ARNOLD AIR FORCE BASE, Tenn. --
The test and evaluation activities that take place in the Arnold Engineering Development Complex facilities at Arnold Air Force Base at times utilize materials labeled as “hazardous.” However, Arnold has programs in place to safeguard its employees and the environment from hazardous materials and hazardous waste.
As part of a requirement of the Environmental Protection Agency’s Resource Conservation and Recovery Act, or RCRA, Arnold AFB had its first RCRA Part B Permit Application for hazardous waste storage signed in April 1984. The current RCRA Permit was issued by the Tennessee Department of Environment and Conservation on Oct. 7, 2019, and it does not expire until Oct. 7, 2029, unless revoked, reissued, terminated or continued.
According to Lisa Douglas, an environmental protection specialist at Arnold, to ensure compliance with the regulatory requirements, the Hazardous Materials and Hazardous Waste Program entails cradle-to-grave management.
“Arnold receives hazardous materials through our HAZMART Pharmacy, which then distributes these materials or products to the shops requesting the materials,” Douglas said. “Arnold tracks all incoming hazardous materials from cradle to grave using the Air Force-wide database called Enterprise Environmental, Safety and Occupational Health Management Information System.”
Douglas added that once a hazardous material reaches the end of its useful life – if it’s expired, spent or ready to be discarded – it becomes a hazardous waste and must be properly disposed.
“Like most Department of Defense services throughout the world, Arnold uses the Defense Logistics Agency Disposition Services to manage the transportation and disposal of hazardous waste generated on base and verify it reaches the proper treatment or disposal facility,” she said.
Arnold is considered a large-quantity generator, meaning that it either generates 2,200 pounds or more of hazardous waste in any calendar month; accumulates more than 2.2 pounds of acute hazardous waste per month; or generates in a calendar month or accumulates at any time 220 pounds or more of acute hazardous spill cleanup material.
Although Arnold falls into this category, Douglas mentioned that steps are continuously taken to lessen how much hazardous waste is being generated or accumulated on base.
“The base has a wide variety of hazardous wastes but every effort is made to reduce our hazardous waste footprint by choosing materials that are not hazardous or are less hazardous whenever possible through our written hazardous waste reduction plan,” she said.
Hazardous waste at Arnold includes items such as waste paint, solids and liquids contaminated with heavy metals, and ignitable and/or corrosive liquids. There is also universal waste, which includes items such as batteries, lamps, aerosol cans, pesticides and mercury-containing equipment.
“Each waste stream generated is reported to the Tennessee Department of Environment and Conservation prior to generation, and the amount generated for each waste stream is disclosed in our annual report to TDEC,” Douglas said.
When employees at Arnold handle any type of hazardous material or hazardous waste, proper safety procedures must be followed.
“A safety data sheet (SDS) book is available for the affected work areas for every chemical that is brought on base,” Douglas said. “These provide employees pertinent information to meet OSHA’s (Occupational Safety and Health Administration) hazard communication standards in a consistent 16-point format. Each SDS also provides information such as the properties of the chemicals; the physical, health and environmental hazards; protective measures; and safety precautions for handling, storing and transporting the chemical. The SDS must be in English but can be in other languages as well and must meet the Globally Harmonized System of Classification and Labeling of Chemicals.”
Arnold employees who manage hazardous waste are required to take a 40-hour initial Hazardous Waste Operations and Emergency Response training course and receive an 8-hour annual refresher training. Employees who sign manifests for shipping documents are required to take initial Department of Transportation training and a refresher course every three years.
The current RCRA Part B permit enables Arnold to store hazardous waste for one year at the base’s main storage facility, and there are three other storage areas able to hold hazardous waste for less than 90 days. Additionally, there are seven initial accumulation points, sometimes called satellite accumulation areas, available for collecting and storing hazardous waste, up to 55 gallons.
“The Facility Support Services II contractor runs the storage areas and each shop area can contact them when hazardous waste is ready for turn-in,” Douglas said.
Employees can call the Hazardous Waste Operations Group at 931-454-7383 for any questions regarding hazardous waste. Employees can call the Operations Center at 931-454-7752 or 931-454-7688 for response to spills or releases.