Section_J_-_RCRA_Final_Permit_with_Class_1_Modification_May2019.pdf

VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY

HAZARDOUS WASTE MANAGEMENT PERMIT

FOR STORAGE AND CORRECTIVE ACTION

U.S. Army Garrison Fort Belvoir U.S. Route 1

Fort Belvoir, VA 22060-5116

EPA I.D. No. VA7213720082

COMMONWEALTH OF VIRGINIA

DEPARTMENT OF ENVIRONMENTAL QUALITY

Street address: 629 East Main Street, Richmond, Virginia 23219

Mailing address: P.O. Box 1105, Richmond, Virginia 23218 www.deq.virginia.gov fd i

David K. Paylor Director

(804) 698-4000 1-800-592-5482

Molly Joseph Ward Secretary of Natural Resources

HAZARDOUS WASTE MANAGEMENT PERMIT

FOR STORAGE AND CORRECTIVE ACTION

Permittee: U. S. Army Garrison Fort Belvoir U. S. Route 1 Fort Belvoir, VA 22060-5116

EPA I.D. No.: VA7213720082

Pursuant to Chapter 14, Article 4, Title 10.1, Code of Virginia (1950), as amended; and regulations promulgated thereunder by the Virginia Department of Environmental Quality, a Permit is issued to the U.S. Army Garrison, Fort Belvoir (hereinafter called the Permittee), to store hazardous waste at a facility located in Fort Belvoir, Virginia in Fairfax County on U.S.

Route I, and with a geographic location of latitude 38° 43’ 00” North and longitude 77° 08’ 30” West.

The Permittee shall comply with all terms and conditions set forth in this Permit including Attachments AA through GG. If the Permit and the above attachments conflict, the wording of the Permit shall prevail. The Permittee shall also comply with all applicable regulations contained in the Virginia Hazardous Waste Management Regulations (VHWMR) as codified in Title 9 of the Virginia Administrative Code, Agency 20, Chapter 60 (9 VAC 20-60), and the Resource Conservation and Recovery Act (RCRA) Regulations in 40 CFR Parts 124, 260, 261, 262, 264, 265, 268, and 270 as adopted by reference in the VHWMR. The Commonwealth of Virginia has received authorization for these programs under Section 3006(b) of the (RCRA), 42 U.S.C. § 6926(b), to administer and enforce the RCRA under the VHWMR in lieu of the federal hazardous waste management program. Applicable regulations are those under the VHWMR (9 VAC 20-60) and the RCRA which are in effect on the date of final administrative action on this Permit and as well as any self-implementing statutory provisions and related regulations which are automatically applicable to the Permittee’s hazardous waste management activities, notwithstanding the conditions of this Permit.

Virginia Department of Environmental Quality EPA ID No. VA7213720082 U. S. Army Garrison Fort Belvoir Effective Date: August 10, 2015 iiiiiiiii

TABLE OF CONTENTS

SIGNATURE PAGE .................................................................................................................................... ii

TABLE OF CONTENTS ............................................................................................................................. iii

DEFINITIONS............................................................................................................................................. iv

MODULE I – STANDARD CONDITIONS

MODULE II – GENERAL FACILITY CONDITIONS

LIST OF ATTACHMENTS

ATTACHMENT II.AA – FACILITY DESCRIPTION

ATTACHMENT II.BB – WASTE ANALYSIS PLAN

ATTACHMENT II.CC – INSPECTION SCHEDULE

ATTACHMENT II.DD – SECURITY PROVISIONS AND PROCEDURES TO PREVENT

HAZARDS

ATTACHMENT II.EE – PERSONNEL TRAINING

ATTACHMENT II. FF – CONTINGENCY PLAN

ATTACHMENT II.GG – CLOSURE PLAN

MODULE III - OPERATING CONDITIONS

MODULE IV - SITE-WIDE CORRECTIVE ACTION

LIST OF ATTACHMENTS

ATTACHMENT IV.A – List and Descriptions of Solid Waste Management Units, Hazardous Waste Management Units, and Areas of Concern

ATTACHMENT IV.B – Submission Requirements

ATTACHMENT IV.C – Sampling/Analyte List and Risk Based Concentration Screening

ATTACHMENT IV.D – Health and Safety Plan Guidance

ATTACHMENT IV.E – Quality Assurance Project Plan and Other Quality Control Requirements

ATTACHMENT IV.F – Sampling and Analysis Plan Requirements

ATTACHMENT IV.G – Community Involvement Plan

ATTACHMENT IV.H – Project Management Plan and Schedule Requirements

ATTACHMENT IV.I – Risk Assessment iv

DEFINITIONS

All definitions contained in 40 CFR Sections 124.2, 260.10, 270.2, 264.141, 264.1031, 264.1051, 264.1081, and 9 VAC 20-60 are hereby incorporated, in their entirety, by reference into this Permit. Any of the definitions used below, (a) through (n), shall supersede any definition of the same term given in 40 CFR Sections 124.2, 260.10, 270.2, 264.141, 264.1031, 264.1051,264.1081, and 9 VAC 20-60. Where terms are not defined in the regulations or the Permit, the meaning associated with such terms shall be defined by a standard dictionary reference or the generally accepted scientific or industrial meaning of the term.

Throughout the permit, all references to 40 CFR parts 261-266, 268, 270, 273, 279, are as adopted by reference in the Virginia Hazardous Waste Management Regulations, 9 VAC 20-60.

a. The term “Permit” shall mean the Permit issued by the Virginia Department of Environmental Quality, pursuant to Chapter 14, Article 4, Title 10.1, Code of Virginia (1950), as amended, and the Virginia Hazardous Waste Management Regulations (VHWMR) as codified in Title 9 of the Virginia Administrative Code, Agency 20, Chapter 60 (9 VAC 20-60).

b. The term “Director” shall mean the Director of the Virginia Department of Environmental Quality or his designated representative.

c. The term “Department” shall mean the Virginia Department of Environmental Quality (VDEQ), (with the address as specified in Permit Condition I.I.2).

d. The terms “facility” or “site” shall mean all contiguous portions of the U.S. Army Fort Belvoir as identified in the physical description of the property (including structures, appurtenances, and improvements). This property description is as set forth in Attachment II.AA of this Permit.

e. The term “permitted storage areas” shall mean those portions of the facility used for container storage of hazardous waste as described in Permit Attachment II.AA.

f. The term "Hazardous Waste Management Unit” is a contiguous area of land on or in which hazardous waste is placed, or the largest area in which there is significant likelihood of mixing hazardous waste constituents in the same area. Examples of hazardous waste management units include a surface impoundment, a waste pile, a land treatment area, a landfill cell, an incinerator, a tank and its associated piping and underlying containment system and a container storage area. A container alone does not constitute a unit; the unit includes containers and the land or pad upon which they are placed.

g. The term “release” shall mean any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment of any hazardous waste or hazardous constituents.

h. The term “Area of Concern” shall mean an area at the facility or an off- site area, which is not at this time known to be a solid waste management unit, where v hazardous waste and/or hazardous constituents are present or are suspected to be present as a result of a release from the facility.

i. The term “Hazardous Constituent” shall mean a constituent that caused the Administrator to list the hazardous waste in 40 CFR 261, subpart D or a constituent listed in Table 1 of 40 CFR 261.24.

j. The term “Permittee” shall mean the facility to which the Permit is issued.

k. The term “Regulated Unit” shall mean the unit for which a permit has been issued by DEQ or EPA.

l. The term “EPA” shall mean United States Environmental Protection Agency.

m. The term “Solid Waste Management Unit” shall mean any discernible unit at which solid wastes have been placed at any time, irrespective of whether the unit was intended for the management of solid or hazardous waste. Such units include any area at a facility at which solid wastes have been routinely and systematically released.

n. The term “Days” shall mean calendar days except as otherwise provided herein.

Module I

MODULE I

STANDARD CONDITIONS

MODULE I – STANDARD CONDITIONS

I.A. EFFECT OF PERMIT

The Permittee is authorized to manage hazardous waste in accordance with the conditions of this Permit and in accordance with the applicable provisions of Title 9 of the Virginia Administrative Code, Agency 20, Chapter 60 (9 VAC 20-60). Any management of hazardous waste by the Permittee in the facility which is not authorized by this Permit or 9 VAC 20-60, and for which a permit is required under Chapter 14, Article 4, Title 10.1, Code of Virginia (1950), as amended, is prohibited. Compliance with this Permit constitutes compliance, for the purposes of enforcement, with Chapter 14, Article 4, Title 10.1, Code of Virginia (1950), as amended. This Permit does not convey any property rights of any sort, or any exclusive privilege. Possession of a permit does not authorize any injury to persons or property or invasion of other private rights, or any infringement of Commonwealth or local laws or regulations. Compliance with terms of this Permit may not constitute a defense to any action brought under Chapter 14, Article. 8 of Title 10.1, Code of Virginia (1950) as amended for any other law governing protection of the public or the environment.

I.B. PERMIT ACTIONS

I.B.1. This Permit may be modified, revoked and reissued, or terminated for cause as specified in 40 CFR § 124.5, 270.30(f), 270.41, and 270.43. The filing of a request by the Permittee for a permit modification, revocation and reissuance, or termination, or the notification of planned changes or anticipated noncompliance does not stay the applicability or enforceability of any Permit Condition.

I.B.2. Permit modifications at the request of the Permittee shall be accomplished as specified by

40 CFR § 270.42.

I.B.3. This Permit may be renewed as specified in 40 CFR 270.10(h), and Permit Condition I.D.2. Review of any application for a permit renewal shall consider improvements in the state of control and measurement technology, as well as changes in applicable regulations.

I.C. SEVERABILITY

I.C.1. The provisions of this Permit are severable, and if any provision of this Permit or the application of any provision of this Permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this Permit shall not be affected thereby. Invalidation of any Commonwealth or Federal statutory or regulatory provision which forms the basis for any condition of this Permit does not affect the validity of any other Commonwealth or Federal statutory or regulatory basis for said condition (40 CFR 124.16(a)(2)).

I.C.2. In the event that a condition of this Permit is stayed for any reason, the Permittee shall continue to comply with the related applicable and relevant permit standards in 40 CFR §

270.10(e) until final resolution of the stayed condition unless the Director determines compliance with the related applicable and relevant permit standards would be technologically incompatible with compliance with other conditions of the Permit which have not been stayed.

I.D. DUTIES AND REQUIREMENTS

I.D.1. Duty to Comply

The Permittee shall comply with all conditions of this Permit, except that the Permittee need not comply with the conditions of this Permit to the extent and for the duration such noncompliance is authorized by an emergency permit under 40 § CFR 270.61. Any permit noncompliance, except under the terms of an emergency permit, constitutes a violation of Title 10.1 Code of Virginia (1950), as amended and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification;

or for denial of a permit renewal application.

I.D.2. Duty to Reapply

If the Permittee wishes to continue an activity regulated by this Permit after the expiration date of this Permit, the Permittee shall apply for and obtain a new permit as specified below.

a. The Permittee shall submit a new and complete permit application at least 180 days before the expiration date of the Permit, unless a later date has been granted by the Director.

b. Pursuant to 40 CFR 270.10(h), the Director shall not grant permission for an application to be submitted later than the expiration date of the existing permit (40 CFR § 270.30(b)).

I.D.3. Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an enforcement action to argue that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this Permit (40 CFR § 270.30(c)).

I.D.4. Duty to Mitigate

In the event of noncompliance with the Permit, the Permittee shall take all reasonable steps to minimize releases to the environment, and shall carry out such measures as are reasonable to prevent significant adverse impacts on human health or the environment (40 CFR § 270.30(d)).

I.D.5. Proper Operation and Maintenance

The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this Permit. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of this Permit (40 CFR § 270.30(e)).

I.D.6. Duty to Provide Information

The Permittee shall furnish, to the Director within a reasonable time, any pertinent information which the Director may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this Permit, or to determine compliance with this Permit. The Permittee shall also furnish to the Director, upon request, copies of records required to be kept by this Permit (40 CFR § 270.30(h)).

I.D.7. Inspection and Entry

The Permittee shall allow the Director or an authorized representative, upon the presentation of credentials and other documents as may be required by law, to:

a. Enter at reasonable times upon the Permittee’s premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this Permit;

b. Have access to and copy, at reasonable times, any records that must be kept under conditions of this Permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this Permit;

and

d. Sample or monitor at reasonable times for the purposes of assuring permit compliance or as otherwise authorized by VHWMR, any substances or parameters at any location (40 CFR § 270.30(i)).

I.D.8. Reporting Planned Changes

The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions to the permitted facility (40 CFR § 270.30(l)(1)). This notice shall include a description of all incidents of noncompliance reasonably expected to result from the proposed changes.

I.D.9. Anticipated Noncompliance

The Permittee shall give advance written notice to the Director of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements (40 CFR § 270.30(l)(2)).

I.D.10. New and Modified Portions of Waste Management Unit

The Permittee shall not store hazardous waste in any new or modified portion of the hazardous waste management unit, except as provided in 40 § CFR 270.42, until the Permittee has submitted to the Director, by certified mail or hand delivery, a letter signed by the Permittee and a Virginia-registered professional engineer stating that the facility has been constructed or modified in compliance with the Permit; and:

a. The Director has inspected the modified or newly constructed facility and finds it is in compliance with the conditions of the Permit; or

b. Within 15 days of the date of submission of the letter required pursuant to Permit Condition I.D.10, if the Permittee has not received notice from the Director of his intent to inspect, prior inspection is ·waived and the Permittee may commence storage of hazardous waste (40 CFR § 270.30(l)(2)).

I.D.ll. Twenty-four Hour Reporting

The Permittee shall report any noncompliance which may endanger health or the environment to the Director. Information shall be provided orally within twenty-four

(24) hours from the time the Permittee becomes aware of the circumstances. The information specified in “a” and “b” below shall be included as information which shall be reported orally within 24 hours.

a. Information concerning the release of any hazardous waste that may cause an endangerment to public drinking water supply sources shall be reported.

b. Any information of a release or discharge of hazardous waste or of a fire or explosion at the facility, which could threaten the environment or human health outside the facility, shall be reported.

The description of the occurrence and its cause shall include:

i. Name, address, and telephone number of the owner or operator;

ii. Name, address, and telephone number of the facility;

iii. Date, time, and type of incident;

iv. Names and quantities of material(s) involved;

v. The extent of injuries, if any;

vi. An assessment of actual or potential hazard to the environment and human health outside the facility, where this is applicable; and

vii. Estimated quantity and disposition of recovered material that resulted from the incident.

c. A written submission shall also be provided to the Director within five (5) days of the time the Permittee becomes aware of the circumstances. The written submission shall contain a description of the noncompliance and its cause; the periods of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. The Permittee need not comply with the 5-day written notice requirement only if the Director waives that requirement following verbal notification and the Permittee submits a written report within (15) days of the time the Permittee becomes aware of the circumstances (40 CFR § 270.30(l)(6)(iii)).

I.D.12. Other Noncompliance

The Permittee shall report all other instances of noncompliance not otherwise reported pursuant to Permit Conditions I.D.ll, I.D.13, and I.E.l at the time monitoring reports are submitted. The reports shall contain the information listed in Permit Condition I.D.ll (40 CFR § 270.30(l)(10)).

I.D.13. Other Information

Whenever the Permittee becomes aware that he failed to submit any relevant facts in the permit application, or submitted incorrect information in a permit application or in any report to the Director, the Permittee shall promptly submit such facts or information to the Director (40 CFR § 270.30(l)(11)).

I.E. MONITORING AND RECORDS

I.E.l. Monitoring shall be performed and results shall be reported at the intervals specified in the Permit and in work plans, monitoring and implementation plans required by the Permit.

I.E.2. Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. The method used to obtain a representative sample of the waste to be analyzed must be the appropriate method specified in Appendix I of 40 § CFR 261 or an equivalent method approved by the EPA. Laboratory methods must be those specified in Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (SW-846, 3rd ed., November, 1986, as updated), Standard Methods of Wastewater Analysis (16th ed., 1985, as updated), or an equivalent method· approved by the EPA.

I.E.3. The Permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this Permit, all certifications required by

40 CFR 264.73(b)(19) and records of all data used to complete the application for this Permit, for a period of at least 3 years (or longer if specified elsewhere in this Permit) from the date of the sample, measurement, report, certification, or record. These retention periods may be extended by the request of the Director at any time and are automatically extended during the course of any unresolved enforcement actions regarding this facility.

I.E.4. Records of monitoring information shall include at a minimum:

a. The date, exact place, and time of sampling or measurements;

b. The individual(s) who performed the sampling or measurements;

c. The date(s) analyses were performed;

d. The individual(s) who performed the analyses;

e. The analytical techniques or methods used; and

f. The results of such analyses. (40 CFR § 270.30(j))

I.F. COMPLIANCE NOT CONSTITUTING DEFENSE

Compliance with the terms of this Permit does not constitute a defense to any action brought under Chapter 14, Article 8 of Title 10.1, Code of Virginia (1950), as amended, or any other Commonwealth law governing protection of the public or the environment.

I.G. TRANSFER OF PERMITS

This Permit is not transferable to any person, except after notice to the Director. The Director may require modification or revocation and reissuance pursuant to 40 CFR 124.5, 270.40, 270.41, 270.42, and 270.43 to change the name of the Permittee and incorporate such other requirements as may be necessary. Before transferring ownership or operation of the facility during its operating life, the Permittee shall notify the new owner or operator in writing of the requirements of 40 CFR Part 264 and 40 CFR Part 270 and at the same time shall send a copy of such notice to the Director (40 CFR § 264.12(c)).

I.H. PERMIT EXPIRATION AND CONTINUATION

This Permit will remain in force until the effective date of a new permit, if the Permittee has submitted a timely, complete application pursuant to Permit Condition I.D.2.a and through no fault of the Permittee, the Director has not issued a new permit with an effective date on or before the expiration date of this Permit. All conditions of the continued permit shall remain fully effective and enforceable.

I.I. REPORTS, NOTIFICATIONS AND SUBMISSIONS TO THE DEPARTMENT

I.I.1. The Permittee shall submit biennial report to the Department, which covers facility activities during the previous calendar year. At a minimum this report will include:

a. The generator biennial report pursuant to 40 § CFR 262.41; and

b. The hazardous waste management facility biennial report pursuant to 40 § CFR 270.30(1)(9).

I.I.2. All reports, notifications or other submissions which are required by this Permit to be sent or given to the Director should be sent or be given to:

Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218

For Permit Modifications:

Attention: Mrs. Leslie Romanchik Hazardous Waste Program Manager Telephone Number: (804) 698-4129

For Groundwater or Corrective Action:

Attention: Mr. Brett Fisher Groundwater / Corrective Action Technical Reviewer Telephone Number: (804) 698-4099

Street Address:

629 East Main Street Richmond, VA 23219

Copies of all such correspondence should also be sent to:

Land Program Manager, Northern Virginia Regional Office Department of Environmental Quality 13901 Crown Court Woodbridge, VA 22193

Virginia Program Manager (3WC21) Environmental Protection Agency, Region III 1650 Arch Street Philadelphia, PA 19103-2029

I.I.3 Signatory Requirements

All applications, reports, or information submitted to the Director shall be signed and certified as specified by 40 CFR § 270.11.

I.J. DOCUMENTS TO BE MAINTAINED AT THE FACILITY SITE

Current copies of the following documents, as amended, revised, and modified, shall be maintained at the facility (or other location approved by the Director). These documents shall be maintained during the term of this Permit, including any reissued permit, unless a lesser time is specified in the Permit.

a. The Permit including all attachments, revisions and modifications;

b. The Part A and Part B Permit Applications;

c. The facility’s operating record required by 40 CFR 264.73 and this Permit.

d. Inspection schedules and logs required by 40 CFR 264.15(b)(2) and 264.15(d);

e. Personnel training documents and records required by 40 CFR 264.16 and this Permit; and

f. Closure Plans as required by 40 CFR 264.112(a) and this Permit.

I.K. APPROVAL/DISAPPROVAL OF SUBMISSIONS

I.K.1. The Department will review the plans, reports, schedules and other documents (hereinafter collectively referred to as “submission”) submitted which require the Director or Department approval. The Department will notify the Permittee in writing of the Department’s approval, conditional approval or disapproval of each submission.

I.K.2. Each submission required by this Permit is, upon approval by the Director, incorporated into this Permit. Any noncompliance with such Department- approved submission shall be deemed noncompliance with this Permit. A conditionally approved submission, including any terms of such conditional approval set forth in Department’s decision, shall constitute the Department-approved submission and shall be incorporated into this Permit.

I.K.3. In the event of Department’s conditional approval of submission, the Director shall specify in writing any deficiencies in the submission and the terms upon which approval of the submission is conditioned. If the Permittee disputes any term upon which approval of the submission was conditioned, the Permittee may file an appeal with the Director within 30 days of the approval (as provided for in Rule 2A:2 of the Supreme Court of Virginia).

I.K.4. In the event of Department disapproval of a submission, the Director shall specify the deficiencies in writing. The Permittee shall modify the submission to correct/address the specified deficiencies within a reasonable time period established by the Director taking into account the tasks to be performed, and submit the revised submission to Department for approval.

I.K.5. If the revised submission is disapproved, the Director will notify the Permitte of the deficiencies in writing and specify a schedule for the Permittee to correct the deficiencies and resubmit the submission to Department. The Permittee shall correct the deficiencies as directed by Department, and forward the revised submission within the time period specified by Department. In the event the Permittee disagrees with Department’s disapproval of the revised submission, the Permittee shall notify the DEQ in writing and the disagreement shall be resolved in accordance with the Dispute Resolution provision in permit condition I.L. of this Permit.

I.L. DISPUTE RESOLUTION

I.L.1. Except as otherwise provided in this Permit, in the event the Permittee disagrees, in whole or in part, with Department disapproval of any submission required by this Permit, the Permittee shall notify the Department in writing of its objections, and the basis thereof, within fourteen (14) days of receipt of the Department's disapproval. Such notice shall set forth the specific matters in dispute, the position(s) the Permittee asserts which should be adopted as consistent with the requirements of the Permit, the basis for the Permittee's position, and supporting documentation considered necessary for the Department's determination.

I.L.2. The Department and the Permittee shall have an additional fourteen (14) days from the

Department's receipt of the notification to meet or confer to resolve any disagreement/dispute. In the event agreement is reached, the Permittee shall submit the revised submission and implement the same in accordance with such agreement.

I.L.3. In the event the Permittee and the Department are not able to reach an agreement on the dispute items within the additional 14-day period, the Department will notify the Permittee in writing of its decision on the dispute and the Permittee shall comply with the terms and conditions of the Department's decision in the dispute. The Permittee does not waive its right to assert any and all available defenses in a proceeding to enforce this Permit.

I.L.4. In the event the Permittee disagrees with the Department’s disapproval of a submission or revised submission and the Department’s written decision regarding dispute items, the Permittee may file an appeal with the Director within 30 days of the disapproval (as provided for in Rule 2A:2 of the Supreme Court of Virginia).

Module II

MODULE II

GENERAL FACILITY CONDITIONS

MODULE II – GENERAL FACILITY CONDITIONS

II.A. WASTE ANALYSIS

II.A.l. General Waste Analysis

The Permittee shall follow the procedures described in the Waste Analysis Plan, Attachment II.BB. Waste analysis shall require, at a minimum, the maintenance of proper functioning instruments, use of approved sampling and analytical methods, verification of the validity of sampling and analytical procedures, and correct calculations. If the Permittee does not have the sufficient capability for analysis, then the Permittee shall inform the laboratory performing the analysis that the laboratory must operate under the waste analysis conditions placed on the Permittee.

II.B. SECURITY

The Permittee shall comply with the security provisions of 40 CFR 264.14. The security provisions shall follow the outline in Attachment II.DD.

II.C. GENERAL INSPECTION REQUIREMENTS

The Permittee shall follow the inspection schedule set out in Attachment II.CC. The Permittee shall remedy any deterioration or malfunction discovered by an inspection as required by 40 CFR 264.15(c). Records of inspections shall be kept as required by 40 CFR 264.15(d) and Permit Conditions II.H.2.c.v.

II.D. PERSONNEL TRAINING

The Permittee shall conduct personnel training as required by 40 CFR 264.16. This training program shall follow the Training Outline, Attachment II.EE. The Permittee shall maintain training documents and records as required by 40 CFR 264.16(d) and Permit Conditions II.H.2.a.xi and II.H.2.c.iii.

II.E. GENERAL REQUIREMENTS FOR IGNITABLE AND REACTIVE WASTE

The Permittee shall comply with the requirements of 40 CFR 264.17. The Permittee shall follow the procedures for the handling of ignitable and reactive waste as specified in the Module III, Section III.E.

II.F. PREPAREDNESS AND PREVENTION

II.F.l. Design and Operation of Facility

The Permittee shall maintain and operate the facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste constituents to air, soil, groundwater, or surface water which could threaten human health or the environment.

II.F.2. Required Equipment

At a minimum, the Permittee shall equip the facility with the equipment set forth in Attachment II.FF, as required by 40 CFR 264.32.

II.F.3. Testing and Maintenance of Equipment

The Permittee shall test and maintain the equipment specified in Permit Condition II.F.2 and in Attachment II.FF as necessary to assure its proper operation in time of emergency

(40 CFR 264.33).

II.F.4. Access to Communications or Alarm System

The Permittee shall maintain access to the communication or alarm system as required by

40 CFR 264.34.

II.F.5. Arrangements with Local Authorities

The Permittee shall maintain arrangements with State and local authorities as required by 40 CFR 264.37 and Attachment II.FF.6. If State and local officials refuse to enter into or renew existing preparedness and prevention arrangements with the Permittee, the Permittee shall document this refusal in the operating record pursuant to Permit Condition II.H.2.d.iv.

II.G. CONTINGENCY PLAN

II.G.l. Implementation of Plan

The Permittee shall immediately carry out the provisions of the Contingency Plan, Attachment II.FF,·and follow the emergency procedures described by 40 CFR 264.56, whenever there is an imminent or actual fire, explosion, or release of hazardous waste or constituents which threaten or could threaten human health or the environment.

II.G.2. Copies of Plan

The Permittee shall comply with the requirements of 40 CFR 264.53.

II.G.3. Amendments to Plan

The Permittee shall review and immediately amend, if necessary, the Contingency Plan, as required by 40 CFR 264.54.

II.G.4. Emergency Coordinator

The Permittee shall comply with the requirements of 40 CFR 264.52(d) and 40 CFR 264.55.

II.G.5. Emergency Procedures

The Permittee shall comply with the requirements of 40 CFR 264.56 including the record keeping and reporting requirements specified in Permit Condition II.H.2.a.iv.

II.H. RECORD KEEPING AND REPORTING

II.H.I. Notification, Certification and Recordkeeping Requirements

In addition to the record keeping and reporting requirements specified elsewhere in this Permit, the Permittee shall comply with all the applicable notification, certification, and record keeping requirements described in 40 CFR 264.73.

II.H.2. Operating Record

The Permittee shall maintain a written operating record at the facility, consisting of records kept for the lengths of time specified below. The record can be a compilation of various documents. The operating record shall include, but not be limited to, the information listed below.

a. The following records shall be maintained until closure is complete and certified:

i. A current map showing the location of hazardous waste management units and non-regulated units within the facility;

ii. A map showing all locations of past hazardous waste management units if different from present locations;

iii. Pursuant to 40 CFR 264.73(b)(1), a description and the quantity of each hazardous waste received, and the method(s) and date(s) of its treatment, storage, or disposal at the facility;

iv. The time, date, and details of any incident that requires implementation of the Contingency Plan, including copies of all reports prepared pursuant to 40 CFR 264.56(i) and Permit Condition I.D.ll.c or II.H.2.iv;

v. Records of spills and releases;

vi. Written reports and records of verbal notification to the Director and the Administrator to address releases, fires, and explosions;

vii. All reports of noncompliance pursuant to Permit Condition I.D.12;

viii. All submittals prepared pursuant to Permit Condition I.D.l3;

ix. Records and results of waste analyses required by 40 CFR 264.73(b)(3), which shall include at a minimum.

A. The date(s), exact place, and times of sampling or measurements;

B. The name of the individual(s) who performed the sampling or measurements;

C. The date(s) analyses were performed, demonstrating that EPA SW-846 holding times were satisfied;

D. The name(s) of the individual(s) who performed the analyses;

E. The analytical techniques or method used;

F. The analytical results;

G. The QA/QC summary; and

H. The type(s) and model number(s) of the equipment used for analysis.

x. All waste determinations, waste profiles, and waste feed composition determinations made pursuant to the Waste Analysis Plan, Attachment II.BB.

xi. Training records of current facility personnel;

xii. Certifications pursuant to 40 CFR 264.73 (Waste Minimization Plan);

xiii. The notice and certification required by a generator under 40 CFR 264.73 and

268.7 (Land Disposal Restrictions); and

xiv. Records of facility construction pursuant to Permit Condition I.D.10.

b. The following records shall be maintained for a minimum of 5 years. This time period may be extended by the Department in the event of enforcement action or notification by the Department that an investigation is ongoing.

i. Facility operation and maintenance records and reports prepared pursuant to this Permit; and

ii. Progress reports and any required notifications prepared pursuant to this Permit.

c. The following records shall be maintained for a minimum of 3 years. This time period may be extended by the Department in the event of enforcement action or notification by the Department that an investigation is ongoing.

i. Generator biennial reports submitted in compliance with 40 CFR 262.41; ·

ii. Facility biennial reports submitted in compliance with 40 CFR 264.75;

iii. Training records of former facility personnel;

iv. Records of all monitoring information pursuant to Permit Condition I.E.3; and

v. Records of all inspections, pursuant to 40 CFR 264.15, which shall include at a minimum:

A. The date and time of the inspection;

B. The name of the person performing the inspection;

C. A notation of the observations made; and

D. The date and nature of any repairs or remedial actions.

d. Current copies of the following documents as amended, revised, and modified shall be maintained at the facility until closure is complete and certified:

i. Waste Analysis Plan;

ii. Personnel Training Plan;

iii. Contingency Plan;

iv. Documentation of arrangements made with local authorities pursuant to 40

CFR 264;

v. Closure Plan; and

vi. Documentation pertaining to the storage of ignitable and reactive wastes required pursuant to 40 CFR 264.17.

II.I. CLOSURE

II.I.l. Performance Standard

The Permittee shall close the permitted storage areas as required by 40 CFR 264.111 and 264.178, and in accordance with the Closure Plan, Attachment II.GG.

II.I.2. Amendments to Closure Plan

The Permittee shall amend the Closure Plan in accordance with 40 CFR 264.112(c) whenever necessary.

II.I.3. Notification of Closure

The Permittee shall notify the Director at least 45 days prior to the date he expects to begin closure as required by 40 CFR 264.112(d).

II.I.4. Time Allowed for Closure

After receiving the final volume of hazardous waste, the Permittee shall treat or remove from the permitted areas all hazardous waste and shall complete closure activities in accordance with the schedules specified in the Closure Plan, Attachment II.GG and 40

CFR 264.113.

II.I.5. Disposal or Decontamination of Equipment

The Permittee shall decontaminate and/or dispose of all facility equipment as required by 40 CFR 264.114 and the Closure Plan, Attachment II.GG.

II.I.6. Certification of Closure

The Permittee shall certify that the permitted storage areas have been closed in accordance with the specifications in the Closure Plan, Attachment II.GG, as required by

40 CFR 264.115.

LIST OF ATTACHMENTS

The following Attachments are incorporated, in their entirety, by reference into this Permit.

These incorporated attachments are enforceable conditions of this Permit. Some of the documents contain excerpts from the Permittee’s Hazardous Waste Permit Application. The Department has, as deemed necessary, modified specific language excerpted from the Permit application. Additional modifications are prescribed in the Permit Conditions (Modules I through IV), and thereby supersede the language of the attachments. Facility operations shall be in accordance with the contents of the Attachments and this Permit.

Attachment II. AA Facility Description

Attachment II. BB Waste Analysis Plan

Attachment II. CC Inspection Schedule

Attachment II. DD Security Provisions and Procedures to Prevent Hazards

Attachment II. EE Personnel Training

Attachment II. FF Contingency Plan

Attachment II. GG Closure Plan

Module II – Attachment II.AA

ATTACHMENT II.AA

FACILITY DESCRIPTION

ATTACHMENT II.AA – FACILITY DESCRIPTION

II.AA.l. Facility

The mission of the U.S. Army Fort Belvoir is to command, control, and operate Fort Belvoir and its assigned attached units. With the implementation of the Base Realignment and Closure Act (BRAC) of 1988 (Public Law (PL) 100-526), Fort Belvoir has become a U.S. Department of the Army Administrative Center in the National Capital Region.

Fort Belvoir is an 8,656-acre installation located in Fairfax County, Virginia, adjacent to the Potomac River. It is situated 11 miles southwest of the City of Alexandria and 18 miles southwest of Washington, D.C. The major highway access to Fort Belvoir is U.S. Route 1, which bisects the main installation into North and South Posts. The main entrance to Fort Belvoir is on U.S. Route 1 at Belvoir Road.

Fort Belvoir is bordered on the northeast by Dogue Creek, on the east by the Potomac River, on the south by Gunston Cove and Pohick Bay, and to the west and northwest by Telegraph Road with commercial and residential properties scattered throughout. Figure II.AA-1, Facility Map, shows the topography and boundaries of Fort Belvoir and the land use of the surrounding area.

One hazardous waste management unit (HWMU) is permitted: one container storage unit. The unit was permitted as a HWMU in the permit dated March 18, 1993, which expired March 18, 2003, under EPA Identification Number VA7213720082. The container storage unit addressed in this permit is designated as the Building 1490 (Old Pest Control Shop Container Storage Unit). The permit was renewed for another 10 year period and with an effective date of October 23, 2004, and expired on October 23, 2014.

The hazardous wastes stored in the unit addressed in this permit are generated at Fort Belvoir. The following are examples of the wastes to be stored in the HWMU.

1. Wastes generated during the use of commercial or military issued products (e.g., paints, adhesives, batteries, bulbs).

2. Wastes, including degreasing agents, fuels, antifreeze and other solvents, generated during equipment, motor pool, and aircraft maintenance.

3. Off-specification commercial and military-issue chemical products and unused military stock items generated at Fort Belvoir. These products and items are stored in the container storage unit if the products or items are kept at Fort Belvoir for more than 90 days after being discarded.

4. Other infrequently generated waste. Examples of these wastes are discarded laboratory equipment containing mercury, chromium from lab processes, cadmium from sealed cadmium batteries, mercury from mercury batteries and laboratory chemicals that have exceeded their shelf lives.

The HWMU addressed in this permit is briefly described below. It is located in the industrial area shown on Figure II.AA-1, Facility Map. A detailed map is provided as Figure II.AA-2, Building 1490 Site Plan.

Building 1490, the Old Pest Control Shop Container Storage Unit was previously used for the storage of pesticide products and pesticide wastes. A curbed multi-bay area in the northernmost part of Building 1490 currently segregates and stores containers of hazardous waste. Containers of hazardous wastes are also stored in a bay in the southernmost part of the building. The total storage capacity for this building is 10,120 gallons.

The wastes are removed approximately once a month to an offsite treatment, storage, or disposal facility (TSDF) for proper treatment and/or disposal.

II. AA.2. General Requirements

The topographic map information, legal boundaries, and the 100-year floodplain are shown on Figure II.AA-1, Facility Map of this permit. The location of the permitted unit is also shown on Figure II.AA-1, Facility Map. An updated land use map and wind rose are shown in Figures II.AA-4 and II.AA-5.

Figure II.AA-2, Building 1490 Site Plan shows the storage unit and an area that includes 1,000 feet around the unit at a scale of 1”= 200’.

Fire hydrant locations are discussed in Attachment II.DD, Procedures to Prevent Hazards.

II.AA.3. Traffic Information

Figure II.AA-3, Building 1490 Transportation Route, depicts the hazardous waste transportation route and traffic pattern for Building 1490.

An installation-wide hazardous waste transportation route plan for Building 1490 is shown on Figure II.AA-3, Building 1490 Transportation Route. The generation point of the route and the surfacing for each road are also indicated on this map. The amount of traffic associated with this route is not expected to increase; less than a five-percent (5%) increase in volume is expected.

Roads leading to and from the facility are composed of a variety of materials. Table II.AA-1lists roads used to move wastes to and from the container storage site. The design standard for these roads was adopted from Fairfax County, which is designed to handle the largest commercial carrier vehicle to be used at this facility.

Traffic controls are limited to roads within Fort Belvoir. The traffic route for the HWMU is shown on Figure II.AA-3, Building 1490 Transportation Route.

Intersections are controlled by traffic signs or traffic lights.

Table II.AA-1 - Roads Used in Support of Fort Belvoir Container Storage Unit

Road

Surface Compositio n (Material)

Width (# of Lanes)

Load- Bearing

Capacity1 US Route 1 Concrete/Asphalt 2-4 >30

Pohick Rd Asphalt 4 30 Gunston Rd Asphalt 4 30

Jackson Loop Asphalt 2 30 Sharon Lane Rd Asphalt 2 30 Fairfax County Parkway Asphalt 4 30 Telegraph Road

Asphalt 4 30 1 Exact numbers for the load-bearing capacity of the roads were not readily available at the time this document was produced. The numbers given were extracted from the previous permit application dated January 4, 1993.

II.AA.4 Floodplain Standard

Figure II.AA.-1, Facility Map, presents the 100-year floodplain for the area.

Building 1490 is not located within the 100-year floodplain. Therefore, the demonstration of compliance, flood proofing and flood protection measures and plan for future compliance with floodplain standards are not applicable.

FIGURE II.AA-1

FACILITY MAP

FIGURE II.AA-2

BUILDING 1490 SITE PLAN

FIGURE II.AA-3

BUILDING 1490 TRANSPORTATION ROUTE

FIGURE II.AA-4

LAND USE MAP, 2012

FIGURE II.AA-5

WIND ROSE, 2012

FIGURE II.AA-6

BUILDING 1490 FLOOR PLAN

Figure II.AA.-1 (Thumbnail only. Oversized Figure located in paper file cabinet.)

Figure II.AA.-2 (Thumbnail only. Oversized Figure located in paper file cabinet.)

Figure II.AA.-3 (Thumbnail only. Oversized Figure located in paper file cabinet.)

Figure II.AA.-4 (Thumbnail only. Oversized Figure located in paper file cabinet.)

Figure II.AA.-5

Figure II.AA.-6

Module II – Attachment II.BB

ATTACHMENT II.BB

WASTE ANALYSIS PLAN

ATTACHMENT II.BB – WASTE ANALYSIS PLAN

II.BB.l. Purpose

This Waste Analysis Plan has been prepared to meet requirements specified in 40 CFR 264.13(b) and 40 CFR 270.14(b)(2) & (3) as referenced by VHWMR, as well as the document EPA Waste Analysis at Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes: A Guidance Manual (January 2013). This Plan describes procedures for conducting waste sampling and analysis for the purpose of characterizing wastes and obtaining information needed to treat, store, or dispose of the waste in accordance with regulatory requirements.

II.BB.2. Facility Description

A facility description is provided in Module II, Attachment II.AA. of this permit. EPA Waste Codes are listed in the Part A Hazardous Waste Permit Information Form.

II.BB.3. Waste Qualification and Acceptance Process

Generators of waste streams are required to identify waste composition prior to turn in by either knowledge of the process or analysis. Wastes not listed in the Part A Hazardous Waste Permit Information Form are not accepted in Bldg. 1490 and may be accumulated in a designated <90 days accumulation area and must be shipped off-site for disposal within the 90 accumulation period pursuant 40 CFR 262.34.

Small containers of waste received at the facility are generally unused hazardous material, laboratory chemicals or pharmaceuticals. A waste determination is accomplished utilizing the SDS for the waste, or through generator knowledge. The containers are then stored on pallets within containment cells according to the type of hazard they present: ignitable, corrosive, toxic or reactive; some waste may be non-hazardous.

Containers with multiple hazards such as ignitable and toxic are stored according to the Department of Transportation (DOT) primary hazard class that is selected during the waste determination process.

A waste that is not specifically listed in the DOT 49 CFR 172.101 table, which meets the definition of more than one hazard class or division, shall be classed according to the highest applicable hazard class as defined in 49 CFR 173.2a (a).

Small containers in poor condition are placed in a small open screw-top plastic pail with locking lid before being stored.

Prior to off-site shipment for disposal the contracted waste vendor reviews the waste profiles for each container and lab packs these small containers in accordance with the waste profile, RCRA and DOT requirements.

II.BB.4. Rejection Policy

Fort Belvoir does not allow hazardous waste produced off-site to be brought on Post for storage.

II.BB.5. Discrepancy Policy

Fort Belvoir does not allow hazardous waste produced off-site to be brought on Post for storage.

II.BB.6.a. Sampling Methods

When sampling is necessary, samples are taken according to EPA SW-846 procedures using the equipment listed in Table II.BB-1. Sample collectors are trained and follow appropriate safety precautions while collecting samples.

Table II.BB-1 - Sampling Equipment Sample Type SW-846 Recommended Sampling Equipment Aqueous Coliwasa or weighted bottle Oil and organic liquid Coliwasa or weighted bottle Sludge Discrete sludge sampler Solids Auger or scoops and shovels

Chain of custody forms are used to document the transfer of samples from the sample collector to the transporter to the analytical laboratory.

II.BB.6.b. Frequency of Analyses

The characteristics of the D- and F-listed wastes are not expected to vary over time because, in general, the processes by which these wastes are generated do not vary. For generated D- and F-listed wastes, when reason exists to suspect waste composition change, such as process changes, re-evaluation/analysis of the waste is required of the generator prior to turn-in. The generator and the hazardous waste disposal contractor will analyze the D- and F-listed wastes when the generator has reason to believe that the materials and/or material composition or processes have changed.

The P- and U-listed wastes are identified in the Safety Data Sheets (SDSs), therefore analyses are not performed. If a new chemical product or material is identified, the published information (publications and/or SDSs) will be reviewed to evaluate presence of P- and U-listed chemicals; and for ignitable, reactive, and compatibility characteristics.