 355, 370, and 372, Environmental Protection & Community Right-to-Know Act (EPCRA) of 1986;

• Sections 101-103 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980;

• 15 U.S.C. §2601 et seq., Toxic Substances Control Act of 1976, Chemical Data Reporting (CDR) requirements

A hazardous material is any substance defined by OSHA as a hazardous substance requiring a SDS. Hazardous materials that need to be reported include but are not limited to chemicals, paints, thinners, sealing compounds, strippers, glues, solvents, all petroleum products including oils, hydraulic fluids, and fuels stored on-site (fuels in vehicles are exempt), pesticides, adhesives, acids, flammables, corrosives, oxidizers, compressed gases (such as but not limited to oxygen, acetylene, propane, flammable and non-flammable gases), all aerosols, and all materials containing hazardous substances.

Hazardous Material Storage: Hazardous materials shall be managed properly at all times while on Eielson AFB. Containers shall be in good condition and shall be properly labeled with the contents and hazard class (flammable, corrosive, oxidizer, etc.) at all times. Containers shall be closed at all times when not in use, hazardous materials shall be kept under cover to protect them from the elements and to prevent storm water runoff contamination. Tanks and 55-gallon liquid drums shall have secondary containment. Gas cylinders shall be maintained in the upright position with caps on and shall be secured with chains to prevent them from falling over. Gas storage areas shall have signs indicating what type gases are stored in the area (i.e., flammable, oxidizer, non-flammable, etc.). NO SMOKING signs shall be posted in all hazardous materials storage areas. In addition, all hazardous materials shall be segregated in storage according to compatibility (i.e., flammables shall not be stored with corrosives, corrosives shall not be stored with oxidizers, flammable gases shall not be stored with flammable liquids, etc.). Eielson AFB is subject to inspections at any time from outside agencies (EPA, ADEC, and OSHA).

Hazardous Materials/Waste (01/06/2021 - Glover Ariane DOD - ariane.m.glover) All contractors performing work on Eielson AFB are required to complete onsite hazardous waste training provided by 354 CES/CEIEC. Contractor training must be completed two weeks prior to field work start date and prior to receiving the Environmental Element signature on the Work Clearance Request (AF Form 103).

Please contact 377-1659 to schedule a training for handling hazardous wastes, including aerosol cans management. All costs associated with waste disposal are the responsibility of the contractor. Empty aerosol cans are the only waste accepted at the base Hazardous Waste Facility for disposal. All Hazardous and Universal waste must be managed in accordance with the requirements for large quantity generators (40 CFR

262.17 and 40 CFR 273, respectively) under the Resource Conservation Recovery Act. Hazardous waste and non-regulated waste manifests must be signed by a designated AF POC prior to shipment off-base. Please coordinate signature through the base Hazardous Waste Facility (377-1668) 10-days prior to planned transport.

Prior to building renovation, all Hazardous and Universal waste to be disposed will need to be identified and included in the Environmental Protection Plan outlining proper management and disposal procedures. Special handling and disposal is required for, but not limited to the following items: lamps (LED, fluorescent, high intensity discharge, neon, mercury-vapor, high-pressure sodium, metal-halide lamps), batteries, and mercury

7/9 containing equipment (thermostats, manometers, barometers, light switches, regulators, water treatment gauges, gas safety relays), and glycol. Additional items of concern are radioactive materials that must be processed through the base Radiation Safety Officer, including, but not limited to smoke detectors, exit signs, and some capacitors.

Disposal of any Aqueous Film Forming Foam (AFFF) or AFFF contaminated media from the fire suppression system must abide by a five step process:

1. Identify AFFF-related waste media to be managed:

a. Liquid. Includes investigative derived waste (IDW), rinsate, residual treatment system liquid, AFFF liquid concentrates/solutions, liquids derived from construction and liquid waste captured from routine system inspections, test, and maintenance, accidental releases, and emergency responses.

b. Soil/sediment. Includes IDW, Remedial Investigation/Action derived waste, and contaminated soil/sediment excavated from a construction project, spill, accidental release, or emergency response

c. Other solids. Includes used personal protective equipment (PPE), sampling equipment, and construction debris (e.g., contaminated rags, tubing, booms, empty containers, concrete, asphalt, and other building materials, etc.).

d. Spent treatment media (non-residential). Includes spent carbon, resin and other treatment media.

e. AFFF (C6 and legacy C8) product. Includes actual product and product infiltrated by water not associated with an accidental release or emergency response.

2. Containerize, sample and characterize generated waste

a. Characterize AFFF-related waste (when applicable) using methods compliant with Quality Systems Manual (QSM) 5.2, Table B-15, or the most current method required by DoD Environmental Laboratories Accreditation Program-accredited laboratories.

3. Determine media-specific treatment/disposal decision points

4. Evaluate media-specific treatment technology options for final disposition.

a. Incineration/thermally destructive technology at an approved permitted facility. Thermal regeneration temperature must reach and be sustained above 1,700 degrees Fahrenheit throughout destruction process.

b. RCRA Subtitle C landfill. Used for disposal of hazardous solid waste. AFFF product or if AFFF-related waste is co-mingled with another COC with concentrations exceeding regulatory standards and regulated hazardous waste was identified and properly managed for disposal.

c. Solidification then landfill. Used for solid and/or liquid waste contaminated with AFFF product at high concentration (e.g., spent media, liquid and solid wastes at fire training facilities). Certain liquid wastes can be solidified prior to landfill in either a Subpart C or Subpart D landfill.

5. Determine Final Disposition for Preferred or Alternate (coordinate with Hazardous Waste PM for review and final approval of proposed disposal method).

AFFF must be disposed of properly. Although it is not characteristic for hazardous waste, nor is it listed as a regulated hazardous waste under RCRA, ADEC recommends that it be solidified and shipped to a non-hazardous waste landfill out of state that will accept this waste, or thermally destructed at a RCRA Part B Subpart O incineration facility. When shipping PFOS-containing AFFF out of state, use a licensed waste transportation and disposal company. AFFF may not be disposed of at sea, or through septic, stormwater, or municipal sewer systems.

Any High Expansion Foam (HEF) to be disposed must be tested to confirm the presence or absence of PFAS.

HEF that contains no PFAS will required disposal at an approved RCRA, Subtitle D landfill and must be transported using a non-hazardous waste manifest.

Other (01/06/2021 - Britton Lonnie DOD - lonnie.j.britton) No comments or concerns

Other (01/07/2021 - Glover Ariane DOD - ariane.m.glover) Lead-Based Paint:

Based on the age of the facility (1997), no known lead based paint concerns.

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EMS:

All contractors working on the installation are required to take the Environmental Management System (EMS) General Awareness Training (course EMS100AFIT00004) offered on TEACH (7 min duration). Training can be accessed electronically at the following site: https://usaf.learningbuilder.com. Training certificates will be required as a submittal and must be provided prior to receiving the Environmental Element signature on the AF Form 103, Work Clearance Request.

Natural Resources (01/08/2021 - Gunderson Ronald DOD - ronald.l.gunderson) No impact to biological resources.

Cultural Resources (01/08/2021 - Gunderson Ronald DOD - ronald.l.gunderson) No impact to cultural resources.

Legal (01/08/2021 - Patino Luisa DOD - luisa.f.patino) Proposed action qualifies for CATEX A2.3.10 and A2.3.8.

Bioenvironmental (01/11/2021 - Turner Ann DOD - ann.e.turner) No concerns

Other (01/11/2021 - Chacho Brian DOD - brian.e.chacho) Please submit a DD 1354 at the conclusion of the project.

Safety and Occupational Health (01/12/2021 - Thomson Joseph DOD - joseph.r.thomson1) Reviewed

AFCEC Restoration (01/12/2021 - Smith Kristina DOD - kristina.a.smith1) Project is in areas of known contamination for PFOS/PFOA, specifically within source areas SS303P and SS314P. An approved Site Specific Sample Analysis Plan (SAP) is required before any excavation can begin.

Hazardous Materials/Waste (01/20/2021 - Glover Ariane DOD - ariane.m.glover) All contractors performing work on Eielson AFB are required to complete onsite hazardous waste training provided by 354 CES/CEIEC. Contractor training must be completed two weeks prior to field work start date and prior to receiving the Environmental Element signature on the Work Clearance Request (AF Form 103).

Please contact 377-1659 to schedule a training for handling hazardous wastes, including aerosol cans management. All costs associated with waste disposal are the responsibility of the contractor. Empty aerosol cans are the only waste accepted at the base Hazardous Waste Facility for disposal. All Hazardous and Universal waste must be managed in accordance with the requirements for large quantity generators (40 CFR

262.17 and 40 CFR 273, respectively) under the Resource Conservation Recovery Act. Hazardous waste and non-regulated waste manifests must be signed by a designated AF POC prior to shipment off-base. Please coordinate signature through the base Hazardous Waste Facility (377-1668) 10-days prior to planned transport.

Prior to building renovation, all Hazardous and Universal waste to be disposed will need to be identified and included in the Environmental Protection Plan outlining proper management and disposal procedures. Special handling and disposal is required for, but not limited to the following items: lamps (LED, fluorescent, high intensity discharge, neon, mercury-vapor, high-pressure sodium, metal-halide lamps), batteries, and mercury containing equipment (thermostats, manometers, barometers, light switches, regulators, water treatment gauges, gas safety relays), and glycol. Additional items of concern are radioactive materials that must be processed through the base Radiation Safety Officer, including, but not limited to smoke detectors, exit signs, and some capacitors.

Disposal of any Aqueous Film Forming Foam (AFFF) or AFFF contaminated media from the fire suppression system must abide by a five step process:

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1. Identify AFFF-related waste media to be managed:

a. Liquid. Includes investigative derived waste (IDW), rinsate, residual treatment system liquid, AFFF liquid concentrates/solutions, liquids derived from construction and liquid waste captured from routine system inspections, test, and maintenance, accidental releases, and emergency responses.

b. Soil/sediment. Includes IDW, Remedial Investigation/Action derived waste, and contaminated soil/sediment excavated from a construction project, spill, accidental release, or emergency response.

c. Other solids. Includes used personal protective equipment (PPE), sampling equipment, and construction debris (e.g., contaminated rags, tubing, booms, empty containers, concrete, asphalt, and other building materials, etc.).

d. Spent treatment media (non-residential). Includes spent carbon, resin and other treatment media.

e. AFFF (C6 and legacy C8) product. Includes actual product and product infiltrated by water not associated with an accidental release or emergency response.

2. Containerize, sample and characterize generated waste

a. Characterize AFFF-related waste (when applicable) using methods compliant with Quality Systems Manual (QSM) 5.2, Table B-15, or the most current method required by DoD Environmental Laboratories Accreditation Program-accredited laboratories.

3. Determine media-specific treatment/disposal decision points

4. Evaluate media-specific treatment technology options for final disposition.

a. Incineration/thermally destructive technology at an approved permitted facility. Thermal regeneration temperature must reach and be sustained above 1,700 degrees Fahrenheit throughout destruction process.

b. RCRA Subtitle C landfill. Used for disposal of hazardous solid waste. AFFF product or if AFFF-related waste is co-mingled with another COC with concentrations exceeding regulatory standards and regulated hazardous waste was identified and properly managed for disposal.

c. Solidification then landfill. Used for solid and/or liquid waste contaminated with AFFF product at high concentration (e.g., spent media, liquid and solid wastes at fire training facilities). Certain liquid wastes can be solidified prior to landfill in either a Subpart C or Subpart D landfill.

5. Determine Final Disposition for Preferred or Alternate (coordinate with Hazardous Waste PM for review and final approval of proposed disposal method).

AFFF must be disposed of properly. Although it is not characteristic for hazardous waste, nor is it listed as a regulated hazardous waste under RCRA, ADEC recommends that it be solidified and shipped to a non-hazardous waste landfill out of state that will accept this waste, or thermally destructed at a RCRA Part B Subpart O incineration facility. When shipping PFOS-containing AFFF out of state, use a licensed waste transportation and disposal company. AFFF may not be disposed of at sea, or through septic, stormwater, or municipal sewer systems.

Any High Expansion Foam (HEF) to be disposed must be tested to confirm the presence or absence of PFAS.

HEF that contains no PFAS will required disposal at an approved RCRA, Subtitle D landfill and must be transported using a non-hazardous waste manifest.

Attachments:

Eielson B1171 65- (B-1) Submittal Basis of Design pp1-52.pdf https://intelshare.intelink.gov/sites/USAFNEPA/Attachments/1608589731373/Eielson%20B1171%2065-%20(B-1)%20Submittal%20Basis%20of%20Design%20pp1-52.pdf