Allen, Pam, NMENV .,j'EJ ENTERED - hwbdocuments.env.nm.gov AFB/2017-12-05 Permit Renewal... · and one Hesco barrier structure. The trenches and Hesco barriers were once used for

Allen, Pam, NMENV

From: Cobrain, Dave, NMENV .,j'EJ ENTERED

Sent: Wednesday, December 06, 2017 9:45 AM To: Allen, Pam, NMENV Subject: Attachments:

FW: CAFB RCRA Permit Renewal Comments - Triple Letter AOCs

Triple Letter AOCs.pdf

Pam,

Here's the first of five.

Direct office phone: 505-476-6055 Main HWB phone: 505-476-6000 Fax: 505-476-6030

-----Original Message-----

From: PALMER, STEVEN L GS-12 USAF AFCEC 27 SOCES/AFCEC-CZO [mailto:[email protected]] Sent: Tuesday, December 05, 2017 3:20 PM To: Cobrain, Dave, NMENV <[email protected]> Cc: Acevedo, Gabriel, NMENV <[email protected]>; Wear, Benjamin, NMENV <[email protected]>; KOTIKAMP, SHEEN T CTR USAF AFSOC 27 SOCES/CEIER

<[email protected]>; SEGURA, CHRISTOPHER G GS-13 USAF AFCEC/CZO <[email protected]>;

CLARK, SCOTI C GS-13 USAF AFCEC/CZO <[email protected]>; HIROHATA, DEREK K GS-13 USAF AFSOC 27 SOW JA/JA

<[email protected]>; GENTRY, DANA K GS-12 USAF AFSOC 27 SOCES/CEIE <[email protected]>; PAUL, ROBIN E GS-13 USAF AFMC AFCEC/CZRX <[email protected]>; Abigail Power P.G.<[email protected]>; Mark

Tepperman <[email protected]> Subject: CAFB RCRA Permit Renewal Comments - Triple Letter AOCs

Dave, Here is the first set of comments from CAFB regarding the Draft Permit.

They provide our response to the inclusion of AOC ZZ through AOC 000 on Table 1 of the Draft Permit.

More to follow.

v/r, Steve

Steve Palmer

Cannon AFB Restoration Program Manager AFCEC/CZO 402 S. Chindit Blvd, Bldg 102 Cannon AFB, NM 88103 575-904-6744 office 850-218-1544 cell

1

CAFB Triple Letter (+ZZ) AOC Descriptions

It is Cannon's position that none of these should be listed on the Permit.

ZZ: Building 133. Maintenance hangar for drone aircraft. Building is currently empty. Had two initial accumulation points (IAPs) for hazardous waste assigned to it when it was active. IAPs were closed out on 21June 2017.

AAA: Building 202. Small warehouse used to store new batteries and aircraft parts. Currently unused, unoccupied and slated for demolition.

BBB: Building 130. This is office space for EOD only. No work on or with explosives is conducted here, and no explosives are stored here.

CCC: Building 199. Former Corrosion Control hanger. Corrosion control was closed 4-5 years ago. Building is slated for renovations. The renovations will prevent reuse as a corrosion control facility. The paint booth and associated ductwork was remediated in 2016 prior to being removed for recycling.

DDD: Building 335. Vehicle maintenance facility. This facility performs Jiffy-Lube type periodic maintenance. Has an active IAP for gasoline filters.

EEE: Building 379. Vehicle maintenance. SWMUs 53 and 57 are located at this site. This facility performs maintenance on heavy equipment. Has two active IAPs, for used oil and antifreeze.

FFF: Facility 2153. Munitions-area wash rack. The wash system was a self-contained recirculating system that did not drain to the environment. It is no longer in use and the pump house has been removed. See photos.

GGG: 98 acre munitions storage area. Is a universal waste generator, mainly for used aerosol cans. This area would be covered under MMRP should there be a munitions related release.

HHH: POL area. If there is to be another AOC in this area it needs to be more clearly defined. This area already contains SWMU 71, 72, 76, and AOCs Z*, AA*, and BB*. Cannon's position is that any concerns in this area are sufficiently covered by the aforementioned SWMUs and AOCs.

Ill: Building 375. Vehicle maintenance facility. Site of SWMU 51. This is a general purpose (civilian type vehicles) maintenance facility. Has IAPs for used oil and antifreeze.

JJJ: Fire training area & pond. This fire training facility is lined to prevent releasing of fire training related materials to the soil.

KKK/LLL: These two AOCs cannot be differentiated from each other based on the provided description. Both are described as being 850 ft NW of AOC F. This area contains concrete foundations for temporary buildings that were removed starting in the mid-1990s, shallow trenches (approximately 6 inches deep) and one Hesco barrier structure. The trenches and Hesco barriers were once used for military training exercises. The trenches were once bunkers that were about 2 feet deep and covered with plywood and sandbags. To the south (600-1000 feet south of AOC F) are several of these bunkers that are relatively intact. When the bunkers at KKK/LLL were demolished, it appears the wood was removed and the sandbags were bulldozed into the trenches to level them out. To the south of this area there are several electrical transformers mounted on raised berms, presumably to prevent flooding during heavy rain. See photos.

MMM: Four water tanks used for firefighting on the C-130 ramp. See photos.

NNN: Hot gun berm. Built to be a safety stop when aircraft land with hot or jammed guns. It has never been fired into. See photo.

000: C-130 Maintenance hangars. Numerous IAPs, primarily in the new corrosion control hangar and the structural maintenance hangar. This is an extremely large area with many diverse activities. To include an entire flight line under one AOC is too broad of a net to cast. That being said, all hazardous waste streams generated from this area are being managed IAW Cannon's hazardous waste program and currently meet all necessary requirements for control of hazardous waste or materials for protection of human health and the environment.

Photos:

AOC FFF: Facility 2153. Looking West.

Pumphouse foundation and wash rack drain. Looking South.

Drain

AOC KKK/LLL:

Concrete pad. Looking East.

Hesco Barriers. Looking SE.

Trenches. Looking SE.

Bunkers 600-1000 feet south of AOC F

; . :

AOCMMM:

NW Water Tanks. Looking West.

AOC NNN: Hot Gun Berm. Looking SE.

Allen, Pam, NMENV

From: Cobrain, Dave, NMENV Sent: To:

Wednesday, December 06, 2017 9:46 AM Allen, Pam, NMENV

Subject: Attachments:

2 of 5



FW: CAFB RCRA Permit Renewal Comments - Table 1 UST AOCs Justification- POL UST Removal from Table 1 of Cannon AFB Draft RCRA Permit Renewal.pdf

From: PALMER, STEVEN L GS-12 USAF AFCEC 27 SOCES/AFCEC-CZO [mailto:[email protected]] Sent: Tuesday, December 05, 2017 4:49 PM To: Cobra in, Dave, NMENV <[email protected]> Cc: Acevedo, Gabriel, NMENV <[email protected]>; Wear, Benjamin, NMENV <[email protected]>; KOTIKAMP, SHEEN T CTR USAF AFSOC 27 SOCES/CEIER


CLARK, SCOTI C GS-13 USAF AFCEC/CZO <[email protected]>; HIROHATA, DEREK K GS-13 USAF AFSOC 27 SOW JA/JA

<[email protected]>; GENTRY, DANA K GS-12 USAF AFSOC 27 SOCES/CEIE <[email protected]>; PAUL,

ROBIN E GS-13 USAF AFMC AFCEC/CZRX <[email protected]>; Abigail Power P.G.<[email protected]>; Mark Tepperman <[email protected]> Subject: CAFB RCRA Pe'rmit Renewal Comments - Table 1 UST AOCs

Dave, Here is our second set of comments for the permit. They regard the AOCs that were moved from Table 2 to Table 1. This section is where we have been having the most trouble locating supporting documents and need more time to

find them.

More to come.

Steve Palmer Cannon AFB Restoration Program Manager

AFCEC/CZO 575-904-6744 office 850-218-1544 cell

1

Table 1: AOC Comments

These AOCs are all POL USTs that were originally placed on Table 2 of

CAFB's RCRA Permit based off the 1987 RFA. Nearly all of them have since been

removed, however, the removal logs or post-removal sampling reports do not

appear to have been filed appropriately and as such have been lost or misplaced

by both the Air Force and NMED. Due to this situation, searching for supporting

documentation has been a lengthy and time-consuming process. CAFB has

managed to find a few records in their archives, and has submitted an IPR to the

PTSB for any records they have on these sites, but has not yet received a

response. It was due to these document gathering issues that CAFB requested an

extension to the public comment period.

AOC CC* - POL Storage Tank No. 420

RFA of 1987 indicates the unit was a 2,500 gallon steel JP-4 fuel tank located in the

Maintenance Shop Area near Building 420. At the time of the 1987 RFA the tank

was active and there had been no history of releases. CAFB believes this tank has

been removed, however, a search of Air Force and NMED records does not provide

any additional information for this site.

AOC EE* - POL Storage Tank No. 444

RFA of 1987 indicates the unit was a 1,000 gallon diesel fuel tank of unknown

construction located in the Maintenance Shop Area near Building 444. At the time

of the 1987 RFA, the tank was active and there had been no history of releases.

CAFB believes this tank has been removed, however, a search of Air Force and

NMED records does not provide any additional information for this site.

AOC FF* - POL Storage Tank No. 728


construction located in Building 728, a Maintenance Shop. At the time of the 1987

RFA, the tank was active and there had been no history of releases. Air Force

records show that this tank had been removed by September 1996. Additionally,

this tank is also managed by NMED's Petroleum Storage Tank Bureau and is listed

in their database {https://www.env.nm.gov/ust/lists.html). Record included

below.

AOC HH* - POL Storage Tank No. 2110

RFA of 1987 indicates the unit was a 550 gallon diesel fuel tank of unknown

construction located in the Maintenance Shop Area near Building 2110. At the time

of the 1987 RFA, the tank was active and there had been no history of releases. Air

Force records show that this tank had been removed by September 1996.

Additionally, this tank is also managed by NMED's Petroleum Storage Tank Bureau

and is listed in their database {https://www.env.nm.gov/ust/lists.html). Record

included below.

AOC II* - POL Storage Tank No. 2160


construction located in the Maintenance Shop Area in the Eastern area of the base.

At the time of the 1987 RFA, it was unknown when the tank when the tank began

or ceased operation and there had been no history of releases. CAFB believes this

tank has been removed, however, a search of Air Force and NMED records does

not provide any additional information for this site.

AOC JJ - POL Storage Tank No. 2276


construction located in the Combat Aircraft Parking Area in the Central area of the

base. At the time of the 1987 RFA, the tank was in use and there had been no

history of releases from the site. A search of Air Force records indicate the tank

was removed in 1992 and that sampling was conducted, however the sample

results have not been located yet. A search of the Air Force and NMED records

could not produce a record of regulatory acceptance of the closure of this tank.

AOC KK- POL Storage Tank No. 2280


construction located in the Combat Aircraft Parking Area. At the time of the 1987

RFA, the tank was active and there had been no history of releases. CAFB believes

this tank has been removed, however, a search of Air Force and NMED records does


AOC LL - POL Storage Tank No. 2285




records show that this tank had been removed by September 1996. Additionally,

this tank is also managed by NMED's Petroleum Storage Tank Bureau and is listed

in their database {https://www.env.nm.gov/ust/lists.html). Record included

below.

AOC MM - POL Storage Tank No. 2300


construction located near the eastern end of Landfill 3. At the time of the 1987


records show that this tank was actually two 250 gallon tanks. One was removed

in January 1993, and the other in September 1996. Record included below.

AOC NN - POL Storage Tank No. 2302


construction located at the southern border of the base. At the time of the 1987


records show that this tank had been removed by September 1996. Record

included below.

AOC 00 - POL Storage Tank No. 2307




records show that this tank had been removed by September 1996.

AOC PP - POL Storage Tank No. 2309

RFA of 1987 indicates the unit was a 2,500 gallon JP-4 fuel tank of steel construction

located in the Combat Aircraft Parking Area. At the time of the 1987 RFA, the tank

was active and there had been no history of releases. Air Force records show that

this tank was removed in November 1988. Record included below.

AOC QQ - POL Storage Tank No. 2313


construction located at the Small Arms Range. At the time of the 1987 RFA, the

tank was active and there had been no history of releases. CAFB believes this tank

has been removed, however, a search of Air Force and NMED records does not

provide any additional information for this site.

AOC RR - POL Storage Tank No. 2321


construction located near the southern border of the base. At the time of the 1987




AOC SS - POL Storage Tank No. 2327




records show that this tank was removed in January 1993. Record included below.

AOC TT - POL Storage Tank No. 2328



RFA, the tank was active and there had been no history of releases. Civil Engineer

personnel confirmed the tank has been removed, but do the date of removal is

unknown at this time.

AOC UU - POL Storage Tank No. 2330






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AF FORM

! s JUN se 1432 REAL PROPERTY ACCOUHTASLE RECORD - MISCELLANEOUS STRUCTURES

u ............... , __ ... ~.-- ·-· ~~~---------·--------------------------

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..::~ .:::. CONDITION

·;: ./--.. 4~" f''? ( . . -... -

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DESCRIPTION

?'> .. )'"::-_: tf,F*~ ~·!;(§~:- ,:'t· ::·:C. /

I

REMARKS

AOC PP Tank No. 2309 Removal Logged 22 Nov 88

DATE COMPLETED

AREA UNIT AMOUNT \ TOTAL

COST

.:j; ::":,: ./9 ::.e:. 2~ ·7· '?5 ~-1_: ~L. ···~I :;~· ·:;:,,;: ~. :"'3· I :'S.

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BALANCES FORWARDED

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TOTAL COST

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REAL PROPERTY~ACCOUNTA~LE ~ECORD -.MISCELLANEOUS STRUCTURES

Allen, Pam, NMENV

From: Sent: To: Subject: Attachments:

3 of 5



Cobrain, Dave, NMENV Wednesday, December 06, 2017 9:46 AM Allen, Pam, NMENV FW: CAFB RCRA Permit Renewal Comments - Comment Matrix Draft Permit Comment Matrix.xlsx

From: PALMER, STEVEN L GS-12 USAF AFCEC 27 SOCES/AFCEC-CZO [mailto:[email protected]]

Sent: Tuesday, December 05, 2017 4:54 PM To: Cobrain, Dave, NMENV <[email protected]>

Cc: Acevedo, Gabriel, NMENV <[email protected]>; Wear, Benjamin, NMENV <[email protected]>; KOTIKAMP, SHEEN T CTR USAF AFSOC 27 SOCES/CEIER

<[email protected]>; SEGURA, CHRISTOPHER G GS-13 USAF AFCEC/CZO <[email protected]>; CLARK, SCOTI C GS-13 USAF AFCEC/CZO <[email protected]>; HIROHATA, DEREK K GS-13 USAF AFSOC 27 SOW JA/JA

<[email protected]>; GENTRY, DANA K GS-12 USAF AFSOC 27 SOCES/CEIE <[email protected]>; PAUL, ROBIN E GS-13 USAF AFMC AFCEC/CZRX <[email protected]>; Abigail Power P.G.<[email protected]>; Mark

Tepperman <[email protected]> Subject: CAFB RCRA Permit Renewal Comments - Comment Matrix

Dave,

Third set of Comments. These comments deal with our concerns regarding the body of the permit.

v/r, Steve


402 S Chindit Blvd, Building 102 Cannon AFB, NM 88103

AFCEC/CZO 575-904-6744 office 850-218-1544 cell

1

Date Reviewer

4-Dec-17 CAFB

Item I Source Section Page Para Line

1.13.8 20

1.13.10.3 22

Part2 25-31 all

2.8.7 31

2.6 27

3.6.1 36

3.6.2 37

Attachment 1 4 1 5-7 ---Attachment 2

10 l I Attachment 3 3 SWMU 70 I Comments

11 I I Attachment 3 3 SWMU 103 I Comments

12 I I AOCZZ-

Attachment 3 6-7 AOCOOO

Class

Common Comment and Response Worksheet1v.,,;o,,1 Document Title (version)

Cannon AFB RCRA Permit Renewal Comments Comment

For security reasons, certain places and activities on CAFB are not permitted to be photographed without prior authorization. Language of paragraph 3) needs to reflect that. Suggest changing paragraph 3 to read: "have

access to and photograph (with 27 Special Operations Wing Security Forces approval, if required) any facilities,

M I equipment (including monitoring and control equipment), practices, or operations regulated or required."

"The Permittee shall include in the report a description of the spill response activities as required in Permit

Section 2.8.5" Section 2.8.5 deals with records, and says nothing about spill response activites. Change to

correct section number.

Cannon's Hazardous Waste program complies with alt requirements to remain a non-permitted operation. By

including Part 2: General facility Conditions in the permit, it overrides the non-permitted status of Cannon's

program.

As outlined in 40 CFR 270.l(c)(2), generators who accumulate hazardous waste on-site for less than the time

periods provided in 40 CFR 262.34 are not required to obtain a RCRA permit; the tatter citation indicates that

waste can be accumulated for 90 days or less "without a permit or without having interim status." Specific

exceptions are addressed, none of which apply to Cannon AFB. Consequently, the exclusion specified in 40 CFR

270.l(c)(2) applies to Cannon AFB.

It appears that the State of New Mexico has implemented 40 CFR 270 with exceptions as outlined in 20.4.1.900

NMAC; however, no exceptions are provided that would remove the exclusion allowed under 40 CFR 270.l(c)(2).

It should also be noted that the State of New Mexico has implemented 40 CFR 262.34 as outlined in 20.4.1.300

NMAC; no exceptions are provided that direct more strenuous time periods.

As previously addressed, specific exclusions to permit hazardous waste accumulation sites (HWAS) are addressed

in 40 CFR; no exceptions to those exclusions are addressed in 20.4.l NMAC. By virtue of the fact that

requirements are placed under Part 2 of the Draft RCRA (Corrective Actions) Permit, the exclusion {40 CFR

270.l(c)(2)} would be over-ridden by permit requirements. Additionally, should the 90-day HW Accumulation

Site become "permitted," it would have to under-go closure action again, a costly activity which was completed in

2012 when Cannon's TSDF was closed; NMED has concurred with that closure action.

Part 2 should be removed from the final Permit.

Will an email suffice as to inform NMED in writing?

Heading "Transport Storage and Disposal of Waste Military Munitions" needs commas: "Transport, Storage, and

Disposal...". Also, first line of the first paragraph says "treatment" instead of "transport". Is one of those

incorrect?

As written this section duplicates the intent of paragraph 3.2.1, but disagrees with the notification period for a

new discovery.

Five day written notice is impractical given the levels of bureacracy involved. Recommend keeping with the 15

day written notification period mentioned in 3.2.1 and contained in the old permit. The oral notification

M I requirement is not unreasonable.

M I same discussion as for 3.6.1

Ensure numbers of SWMUs & AOCs that require corrective action and those that have completed corrective

action are correct.

Cannon map will need to be updated to reflect the status of any SWMUs and AOCs that have shifted Tables.

Cannon will provide an updated map once the matters have been resolved.

UST@ SWMU 70 was only 220 gallons, not 20,000 gallons.

SWMU receives discharge from SWMU 100 via SWMU 99, not SWMU 9.

The Air force contests all of these AOCs pending NMED providing an RF A-like document containing justification

M I as to why they should be included on the permit.

I I J i ______ L_ I

~olumn A: _ ~omf!l_i:n! Identifier Number Comment Classifications

Column B: iSource (Commenter/Authority) (C) Critical: Critical comments will result in a critical issue. Provide convincing support.

Contract/TO Number

Response

(M) Major: Major comments are significant concerns that may result in a major issue. This category may be used with a general stat;ment of concern followed by -;detailed com-ment on the specific entries in the document that,

Column C: ·- Section Number of Comment considered in total, constitute the concern.

(SJ Substantive: An entry in the document that appears to be or is potentially unnecessary, misleading, incorrect, or confusing.

Column D: I Page Number of _~~ment_J!!!:~ page associated with comment)

Column E: Paragraph number, on page, of Comment (A) Administrative: Administrative comments correct inconsistencies between different sections, typographical and grammatical errors.

Column F: 1-----.·- Line Number (wJ!.hin ~aragraph ~9-v~e)_o_f C_o_m_m_e_o_t ____ ~------

Column G: I Comment Classi~c.~~--- ---··---------~---------Column H: Comment I

lcolumn-1: _ I Response -------~- ___ J_ Notes: i Comments must be actionable ("add the following ~!~.'..:.:.~~:·~~~ete .. ","change text to:") ____ _

'Place only one comment per row.

i Classify comment as C, M, S, or A. r------~--~--~-~----

--------"'- -------·--

Allen, Pam, NMENV



Subject: FW: CAFB RCRA Permit Renewal Comments - Table 1 SWMUs

Attachments: Justification- SWMU Removal from Table 1 of Cannon AFB Draft RCRA Permit Renewal.pdf

4 of 5

Direct office phone: 505-476-6055 Main HWB phone: 505-476-6000

Fax: 505-476-6030

-----Original Message-----From: PALMER, STEVEN L GS-12 USAF AFCEC 27 SOCES/AFCEC-CZO [mailto:[email protected]]

Sent: Tuesday, December 05, 2017 4:57 PM To: Cobrain, Dave, NMENV <[email protected]>

Cc: Acevedo, Gabriel, NMENV <[email protected]>; Wear, Benjamin, NMENV <[email protected]>; KOTIKAMP, SHEEN T CTR USAF AFSOC 27 SOCES/CEIER


CLARK, SCOTI C GS-13 USAF AFCEC/CZO <[email protected]>; HIROHATA, DEREK K GS-13 USAF AFSOC 27 SOW JA/JA <[email protected]>; GENTRY, DANA K GS-12 USAF AFSOC 27 SOCES/CEIE <[email protected]>; PAUL,

ROBIN E GS-13 USAF AFMC AFCEC/CZRX <[email protected]>; Abigail Power P.G.<[email protected]>; Mark Tepperman <[email protected]> Subject: RE: CAFB RCRA Permit Renewal Comments - Table 1 SWMUs

Dave,

Fourth set of Comments. These comments provide our justifications for removing SWMUs from Table 1 of the draft permit.

v/r, Steve


402 S Chindit Blvd, Building 102

Cannon AFB, NM 88103 AFCEC/CZO 575-904-6744 office 850-218-1544 cell

1

Table 1: SWMUs to Remove

This document provides Cannon AF B's justification for removal of the

following Solid Waste Management Units from Table 1 of Cannon AFB Draft RCRA

Permit: 21, 22a & b, 23a & b, 24a & b, 25, 26, 27, 28, 29, 30, 36, 64, and 65.

SWMU 21- NDI lab dip tank

1987 RCRA Facility Assessment (RFA) indicates the tank was a process tank and did

not manage wastes. The solution in the tank was removed on an annual basis at

which time it would be determined to be a waste. This waste was containerized

and disposed of through the Air Force (DPDO.) Any releases from the tank would

have collected in the floor drains of the building, connected to the Sanitary Sewer

Line (SWMU 98) which was closed via Class Ill Permit Modification (Mod) dated 20

Jan 2015. NMED concurred with the USEPA's conclusion that the site did not

warrant further investigation as noted in Table 2 in Attachment 1 of their February

27, 2006 RCRA Permit Modification. As the NDI lab dip tank was never used for the

management of wastes, the Air Force recommends that SWMU 21 be removed

from any future consideration under the Cannon AFB RCRA Permit. Barring that

course of action, as no releases were identified from this unit at the time of the

RFA, or any time since, and any contamination would have been released via the

floor drains to the sanitary sewer (SWMU 98), Cannon AFB recommends that this

SWMU follow the same path as SWMU 98 and be placed on Table 3 of the Permit.

Unit is currently in use.

SWMU 22 a, b - NDI lab developer tank

The 1987 RFA indicates the tank was a process tank and did not manage wastes.

The solution in the tank was removed approximately every three months at which

time the solution would be determined to be a waste. This waste was containerized

and disposed of through the Air Force (DPDO). Any releases from the tank would

have collected in the floor drains of the building, connected to the Sanitary Sewer

Line (SWMU 98) which was closed via Class Ill Permit Modification (Mod) dated 20

Jan 2015. Additionally note that the RFA indicated that no releases were reported

from this SWMU. NMED concurred with the USEPA's conclusion that the site did

not warrant further investigation as noted in Table 2 in Attachment 1 of their

February 27, 2006 RCRA Permit Modification. As the NOi lab developer tank was

never used for the management of wastes, the Air Force recommends that SWMU

22 be removed from any future consideration under the Cannon AFB RCRA Permit.

Barring that course of action, as no releases were identified from this unit at the

time of the RFA, or any time since, and any contamination would have been

released via the floor drains to the sanitary sewer (SWMU 98), Cannon AFB

recommends that this SWMU follow the same path as SWMU 98 and be placed on

Table 3 of the Permit. Unit is currently in use.

SWMU 23 a, b - NDI lab emulsifier processing tank

1987 RFA indicates the tank was a process tank and did not manage wastes. The

solution in the tank was removed approximately every three months at which time

the solution would be determined to be a waste. After 1986, this waste was

containerized and disposed of through the Air Force (DPDO). Prior to 1986 this

waste was discharged to the Sanitary Sewer Line (SWMU 98). Also note that any

releases which could have occurred from the tank would have collected in the floor

drains of the building, connected to the Sanitary Sewer Line (SWMU 98). SWMU

98 was closed via Class Ill Permit Modification (Mod) dated 20 Jan 2015.

Additionally note that the RFA indicated that no releases were reported from this

SWMU. NMED concurred with the USEPA's conclusion that the site did not warrant

further investigation as noted in Table 2 in Attachment 1 of their February 27, 2006

RCRA Permit Modification. As the NDI lab emulsifier processing tank was never

used for the management of wastes, the Air Force recommends that SWMU 23 be

removed from any future consideration under the Cannon AFB RCRA Permit.

Barring that course of action, as no releases were identified from this unit at the

time of the RFA, or any time since, and any contamination would have been

released via the floor drains to the sanitary sewer (SWMU 98), Cannon AFB



SWMU 24 a, b - NDI lab silver recovery tank

1987 RFA indicates the unit was a "silver recovery unit" that processes "waste fixer

solution for silver recovery", and as such would be exempt under 40 CFR 261.6.

Also note that any releases which could have occurred from the tank would have

collected in the floor drains of the building, connected to the Sanitary Sewer Line

(SWMU 98). SWMU 98 was closed via Class Ill Permit Modification (Mod) dated 20

Jan 2015. Additionally note that the RFA indicated that no releases were reported

from this SWMU. NMED concurred with the USEPA's conclusion that the site did


February 27, 2006 RCRA Permit Modification. As the NDI lab silver recovery tank

was never used for the management of wastes, the Air Force recommends that

SWMU 24 be removed from any future consideration under the Cannon AFB RCRA

Permit. Barring that course of action, as no releases were identified from this unit

at the time of the RFA, or any time since, and any contamination would have been

released via the floor drains to the san itary sewer (SWMU 98), Cannon AFB



SWMU 25 - NOi lab drum storage area

1987 RFA indicates that this SWMU was located in Building 185, which was

demolished in September 1996 (The AF Form 1430 - Real Property Record for

Building 185 is attached at the end of this document). The unit was not in use at

the time of the 1987 RFA. NMED concurred with the USEPA's conclusion that the

site did not warrant further investigation as noted in Table 2 in Attachment 1 of

their February 27, 2006 RCRA Permit Modification. RFA records also indicate that

there were no releases from the site. If any releases occurred inside the drum

storage area in former Building 185, fluids would have discharged to floor drains

that were connected to the Sanitary Sewer Line (SWMU 98), which was closed Class

Ill Permit Modification (Mod) dated 20 Jan 2015. The 1987 RFA indicates there are

no records of a release to the environment from this solid waste unit, therefore

SWMU 25 should follow the same path as SWMU 98 and be placed on Table 3 of

the Draft RCRA Permit Renewal.

SWMU 26 - NOi lab fixer processing tank

1987 RFA indicates that this SWMU was originally located in Building 185, which

was demolished in September 1996, before being moved to its present location in

Building 593. NMED concurred with the USEPA's conclusion that the site did not


27, 2006 RCRA Permit Modification. The RFA records also indicate that there has

been no release from this site. If any releases occurred from the lab fixer

processing tank, fluids would have discharged to floor drains that were connected

to the Sanitary Sewer Line (SWMU 98), which was closed Class Ill Permit

Modification (Mod) dated 20 Jan 2015. Additional research of the NDI process

indicates that the fixer processing tank is actually connected in series to the silver

recovery tank and therefore is not managing wastes and should be removed from

any future consideration under the Cannon AFB RCRA Permit. Barring that course

of action, as no releases were identified from this unit at the time of the RFA, or

any time since, and any contamination would have been released via the floor

drains to the sanitary sewer (SWMU 98), Cannon AFB recommends that this SWMU

follow the same path as SWMU 98 and be placed on Table 3 of the Permit. Unit is

currently in use.

SWMU 27 - Lead acid battery shop neutralization tank

1987 RFA indicates this polyethylene tank was used to neutralize the sulfuric acid

contained in lead acid batteries prior to discharge to the Sanitary Sewer Line

(SWMU 98), which was closed in the Class Ill Permit Modification dated 20 Jan

2015. SWMU 27 was located inside Building 185 which was demolished in

September 1996. NMED concurred with the USEPA's conclusion that the site did


February 27, 2006 RCRA Permit Modification. The 1987 RFA also indicates that no

discharges from the polyethylene tank were ever reported. Additionally, any

possible releases from the tank would have collected in the floor drains of the

building which also discharged to the now closed SWMU 98. The Air Force requests

that SWMU 27 be listed on Table 3 of the Draft RCRA Permit Renewal.

SWMU 28- Used battery casing storage area

1987 RFA indicates the unit was a storage area with plywood walls and a concrete

floor where lead acid battery casings were stored on a wooden topped metal

framed table. The area was used for storage only and no treatment or disposal of

wastes occurred at the location. This SWMU was located inside Building 185 which

was demolished in September 1996. NMED concurred with the USEPA's conclusion

that the site did not warrant further investigation as noted in Table 2 in Attachment

1 of their February 27, 2006 RCRA Permit Modification. Any releases from the

storage area would have collected in the Sanitary Sewer Line (SWMU 98) which was

closed in the Class Ill Permit Modification dated 20 Jan 2015. The Air Force requests

that SWMU 27 be listed on Table 3 of the Draft RCRA Permit Renewal.

SWMU 29 - NiCad Battery Rinse sink

1987 RFA indicated the sink collected possible nickel and cadmium impacted rinse

water from the NiCad battery preparation area. This SWMU was located inside

Building 185 which was demolished in September 1996. NMED concurred with the

USEPA's conclusion that the site did not warrant further investigation as noted in

Table 2 in Attachment 1 of their February 27, 2006 RCRA Permit Modification. The

sink drained to the Sanitary Sewer line (SWMU 98). Any spillage from the sink

would have collected in the floor drains of the building which also discharged to

SWMU 98, which was closed in the Class Ill Permit Modification dated 20 Jan 2015.

The Air Force requests that SWMU 27 be listed on Table 3 of the Draft RCRA Permit

Renewal.

SWMU 30 - AGE Maintenance Shop Washrack

1987 RFA indicates the unit, a washrack for aircraft ground equipment cleaning,

was near building No. 185 and discharged to SWMU 1 (Oil water separator at

Building 119). Building 185 was demolished in September 1996 and SWMU 1 was

determined to require "no further action" per the February 27, 2006 RCRA Permit

Modification. NMED concurred with the USEPA's conclusion that SWMU 30 did not


27, 2006 RCRA Permit Modification. The Air Force requests that SWMU 27 be listed

on Table 3 of the Draft RCRA Permit Renewal.

SWMU 36 (SWMU 36A} - Former MWR Auto Body Shop (now building 214}

The 1987 RFA indicates this unit is a 110 gallon dip tank used to clean aircraft

wheels (cleaning product named PD-680 Type 11, ceased manufacturing in 1999) in

Building 194. Additionally the RFA identifies waste PD-680 as being sent to SWMU

26 from 1965-75. After 1975 the waste went to either the landfill or DPDO for

disposal. The "Corrective Action Complete Proposal for SWMU 36a and SWMU

128", (8 Feb 2016 - FPM Remediation, Inc. /URS Group, Inc.) provides clarification

on the naming and description of this unit. This document indicates that Cannon

AFB staff and NMED staff "confirmed that two sites (MWR Auto Body Shop (AOC

36) and the Wheel and Tire Shop PD-680 Cleaning Dip Tank were identified as

SWMU 36." Additionally, the NMED representative proposed renaming the MWR

Auto Body Shop to SWMU 36a and also indicated that "AOC 36/SWMU 36a could

be moved to Table 3 upon permit renewal by submitting a CAC (Corrective Action

Complete) proposal requesting CAC without Controls for SWMU 36a". The Air

Force requests that SWMU 36 (36a) be listed on Table 3 of the Draft RCRA Permit

Renewal.

SWMU 64 - Civil engineering open yard PCB storage

1987 RFA indicates the actual construction of the unit and the actual location in the

Civil Engineering Yard is unknown. The unit was used to store out of service PCB

containing transformers until 1981 when a building was constructed to store these

transformers. Prior to 1978 the transformers were sent for salvage, and after 1978

they were sent to DPDO for proper disposal. No releases from the unit were

documented. Additionally, NMED concurred with the USEPA's conclusion that the

site did not warrant further investigation as noted in Table 2 in Attachment 1 of

their February 27, 2006 RCRA Permit Modification. Because no location is known

and no release is suspected, the Air Force requests that SWMU 64 be listed on Table

3 of the Draft RCRA Permit Renewal.

SWMU 65 - Former interim status hazardous waste storage facility

RFA of 1987 indicates the unit consisted of a fenced area on a concrete pad

surrounded by a 6 inch berm and was used for the temporary storage of hazardous

wastes that were generated across the base. The facility ceased use in 1983. NMED

concurred with the USEPA's conclusion that the site did not warrant further

investigation as noted in Table 2 in Attachment 1 of their February 27, 2006 RCRA

Permit Modification. The Air Force requests that SWMU 65 be listed on Table 3 of

the Draft RCRA Permit Renewal.

I I -I ~-',;;,r,:-,0:1'""'7iz:i:c ?o-:·:;-o_, -~&s?; ,~~~~ -- i ;c- F.:o?:' 62 !cr~-?-37/6 .. : r

INSTALLATION NAME AND NO. DATE • l ORAW\NG .-;;). 1>10.

.< .. :·.~?. ,('. :~ .~~~~

CO'ITROL NO.

.. ,:/ t' i..... ... ,""\>:'-'

r-..:...--~::: BU!LOING NO.

DIMENSIONS (Width x length)

MAIN SUILOING OFFSETS 2nd Jf.R1~x Fl oo rl~'u:-,..:.eJi.xs.OIE«T._&;_ <;? 1 2 11 X_ l'~C!'(ltt l j 25 1 x J-~l ( • .X. )i .. '

--:r:r·t-11-!t' :{ 39·e o~ x 22?' Tl~n~rF:l~. i'::-:-it jrH1JH~-=rd --~r~ o-::?n ~:~I 9-,--x 24'8:! 3r1c:rt x l3~

MATER I A LS 6 YEW x 3 t sn FOUNDATION FLOOR WALL ROOF

ConcI ... ete Concrete 2-Ta.son?"7Y .. Gor~1c1G si. ti ~r1 HEATING

SOURCE

Eo:Ller·, 2:team

I _,_ ~~ .:.,..,-1 j TYf>q-:~C.t---.L'-'~-l -

I ~-j eat e::·s J· '.) i._ {i;\' r'i(il"\P!T'T'ifl FUEL

...:::__j_"'+"_"":V ·' ·v._.•V.!.J- ..._,

Gas I

NO. OF USABLE FLOORS FIRE PROTFC'TION

·n,ro UTILITY CONNECTIONS BLDG EQPT NO. TOTAL CAPACITY

WATER

l-6~1

SEWER

2-6tt a.nd g~t

ElECTR IC 2-110-220

GAS

STEAMJ_-}011·

CONDENSATE.

1-2±" VOUCHER NO. DATE

57-14.0 i1 -' ""'' ,-.... iv .... ~ ... ~ 57

62-:~2 q lla.'V 6.2

63-1) S-B-62

63-104 ; 7 Sept 62

AIR

CONDITIONING

EVAPORATIVE

COOL I NG

MECH AN I CAL

COOLING

HOT WATER

FACILITIES

DESCRIPT!ON

Origina.l BuiI.ding

l

l

50CJ0 GF~,

i

I I yr - ••"'

111.E:i;-I::..,ee

DATE COMPLETED

19~.3

s.ubsecuer1t Im."::')ro;remerrt.s thr1J. 27 .. 11 .. Drl 62

r-·Iodif~r Bat ter·sr ~311.0'0 16 ?eb 62

Lay high pressure airline, ll-S-61

Construct concrete ramp 3-5-62

BALANCES FORWARDED

---.·.-·.;.'.

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I'T et~ 1< exi ·r:c 732 ASS I GNIAENT

r-n '1' n r'"'

TYPE OF CONSTRUCTION

F· er-r:L;.:r.:ent 1 CONDITION

tJsable l OCCUPANCY

Aj_.r Force l AIR FORCE INTEREST

Cri.r.rr-.:.ed l

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REMARKS

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TOTAL COST '}. ,· ___ ,..,.. _ _,)

AREA UN IT .--sr-COST

M!OUNT TOTAL

~506 S506 2.3,:?92100 23,292 00

(186~ a.~ ..... r. C· JG\.;' 10~267128 .42.559!28

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_1, '-'7C· ~1 .,.., 7. D- 47,529 .~""t ::;,.:_

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-ss.+o-- ~ ;•.;.,_ 155IS8 47,685[ (J:;

0 ·<ik.1~: 1)1~ '.32 I 32 47,718L01

I AF FORM

i 5 ..JUN 56. Jl+30 REPLACES DA FORM 5-47. 1 NOV 4S WHICH \S

OBSOLETE iN THE USAF. REAL PROPERTY ACCOUNTABLE RECORD - BUILDINGS ,. ~\

!' ,, "\.j ....

VOUCHER NO. DATE

17 Sept 62

63-115 !l? Sep 62

..- i -... .• L.: - .......

6L.-10 l? Sept 63

25l-66 •l At!r 66

.• /·. ,' ,:_,~,! i:; .. .? .: ,.. , ,.:;

DESCRIPTION

BALANCES FORWARDED

Replace compressor

- . - • . ··-~'...!o<L. .Lnstall water cooilng svst.em __... ... _, __ ... -i..:: __ •--.J..- ~ ... ~~ ~· ~-..,_-~-V"'VW lW'-..... -,.: $

Install ex..haust S\'Ster'.l

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DATE COMPLETED

6-26-61

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2-ll-6J

30 Ju.n 65

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8ALAMCES FORWARDED

8/3

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AREA UNIT

AMOUNT l TOTAL

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TOTAL COST

47, 718! 01

51.,6?4177

53,176 129

54,625 .1 90

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GPO 910393

-,.-. \

Allen, Pam, NMENV



Subject: FW: Admin Comment Matrix Attachments: Draft Permit Admin Comment Matrix.xlsx

5 of 5


-----Original Message-----From: PALMER, STEVEN L GS-12 USAF AFCEC 27 SOCES/AFCEC-CZO [mailto:[email protected]] Sent: Tuesday, December 05, 2017 5:00 PM To: Cobra in, Dave, NMENV <[email protected]> Cc: Acevedo, Gabriel, NMENV <[email protected]>; Wear, Benjamin, NMENV <[email protected]> Subject: Admin Comment Matrix

Dave, Since I had a minute left I figured I'd send along the comment matrix with the admin comments we found while reviewing the draft.

Steve

Steve Palmer Cannon AFB Restoration Program Manager 402 S Chindit Blvd, Building 102 Cannon AFB, NM 88103 AFCEC/CZO 575-904-6744 office 850-218-1544 cell

1

Date

Item I Source

10 11

12

13 14

15

Column A:

Column B:

ColumnC

Column D:

Column E:

Reviewer

Section Page I Para I 1.10.1 14

1.13.10 21-23

various

1.13.9.1 20

3.3.2.1 34

2.1 25

2.5.4 26 2.5.8 27

2.8.5 30

3.3.1 33 2

3.4 35 1

1.13.10.3 21 1

Attachment 1 3

Attachment 1 1

Attachment 3 2 Table 2

Comment Identifier Number

Sour~~JS:ommenter I Aut~.?rity)

Section Number of Comment -·--- -

Line

3, 4

2,3

4 heading

5

5WMU41

Common Comment and Response Worksheet1version3)

. _____ D_o_c_u_m_en_! Title (version) ___ _

Class Comment

A I remove second period at the end of the last sentence. A I paragraph numbering is incorrect. There are two 1.13.10.3 paragraphs. A !Some places it's "NMEO", others it is Hthe NMED". Consistancy?

A I need space between equivalent and NMEO. A I Add comma between "residential land useH and "industrial use" A I delete "rH between "waste," and "hazardous"

A !Change "CFR part262" to "CFR Part 262" A I 2.5.8 used for "Land Disposal Restrictions" and "Waste Minimization"

A I change" ... the all records" to " ... all the records" or " ... all records"

A I change " ... standard or an MCL has not been ... " to " ... standard nor an MCL has been .. A I change "as it may be updated" to "as updated" for consistency

Permit section #s 1.13.10.c.l, 1.13.10.c.2, and 1.13.10.d refer to the previously issued permit (2003). Change to

A I match current paragraph numbering. A !Change "Discription" to "Description"

A I Change "64/84" to "60/84"

A I Should have "1" in Comments column

Contract/TO Number

Response

Comment Classifications -----= -----------------t'(~ct Critical: Critical comments will result in a critical issue. Pro~de convincing support. . __ _ ____ __,

(M) Major: Major comments are significant concerns that may result in a major issue. This category may be used with a general statement of concern followed by a detailed comment on the specific entries in the document that,

considered in total, constitute the concern.

(S) Substantive: An entry in the document that appears to be or is potentially unnecessary, misleading, incorrect, or confusing.

: Page Number of Comment (first page associated with comment)

Caragraph number, on page, of Commen~ -I .. ~ . {A) Administrative: Administrative comments correct inconsistencies between different sections,_!'(pographical and grammatical errors.

l-----+-u_·n_e_N_um_be_!"_ (within Paragra_1_>h above) of Comment

Comment Classification --I t----~iC_omment __________ _

'.Response

0--~---+I Comments mu;f: be ac_!ionable ("-~dd the following text: .. ","delete .. ","change text to:")

0------+-P_la_ce_o_n~ly_one comment per r_o_w_. ----· ______ _

11· Classify commen_!._a_s~C~, M_,~5~, o_r_A_. ~----~----~-~----

Documents

Allen, Pam, NMENV .,j'EJ ENTERED - hwbdocuments.env.nm.gov AFB/2017-12-05 Permit Renewal... · and one Hesco barrier structure. The trenches and Hesco barriers were once used for