ENFORCEMENT CONFIDENTIAL-FOIAEXEMPT-DONOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINES S INFORMATION £EPA United States Environmental Protection Agency Office of Enforcement and Compliance Assmance Office of Criminal Enforcement, Forensics and Training NEICVP1068E02 MULTIMEDIA COMPLIANCE INVESTIGATION Radford Army Ammunition Plant (RF AAP) Radford, Virginia NEIC Project No.: VP1068 December 2014 �� Almando Bustamante, nvironmental Engineer Jessica Duggan, Physical Scientist Other Contributors: Doreen Au, Chemical Engineer Alison Ruhs, Environmental Scientist Linda TeKrony, Enviromnental Engineer Jackie Vega, Environmental Engineer David Holzwai1h, Info1mation Technology Specialist Jon Beihoffer, Principal Analytical Chemist Prepared for: EPA Region 3 1650 AI·ch Street Philadelphia, Pennsylvania 19103 Authorized for Release by: Suzanne Schuhnan, Civil Services Section Chief NATIONAL ENFORCEMENT INVESTIGATIONS CENTER P.O. Box 25227 Building 25, Denver Federal Center Denver, Colorado 80225 Page I of62 ENFORCENEN CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION CONTENTS INTRODUCTION 5 GENERAL BACKGROUND 5 ON- SITE INSPECTION SUMMARY 10 INSPECTION ACTIVITIES 10 Clean Air Act 10 Resource Conservation and Recovery Act 13 Clean Water Act 14 Clean Air Act 112(1?) 15 Emergency Plarming and Community Right-to-Know Act 17 SUMMARY OF FINDINGS AND OBSERVATIONS 19 POTENTIAL AREAS OF NONC OMPLIANC 19 CAA - AREAS OF CONCERN 33 RC RA POTENTIAL AREAS OF NONC OMPLIANC 36 OF CONCERN 39 WA POTENTIAL AREAS OF NONC OMPLIANC 39 WA AREAS OF CONCERN 54 AA POTENTIAL AREAS OF NONC OMPLIANC 56 OF CONCERN 59 EPC RA SECTION 313 POTENTIAL AREAS OF NONC OMPLIANC 61 TABLES 1 Limits for Incinerator?s 11 2 Summary of Observations 19 FIGURE 1 RFAAP operations ?owchart 7 APPENDICES -created Document) General Appendices (?Referenced only in General Appendix B) A Clean Air Act (CAA) Appendices AA A Comprehensive Performance Test Report and on?rmatory Test Summary (74 pages) AA Incinerator Tag Descriptions (2 pages) AA Incinerator 440 One-Horn Rolling Average Query Results (Excel spreadsheet) AA Incinerator 440 One-Horn Rolling Average Query Results (Excel spreadsheet) AA Incinerator Time Gaps (Excel spreadsheet) AA Hazardous Waste Incinerator Semiannual MAC Reports (100 pages) NEICVP1068E02 Page 2 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION CAAG CAAH CAAI Title Semiannual Reports (259 pages) Title Peimit as Amended May 2013 (50 pages) 2013 Quarterly Boiler Excess Emission Repons (33 pages) Opacity Exceedances (Excel spreadsheet) Resource Conservation and Recovery Act (RCRA) Appendices RCRAA RCRAB RCRAC RCRAD RCRAE RCRAF RCRAG RCRAH RCRAJ RFAAP RC RA Pennit for Incinerators and Storage (285 pages) RFAAP RC RA Pennit for 0 en B11111an Ground 385 ages 2013 and 2014 Ash Anal ical Results 12 ages) RCRA Photogra hs 41 ages Clean Water Act (CW A) Appendices CWAA CWAC CWAE CWAF CWAG CWAH CWAI CWAK CWAL CWAM VPDES Peimit No. VA0000248 (65 pages) WA Photogl?a 11s 19 Referenced DMRs (31 pages) Consent Order for US. Anny and BAE for State Water Control Law Violations (12 pages) VADEQ Notices of Violations for VPDES Permit No. VA0000248 (7 PageS) NEIC Summaiy of RFAAP's Unauthorized Discharges and Associated Noncompliance Noti?cations (1 page) Fact Sheet for VPDES Permit No. VA0000248 (192 pages) Clean Air Act 112(r) (CAA 112(r)) Appendices NEIC Photo ?a 115 16 ages CAA 112(1) CAA 112(1) CAA 112(1?) NEICVP1068E02 Radford Army Ammunition Plant Page 3 0f 62 Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE NIAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION CAA 112(1) CAA 112(1) CAA 112(1) 1: CAA 112(1) CAA 112(1) CAA 112(1)1 CAA 112(1) CAA 112(1) CAA 112(1) CAA 112(1) CAA 112(1) CAA 112(1) 0 Emergency Planning and Community Right to Know Act Section 313 (EPCRA 313) Appendices EPC 313 Orlgma an onecte Fonn 811 nutta 39 pages EPCRA 313 MSDS for LC 12-15 (3 pages) EPC RA 313 RY 2012 Copper Compounds Form (6 pages) This Contents page presents all sections contained in this report and provides a clear indication of the end of this report Radford Army Ammunition Plant NEICVP1068E02 Page 4 of 62 R3 11101 d, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION INTRODUCTION At the request of U.S. Environmental Protection Agency (EPA) Region 3, EPA’s National Enforcement Investigations Center (NEIC) conducted a multimedia compliance investigation of the Radford Army Ammunition Plant (RFAAP) in Radford, Virginia. RFAAP’s operations and associated waste streams are subject to major environmental statutes, including the Clean Air Act (CAA), Resource Conservation and Recovery Act (RCRA), Clean Water Act (CWA), Clean Air Act 112(r) (CAA 112(r)), and the Emergency Planning and Community Right-toKnow Act (EPCRA). Facility pollution control, waste generation, and waste management operations are subject to the requirements in environmental permits and regulations administered by the EPA and the Virginia Department of Environmental Quality (VADEQ). GENERAL BACKGROUND RFAAP is a U.S. Department of Defense (DOD) government-owned, contract-operated (GOCO) facility that manufactures specialty munitions, propellants, explosives, and chemicals for the U.S. Army and other users. BAE Systems Ordnance Systems, Inc. (BAE) became the principal operating contractor in July 2012. Alliant Techsystems, LLC (ATK) previously was RFAAP’s principal operating contractor. RFAAP was originally constructed in 1940 and 1941, and was one of the first single-base smokeless powder plants. The facility property totals acres; the Main Plant is situated on acres in Pulaski and Montgomery Counties. The New River separates the two counties and subdivides the Main Plant into the Main Manufacturing Area (Montgomery County) and the Horseshoe Area (Pulaski County). The remaining acres are used as a storage facility, called the New River Storage Unit, which lies southeast of Dublin, Virginia, in Pulaski County. The New River Storage Unit is not a manufacturing area and was not part of the NEIC investigation. RFAAP is categorized in the North American Industry Classification System (NAICS) as an explosives manufacturer (code 325920), a nitrogenous fertilizer manufacturer (code 325311), a small arms ammunition manufacturer (code 332992), and an ammunition (except small arms) manufacturer (code 332993). The Main Plant includes areas operated by BAE and major tenants on the property. General Appendix A lists all of the tenants and the applicable environmental regulations for each operation. Four of the tenants are subject to environmental regulation ( ). BAE has six management departments (environmental, quality, engineering, sales and marketing, facilities, and manufacturing areas). Currently, BAE operates five manufacturing areas: production (formally known as production NEICVP1068E02 Page 5 of 62 production) Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION production (formally known as production production) production Trinitrotoluene (TNT) production and dinitrotoluene (DNT) production processes previously were operated on the RFAAP site, but these processes are no longer in operation. Auxiliary operations managed and performed by BAE include: three laboratories (main laboratory, water laboratory, and laboratory); site-wide water treatment and three wastewater treatment areas; decontamination ovens; and powerhouse. Figure 1 is a flowchart that summarizes the operations performed by BAE and the four tenants subject to environmental regulations on-site. Figure 1 also identifies the operating areas and tenants inspected by NEIC; each area identified may have only been inspected by certain media groups. When BAE assumed the role of RFAAP’s principal operating contractor in July 2012, ATK retained three production areas as a tenant on-site: is more commonly referred to as New River Energetics (NRE), which is owned by ATK and Allegany Ballistics (ABL). NRE manufactures . NRE was part of the NEIC inspection, and a separate report (NEICVP1068E01) was prepared that summarizes that portion of the inspection. The three additional tenants on-site perform the following operations: NEICVP1068E02 Page 6 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOLA EXEMPT DO NOT RELEASE NIAY CONTAIN CONFIDENTIAL INF ORNIATION Figure 1. RFAAP operations flowchart Radford Army Ammunition Plant (RFAAP) Radford, Virginia . . Radford Army Ammunition Plant .NEIC Page 7 0f 62 Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION RFAAP is operating under CAA Title V permit No. VA-20656. This permit became effective on January 15, 2004, and expired on January 15, 2009, and the last administrative amendment was May 9, 2013. RFAAP applied for a new Title V permit on June 17, 2008; a new permit has not been issued. Several production processes are listed as part of the Title V permit, but do not have specific operational requirements: NG 1&2 – Nitrate Esters (now referred to as Nitroglycerin, only NG2 is still operating) SB – Single Base propellant (Solvent Propellant production area) MB – Multi Base propellant (Solvent and Solventless Propellant production areas) Process CW – Chemical Weighing and Grinding (Solvent Propellant production area) Misc 1 – Degreasing Operations (Maintenance area under Facilities Department) Misc 2 – Painting and Surface Coating (no longer operated – utilize contractors/tenants) Misc 3 – Abrasive Blasting (utilize contractors/tenants) Misc 4 – Rocket Manufacturing (Solventless Propellant production area) Misc 6 – Solvent Recovery (Solvent Propellant production area) Misc 7 – Onsite landfill Misc 8 – Open burning (Nitroglycerine production area) Misc 9 – Rolled powder (Solventless Propellant production area) Misc 10 – Nitric and Sulfuric Acid Concentrator (NAC-SAC) (Acids production area) Misc 11 – Decontamination oven (Utilities area under Facilities Department) Misc 12 – Vibratory conveyors Misc 13 – Misc. storage and process tanks Process LR – loading racks The RFAAP facility is RCRA permitted (permit No. VA1210020730) for treatment and storage of hazardous waste by VADEQ through three permitting documents (with the same permit number). The three permitting documents at RFAAP are for the following three areas/activities: (1) incinerator and associated storage areas, also referred to as the Explosive Waste Incinerator (EWI) permit, (2) open burning ground (OBG), and (3) corrective action activities. The RCRA permitting document addressing incineration and associated storage of hazardous waste (EWI) was issued on October 31, 2002, and expired on October 31, 2012. The U.S. Army and BAE submitted a permit renewal application in April 2012, which had not been processed by VADEQ at the time of the NEIC inspection. BAE was still operating under the expired permit that was issued on October 31, 2002, at the time of the NEIC inspection. The incinerators are also subject to maximum achievable control technology (MACT) standards under 40 Code of Federal Regulations (CFR) Part 63, Subpart EEE – National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors (Hazardous Waste Incinerator MACT). Permit No. VA1210020730 is for incineration treatment activities located in the northcentral portion of the main manufacturing area of the Main Plant. Included in the permitted incinerator treatment and storage area are the locations of all grinding, tank storage NEICVP1068E02 Page 8 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION and treatment, and incinerator operations (two incinerators) associated with the incineration of waste propellant at the facility. The RCRA permitting document addressing the open burning ground is effective for the southeast portion of the Horseshoe Area (in the loop of the river) of the Main Plant, on the northern bank of the New River. This permit became effective on October 28, 2005, and expires on October 28, 2015 (Appendix RCRA B). OBG operations are conducted in an area approximately 100 feet by 1,500 feet, in 6-foot by 18-foot pans situated on raised pads about 250 square feet in size. There are 8 pads at the OBG, each containing 2 burn pans, for a total of 16 pans. Virginia Pollutant Discharge Elimination System (VPDES) discharge permit No. VA0000248 (VPDES permit) identifies both the U.S. Army and BAE Systems Ordnance Systems Inc. as the “owners” of the RFAAP facility (Appendix CWA A). RFAAP is subject to the requirements of the VPDES permit, which became effective June 10, 2010, was modified on July 1, 2012, and is set to expire on June 9, 2015. RFAAP is authorized to discharge to the New River through 19 outfalls, which are categorized as 10 process outfalls, 8 storm water outfalls, and 1 outfall reported as the arithmetic addition of effluent monitoring at outfalls 402, 005, 006, 007, 014, 024, 026, 028, and 029. There are more than 100 additional storm water outfalls in the manufacturing area of RFAAP, but these outfalls are not identified in the VPDES permit. According to RFAAP’s VPDES permit fact sheet, at outfalls 007 and 029, RFAAP is also subject to the Organic Chemicals, Plastics and Synthetic Fibers regulations under 40 CFR Part 414, and at outfall 029, to the Explosives Manufacturing Point Source Category regulations under 40 CFR Part 457. Effluent limits in the VPDES permit were calculated and based on production and average flow from certain manufacturing processes and are explained in the VPDES permit fact sheet. Under the CAA 112(r) requirements, RFAAP submitted (on October 19, 2010) a risk management plan that covered three Program 1 process units and three Program 3 process units. Toxic chemicals (oleum, nitric acid, and ammonia), as well as flammable mixtures, are contained within the process units operated on-site. RFAAP has reported a couple incidents to the National Response Center in the last 3 years in which risk management program (RMP) chemicals were released due to equipment failure. For the EPCRA portion of the on-site inspection, NEIC conducted interviews and reviewed provided documentation for reporting years 2010, 2011, and 2012. The main RFAAP contact for discussions of EPCRA compliance was , BAE environmental manager. NEIC requested additional documentation, which RFAAP provided following the on-site inspection. NEICVP1068E02 Page 9 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION ON-SITE INSPECTION SUMMARY NEIC conducted the on-site inspection of the RFAAP facility February 4 through 12, 2014. The NEIC on-site inspection team consisted of Armando Bustamante (project manager), Jessica Duggan (project manager), Doreen Au, Alison Ruhs, Linda TeKrony, and Jackie Vega. Credentials were presented to U.S. Army Lieutenant Colonel Luis Ortiz, Commander of RFAAP, during the opening meeting on February 4, 2014. A closing meeting was held via telephone conference call on February 24, 2014, to discuss some of the preliminary inspection observations. The NEIC inspection team stressed that final determinations will be made in conjunction with regional personnel and after review of documents provided by RFAAP. General Appendix B (Process Report) summarizes the processes at RFAAP observed and discussed during the NEIC on-site inspection. INSPECTION ACTIVITIES Clean Air Act NEIC’s evaluated RFAAP’s compliance with the electronic data requirements and parametric monitoring conducted in accordance with 40 CFR Part 63 Subpart EEE – National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors (Hazardous Waste Incinerator MACT). NEIC inspection team members interviewed personnel, and collected and reviewed electronic data generated by RFAAP. NEIC inspection team members also interviewed personnel and collected electronic data for the boiler house to evaluate compliance with the opacity standard established in RFAAP’s CAA permit. NEIC was asked to determine if RFAAP’s Nitric Acid plant is subject requirements in 40 CFR Part 63, however, RFAAP is no longer operating a Nitric Acid plant. Incinerator Evaluation RFAAP has two hazardous waste incinerators, 440 and 441. 40 CFR §63.1209 establishes that facilities can set operating parameter limits for CEMS to demonstrate compliance with emission limits established under 40 CFR §63.1219, the replacement standards for hazardous waste incinerators. These limits were established using methods listed under 40 CFR §§63.1207 (b)(1) and (2). Generally RFAAP has established operating parameter limits from data collected during comprehensive performance tests [CPTs] and verified through confirmatory performance tests (Appendix CAA A). RFAAP conducted testing of the incinerators using the required test methods in 40 CFR § 63.1208. The minimum wet scrubber pressure drop was established using data other than results from CPTs. Operating parameter limits established from the CPTs are included as part of Appendix CAA A. Results of the confirmatory performance tests that recently established that the original limits were still valid were submitted in a Notification of Compliance document in June 2012 (Appendix CAA A). NEICVP1068E02 Page 10 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION The original limits were established in the comprehensive performance test (Appendix CAA A). NEIC collected electronic data from January 1, 2011, through December 31, 2013. RFAAP also provided a list of tag names and descriptions for the electronic data (Appendix CAA B). NEIC then performed the following queries on the data collected. For all times when waste feed is in the incinerator system, NEIC calculated, for each incinerator, either 60-minute rolling averages, or 12-hour rolling averages (as appropriate), of one minute averages for each of the operating parameter limits listed in Table 1. Incinerator A is incinerator 440, and incinerator B is incinerator 441. Both incinerators are identical in make model and process set up. RFAAP received permission to use the same operating parameter limits for both incinerators. 40 CFR § 63.1201 defines a rolling average as the average of all one-minute averages over the averaging period. Therefore NEIC, calculated its rolling average of all one-minute averages during a 60-minute time frame or 12-hour time frame, rolled each minute. Table 1. LIMITS FOR INCINERATORS Radford Army Ammunition Plant Radford, Virginia Data Tag IDs (for one minute average) A_TRAVG_475 B_TRAVG_475 A_TRAVG_476 B_TRAVG_476 A_FRAVG_360 B_FRAVG_360 A_FRAVG_360 B_FRAVG_360 A_FRAVG_400 B_FRAVG_400 A_Merc_RAVG B_Merc_RAVG A_ASH_RAVG B_ASH_RAVG A_SVM_RAVG B_SVM_RAVG A_LVM_RAVG B_LVM_RAVG A_CHLOR_RAVG B_CHLOR_RAVG A_TRAV_302 B_TRAV_302 A_FRAVG_371 B_FRAVG_371 Operating Parameter Limit Minimum kiln temperature 1306 degrees Fahrenheit (F) Minimum afterburner temperature 40 CFR Part 63 Subpart EEE Required Averaging Period Hourly rolling average (HRA) 1605 °F HRA Minimum flue gas velocity 20 feet per second (fps) HRA Maximum flue gas velocity 50 fps HRA 2,061 pounds/hour HRA Maximum total hazardous waste feedrate Maximum mercury feedrate Maximum ash feedrate Maximum semivolatile metals feedrate Maximum low volatile metals feedrate Maximum chlorine feedrate Maximum baghouse inlet temperature Minimum total scrubber system liquid flow rate 0.00040 pounds/hour 12-hour rolling average (RA) 49 pounds/hour 12-hour RA 6.4 pounds/hour 12-hour RA 1.7 pounds/hour 12-hour RA 19 pounds/hour 12-hour RA 356 F HRA 70 gallons per minute HRA Spreadsheets listing those times when RFAAP operated outside of these established parameters are included as Appendices CAA C and D and are discussed in the summary of observations table. NEIC did not review the maximum stack gas carbon monoxide NEICVP1068E02 Page 11 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION concentration, minimum wet scrubber pressure drop, minimum wet scrubber liquid pH, and the maximum kiln pressure operating parameters. NEIC established that waste was in the incinerator system by evaluating the waste feedrate tags (A_FRAVG_400 and B_FRAVG_400). If data existed in this tag, RFAAP was feeding waste into the incinerators. When RFAAP had cut off waste feed, these tags would contain a zero reading. As RFAAP described, in Appendix A, waste would still remain in their incinerators for approximately 20 minutes after the waste feedrate was cut off. Therefore, NEIC also included 20 minutes of data immediately after the waste feed was cut off. RFAAP also calculated its own HRA and 12-hour RAs for the reviewed parameters; the values of these tags are included in the data spreadsheets for comparison only. Based on NEIC’s queries, there were no exceedances of any 12-hour RAs. As detailed in the process description report, the hazardous waste incinerators are operated on an intermittent schedule. If waste feed is not in the incinerator system, the Hazardous Waste Incinerator MACT requirements do not apply. To account for this intermittent operating schedule with the HRA and the 12-hour RA, NEIC followed the requirements in 40 CFR § 63.1209(a)(6)(ii) for continuous emission monitoring systems (CEMS) and 40 § 63.1209(b)(5)(ii) for continuous monitoring systems (CMS). These requirements state, “You must ignore periods of time when one-minute values are not available for calculating the hourly rolling average. When one-minute values become available again, the first one-minute value is added to the previous 59 values to calculate the hourly rolling average.” Some time periods were missing from the electronic data NEIC received from RFAAP. Dates and times of these missing data are included in Appendix CAA E. Electronic data for both incinerators are recorded in two separate data systems, which ensures that if one data system is not collecting data, but the control systems are operational, the other data system is collecting data for both incinerators. Appendix CAA E only lists those times when neither electronic data system contains data for the incinerators. If NEIC used data from the other incinerator’s data system, it is identified as replacement values in the spreadsheets contained in Appendices CAA C and D. RFAAP reported incinerator exceedances in its hazardous waste incinerator semiannual MACT reports (Appendix CAA F) as well as in its Title V semi-annual reports (Appendix CAA G). In the hazardous waste incinerator semiannual MACT reports, all exceedances for the semi-annual time frame are summarized as a total duration and also as a percent of operating time when exceedances occurred. Several operating parameter exceedances may be occurring during the same time. Due to this overlap and summary reporting style, NEIC cannot compare the individual instances of exceedances to the reported total exceedances to determine if RFAAP met the reporting requirements in 40 CFR § 63.10(d)(4), as referenced by 40 CFR § 63.1211. NEICVP1068E02 Page 12 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION Boiler Evaluation NEIC requested and received 1-minute electronic data from January 2011 through December 2013 for boiler opacity measurements. NEIC calculated 6-minute block average opacities, starting at the top of the hour, for a total of 10 block averages each hour. According to permit VA-20656 (Appendix CAA H), requirements for boilers PH1 through PH5 (p. 16 of 50), “5. Visible emissions from each of the boiler stacks shall not exceed 20 percent opacity except during one six-minute period in any one hour in which visible emissions shall not exceed 60 percent opacity.” NEIC compared block average opacities to powerhouse opacity exceedances reported by RFAAP in its 2013 quarterly powerhouse excess emission reports (Appendix CAA I) and Title V semiannual reports (Appendix CAA G). Opacities with a block average of less than 20.5 were rounded down to 20 percent. Appendix CAA J is a spreadsheet that contains opacity exceedances found during the electronic data analysis that were not reported by RFAAP. For each exceedance, at least two 6-minute periods occurred within the hour that was greater than 20 percent opacity, or one exceedance occurred that was greater than 60 percent opacity. Exceedances are included in the Summary of Observations table. NEIC also conducted an inspection at NRE; the results of that inspection are included in a separate report (NEICVP1068E01). Resource Conservation and Recovery Act For the BAE-operated areas, NEIC evaluated RFAAP’s compliance with hazardous waste determinations and waste management practices, including handling and management practices for waste streams from tenants and off-site facilities. The waste determinations and waste management practices were evaluated at three BAE production areas (acids, nitrocellulose, and nitroglycerin); the decontamination ovens area managed by BAE; and at ATK’s Commercial Powder production areas (NRE). Additionally, NEIC evaluated waste management practices related to storage and treatment operations performed in the incinerator and OBG areas managed by the nitroglycerin production area (operated by BAE). The incinerators and OBG are hazardous waste management units (HMWUs) and RCRA-permitted by VADEQ. NEIC conducted the following tasks during the inspection: Reviewed waste determination records Inspected portions of and OBG) production areas (including the two incinerators Inspected several satellite hazardous waste accumulation areas associated with the main laboratory NEICVP1068E02 Page 13 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION Inspected several less-than-90-day hazardous waste accumulation areas (less-than-90-dayaccumulation areas) Conducted interviews with BAE and U.S. Army personnel Some of the interviews held with BAE and U.S. Army personnel regarded the use of the OBG rather than the incinerators, and under what circumstances the decontamination oven and associated scrap burn pile (SBP) would be used. Wastes that exhibit the hazardous waste characteristic of ignitability (EPA hazardous waste No. D001) or reactivity (EPA hazardous waste No. D003) are managed at the incinerators or the OBG. BAE personnel explained that the incinerators and their feed mechanisms limit the type of waste that can be managed and fed safely. Currently, the incinerators are designed to accept waste propellants only as slurries and liquids. Solid material cannot be directly fed to the incinerators, and must be slurried through grinding and the addition of water. The process of grinding a reactive waste poses a hazard that must be minimized by ensuring the waste does not contain sparking material. BAE personnel stated that replacing the current incinerator system with one that accepts solids has been proposed, but would be a very expensive upgrade that will not occur for some time. BAE provided a summary of the proposed new incinerator systems (Appendix RCRA C). In the interim, BAE has been decreasing the amount of propellant waste that must be managed at the OBG by working closely with the process area personnel to identify and minimize waste management practices that could cause contamination of the propellant waste with sparking debris (metal objects). BAE claims that more than 77 percent of the propellant waste by weight is being managed in the incinerators compared to less than 23 percent at the OBG. Additionally, only one burn is typically performed in a day at the OBG, using two or three pads per burn. Used equipment that may contain residual propellant material that must be decontaminated before reuse or scrapping is treated in the decontamination oven or the SBP. RFAAP provided NEIC a letter explaining how a non-hazardous waste determination was made for the equipment being decontaminated in the oven and/or the SBP (Appendix RCRA D). BAE and U.S. Army personnel stated that the SBP is only used to decontaminate equipment that is too large to be managed in the decontamination oven. According to the U.S. Army, large equipment cannot be cut down to fit into the decontamination oven for safety reasons. Although BAE and the U.S. Army believe it is highly unlikely that cutting equipment will cause an explosion, they are not willing to take that risk, and, therefore, believe that using the SBP for large equipment is the safest practice available. According to U.S. Army personnel, the SBP is currently used infrequently, less than once a year. Clean Water Act NEIC’s main objective for the CWA portion of the investigation was to evaluate RFAAP’s compliance with the VPDES permit. NEIC conducted a process-based evaluation of the biological wastewater treatment plant (bioplant), AB waste acid treatment plant (AB waste NEICVP1068E02 Page 14 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCENEIN CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION acid plant), and trickling ?lter treatment plant (sanitary plant). The Imhoff sanitary tank was not operating nor discharging at the time of the inspection. NEIC reviewed RFAAP sewer diagrams and did not identify or observe process wastewater discharges into the sanitary plant. NEIC focused on identifying process wastewater discharges from RFAAP and tenants to the bioplant and AB waste acid plant. NEIC also evaluated compliance monitoring and sampling at the following outfalls: process wastewater outfalls 007 and 029, sanitary wastewater outfall 026, and storm water outfall 017. Appendix CWA contains photographs for the CWA portion of the inspection. All ?eld measurements (global positioning system data associated with CWA photographs) in this report are within the scope of 17025 accreditation issued by AN SI-ASQ National Accreditation Board/FQS (Certi?cate NEIC conducted the following tasks during the inspection: 0 Process evaluation and wastewater generation discussions 0 Inspected and reviewed wastewater management at the on-site wastewater treatment plants (bioplant, AB waste acid plant, and sanitary plant) 0 Inspected and reviewed some of the wastewater management collection and distribution locations (equalization basins, tanks, and tenant monitoring points) 0 Inspected select VPDES outfalls Evaluated wastewater management operations, including compliance sampling and momtoring. Clean Air Act 112(r) NEIC ?s objective for the Clean Air Act 1120') portion of the investigation was to evaluate compliance with the 40 CFR Part 68 RMP requirements. The inspection focused on the RMP chemicals and the process areas covered by the risk management plan submitted in October 2010. Appendix CAA 112(r) A contains photographs for the Clean Air Act 112(1') portion of the inspection. RFAAP included three Program 1 process imits and three Program 3 process units in its crurent risk management plan, submitted on October 19, 2010. Toxic chemicals (oleurn, nitric acid, and ammonia), as well as ?ammable mixtures, are contained within the process imits operated on?site. Covered processes are: - located in the storage area 0 Propellant solvents area (Program 1 ethyl ether) storage (Program 1 - tank located in the storage area - i (Program 3 rank in the I main area tank farm at Radford Army Ammunition Plant NEICVP1068E02 Page 15 of 62 ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE NIAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION 0 ManufaF (Program 3 tanks at. main tank farm at Purchased_ (Program 1 RFAAP operates two cooling systems that contain RFAAP operates two processes that use chlorine for disinfection: drinking water treatment and sanitary waste treatment. There are --pound cylinders at drinking water treatment. and -pound cylinders at sanitary waste treatment. Both of these processes contain below the threshold quantity of chlorine. RFAAP categorizes on-site incidents into foru? different classes, A through D. Classes and are considered an incident under the risk management program and require the completion of an incident investigation. RFAAP has had two incidents in the last 3 years. The second incident occurred in October 2012 and involved a A HALO water suppression system is operated in the .tank farm area where the storage tanks are located. The system consists of. sensors. RFAAP follows ?preventative maintenance? (PM) documents to implement mechanical integiity inspections and requirements. Each month. the facility?s - computer system generates the PM activities that are required to be completed that month. The PM activities are scheduled with the maintenance department and. when completed. are logged into the Radford Army Ammunition Plant 7 'El( Page 16 of 62 Radiord?Virginia ENFORCENIENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION computerized tracking system. Internal and external inspections are recorded on paper documents. RFAAP uses an outside contractor to conduct the internal and external inspections on the ammonia handling system, including the pressru'e system, fail safe system, and release system. During the on-site inspection, RFAAP provided NEIC process hazard assessments (PHAS) for the following processes: tank farm - tank farm), - main tank farm at- and- storage. RFAAP tracks recommendations ?'om the PHAs as safety action requests, which are forwarded to the operating area for completion. Once completed, the safety action request is returned to the hazards analysis department. The environmental department tracks compliance audit ?ndings. RFAAP operates a hazardous material trained ?re team and a ?re department on-site. The hazardous material the team is Level A-trained and attends annual refreshers. Annual drills are held with Montgomery and Pulaski ormty ?re departments. Emergency Planning and Community Right-to-Know Act NEIC ?s objectives for the EPC RA portion of the investigation were to determine compliance with EPC RA Section 313 requirements as they apply to RFAAP, focusing on threshold determinations for Toxics Release Inventory (TRI) chemicals manufactured, processed, or otherwise (M, P, 0) used at the facility for reporting years (RYs) 2010, 2011, and 2012 and data quality issues for TRI-reported chemicals. RFAAP reported the following chemicals on its RYs 2010, 2011, and/012012 EPCRA TRI Form submittals: 2,4-dinitrotoluene Ammonia Chlorine 0 Copper 0 Dibutyl phthalate Dioxin and dioxin-like compormds Diphenylamine Hydrochloric acid 0 Lead 0 Mercruy Nitrate compormds Nitric acid 0 Nitroglycerin Radford Army Ammunition Plant NEICVP1068E02 Page 17 of 62 Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION Sulfuric acid NEIC reviewed RFAAP’s EPCRA TRI Form R submittals for RYs 2010, 2011, and 2012. NEIC also reviewed threshold calculations, release calculations, and material safety data sheets (MSDSs) for some chemical mixtures for the same three years. RFAAP uses a combination of mass balance calculations, emission factors, and engineering judgment to calculate releases. NEICVP1068E02 Page 18 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION SUMMARY OF FINDINGS AND OBSERVATIONS Findings identified by NEIC during the RFAAP investigation are summarized in the observations table below. These findings are linked to specific supporting documents that can be found in individual appendices to this table. These findings are categorized as potential areas of noncompliance (AON) and as areas of concern (AOC). Areas of concern are inspection observations of potential problems or activities that could impact the environment or result in future or current noncompliance. EPA Region 3 will assess the applicability of regulatory requirements based on its review of this report and other technical, regulatory, and facility information. # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence CAA– POTENTIAL AREAS OF NONCOMPLIANCE 1 40 CFR §63.1209(j) DRE. To remain in compliance with the Finding: destruction and removal efficiency (DRE) standard, you must establish operating limits during the comprehensive performance test…for the following parameters… and comply with those limits at all times that the hazardous waste remains in the combustion chamber… (1) Minimum combustion chamber temperature…(ii)You must establish a minimum hourly rolling average limit as the average of the test run averages (2) Maximum flue gas flow rate or production rate (ii) You must comply with this limit on a hourly rolling average basis (3) Maximum hazardous waste feedrate (i) You must establish limits on the maximum pumpable and total …hazardous waste feedrate for each location where hazardous waste is fed…(iii)You must comply with the feedrate limit(s) on a hourly rolling average basis. Permit VA-20656, Process Equipment Requirements – RCRA Hazardous Waste Incinerators A. Limitations 1. In accordance with 40 CFR 63, Subpart EEE, Section 63.1203(a), the permittee shall not discharge or cause combustion gases to be emitted into the atmosphere that contain emissions in excess NEICVP1068E02 RFAAP did not remain in compliance with the DRE standard because it did not comply with the operating limits standards on an hourly rolling average for the minimum combustion chamber temperature (kiln and afterburner) and the maximum flue gas flow rate. Notes: The minimum kiln combustion chamber temperature for incinerator 440 was not met on the following dates. Date Semi-annual Period Number of Rolling Hourly Exceedances 01/12/2011 1/1/2011 - 6/30/2011 32 03/25/2011 1/1/2011 - 6/30/2011 25 05/02/2011 1/1/2011 - 6/30/2011 48 05/03/2011 1/1/2011 - 6/30/2011 34 05/04/2011 1/1/2011 - 6/30/2011 22 07/13/2011 7/1/2011 - 12/31/2011 23 07/14/2011 7/1/2011 - 12/31/2011 130 12/21/2011 7/1/2011 - 12/31/2011 11 12/23/2011 7/1/2011 - 12/31/2011 55 01/06/2012 1/1/2012 - 6/30/2012 26 Page 19 of 62 Appendix CAA A – Comprehensive Performance Test Report and Confirmatory Test Summary Appendix CAA C – Incinerator 440 One-Hour Rolling Average Query Results Appendix CAA D – Incinerator 441 One-Hour Rolling Average Query Results Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information of the following: B. Monitoring 1. The permittee shall comply with the operating requirements and operating parameter limits specified in the September 29, 2003 or most current Documentation of Compliance prepared pursuant to 40 CFR 63, Subpart EEE, Section 63.1211; with the operating requirements and operating parameter limits specified in the Notification of Compliance prepared pursuant to 40 CFR, Subpart EEE, Section 63.1210; and with monitoring requirements in accordance with 40 CFR 63 Subpart EEE, Section 63.1209. NEICVP1068E02 Evidence 01/07/2012 1/1/2012 - 6/30/2012 56 01/11/2012 1/1/2012 - 6/30/2012 11 01/14/2012 1/1/2012 - 6/30/2012 54 02/01/2012 1/1/2012 - 6/30/2012 11 02/03/2012 1/1/2012 - 6/30/2012 54 02/15/2012 1/1/2012 - 6/30/2012 11 02/16/2012 1/1/2012 - 6/30/2012 47 05/19/2012 1/1/2012 - 6/30/2012 63 06/06/2012 1/1/2012 - 6/30/2012 55 06/27/2012 1/1/2012 - 6/30/2012 22 06/28/2012 1/1/2012 - 6/30/2012 64 06/29/2012 1/1/2012 - 6/30/2012 46 07/03/2012 7/1/2012 - 12/31/2012 8 07/04/2012 7/1/2012 - 12/31/2012 52 07/12/2012 7/1/2012 - 12/31/2012 20 07/13/2012 7/1/2012 - 12/31/2012 54 10/01/2012 7/1/2012 - 12/31/2012 31 10/15/2012 7/1/2012 - 12/31/2012 57 11/29/2012 7/1/2012 - 12/31/2012 64 03/29/2013 1/1/2013 - 6/30/2013 22 04/04/2013 1/1/2013 - 6/30/2013 57 04/30/2013 1/1/2013 - 6/30/2013 23 05/03/2013 1/1/2013 - 6/30/2013 56 05/17/2013 1/1/2013 - 6/30/2013 4 05/24/2013 1/1/2013 - 6/30/2013 54 05/31/2013 1/1/2013 - 6/30/2013 29 07/02/2013 7/1/2013 - 12/31/2013 37 07/30/2013 7/1/2013 - 12/31/2013 29 Page 20 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 07/31/2013 7/1/2013 - 12/31/2013 32 11/01/2013 7/1/2013 - 12/31/2013 58 11/21/2013 7/1/2013 - 12/31/2013 56 The minimum kiln combustion chamber temperature for incinerator 441 was not met on the following dates. NEICVP1068E02 Date Semi-annual Period Number of Rolling Hourly Exceedances 05/30/2011 1/1/2011 - 6/30/2011 51 06/15/2011 1/1/2011 - 6/30/2011 26 06/16/2011 1/1/2011 - 6/30/2011 56 07/09/2011 7/1/2011 - 12/31/2011 58 08/04/2011 7/1/2011 - 12/31/2011 52 09/03/2011 7/1/2011 - 12/31/2011 63 12/22/2011 7/1/2011 - 12/31/2011 18 12/23/2011 7/1/2011 - 12/31/2011 30 12/30/2011 7/1/2011 - 12/31/2011 56 02/11/2012 1/1/2012 - 6/30/2012 11 02/12/2012 1/1/2012 - 6/30/2012 54 03/03/2012 1/1/2012 - 6/30/2012 23 03/04/2012 1/1/2012 - 6/30/2012 57 03/05/2012 1/1/2012 - 6/30/2012 71 03/07/2012 1/1/2012 - 6/30/2012 8 03/08/2012 1/1/2012 - 6/30/2012 50 06/06/2012 1/1/2012 - 6/30/2012 59 06/09/2012 1/1/2012 - 6/30/2012 8 06/10/2012 1/1/2012 - 6/30/2012 47 06/28/2012 1/1/2012 - 6/30/2012 22 Page 21 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 06/30/2012 1/1/2012 - 6/30/2012 56 08/24/2012 7/1/2012 - 12/31/2012 27 08/26/2012 7/1/2012 - 12/31/2012 52 11/01/2012 7/1/2012 - 12/31/2012 25 11/26/2012 7/1/2012 - 12/31/2012 57 11/28/2012 7/1/2012 - 12/31/2012 23 12/04/2012 7/1/2012 - 12/31/2012 56 12/19/2012 7/1/2012 - 12/31/2012 26 01/30/2013 1/1/2013 - 6/30/2013 29 02/12/2013 1/1/2013 - 6/30/2013 56 04/26/2013 1/1/2013 - 6/30/2013 73 04/27/2013 1/1/2013 - 6/30/2013 35 08/01/2013 7/1/2013 - 12/31/2013 21 08/31/2013 7/1/2013 - 12/31/2013 25 10/04/2013 7/1/2013 - 12/31/2013 24 11/13/2013 7/1/2013 - 12/31/2013 27 11/29/2013 7/1/2013 - 12/31/2013 26 12/10/2013 7/1/2013 - 12/31/2013 56 The minimum afterburner combustion chamber temperature for incinerator 440 was not met on the following dates. NEICVP1068E02 Date Semi-annual Period Number of Rolling Hourly Exceedances 01/12/2011 1/1/2011 - 6/30/2011 34 02/07/2011 1/1/2011 - 6/30/2011 55 03/25/2011 1/1/2011 - 6/30/2011 27 05/02/2011 1/1/2011 - 6/30/2011 48 05/03/2011 1/1/2011 - 6/30/2011 34 Page 22 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # NEICVP1068E02 Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 05/04/2011 1/1/2011 - 6/30/2011 51 07/13/2011 7/1/2011 - 12/31/2011 26 07/14/2011 7/1/2011 - 12/31/2011 97 08/25/2011 7/1/2011 - 12/31/2011 10 08/27/2011 7/1/2011 - 12/31/2011 45 12/01/2011 7/1/2011 - 12/31/2011 20 12/02/2011 7/1/2011 - 12/31/2011 26 12/06/2011 7/1/2011 - 12/31/2011 58 12/21/2011 7/1/2011 - 12/31/2011 17 12/23/2011 7/1/2011 - 12/31/2011 57 01/06/2012 1/1/2012 - 6/30/2012 28 01/07/2012 1/1/2012 - 6/30/2012 58 01/11/2012 1/1/2012 - 6/30/2012 15 01/14/2012 1/1/2012 - 6/30/2012 57 02/01/2012 1/1/2012 - 6/30/2012 15 02/03/2012 1/1/2012 - 6/30/2012 57 02/15/2012 1/1/2012 - 6/30/2012 15 02/16/2012 1/1/2012 - 6/30/2012 49 03/30/2012 1/1/2012 - 6/30/2012 67 04/25/2012 1/1/2012 - 6/30/2012 69 04/26/2012 1/1/2012 - 6/30/2012 12 05/19/2012 1/1/2012 - 6/30/2012 71 06/06/2012 1/1/2012 - 6/30/2012 61 06/27/2012 1/1/2012 - 6/30/2012 24 06/28/2012 1/1/2012 - 6/30/2012 64 06/29/2012 1/1/2012 - 6/30/2012 55 07/03/2012 7/1/2012 - 12/31/2012 15 07/04/2012 7/1/2012 - 12/31/2012 52 Page 23 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 07/12/2012 7/1/2012 - 12/31/2012 23 07/13/2012 7/1/2012 - 12/31/2012 57 10/01/2012 7/1/2012 - 12/31/2012 33 10/15/2012 7/1/2012 - 12/31/2012 58 10/29/2012 7/1/2012 - 12/31/2012 69 11/29/2012 7/1/2012 - 12/31/2012 73 03/29/2013 1/1/2013 - 6/30/2013 24 04/04/2013 1/1/2013 - 6/30/2013 58 04/30/2013 1/1/2013 - 6/30/2013 25 05/03/2013 1/1/2013 - 6/30/2013 67 05/17/2013 1/1/2013 - 6/30/2013 9 05/24/2013 1/1/2013 - 6/30/2013 57 05/31/2013 1/1/2013 - 6/30/2013 31 07/02/2013 7/1/2013 - 12/31/2013 37 07/30/2013 7/1/2013 - 12/31/2013 29 07/31/2013 7/1/2013 - 12/31/2013 55 11/01/2013 7/1/2013 - 12/31/2013 60 11/21/2013 7/1/2013 - 12/31/2013 58 The minimum afterburner combustion chamber temperature for incinerator 441 was not met on the following dates. NEICVP1068E02 Date Semi-annual Period Number of Rolling Hourly Exceedances 05/19/2011 1/1/2011 - 6/30/2011 28 05/25/2011 1/1/2011 - 6/30/2011 59 05/28/2011 1/1/2011 - 6/30/2011 75 06/15/2011 1/1/2011 - 6/30/2011 28 06/16/2011 1/1/2011 - 6/30/2011 58 Page 24 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # NEICVP1068E02 Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 07/09/2011 7/1/2011 - 12/31/2011 67 08/04/2011 7/1/2011 - 12/31/2011 61 08/06/2011 7/1/2011 - 12/31/2011 58 09/03/2011 7/1/2011 - 12/31/2011 64 11/01/2011 7/1/2011 - 12/31/2011 2 11/02/2011 7/1/2011 - 12/31/2011 56 12/22/2011 7/1/2011 - 12/31/2011 20 12/23/2011 7/1/2011 - 12/31/2011 30 12/30/2011 7/1/2011 - 12/31/2011 58 02/02/2012 1/1/2012 - 6/30/2012 50 02/11/2012 1/1/2012 - 6/30/2012 15 02/12/2012 1/1/2012 - 6/30/2012 56 03/03/2012 1/1/2012 - 6/30/2012 24 03/04/2012 1/1/2012 - 6/30/2012 58 03/05/2012 1/1/2012 - 6/30/2012 79 03/07/2012 1/1/2012 - 6/30/2012 16 03/08/2012 1/1/2012 - 6/30/2012 55 05/17/2012 1/1/2012 - 6/30/2012 28 05/21/2012 1/1/2012 - 6/30/2012 58 06/06/2012 1/1/2012 - 6/30/2012 60 06/09/2012 1/1/2012 - 6/30/2012 13 06/10/2012 1/1/2012 - 6/30/2012 54 06/28/2012 1/1/2012 - 6/30/2012 24 06/30/2012 1/1/2012 - 6/30/2012 58 07/03/2012 7/1/2012 - 12/31/2012 59 08/24/2012 7/1/2012 - 12/31/2012 31 08/26/2012 7/1/2012 - 12/31/2012 56 11/01/2012 7/1/2012 - 12/31/2012 27 Page 25 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 11/26/2012 7/1/2012 - 12/31/2012 58 11/28/2012 7/1/2012 - 12/31/2012 25 12/04/2012 7/1/2012 - 12/31/2012 58 12/19/2012 7/1/2012 - 12/31/2012 28 01/30/2013 1/1/2013 - 6/30/2013 29 02/12/2013 1/1/2013 - 6/30/2013 58 02/28/2013 1/1/2013 - 6/30/2013 24 03/29/2013 1/1/2013 - 6/30/2013 28 04/24/2013 1/1/2013 - 6/30/2013 27 04/26/2013 1/1/2013 - 6/30/2013 76 04/27/2013 1/1/2013 - 6/30/2013 49 06/26/2013 1/1/2013 - 6/30/2013 32 07/01/2013 7/1/2013 - 12/31/2013 38 07/03/2013 7/1/2013 - 12/31/2013 48 08/01/2013 7/1/2013 - 12/31/2013 23 08/31/2013 7/1/2013 - 12/31/2013 25 10/04/2013 7/1/2013 - 12/31/2013 24 11/13/2013 7/1/2013 - 12/31/2013 27 11/29/2013 7/1/2013 - 12/31/2013 26 12/10/2013 7/1/2013 - 12/31/2013 58 The maximum flue gas flow rate for incinerator 440 was exceeded on the following dates: NEICVP1068E02 Date Semi-Annual Period Number of Rolling Hourly Exceedances 05/04/2011 1/1/2011 - 6/30/2011 34 07/08/2011 7/1/2011 - 12/31/2011 61 07/20/2011 7/1/2011 - 12/31/2011 49 Page 26 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 07/21/2011 7/1/2011 - 12/31/2011 7 12/11/2011 7/1/2011 - 12/31/2011 61 11/30/2012 7/1/2012 - 12/31/2012 32 During the time frame reviewed, the maximum flue gas flow rate for incinerator 441 was not exceeded. 2 40 CFR §63.1209(k) Dioxins and furans. You must comply with the dioxin and furans emission standard by establishing and complying with the following operating parameter limits. You must base the limits on operations during the comprehensive performance test… (1) Gas temperature at the inlet to a dry particulate matter control device (i)…if the combustor is equipped with a…baghouse (fabric filter)…you must establish a limit on the maximum temperature of the gas at the inlet to the device on an hourly rolling average. (2) Minimum combustion chamber temperature…(ii)You must establish a minimum hourly rolling average limit as the average of the test run averages. (3) Maximum flue gas flow rate or production rate…(ii) You must comply with this limit on a hourly rolling average basis. (4) Maximum hazardous waste feedrate (i) You must establish limits on the maximum pumpable and total hazardous waste feedrate for each location where hazardous waste is fed…(iii)You must comply with the feedrate limit(s) on a hourly rolling average basis. Permit VA-20656, Process Equipment Requirements – RCRA Hazardous Waste Incinerators A. Limitations NEICVP1068E02 During the time frame reviewed, the maximum hazardous waste feedrate for neither incinerator 440 nor incinerator 441 was exceeded. Finding: RFAAP did not remain in compliance with the dioxins and furans emission standard because it did not comply with the operating limits standards on an hourly rolling average for the maximum temperature of the gas at the inlet to the baghouse, minimum combustion chamber temperature in the kiln and afterburner, and the maximum flue gas flow rate. Notes: The maximum inlet temperature of the gas at the inlet to the baghouse for incinerator 440 was exceeded on the following dates: Date Semi-Annual Period Number of Rolling Hourly Exceedances 01/22/2011 1/1/2011 – 6/30/2011 6 10/24/2011 7/1/2011 – 12/31/2011 62 12/27/2011 7/1/2011 – 12/31/2011 28 02/16/2012 1/1/2012 – 6/30/2012 2 11/01/2013 7/1/2013 – 12/31/2013 61 11/21/2013 7/1/2013 – 12/31/2013 59 11/25/2013 7/1/2013 – 12/31/2013 3 Appendix CAA A – Comprehensive Performance Test Report and Confirmatory Test Summary Appendix CAA C – Incinerator 440 One-Hour Rolling Average Query Results Appendix CAA D – Incinerator 441 One-Hour Rolling Average Query Results The maximum inlet temperature of the gas at the inlet to the baghouse for incinerator 411 was exceeded on the following dates: Page 27 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # 3 Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information 1. In accordance with 40 CFR 63, Subpart EEE, Number of Section 63.1203(a), the permittee shall not Rolling discharge or cause combustion gases to be emitted Date Semi-Annual Period Hourly into the atmosphere that contain emissions in excess Exceedances of the following: 01/13/2011 1/1/2011 – 6/30/2011 8 B. Monitoring 01/15/2011 1/1/2011 – 6/30/2011 54 1. The permittee shall comply with the operating requirements and operating parameter limits 03/13/2011 1/1/2011 – 6/30/2011 5 specified in the September 29, 2003 or most current 08/04/2011 7/1/2011 – 12/31/2011 59 Documentation of Compliance prepared pursuant to 40 CFR 63, Subpart EEE, Section 63.1211; with the 06/06/2012 1/1/2012 – 6/30/2012 4 operating requirements and operating parameter 07/03/2012 7/1/2012 – 12/31/2012 8 limits specified in the Notification of Compliance 08/23/2012 7/1/2012 – 12/31/2012 4 prepared pursuant to 40 CFR, Subpart EEE, Section 63.1210; and with monitoring requirements in accordance with 40 CFR 63 Subpart EEE, See AON 1 for list of dates of exceedances of the minimum Section 63.1209. combustion chamber temperature and maximum flue gas flow rate. Finding: 40 CFR §63.1209(m) Particulate matter. You must comply with the particulate matter emission standard by establishing RFAAP did not remain in compliance with the particulate and complying with the following operating parameter matter emissions standard because it did not comply with the limits… operating limits standards on an hourly rolling average for the (2) Maximum flue gas flow rate… (i) As an indicator of maximum flue gas flow rate. gas residence time in the control device, you must Notes: establish a limit on the maximum flue gas See AON 1 for dates of exceedances of the maximum flue gas flow flowrate…as the average of the maximum hourly rate. rolling averages for each run (ii) You must comply with this limit on a hourly rolling average basis. During the time frame reviewed, the maximum ash feedrate for (3) Maximum ash feedrate. Owners and operators of neither incinerator 440 nor incinerator 441 was exceeded. hazardous waste incinerators… must establish a maximum ash feedrate limit as a 12-hour rolling average. Permit VA-20656, Process Equipment Requirements – RCRA Hazardous Waste Incinerators A. Limitations 1. In accordance with 40 CFR 63, Subpart EEE, Section 63.1203(a), the permittee shall not discharge or cause combustion gases to be emitted into the atmosphere that contain emissions in excess of the following: NEICVP1068E02 Page 28 of 62 Evidence Appendix CAA A – Comprehensive Performance Test Report and Confirmatory Test Summary Appendix CAA C – Incinerator 440 One-Hour Rolling Average Query Results Appendix CAA D – Incinerator 441 One-Hour Rolling Average Query Results Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # 4 Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information B. Monitoring 1. The permittee shall comply with the operating requirements and operating parameter limits specified in the September 29, 2003 or most current Documentation of Compliance prepared pursuant to 40 CFR 63, Subpart EEE, Section 63.1211; with the operating requirements and operating parameter limits specified in the Notification of Compliance prepared pursuant to 40 CFR, Subpart EEE, Section 63.1210; and with monitoring requirements in accordance with 40 CFR 63 Subpart EEE, Section 63.1209. 40 CFR§63.1209(n) Semivolatile metals and low volatility metals. You must comply with the semivolatile metal…and low volatile metal emission standards by establishing and complying with the following operating parameter limits. (1) Maximum inlet temperature to dry particulate matter air pollution control device. You must establish a limit on the maximum inlet temperature to the primary dry metals emissions control device…on an hourly rolling average. (2) Maximum feedrate of semivolatile and low volatile metals (i) General. You must establish feedrate limits for semivolatile metals…and low volatile metals as follows…(ii) For incinerators…you must establish 12-hour rolling average limits for the total feedrate of semivolatile and low volatile metals. (3) Control device operating parameter limits. You must establish operating parameter limits on the particulate matter control device as specified by paragraph (m)(1) of this section (4) Maximum total chlorine and chloride feedrate. You must establish a 12-hour rolling average limit for the feedrate of total chlorine and chloride in all feedstreams… (5) Maximum flue gas flow rate…(i) As an indicator of gas residence time in the control device, you must establish a limit of the maximum flue gas flowrate… as the average of the maximum hourly rolling NEICVP1068E02 Evidence Finding: RFAAP did not remain in compliance with the semivolatile metals and low volatility metals emission standards because it did not comply with the maximum inlet temperature to the baghouse and maximum flue gas flow rate. Notes: See AON 2 for dates of exceedances of the maximum inlet temperature to the baghouse. See AON 1 for dates of exceedances of the maximum flue gas flow rate. During the time frame reviewed, the maximum semivolatile, low volatile, total chloride, and chlorine feedrate rates for neither incinerator 440 nor incinerator 441 were exceeded. Page 29 of 62 Appendix CAA A – Comprehensive Performance Test Report and Confirmatory Test Summary Appendix CAA C – Incinerator 440 One-Hour Rolling Average Query Results Appendix CAA D – Incinerator 441 One-Hour Rolling Average Query Results Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # 5 Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information average(ii) You must comply with this limit on a hourly rolling average basis for each run Permit VA-20656, Process Equipment Requirements – RCRA Hazardous Waste Incinerators A. Limitations 1. In accordance with 40 CFR 63, Subpart EEE, Section 63.1203(a), the permittee shall not discharge or cause combustion gases to be emitted into the atmosphere that contain emissions in excess of the following: B. Monitoring 1. The permittee shall comply with the operating requirements and operating parameter limits specified in the September 29, 2003 or most current Documentation of Compliance prepared pursuant to 40 CFR 63, Subpart EEE, Section 63.1211; with the operating requirements and operating parameter limits specified in the Notification of Compliance prepared pursuant to 40 CFR, Subpart EEE, Section 63.1210; and with monitoring requirements in accordance with 40 CFR 63 Subpart EEE, Section 63.1209. 40 CFR §63.1209(o) Hydrogen chloride and chlorine gas. Finding: You must comply with the hydrogen chloride and chlorine RFAAP did not remain in compliance with the hydrogen gas emission standard by establishing and complying with chloride and chlorine emissions standard because it did not the following operating parameter limits. You must base the comply with the minimum scrubber water flow rate and limits on operations during the comprehensive performance maximum flue gas flow rate. test… Notes: (1) Feedrate of total chlorine and chloride (i) The minimum total scrubber system liquid flow rate for incinerator Incinerators…You must establish a 12-hour rolling 440 was not met on the following dates. average limit for the total feedrate of chlorine in all feedstreams… Number of Rolling (3) (v) You must establish limits on…the minimum Date Semi-annual Period Hourly Exceedances scrubber water flow rate and maximum flue gas 01/12/2011 1/1/2011 – 6/30/2011 14 flow rate on an hourly rolling average…. Permit VA-20656, Process Equipment Requirements – RCRA Hazardous Waste Incinerators A. Limitations NEICVP1068E02 03/25/2011 1/1/2011 – 6/30/2011 2 05/02/2011 1/1/2011 – 6/30/2011 36 12/01/2011 7/1/2011 – 12/31/2011 7 Page 30 of 62 Evidence Appendix CAA A – Comprehensive Performance Test Report and Confirmatory Test Summary Appendix CAA C – Incinerator 440 One-Hour Rolling Average Query Results Appendix CAA D – Incinerator 441 One-Hour Rolling Average Query Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation 1. Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information In accordance with 40 CFR 63, Subpart EEE, Section 63.1203(a), the permittee shall not discharge or cause combustion gases to be emitted into the atmosphere that contain emissions in excess of the following: B. Monitoring 1. The permittee shall comply with the operating requirements and operating parameter limits specified in the September 29, 2003 or most current Documentation of Compliance prepared pursuant to 40 CFR 63, Subpart EEE, Section 63.1211; with the operating requirements and operating parameter limits specified in the Notification of Compliance prepared pursuant to 40 CFR, Subpart EEE, Section 63.1210; and with monitoring requirements in accordance with 40 CFR 63 Subpart EEE, Section 63.1209. Evidence 12/02/2011 7/1/2011 – 12/31/2011 26 12/06/2011 7/1/2011 – 12/31/2011 44 01/06/2012 1/1/2012 – 6/30/2012 15 01/07/2012 1/1/2012 – 6/30/2012 40 05/09/2012 1/1/2012 – 6/30/2012 58 06/27/2012 1/1/2012 – 6/30/2012 23 06/28/2012 1/1/2012 – 6/30/2012 60 10/01/2012 7/1/2012 – 12/31/2012 32 10/15/2012 7/1/2012 – 12/31/2012 38 03/29/2013 1/1/2013 – 6/30/2013 7 04/04/2013 1/1/2013 – 6/30/2013 39 04/30/2013 1/1/2013 – 6/30/2013 7 05/03/2013 1/1/2013 – 6/30/2013 40 05/31/2013 1/1/2013 – 6/30/2013 15 07/02/2013 7/1/2013 – 12/31/2013 37 07/30/2013 7/1/2013 – 12/31/2013 29 07/31/2013 7/1/2013 – 12/31/2013 20 11/01/2013 7/1/2013 – 12/31/2013 45 11/21/2013 7/1/2013 – 12/31/2013 44 Results The minimum total scrubber system liquid flow rate for incinerator 441 was not met on the following dates. NEICVP1068E02 Date Semi-annual Period Number of Rolling Hourly Exceedances 05/19/2011 1/1/2011 – 6/30/2011 18 05/25/2011 1/1/2011 – 6/30/2011 47 06/15/2011 1/1/2011 – 6/30/2011 19 06/16/2011 1/1/2011 – 6/30/2011 32 Page 31 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # NEICVP1068E02 Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 08/04/2011 7/1/2011 – 12/31/2011 58 12/22/2011 7/1/2011 – 12/31/2011 11 12/23/2011 7/1/2011 – 12/31/2011 30 12/30/2011 7/1/2011 – 12/31/2011 48 03/03/2012 1/1/2012 – 6/30/2012 14 03/04/2012 1/1/2012 – 6/30/2012 46 03/10/2012 1/1/2012 – 6/30/2012 2 03/21/2012 1/1/2012 – 6/30/2012 33 05/17/2012 1/1/2012 – 6/30/2012 13 05/21/2012 1/1/2012 – 6/30/2012 44 06/28/2012 1/1/2012 – 6/30/2012 24 06/30/2012 1/1/2012 – 6/30/2012 47 11/01/2012 7/1/2012 – 12/31/2012 24 11/26/2012 7/1/2012 – 12/31/2012 57 11/28/2012 7/1/2012 – 12/31/2012 24 12/04/2012 7/1/2012 – 12/31/2012 48 12/19/2012 7/1/2012 – 12/31/2012 14 01/30/2013 1/1/2013 – 6/30/2013 29 02/12/2013 1/1/2013 – 6/30/2013 47 02/28/2013 1/1/2013 – 6/30/2013 12 03/29/2013 1/1/2013 – 6/30/2013 28 04/24/2013 1/1/2013 – 6/30/2013 27 04/26/2013 1/1/2013 – 6/30/2013 47 06/26/2013 1/1/2013 – 6/30/2013 25 07/01/2013 7/1/2013 – 12/31/2013 38 07/03/2013 7/1/2013 – 12/31/2013 12 08/01/2013 7/1/2013 – 12/31/2013 15 08/31/2013 7/1/2013 – 12/31/2013 25 Page 32 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 10/04/2013 7/1/2013 – 12/31/2013 24 11/13/2013 7/1/2013 – 12/31/2013 27 11/29/2013 7/1/2013 – 12/31/2013 26 12/10/2013 7/1/2013 – 12/31/2013 47 See AON 1 for dates of exceedances of the maximum flue gas flow rate. 6 Permit VA-20656, Fuel Burning Requirements – Boilers PH1 through PH5, A. Limitations 5. Visible emissions from each of the boiler stacks shall not exceed 20 percent opacity except during one six-minute period in any one hour in which visible emissions shall not exceed 60 percent opacity. During the time frame reviewed, the maximum total chloride and chlorine feedrates for neither incinerator 440 nor incinerator 441 was exceeded. Finding: RFAAP exceeded the opacity limits for the boilers. RFAAP reported exceedances in its quarterly boiler excess emission reports and Title V semiannual reports. Notes: NEIC reviewed electronic data to determine if any additional opacity exceedances occurred that were not reported by RFAAP. Additional exceedances not reported by RFAAP are listed the below: January 1 through June 30, 2011: 5 exceedances July 1 through December 31, 2011: 6 exceedances January 1 through June 30, 2012: 36 exceedances July 1 through December 31, 2012: 135 exceedances January 1 through June 30, 2013: 56 exceedances July 1 through December 31, 2013: 49 exceedances CAA - AREAS OF CONCERN A 40 CFR §63.1209(l) Mercury. You must comply with the mercury emission standard by establishing and complying with the following operating parameter limits. You must base the limits on operations during the comprehensive performance test…(1) Feedrate of Mercury. For incinerators… you must establish a 12-hour rolling average limit for the total feedrate of mercury in all feedstreams as the average of the test run average. NEICVP1068E02 Appendix CAA G – Title V Semiannual reports Appendix CAA I – 2013 Quarterly Boiler Excess Emission Reports Appendix CAA J – Opacity Exceedances Notes: RFAAP did not exceed the 12-hour RA for mercury; however, it also monitors a minimum flue gas velocity for mercury on an hourly rolling average. The minimum flue gas velocity for incinerator 440 was not met on the following dates. Page 33 of 62 Appendix CAA H – Title V Permit Appendix CAA A Confirmatory Performance Test Reports Appendix CAA C – Incinerator 440 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence Date Semi-annual Period Number of Rolling Hourly Exceedances 01/12/2011 1/1/2011 – 6/30/2011 7 03/25/2011 1/1/2011 – 6/30/2011 1 05/02/2011 1/1/2011 – 6/30/2011 33 07/21/2011 7/1/2011 – 12/31/2011 30 12/02/2011 7/1/2011 – 12/31/2011 14 12/06/2011 7/1/2011 – 12/31/2011 20 06/27/2012 1/1/2012 – 6/30/2012 2 06/28/2012 1/1/2012 – 6/30/2012 2 10/01/2012 7/1/2012 – 12/31/2012 5 10/15/2012 7/1/2012 – 12/31/2012 26 05/31/2013 1/1/2013 – 6/30/2013 7 07/02/2013 7/1/2013 – 12/31/2013 37 07/30/2013 7/1/2013 – 12/31/2013 29 11/01/2013 7/1/2013 – 12/31/2013 32 11/21/2013 7/1/2013 – 12/31/2013 26 One-Hour Rolling Average Query Results Appendix CAA D – Incinerator 441 One-Hour Rolling Average Query Results The minimum flue gas velocity for incinerator 441 was not met during the following dates. NEICVP1068E02 Date Semi-annual Period Number of Rolling Hourly Exceedances 05/19/2011 1/1/2011 – 6/30/2011 14 05/25/2011 1/1/2011 – 6/30/2011 35 08/04/2011 7/1/2011 – 12/31/2011 15 12/23/2011 7/1/2011 – 12/31/2011 23 12/30/2011 7/1/2011 – 12/31/2011 36 03/04/2012 1/1/2012 – 6/30/2012 2 Page 34 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # B NEICVP1068E02 Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence 06/30/2012 1/1/2012 – 6/30/2012 40 11/28/2012 7/1/2012 – 12/31/2012 4 12/04/2012 7/1/2012 – 12/31/2012 51 01/30/2013 1/1/2013 – 6/30/2013 26 02/12/2013 1/1/2013 – 6/30/2013 29 03/29/2013 1/1/2013 – 6/30/2013 25 04/24/2013 1/1/2013 – 6/30/2013 27 04/26/2013 1/1/2013 – 6/30/2013 76 04/27/2013 1/1/2013 – 6/30/2013 4 06/26/2013 1/1/2013 – 6/30/2013 3 07/01/2013 7/1/2013 – 12/31/2013 32 10/04/2013 7/1/2013 – 12/31/2013 24 11/13/2013 7/1/2013 – 12/31/2013 27 11/29/2013 7/1/2013 – 12/31/2013 26 12/10/2013 7/1/2013 – 12/31/2013 27 Notes: Electronic data for incinerators 440 and 441 are recorded in two separate data systems, which ensure that if one data system is not collecting data, but the control systems are operational, the other data system is collecting data for both incinerators. Despite this redundant system, no operating data was recorded during the following times. It is unclear what caused the missing data. Start Time End Time DDHHMMSS 2/18/11 1:49 PM 2/18/11 1:55 PM 00:00:08:00 4/1/11 9:52 AM 4/1/11 10:02 AM 00:00:12:00 6/28/11 2:01 PM 6/28/11 2:07 PM 00:00:08:00 2/26/12 12:00 AM 2/26/12 11:23 AM 00:11:25:00 12/21/12 1:01 PM 12/21/12 2:02 PM 00:01:03:00 12/30/12 11:54 PM 12/31/12 11:59 PM 01:00:07:00 Page 35 of 62 Appendix CAA E – Incinerator Time Gaps Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL OIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information 1/2/134228 PM 1/3/139200 AM 00:16:34200 E?dence 12/22/13 2:28 PM 12/22l13 2:30 PM 00100102100 Notes: review of the boiler opacity data showed that there is null data from January 201 1 through May 201 l. Opacity readings from December 30, 2012, through January 4, 2013, equaled the same value of 23.5. It is unlikely that the opacity did not vary during this 5-day time frame. It is unclear if these problems are with the analyzer or the data acqu_isition device. RCRA - POTENTIAL AREAS OF NONCOMPLIANCE Title 9 of the Virginia Administrative Code (VAC) 20-60- 262. Adoption of 40 FR Part 262 by reference. A. Except as otheiwise provided, the regulations of the United States Environmental Protection Agency set forth in 40 CFR Part 262 are hereby incorporated as part of the Virginia Ha:ardous Waste Management Regulations. 40 CFR 262.11 A person who generates a solid waste, as de?ned in 40 CFR 261.2, must determine if that waste is a ha:ard0us waste Finding: main laboratory (technical analytical laboratory, also referred to as the laboratory) disposes of analyzed ash samples as non?hazardous waste as part of the regular trash without making a hazardous waste determination based on sample analyses. The ash samples are from the hazardous waste incinerator and open burning ground, and RFAAP manages the ash from these areas as hazardous waste. Notes: Composite samples are collected of the ash from the open burning gromld and also ed off- . The two composite samples for each shipment of ash are tested in the on-site laboratory for moisture. tics. and oxidizer characteristics. According to chemist at RFAAP. the remaining solids from the ash analyses are disposed of in the general trash. RFAAP ships the ash to .under three separate pro?les. one for incinerator ash and two for open binning gromld ash. The incinerator ash is shipped as a hazardous waste characteristic for ignitability and lead (hazardous waste munbers D001and D008). The open burning grormd ash is shipped as either hazardous waste characteristic for lead only (D008) or for both ignitability and lead Appendix RCRA 2013 and 2014 Ash Analytical Results WF NEICVP1068E02 Page 36 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence (D001and D008). Ash resulting from a burn containing ?ash suppressant materials will test positive as an oxidizer. which is an ignitable hazardous waste. hazardous waste munber D001. For the binning gromld ash. the oxidizer test is used to determine if it should be shipped as an ignitable hazardous waste. Toxicity characteristic leaching procedure (TCLP) analysis for metals is performed on the ash sample annually by an outside laboratory.?. The TCLP metals analytical results for 2013 and 2014 are included in RCRA Appendix E. For the TC LP analytical results from August 2013. lead was non-detect for the open binning ground ash and showed 20.5 mg/L TC LP lead for the incinerator ash. tracking records to for 201 sh were included in the records provided The three shipments included: 0 6/19/13 incinerator ash D001. open binning gromld ash D008 0 4/25/13 incinerator ash D001. D008: open binning ground ash D008 0 2/14/13 incinerator ash D001. D008: open binning gromld ash D001 . open burning ground ash D008 Using only the shipment records NEIC was provided during the inspection and discounting the open burning ground ash shipments that were only shipped as D008 (since the 2013 lead results were non-detect). hazardous waste ash was disposed in the general trash from four sets of analytical results. (Appendix RCRA Appendix G). The ash sample analyses results may not always exhibit the characteristics of a hazardous waste. However. the laboratory currently manages the ash samples as non-hazardous waste NEICVP1068E02 Page 37 0 62 Radford Army Ammunition Plant Radford, Virginia ENFORCENIENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence regardless of the analytical results. A waste determination must be made on the ash sample residues prior to disposal to ensru?e appropriate management. 2 9 VAC 20?60?270. Adoption of 40 CFR Part 270 by reference - A. Except as othetwise provided, those regulations of the United States Environmental Protection Agency set forth in 40 CFR Part 2 70 are hereby incmporated as part of the Virginia Ha:ardous Waste Management Regulations. 40 CFR 270.1(c) Scope of the RCRA pennit requirement RCRA requires a pennit for the ?treatment, ?storage, and ?disposal of an)" ?hazardous waste as identified or listed in 40 CFRpart 261 Finding: BAE-operated manufacturing areas are accepting and managing tenant-generated hazardous waste at less- than-90-day accumulation areas rather than in RCRA- permitted storage areas. Notes: Although BAE is the site-wide operating contractor and the operator of several manufacturing areas on-site. several manufacturing operations on-site are perf r' ual and BAE manages many of the waste streams generated by other tenants as part of BAE- generated hazardous waste. Upon review of the waste tracking records for tenant waste received and managed by BAE at RFAAP. it is documented that tenant waste was received and stored in BAE less-than-90-day accumulation areas. Waste tracking records for hazardous waste generated at NRE and taken to BAE less-than-90- day accumulation areas during August 9 through October 6. 2013 are included in Appendix H. This was also observed during NEIC's inspection of several less-than-90-day-accumulation areas (Appendix RCRA I RCRA photographs images IMGP0073 through IMGPOOSO). The tenants? hazardous waste is similar to BAE-generated waste. and both are treated the same by BAE. Although the tenants? original accrunulation date is maintained and utilized by BAE. ensru?ing that the waste is treated or disposed within 90-days. BAE is not the generator of these waste streams. and BAE should be managing the tenant?s hazardous waste in a RC RA permitted area. not a less-than-90-accumulation area. As stated in the December 31. 1980 Federal Register [45 FR 86969]: he provisions of 262.34 do not applv, however, to ha:ard0us wastes which the owner or operator did not generate, that is, ha:ard0us wastes which he received are not eligible for the accumulation time Appendix RCRA I RCRA Photographs Page 38 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia I Regulatory Citation I Findings/Supporting Information I Evidence RCRA AREA OF CONCERN A. 9 VAC 20?60?270. Adoption of 40 CF Part 270 by Finding: General Appendix reference - A. Except as otherwise provided, those BAE may be storing a material exhibiting the hazardous waste Process Report regulations of the United States Environmental Protection characteristic of reactivity (EPA hazardous waste No. D003) A getter set forth in 40 CFR Part 2 70 are herebr vu?thout a permit. incmporated as part of the Virginia Ha:ardous Waste Management Regulations. Notes: 40 CFR 270.1(c) Scope of the RCRA peimit requirement RCRA requires a peimit for the ?treannent, ?storage, and ?disposal of any ?ha:ard0us waste as identi?ed or listed in 40 CFR part 261 . BAE claims that the hill tank has never been emptied or cleaned out. but plans have been submitted to remove the tank in the future. The hill tank has been in-sen?ice since the 19803. The operation of hill tank and future plans are documented in a response letter from the US. Anny t0 NEIC (Appendix RCRA J). CW A POTENTIAL AREAS OF NONCOMPLIAN CE 1 VPDES Permit No. VA0000248, Part I. A. Final Effluent Finding: Appendix CWA A Limitations and Monitoring Requirements RFAAP collects a composite sample at outfall 007 for ef?uent VPDES Permit 1. During the period beginning with the permit e?ectire characteristics required to be monitored annually, but the No. VA0000248 date and lasting until the pennit ?s expiration date, the VPDES permit requires the collection of grab samples. RFAAP pennittee is authori:ed to discharge ?'om ouU?a/l serial collects the annual samples at outfall 007 using an automatic General Appendix number 007 composite sampler equipped with plastic tubing and a plastic Process sample container, but 40 CFR Part 136 requires glass Description Repon ?luent Characteristics: 2? Vitrophenol, 4?Nit7?0phenol, 1, 1? containers to be used for collecting the samples for monitoring Dichloroethane, 1,2?Dichl0roethane, 1,2?trans? certain ef?uent characteristics. Additionally, RFAAP is not Dichloroetln?lene, 1,1? Dichloroetln'lene, 1,2? following the operation and maintenance manual for Dichloroben:ene, 1,4? outfall 007, because the manual identifies the use of glass Dichloroben:ene, 1,2?Dichloropropane, 1,3? bottles and grab sample techniques to collect the required Dichloroproprlene, 2,4?Dinitrophenol, annual grab samples. Radford Army Ammunition Plant NEICVP1068E02 Page 39 of 62 Radford, Virginia ENFORCENIENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence 4, 6?Dinitro?o?cresol, 1,1,1?Tlichloroethane, 1,1,2? Trichloroethane, 1, 2,4 - I ichloroben:ene, Acenaphthene, Acijrloninile, Anthracene, Ben:ene, Bis/2- Carbon tetrachloride, Chloroben:ene, Chloroethane, Chloroform, luoranthene, luorene, Herachloroben:ene, Hexachlo;'obutadiene, Herachloroethane, Methyl Chloride, Methvlene Chloride, Naphthalene, Nitroben:ene, Phenanthrene, Phenol, Pvrene, etrachlor'oetln?lene, Toluene, Total Cvanide, Zi'ichloroetln'lene, Vinyl Chloride Monitoring Requirements: Frequency! is I/vear, Sample I we is Grab. VPDES Permit No. VA0000248, Part II. A. Monitoring 2. Monitoring shall be conducted according to procedures approved under Title 40 Code of Federal Regulations Part 136 or alternative methods approved by the US. Environmental Protection A gencv, unless other procedures have been speci?ed in this pennit. 40 CFR ?l36.3 Identi?cation of test procedures, Table II, Required Containers, Preservation Techniques, and Holding Times Table IC Organic Tests Container is Glass and FP-lined cap/septum for: Halocarbons, Purgeable aromatic ln-?drocarbons, Phenols, Phthalate esters, Nitroaromatics, Polvnuclear aromatic ln?drocarbons, and Chlorinated hvdrocarbons Purgeable VPDES Permit No. VA0000248, Part I. B. 15. Operations and Maintenance Manuals The pennittee will maintain an accurate, approved operation and maintenance manual for each treatment works. These manuals shall detail the practices and procedures which will be followed to ensure Notes: VPDES permit requires the collection of annual grab samples at outfall 007 for monitoring certain ef?uent characteristics (Appendix CWA A). RFAAP does not collect the required grab samples. and instead collects a 24-hour composite sample at outfall 007. NEIC inspected the AB waste acid plant 011 Febrl The area checker from the BAE utilities departmem. stated that he uses an automatic composite sampler to collect the VPDES compliance samples at outfall 007.. The automatic composite sampler is equ' 1 plastic tubing and a 15-liter (L) plastic sample container. Wcon?rmed that a composite sample is collected instead of the required annual grab samples at outfall 007. The composite sample is poured into glass iners 7 efore analyses are performed by Mb) laboratory. a contract laboratory (General Appendix B). VPDES permit also requires monitoring to be conducted according to procedures speci?ed in 40 CFR Part 136. 40 CFR Part 136 requires the use of speci?c containers to collect samples for analysis of certain ef?uent characteristics required to be monitored at outfall 007. such as volatile organic and semivolatile organic compounds. For example. for analysis of phenols. the sample is required to be collected into a glass container. By collecting the sample using an automatic sampler equipped with plastic tubing and a plastic sample container, RFAAP is not following the sample technique speci?ed in 40 CFR Part 136. NEIC requested the manuals for each treatment plant. According to the VPDES pennit. the manuals are enforceable parts of the permit. manual for the AB waste acid plant and outfall 007. dated August 2010. identi?es parameters listed in Table 6-5 to be collected as grab samples (Appendix CWA C). The manual explains that grab samples are collected at a speci?c time and represent the condition of the wastewater onlv at that time. The manual speci?es Appendix CWA Summary Table of NEIC DMR Rew'ew Interviews with BAE personnel NEICVP1068E02 Page 40 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information glass bottles for the annual monitoring parameters, except total compliance with the requirements of the permit. The cyanide, identified in Table 6-10 of the O&M manual. Tables 6-5 permittee shall operate the treatment works accordance with and 6-10 correspond to the annual effluent characteristics identified the approved O&M Manuals… Upon approval of the in the VPDES permit. RFAAP is not following the O&M manual submitted manual changes, the revised manual becomes an for outfall 007, because grab samples are not being collected and enforceable part of the permit. Noncompliance with the O & the annual monitoring samples are not collected into glass bottles. M Manuals shall be deemed a violation of the permit. Final Operations and Maintenance Manual for Outfall 007, Acidic Wastewater Treatment, 6.2 Outline of Sampling and Testing Program – Table 6-5 Outfall 007 Annual Monitoring Parameter Monitoring Requirements Frequency Sample Type N-nitroso-diphenylamine 1/Year 24-hour composite 2-Nitrophenol 1/Year Grab 4-Nitrophenol 1/Year Grab 1,1-Dichloroethane 1/Year Grab 1,2-Dichloroethane 1/Year Grab 1,2-trans-Dichloroethylene 1/Year Grab 1,1-Dichloroethylene 1/Year Grab 1,2-Dichlorobenzene 1/Year Grab 1,3-Dichlorobenzene 1/Year Grab 1,4-Dichlorobenzene 1/Year Grab 1,2-Dichloropropane 1/Year Grab 1,3-Dichloropropylene 1/Year Grab 2,4-Dimethylphenol 1/Year Grab 2,4-Dinitrophenol 1/Year Grab 4,6-Dinitro-o-cresol 1/Year Grab 1,1,1-Trichloroethane 1/Year Grab 1,1,2-Trichloroethane 1/Year Grab 1,2,4-Trichlorobenzene 1/Year Grab Acenaphthene 1/Year Grab Acenaphthylene 1/Year Grab Acrylonitrile 1/Year Grab Anthracene 1/Year Grab NEICVP1068E02 Evidence NEIC reviewed RFAAP’s July 2012 through January 2014 monthly, quarterly, semi-annual, and annual discharge monitoring reports (DMRs) and supporting laboratory data that were submitted to VADEQ. NEIC focused its review on the continuously discharging and process wastewater outfalls only (i.e., outfalls 005, 007, 026, and 029). Appendix CWA D contains NEIC’s summary of its review of DMR data. RFAAP reported that 24-hour composite samples were collected at outfall 007 for monitoring effluent characteristics that require collection of an annual grab sample. Page 41 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Benzene 1/Year Benzo(a)anthracene 1/Year 3,4-Benzofluoranthene 1/Year Benzo(a)pryene 1/Year Benzo(k)fluoranthene 1/Year Bis(2-ethylhexyl)phthalate 1/Year Carbon tetrachloride 1/Year Chlorobenzene 1/Year Chloroethane 1/Year Chloroform 1/Year Chrysene 1/Year Diethyl phthalate 1/Year Dimethyl phthalate 1/Year Di-n-butyl phthalate 1/Year Ethylbenzene 1/Year Fluoranthene 1/Year Fluorene 1/Year Hexachlorobenzene 1/Year Hexachlorobutadiene 1/Year Hexachloroethane 1/Year Methyl Chloride 1/Year Methylene Chloride 1/Year Naphthalene 1/Year Nitrobenzene 1/Year Phenanthrene 1/Year Phenol 1/Year Pyrene 1/Year Tetrachloroethylene 1/Year Toluene 1/Year Total Cyanide 1/Year Trichloroethylene 1/Year Vinyl Chloride 1/Year Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Evidence Table 6-10 Outfall 007 Annual Monitoring Requirements Parameter Bottle NEICVP1068E02 Page 42 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation N-nitroso-diphenylamine G, T 2-Nitrophenol G, T 4-Nitrophenol G, T 1,1-Dichloroethane G, T 1,2-Dichloroethane G, T 1,2-trans-Dichloroethylene G, T 1,1-Dichloroethylene G, T 1,2-Dichlorobenzene G, T 1,3-Dichlorobenzene G, T 1,4-Dichlorobenzene G, T 1,2-Dichloropropane G, T 1,3-Dichloropropylene G, T 2,4-Dimethylphenol G, T 2,4-Dinitrophenol G, T 4,6-Dinitro-o-cresol G, T 1,1,1-Trichloroethane G, T 1,1,2-Trichloroethane G, T 1,2,4-Trichlorobenzene G, T Acenaphthene G, T Acenaphthylene G, T Acrylonitrile G Anthracene G, T Benzene G, T Benzo(a)anthracene G, T 3,4-Benzofluoranthene G, T Benzo(a)pryene G, T Benzo(k)fluoranthene G, T Bis(2-ethylhexyl)phthalate G, T Carbon tetrachloride G, T Chlorobenzene G, T Chloroethane G, T Chloroform G, T Chrysene G, T Diethyl phthalate G, T Dimethyl phthalate G, T Di-n-butyl phthalate G, T Ethylbenzene G, T NEICVP1068E02 Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Page 43 of 62 Evidence Radford Army Ammunition Plant Radford, Virginia ENF ORCEMEN CONFIDENTIAL OIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information E?dence luoranthene G, luorene G, Hexachloroben:ene G, Hexachlorobutadiene G, Herachloroethane G, Methrl Chloride G, Methylene Chloride G, Naphthalene G, Nitroben:ene G, Phenanthrene G, Phenol G, Prrene G, etrachloroetln'lene G, Toluene G, Total Cranide P, richloroetlu?lene G, Vim'l Chloride G, Bottle ape: Polrethrlene Glass eflon?lined septum 2 VPDES Permit No. VA0000248, Part I. A. Final Effluent Finding: Appendix CWA A Limitations and Monitoring Requirements 1. During the RFAAP collects a composite sample at outfall 029 for VPDES Pennit period beginning with the pennit?s e?ectire date and lasting monitoring certain ef?uent characteristics, but the VPDES No. VA0000248 until the pennit 's expiration date, the pennittee is authori:ed permit requires grab samples to be collected. RFAAP collects to discharge ?'om ou?all serial number the composite sample at outfall 029 using an automatic General Appendix composite sampler equipped with plastic tubing and a plastic Process E?luent Characteristics: 2,4-Dinitrotoluene. Monitoring sample container, but 40 CFR Part 136 requires glass Description Report Requirements: requencv is 1/1reek, Sample rpe is containers to be used for collecting the samples for monitoring Grab. certain ef?uent characteristics. Additionally, RFAAP is not Appendix CWA following the manual for outfall 029, because the E?luent Characteristics: manual identi?es the use of glass bottles and grab sample Monitoring Requirements: Frequency is 1/3 Months, Sample techniques to collect certain weekly, quarterly, and annual we is Grab. monitoring samples. E?luent Characteristics: Acenaphthene, Acu'lonitrile, Notes: Ben:ene, Carbon tetrachloride, Chloroben:ene, 1,2,4- VPDES pennit requires weekly. quanerly. and annual richloroben:ene, Hexachlorobenxne, 1,2-Dichl0roethane, grab samples to be collected at outfall 029 for monitoring certain 1,1,1?Trichloroethane, Hexachloroethane, 1.1? ef?uent characteristics (Appendix CWA A). RFAAP does not NEICVP1068E02 Page 44 0 62 Radford Army Ammunition Plant Radford, Virginia ENFORCENIENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence Dichloroethane, 1,1,2?Trichloroethane, Chloroethane, collect the required grab samples. and instead collects a 24-hour Appendix CWA Chloroform, 2-Chlorophenol, 1,2- Dichloroben:ene, 1,3- composite sample at outfall 029. - Summary Table of Dichloroben:ene, 1,4- Dichloroben:ene, 1,1 NEIC DMR Review Dichloroethylene, 2, 4- Dichlorophenol, 1,2- Dichloropropane, 1,3- Dichloroproprlene, 2,4? 2,6?Dinitrotoluene, luoranthene, Methylene Chloride, Methyl Chloride, Herachlorobutadiene, Naphthalene, Nitroben:ene, Z?Nitrophenol, 4?Nit7'ophenol, 2, 4?Dinitrophenol, 4, 6? Dinitro?o?cresol, Phenol, Diethyl phthalate, Chiysene, Anthracene, luorene, Phenanthrene, Pvrene, etrachloroethvlene, Toluene, richloroethvlene, Vinyl Chloride, Total Cranide Monitoring Requirements: requencr is I/year, Sample Tipe is Grab. VPDES Permit No. VA0000248, Part II. A. Monitoring 2. Monitoring shall be conducted according to procedures approved under Title 40 Code of Federal Regulations Part 1 3 6 or alternative methods approved by the US. Environmental Protection Agency, unless other procedures have been speci?ed in this permit. 40 CFR ?136.3 Identi?cation of test procedures, Table 11, Required Containers, Preservation Techniques, and Holding Times Table 1C Organic Tests Container is Glass and FP-lined cap/septumfor: Purgeable Halocarbons, Purgeable aromatic ln-?drocarbons, Acrrlonitrile, Phenols, Phthalate esters, Nitroaromatics, Polynuclear aromatic hrdrocarbons, and Chlorinated hrdrocarbons VPDES Permit No. VA0000248, Part I. B. 15. Operations and Maintenance Manuals he pennittee will maintain NEIC inspected the bioplant on The bioplant operators.eW'y both stated that the bioplant operator on duty uses an automatic composite sampler to collect the compliance samples at outfall 029. The automatic composite sampler is r' 1g and a 15-L plastic sample containerqm also con?rmed that grab samples are not collected at outfall 029. The composite sample is poured into glass con in the water laboratory before analyses are performed at thew laboratory (General Appendix B). VPDES pennit also requires monitoring to be conducted according to procedures speci?ed in 40 CFR Part 136. 40 CFR Part 136 requires the use of speci?c containers to collect samples for analysis of certain effluent characteristics required to be monitored at outfall 029. such as volatile organic and semivolatile organic compounds. For example. for analysis of phenols. the sample is required to be collected into a glass container. By collecting the sample using an automatic sampler equipped with plastic tubing and a plastic sample container. RFAAP is not following the sample technique in 40 CFR Part 136. According to the VPDES permit. the manuals are enforceable parts of the permit. manual for the bioplant and outfall 029. dated August 2010. identi?es parameters listed in Tables 6-2. 6-4. and 6-5 to be collected as grab samples (Appendix CWA E). The manual explains that grab samples are collected at a speci?c time and represent the condition of the wastewater only at that time. The manual speci?es glass bottles for certain parameters. except total cyanide. identi?ed in Tables 6-7. 6-9. and 6-10 of the manual. Tables 6-2. 6-4. 6-5. 6-7. 6-9. and 6-10 of the manual correspond to ef?uent characteristics required to be monitored weekly. quarterly. and annually as identi?ed in the VPDES permit. RFAAP is not following the manual for outfall 029. because grab samples are not being collected and certain weekly. quarterly. and armually Interviews with BAE personnel NEICVP1068E02 Page 45 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information monitoring samples are not collected into glass bottles. an accurate, approved operation and maintenance manual for each treatment works. These manuals shall detail the NEIC reviewed RFAAP’s July 2012 through January 2014 practices and procedures which will be followed to ensure monthly, quarterly, semi-annual, and annual DMRs and supporting compliance with the requirements of the permit. The laboratory data that were submitted to VADEQ. NEIC focused its permittee shall operate the treatment works accordance with review on the continuously discharging and process wastewater the approved O&M Manuals… Upon approval of the outfalls only (i.e., outfalls 005, 007, 026, and 029). Appendix submitted manual changes, the revised manual becomes an CWA D contains NEIC’s summary of its review of DMR data. enforceable part of the permit. Noncompliance with the O & RFAAP reported that 24-hour composite samples were collected at M Manuals shall be deemed a violation of the permit. outfall 029 for monitoring the effluent characteristics that require collection of a weekly, quarterly, or annual grab sample. Final Operations and Maintenance Manual for Outfall 029, Biological Wastewater Treatment Plant, 6.2 Outline of Sampling and Testing Program– Table 6-2 Outfall 029 Weekly Sampling Monitoring Requirements Parameter Sample Frequency Type 2,4-Dinitrotoluene 1/Week Grab Evidence Table 6-4 Outfall 029 Quarterly Monitoring Monitoring Requirements Parameter Sample Frequency Type Di-n-butyl phthalate 1/3 Months Grab Table 6-5 Outfall 029 Annual Monitoring Monitoring Requirements Parameter Frequency Sample Type 1,1,1-Trichloroethane 1/Year Grab 1,1,2-Trichloroethane 1/Year Grab 1,1-Dichloroethane 1/Year Grab 1,1-Dichloroethylene 1/Year Grab NEICVP1068E02 Page 46 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation 1,2,4-Trichlorobenzene 1/Year 1,2-Dichlorobenzene 1/Year 1,2-Dichloroethane 1/Year 1,2-Dichloropropane 1/Year 1,2-trans-Dichloroethylene 1/Year 1,3-Dichlorobenzene 1/Year 1,3-Dichloropropylene 1/Year 1,4-Dichlorobenzene 1/Year 2,4-Dichlorophenol 1/Year 2,4-Dimethylphenol 1/Year 2,4-Dinitrophenol 1/Year 2,6-Dinitrotoluene 1/Year 2-Chlorophenol 1/Year 2-Nitrophenol 1/Year 3,4-Benzofluoranthene 1/Year 4,6-Dinitro-o-cresol 1/Year 4-Nitrophenol 1/Year Acenaphthene 1/Year Acenaphthylene 1/Year Acrylonitrile 1/Year Anthracene 1/Year Benzene 1/Year Benzo(a)anthracene 1/Year Benzo(a)pryene 1/Year Benzo(k)fluoranthene 1/Year Bis(2-ethylhexyl)phthalate 1/Year Carbon tetrachloride 1/Year Chlorobenzene 1/Year Chloroethane 1/Year Chloroform 1/Year Chrysene 1/Year Diethyl phthalate 1/Year Dimethyl phthalate 1/Year Ethylbenzene 1/Year Fluoranthene 1/Year Fluorene 1/Year Hexachlorobenzene 1/Year NEICVP1068E02 Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Page 47 of 62 Evidence Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Hexachlorobutadiene 1/Year Hexachloroethane 1/Year Methyl Chloride 1/Year Methylene Chloride 1/Year Naphthalene 1/Year Nitrobenzene 1/Year N-nitroso-diphenylamine 1/Year Phenanthrene 1/Year Phenol 1/Year Pyrene 1/Year Tetrachloroethylene 1/Year Toluene 1/Year Total Cyanide 1/Year Trichloroethylene 1/Year Vinyl Chloride 1/Year Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Evidence Table 6-7 Outfall 029 Weekly Monitoring Requirements Parameter Bottle 2,4-Dinitrotoluene G, T Table 6-9 Outfall 029 Quarterly Monitoring Requirements Parameter Bottle Di-n-butyl phthalate G, T Table 6-10 Outfall 029 Annual Monitoring Requirements Parameter Bottle N-nitroso-diphenylamine G, T 2-Nitrophenol G, T 2-Chlorophenol G, T 4-Nitrophenol G, T 1,1-Dichloroethane G, T 1,2-Dichloroethane G, T NEICVP1068E02 Page 48 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation 1,2-trans-Dichloroethylene G, T 1,1-Dichloroethylene G, T 1,2-Dichlorobenzene G, T 1,3-Dichlorobenzene G, T 1,4-Dichlorobenzene G, T 1,2-Dichloropropane G, T 1,3-Dichloropropylene G, T 2,4-Dichlorophenol G, T 2,4-Dimethylphenol G, T 2,4-Dinitrophenol G, T 4,6-Dinitro-o-cresol G, T 1,1,1-Trichloroethane G, T 1,1,2-Trichloroethane G, T 1,3-Dichlorobenzene G, T 1,2,4-Trichlorobenzene G, T Acenaphthene G, T Acenaphthylene G, T Acrylonitrile G Anthracene G, T Benzene G, T Benzo(a)anthracene G, T 3,4-Benzofluoranthene G, T Benzo(a)pryene G, T Benzo(k)fluoranthene G, T Bis(2-ethylhexyl)phthalate G, T Carbon tetrachloride G, T Chlorobenzene G, T Chloroethane G, T Chloroform G, T Chrysene G, T Diethyl phthalate G, T Dimethyl phthalate G, T Ethylbenzene G, T Fluoranthene G, T Fluorene G, T Hexachlorobenzene G, T Hexachlorobutadiene G, T NEICVP1068E02 Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Page 49 of 62 Evidence Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # 3 Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Regulatory Citation Hexachloroethane G, T Methyl Chloride G, T Methylene Chloride G, T Naphthalene G, T Nitrobenzene G, T Phenanthrene G, T Phenol G, T Pyrene G, T Tetrachloroethylene G, T Toluene G, T Total Cyanide P, G Trichloroethylene G, T Vinyl Chloride G, T Bottle type: P = Polyethylene G = Glass T = Teflon-lined septum VPDES Permit No. VA0000248, Part I. A. Final Effluent Limitations and Monitoring Requirements – 1. During the period beginning with the permit’s effective date and lasting until the permit’s expiration date, the permittee is authorized to discharge from outfall serial number 005… Effluent Characteristics: pH (SU)2 Discharge Limitation: Minimum is 6.0 and Maximum is 9.0 2. The discharge shall have a pH value between 6.0 and 9.0 at all times, except as noted in Part 1.B.12, and shall be monitored continuously. VPDES Permit No. VA0000248, Part I. B. 12. Excursion Time – The total time limit for pH excursions of 7 hours and 26 minutes in any calendar month shall apply to the excursions for outfalls 005, 006,007, and 029. The time limit of 60 minutes for an individual excursion shall also apply to these outfalls. The time limitations only apply to pH excursions outside the range of 6.0 to 9.0 and within the range 4.0 to 11.0. All excursions exceeding the range 4.0 to 11.0 are violations and shall be reported. After individual excursions exceeding 60 minutes or the 4.0 to 11.0 range the NEICVP1068E02 Evidence Finding: NEIC reviewed RFAAP’s July 2012 through January 2014 monthly, quarterly, and annual DMRs and supporting laboratory data submitted to VADEQ. A VADEQ-issued consent order, dated December 4, 2013, addresses some DMR violations. Appendix CWA A – VPDES Permit No. VA0000248 The following discharge limit exceedances were documented in the DMRs: 1) Minimum and maximum pH exceedances at outfall 005 in July 2012 monthly DMR. Addressed in VADEQ consent order. 2) Minimum and maximum pH exceedances at outfall 007 in August 2012 monthly DMR. 3) Monthly average di-n-butyl phthalate exceedance at outfall 029 in October 2012 quarterly DMR. Addressed in VADEQ consent order. 4) Maximum acute whole effluent toxicity (WET) exceedance for outfall 029 in October 2012 quarterly DMR. Addressed in VADEQ consent order. 5) Monthly average 5-day biochemical oxygen demand (BOD) loading exceedance at outfall 007 in February Appendix CWA D – Summary Table of NEIC DMR Review Page 50 of 62 Appendix CWA F – Referenced DMRs Appendix CWA G – Consent Order for U.S. Army and BAE for State Water Control Law Violations Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information receiving stream shall be examined for evidence of 2013 monthly DMR. environmental damage. Notification required by Part II of this permit shall include this information. Additionally, RFAAP inaccurately reported the sample type on the following DMRs: 1) 2,4-Dinitrotoluene at outfall 029 was reported as a VPDES Permit No. VA0000248, Part I. A. Final Effluent Limitations and Monitoring Requirements – 1. During the grab sample in the February 2013 monthly DMR, but period beginning with the permit’s effective date and lasting the chain of custody (COC) states a 24-hour composite until the permit’s expiration date, the permittee is authorized sample was collected. to discharge from outfall serial number 007… 2) Di-n-butyl phthalate at outfall 029 was reported as a grab sample in the July 2013 quarterly DMR, but the Effluent Characteristics: pH (SU)2 COC states a 24-hour composite sample was collected. Discharge Limitation: Minimum is 6.0 and Maximum is 9.0 3) 2,4-Dinitrotoluene at outfall 029 was reported as a grab sample in the August 2013 monthly DMR, but the COC Effluent Characteristics: Biochemical Oxygen Demand, 5 states a 24-hour composite sample was collected. day 4) Di-n-butyl phthalate at outfall 029 was reported as a Discharge Limitation: Monthly Average is 24 mg/l and 233 grab sample in the October 2013 quarterly DMR, but kg/d. Maximum is 64 mg/l and 621 kg/d. the COC states a 24-hour composite sample was collected. Effluent Characteristics: 2,4-Dinitrotoluene 5) 2,4-Dinitrotoluene at outfall 007 was reported as a grab Monitoring Requirements: Frequency is 1/month, Sample sample in the January 2014 monthly DMR, but the Type is 24-hour composite. COC states a 24-hour composite sample was collected. 6) Di-n-butyl phthalate at outfall 029 was reported as a grab sample in the January 2014 quarterly DMR, but VPDES Permit No. VA0000248, Part I. A. Final Effluent Limitations and Monitoring Requirements – 1. During the the COC states a 24-hour composite sample was period beginning with the permit’s effective date and lasting collected. Notes: until the permit’s expiration date, the permittee is authorized RFAAP’s VPDES permit lists discharge limits and monitoring to discharge from outfall serial number 029… requirements for effluent characteristics at each outfall (Appendix CWA A). Effluent Characteristics: Di-n-butyl phthalate Discharge Limitation: Monthly Average is 0.099 kg/d. NEIC reviewed RFAAP’s July 2012 through January 2014 Maximum is 0.20 kg/d. Monitoring Requirements: Frequency is 1/3 Months, Sample monthly, quarterly, semi-annual, and annual DMRs and supporting laboratory data that were submitted to VADEQ. NEIC focused on Type is Grab. the continuously discharging and process wastewater outfalls (i.e., outfalls 005, 007, 026, and 029). NEIC observed exceedances for Effluent Characteristics: Acute Whole Effluent Toxicity3 pH, di-n-butyl phthalate, acute WET, and BOD (Appendix CWA Discharge Limitation: Maximum is 1 TUa F) and summarized the review of DMR data in Appendix CWA D. 3. See Part I.C and I.D for additional TMP monitoring VADEQ issued the U.S. Army and BAE a consent order, dated requirements. NEICVP1068E02 Page 51 of 62 Evidence Radford Army Ammunition Plant Radford, Virginia ENFORCENIENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence December 4, 2013 for resolving certain violations of the State E?luent Characteristics: 2,4-Dinitrotoluene. Monitoring Water Control Law and VPDES permit (Appendix CWA G). Requirements: requencj' is I/n'eek, Sample Irpe is NEIC identi?ed in the DMR summary table the speci?c violations Grab. cited in Section of the VADEQ-issued consent order. Additionally. NEIC compared the COC sample collection data to the sample type reported in the DMRs. RFAAP inaccurately reported the sample type for certain e?luent characteristics at speci?ed outfalls in the DMRs identi?ed above and in Appendix CWA D. 4 VPDES Permit No. VA0000248, Part II. A. Monitoring Finding: Appendix CWA A 2. Monitoring shall be conducted according to procedures Oil and grease samples at storm water outfalls 041, 044, VPDES Permit approved under Title 40 Code of Federal Regulations Part 1 3 6 or alternative methods approved by the US. Environmental Protection A gencj?, unless other procedures have been speci?ed in this permit. 40 Identi?cation of test procedures, Table II, Required Containers, Preservation Techniques, and Holding Times Oil and grease container is glass. VPDES Permit No. VA0000248, Part I. A. Ef?uent Limitations and Monitoring Requirements Storm Event Monitoring pennittee is authorized to discharge ?'om outfall serial number 041 E?luent Characteristics: Oil and Monitoring Requirements: requencj? is Months, Sample [we is permittee is authori:ed to discharge from outfall serial number 044 E?luent Characteristics: Oil and Monitoring Requirements: Frequency is 1/6 Months, Sample Iipe is Grab. the permittee is authori:ed to discharge from ouq?all serial number 050. .. E?luent Characteristics: Oil and Monitoring Requirements: Frequencv is Months, Sample and 050 are not collected directly into a glass container, as required in 40 CFR Part 136. Notes: VPDES permit requires monitoring to be conducted according to procedures in 40 CFR Part 136 (Appendix CWA A). Oil and grease ef?uent characteristic is required to be monitored at stomr water outfalls 041. 044. and 050. On February 12. 2014.-, chief water laboratory technician. explained that area checkers collect storm water samples into clear plastic. l-L cubic containers. The sample is brought to the water laboratory. where- pours the stomr water sample into the glass containers with preservatives. According to 40 CFR Part 136. samples are required to be collected into glass containers. RFAAP is not following 40 CF Part 136 requirements. since the samples at storm water outfalls are not collected directly into glass containers. No. VA0000248 Interviews with BAE personnel NEICVP1068E02 Page 52 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information Evidence Type is Grab. 5 VPDES Permit No. VA0000248, Part II. F. Unauthorized Discharges – Except in compliance with this permit, or another permit issued by the Board, it shall be unlawful for any person to: 1. Discharge into state waters sewage, industrial wastes, other wastes, or any noxious or deleterious substances; or 2. Otherwise alter the physical, chemical or biological properties of such state waters and make them detrimental to the public health, or to animal or aquatic life, or to the use of such waters for domestic or industrial consumption, or for recreation, or for other uses. VPDES Permit No. VA0000248, Part II. G. Reports of Unauthorized Discharges – Any permittee who discharges or causes or allows a discharge of sewage, industrial waste, other wastes or any noxious or deleterious substance into or upon state waters in violation of Part IIF; or who discharges or causes or allows a discharge that may reasonably be expected to enter state waters in violation of Part IIF, shall notify the Department of the discharge immediately upon discovery of the discharge, but in no case later than 24 hours after said discovery.… NEICVP1068E02 Finding: NEIC reviewed RFAAP’s July 2012 through January 2014 unauthorized discharges and associated noncompliance notifications submitted to VADEQ. VADEQ issued a consent order, dated December 4, 2013, to address some unauthorized discharges. The following unauthorized discharges were listed in the noncompliance notifications: 1) Discharged 15,000 gallons of oleum (fuming sulfuric acid) to a containment dike, and an undetermined amount of acidified storm water discharged through outfall 005 on July 1 and 2, 2012. Addressed in VADEQ consent order. 2) Discharged 2,500 gallons of muddy water through outfall 006 on July 30, 2012. 3) Discharged 300 to 500 gallons of diethyl ether through outfall 005 on October 16, 2012. The notification call to VADEQ regarding this incident may have been made later than 24 hours after its discovery. Addressed in VADEQ consent order. 4) Discharged muddy water through outfall 006 on November 7, 2012. 5) Discharged turbid water through un-numbered storm water outfall on December 28, 2012. 6) Discharged muddy water through outfall 006 on January 8, 2013. 7) Discharged muddy water through outfall 041 on January 16, 2013. 8) Discharged 35,000 gallons of wastewater unmonitored from the little crowder tank at AB waste acid plant through outfall 007 on March 27, 2013. 9) Discharged 50 gallons of untreated sanitary wastewater near outfall 044 on March 27, 2013. 10) Bypassed coal wastewater treatment, resulting in discharge of 450 gallons of untreated wastewater through outfall 004 on June 6, 2013. Page 53 of 62 Appendix CWA A – VPDES Permit No. VA0000248 Appendix CWA H – Noncompliance Notifications Associated with Unauthorized Discharges Appendix CWA I – VADEQ Notices of Violations for VPDES Permit No. VA0000248 Appendix CWA F – Consent Order for U.S. Army and BAE for State Water Control Law Violations Appendix CWA J – NEIC Summary of RFAAP's Unauthorized Discharges and Associated Noncompliance Notifications Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information 11) Discharged 125,000 gallons of muddy water through outfall 005 on July 21, 2013. 12) Discharged 7,000 gallons of muddy water through outfall 041 on September 1, 2013. 13) Discharged muddy water through outfall 006 on November 20, 2013. Evidence Notes: RFAAP’s VPDES permit defines unauthorized discharges and explains the required reports by the permittee of such discharges (Appendix CWA A). RFAAP provided NEIC with information regarding unauthorized discharges that occurred between July 2012 and January 2014, including the noncompliance notifications associated with those discharges that were submitted to VADEQ (Appendix CWA H). RFAAP also provided the VADEQ-issued notices of violations (Appendix CWA I). VADEQ issued the U.S. Army and BAE a consent order, dated December 4, 2013, for resolving certain violations of State Water Control Law and VPDES permit (Appendix CWA F). Appendix CWA J contains NEIC’s summary of the unauthorized discharge information. CWA – AREAS OF CONCERN A VPDES Permit No. VA0000248, Part I. A. Final Effluent Limitations and Monitoring Requirements – During the period beginning with the permit’s effective date and lasting until the permit’s expiration date, the permittee is authorized to discharge from outfall serial number 029… Effluent Characteristics: BOD, 5 day, influent, mg/l COD, influent, mg/l TSS, influent, mg/l Fact Sheet for VPDES Permit No. VA0000248, Effluent Screening and Limitation Development (page 21) – Influent monitoring is recommended for BOD, COD, and TSS since the treatment works has been subject to NEICVP1068E02 Finding: BOD, chemical oxygen demand (COD), and total suspended solids (TSS) influent samples at the bioplant (outfall 029) are being collected from the equalization basin effluent at a point just before the rotating biological contactors (RBCs), rather than from the influent to the bioplant. Notes: RFAAP’s VPDES permit requires monitoring for the following effluent characteristics: BOD, 5 day, influent; COD, influent; TSS, influent (Appendix CWA A). The VPDES permit fact sheet states, Influent monitoring is recommended for BOD, COD, and TSS since the treatment works has been subject to overloading in the past and the treatment efficiency is dependent upon varying propellant formulations and Page 54 of 62 Appendix CWA A – VPDES Permit No. VA0000248 Appendix CWA K – Fact Sheet for VPDES Permit No. VA0000248 Appendix CWA L – Email from Kevin Harlow at VADEQ General Appendix B – Process Report Radford Army Ammunition Plant Radford, Virginia ENFORCENIENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence overloading in the past and the treatment e?iciency is dependent upon varying propellant fonmtlations and operation of the equali:ation basins. This will also help in establishing operational controls for the plant. operations of the equali:ation basins (Appendix CWA K. page 21). RFAAP collects the BOD. COD. and T88 in?uent samples ??om the equalization basin ef?uent at a point before the RBCs. During discussions with NEIC personnel on February 11. 2014. BAE personnel interpreted the VPDES permit fact sheet language to mean that the in?uent BOD. COD. and T88 samples are used to understand the treatment ef?ciency of the RBCs. NEIC personnel asked why the in?uent samples were not collected aw water bioplant before receiving any treatment a BAE envirormrental specialist. said that. historically. the in?uent BOD. COD. and T88 samples were collected at a point before the RBCs. NEIC personnel asked VADEQ for a de?nition or explanation of where in?uent BOD. COD. and T88 samples should be collected. Kevin Harlow. VADEQ permit writer. replied that the sample location for the in?uent to the bioplant is not speci?ed in the permit or fact sheet. but that historically had been sampled at the bar screen (Appendix CWA L). The bar screen is located in the raw water well at the bioplant. prior to the equalization basins (General Appendix B). Interviews with BAE personnel Finding: Access to storm water outfall 017 during storm water events. Notes: The compliance sampling point for storm water outfall 017 is located behind a locked gated. RFAAP personnel are required to call security personnel to unlock the gate and gain access to outfall 017. On February 7. 2014. the security personnel had dif?culty unlocking the gate. During a storm water event. it could be difficult for RFAAP personnel to gain access and collect samples from outfall 017. 40 CFR 144.3 Definitions Well means: A bored, drilled, or driven shaft whose depth is greater than the largest smface dimension; or, a dug hole whose depth is greater than the largest smface dimension; or, an improved Finding: The settling basin for storm water outfall 017 may be considered a well under 40 CFR Part 144, Underground Injection Control Program. NEICVP1068E02 Page 55 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence sinkhole; or, a subsuiface?uid distribution system. Improved sinkhole means a naturallr occutring karst depression or other natural crevice found in volcanic terrain and other geologic .settings which have been modi?ed by man for the puipose of directing and emplacing ?uids into the subsutface. 40 CFR Part 144, Subpart Requirements for Owners and Operators of Class Injection Wells, 144.81, Does this subpart apply to me? This subpart applies to you ifyou own or operate a Class well, for example: (4) Drainage wells used to drain suiface ?uids, primarilr' stonn runo?, into a subsurface fonnation; Notes: BAE envirornnental staff explained that RFAAP and the surrormding area are built on karst topography. Any storm water collected in the settling basin at outfall 017 percolates into the ground rather than discharging through outfall 017. NEIC requested the most recent conceptual engineering report for cannot determine if the modi?cations to the settling basin at outfall 017 would be considered a class well under 40 CFR Part 144. but is concerned that storm water from the open burning ground per?colates into the ground instead of being discharged and monitored. Intern'ews with BAE personnel CAA POTENTIAL AREAS OF NONCOMPLIANCE 1 40 CFR The owner or operator shall submit in the RMP infozmation: (1 One worst-case release scenario for each Program 1 process Finding: RFAAP did not include a worst-case release scenario for each Program 1 process in its October 2010 risk management plan. Notes: RFAAP operates three processes containing the regulated ?ammable chemical eth ether in amorurts over the threshold uantities: The risk management plan contains one worst-case release scenario for one Program 1 process containing ethyl ether. Based on the information provided in the risk management plan and interviews with facility personnel, NEIC was not able to determine which ethyl ether process was included in the plan?s worst-case release scenario. Dru?ing the orr-site inspection. RFAAP provided worst-case release calculations for all tlu'ee ethyl ether processes. and a quick RMP- omp check of the calculations indicated that all three processes are Program 1. NEICVP1068E02 Page 56 0f 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence 40 CFR 68.42(a) The owner or operator shall include in the ?ve?year accident history all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known o?site deaths, injuries, evacuations, sheltering in place, property damage, or em'iromnental damage. 40 CFR 68.195 The owner or operator of a stationary source for which a RMP was submitted shall correct the RMP as follows: New accident history information For any release meeting the five-year accident history reporting criteria of 68. the owner or operator shall submit the data required under 68.168, 68.] 700'), and 68.1 75 with respect to that accident within six months of the release. Finding: RFAAP did not correct and update the ?ve?year accident 'thin 6 months of the months of the with the reclamation area in the process. 40 CFR 68.79(d) The owner or operator shall determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. Appendix . Appendix . 112 1? Finding: RFAAP has not documented that corrective actions found in the April 2010 compliance audit were corrected. RFAAP did not address the corrective actions found in the April 2010 compliance audit. Not me? (Appendix CAA 1120912) RFAAP provided to NEIC contains a list of con?ectix?e actions (tasks) identi?ed during the audit that need to be completed. The list includes responsible person. target date. and completion date. Of the 22 corrective actions listed in the repon. 16 do not have completion dates or an explanation as to why RFAAP has decided NEICVP1068E02 Page 57 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence not to implement the task. NEIC asked RFAAP to provide completion dates for the 16 tasks that did not i1 Of the 22 con?ective actions listed in the report. 4 were not completed tuitil June 2012. more than 2 years after the compliance audit was conducted. 4 40 CFR 68.67(f) At least ererv ?ve (5) years after the Finding: Appendix CAA completion of the initial process ha:ard analrsis, the process RFAAP did not update and revalidate the process hazard NEIC ha:ara' analvsis shall be updated and revalidatea? 5 by a team meeting the requirements in paragraph of this section, to assure that the process ha:ara? analrsis is consistent with the current process. Notes: Dining the on-site NEIC inspectio . These PHAs were dated 2 2010. As shown in the (Appendix CAA 112(r) G). NEIC requested the previous PHA for each covered process. RFAAP responded (Appendix CAA 112(r) G, page 2) that the PHAs conducted prior to the 2009/2010 time frame were conducted between May 1997 and May 1999. PHAs RFAAP provided to NEIC . May 1997 (Appendix CAA 112(r) H) and September 2010 (Appendix CAA 112(r) Appendix CAA I 112 0 November 1997 (Appendix CAA 112(r) J) and December 2009 (Appendix CAA 112 0 ?May1999 (Appendix CAA 112(r) L) and October 2010 (Appendix CAA 112(r) M) Radford Army Ammunition Plant NEICVP1068E02 Page 53 0f 62 Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence Appendix Appendix 1'51 5 40 CFR 68.73(4) The owner or operator shall document each inspection and test that has been peiformed on process equipment. Finding: RFAAP has not kept documentation for each inspection and test that has been performed on process equipment. Notes: RFAAP provided a summary table summarizing the inspections and documentation for speci?c preventative maintenance programs on identi?ed tanks (Appendix As shown in the table. some documentation for ?lm inspections could not be located in the historical records. A total of 15 records documenting inspections on the ammonia tanks were not kept. AREAS OF CONCERN A 40 CFR - The owner or operator of a stationan' source shall revise and update the RMP submitted Finding: RFAAP has had several releases of ethvl ether from the tank NEICVP1068E02 Page 59 of 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence under 68.150 as follows: 7) Within six months of a change farm associated with the reclamation area in the solvent that alters the Program level that applied to a covered propellant process. process. 40 CFR Program 1 eligibility requirements. A covered process is eligible for Program 1 requirements as provided in 68.12/b) if it meets all of the following requirements: (1) For the ?ve years prior to the submission of an RMP, the process has not had an accidental release of a regulated substance where exposure to the substance, its reaction products, oveipressure generated by an explosion involving the substance, or radiant heat generated by a ?re involving the substance led to any of the following off-site: Response or restoration activities for an evposure of an environmental receptor. 40 CFR ?68.3 Definitions. Environmental receptor means natural areas such as national or state parks, forests, or monuments; o?icially designated wildlife sanctuaries, pres-elves, refuges, or areas; and Federal wildeiness areas, .._and than can be identified on local US. Geological Sulvey maps. Clean Air Act 112(r) FAQs (ren'sed February 2006) A process covered under 40 FR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR Those criteria include a requirement that the process cannot have had an accidental release of a regulated substance that led to o?site death, injury, or environmental response or restoration activities within ?ve years prior to the risk management plan (RMP) submission. If there is an accident that results in serious o?site consequences ??om a previously identified and documented Program 1 process, when will the process lose its Program 1 status." Must the RMP be revised to re?ect the change in status and requirements for that process.? I he process in this scenario will lose its Program 1 status immediately; and the owner or operator will have to comply with the requirements of the new program level applicable to Radford Army Ammunition Plant NEICVP1068E02 Page 60 0f 62 Radford, Virginia ENFORCEMENT CONFIDENTIAL FOIA EXEMPT DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORNIATION Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Regulatory Citation Findings/Supporting Information Evidence the process (40 CFR he owner or operator will be required to revise and update the RMP to re?ect that change within six months of the incident (40 CFR 40 CFR 68.81(b) An incident investigation shall be Finding: initiated as as possible, but not later than 48 hours following the incident. ?Safety Incident Reporting Investigation Requirements? procedure does not contain time frames required for initiating incident investigations. Notes: m" does not include a requirement that incident investigations shall be initiated within 48 hours following the incident. NEIC reviewed two incident investigation reports. and both investigations were initiated the day after the incident occmred. Facility personn EPCRA SECTION 313 POTENTIAL AREAS OF NONCOMPLIANCE Appendix 1 EPCRA 313 [40 CFR For each toxic Finding: chemical lrnown by the owner or operator to be NEIC found data quality errors in TRI submittal for manufactured (including imported), processed, or otheiwise reporting year (RY) 2012. used in excess of an applicable threshold for a calendarj'ear, the owner or operator must submit to EPA Notes: and to the State in which the facility is located a completed Appendix EPCRA 313 A contains a table summarizing the data EPA 017)) (EPA Fonn accordance with the quality errors identi?ed during the NEIC inspection for the Appendix EPCRA instructions refen'ed to in subpart of this part. following chemicals: dibutyl phthalate, lead compounds, and nitric 3 3 acid. Positive changes indicate that a release amount was underreported. Appendix EPCRA 313 - Original and Corrected Fonn . For RY 2012, Submittals RFAAP did not include all o?-site transfer amounts in the reported totals for dibutyl phthalate, lead compounds, and nitric acid. Appendix EPCRA 313 contains the spreadsheet that RFAAP NEICVP1068E02 Page 61 0f 62 Radford Army Ammunition Plant Radford, Virginia ENFORCEMENT CONFIDENTIAL – FOIA EXEMPT – DO NOT RELEASE MAY CONTAIN CONFIDENTIAL BUSINESS INFORMATION # 2 Regulatory Citation Table 2. SUMMARY OF OBSERVATIONS Radford Army Ammunition Plant (RFAAP) Radford, Virginia Findings/Supporting Information used to track calendar year 2012 off-site transfers. EPCRA § 313 [40 CFR § 372.30(a)] – For each toxic chemical known by the owner or operator to be manufactured (including imported), processed, or otherwise used in excess of an applicable threshold quantity…for a calendar year, the owner or operator must submit to EPA and to the State in which the facility is located a completed EPA Form R (EPA Form 9350-1)…in accordance with the instructions referred to in subpart E of this part. Evidence RFAAP submitted corrected RY 2012 Form Rs following the NEIC inspection, and these are included in Appendix EPCRA 313 C, along with the original Form R submittals. Finding: RFAAP did not submit a Form R for copper compounds in RY 2012, even though background documentation shows the facility exceeds the processing threshold of 25,000 pounds. Notes: RFAAP provided NEIC a copy of the MSDS for copper lead resorcylate salicylate complex (LC 12-15) (Appendix EPCRA 313 D). The MSDS for LC 12-15 shows that the material contains 12 percent copper and 38 percent lead, a lead/copper compound. LC 12-15 is used in the manufacture of propellant. Information RFAAP provided for RY 2012 indicates a usage amount of 44,080 pounds. RFAAP calculated a processed amount by multiplying the usage amount by 11.2 percent copper, resulting in a usage amount of 4,937 pounds, which is below the process threshold of 25,000 pounds. The copper percentage is less than 12 percent indicated on the MSDS and was determined through laboratory analysis. NEIC used the total usage amount of 44,080 pounds of LC 12-15, to apply toward the process threshold for copper compounds in RY 2012, which exceeds the threshold and would require RFAAP to submit a Form R for copper compounds. Appendix EPCRA 313 D – MSDS for LC 12-15 Appendix EPCRA 313 E – RY 2012 Copper Compounds Form R RFAAP submitted a RY 2012 Form R for copper compounds following the NEIC inspection, and this is included in Appendix EPCRA E. NEICVP1068E02 Page 62 of 62 Radford Army Ammunition Plant Radford, Virginia