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Programs at Arnold AFB help foster harmony between mission, environmental responsibilities

Christina Norman checks the label of one of the barrels in the hazardous waste storage facility at Arnold Air Force Base, Tenn., prior to it being loaded on a truck and taken to the disposal site on June 15, 2021. A current Resource Conservation and Recovery Act Part B permit enables Arnold to store hazardous waste for one year at the base’s main storage facility for less than 90 days. (U.S. Air Force photos by Deidre Moon)

  • By Bradley Hicks
  • AEDC Public Affairs

The pursuit of the mission at Arnold Air Force Base requires maintaining a delicate balance.

Ground test work performed across Arnold must comply with local, state and federal environmental regulations.

Several teams are in place at Arnold AFB, headquarters of Arnold Engineering Development Complex, to help ensure the testing efforts occurring within the approximately 4,000 acres making up the Arnold mission area has the least possible impact on the forests, wetlands and waterbodies found across the remaining 36,000 acres of Arnold AFB property.

In the days leading up to Earth Day, celebrated this year on April 22, environmental subject matter experts across Arnold AFB shared some insight into their programs and how their work helps protect the environment in and around the base.

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Air permitting, storage tanks and water discharge

“Noncompliance with environmental requirements can negatively impact the AEDC testing mission,” said Trung Le, Environmental Compliance Manager at Arnold AFB. “In addition, it is important to protect the health and well-being of the surrounding communities and natural habitat of the base property. All programs have regularly required reports that are submitted to the regulating authorities for review. By monitoring our compliance with these requirements, we reduce the facility’s impact to the environment and test mission.”

Le oversees the air permitting, storage tank and water discharge programs at Arnold Air Force Base.

This work includes oversight of the Arnold AFB Title V Operating Permit. In general, the permit is required of companies that have operations involving a major air contaminant source or a non-major air contaminant source.

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Congress established the Title V Operating Permit program as part of the 1990 Clean Air Act Amendment, and the U.S. EPA has delegated authority to the Tennessee Department of Environment and Conservation Division of Air Pollution.

Arnold AFB received its first Title V Operating Permit in the early 2000s. The permit covers more than 50 test facilities and more than 20 groups of emission sources. Permit requirements include recording operating hours, fuel/materials consumed and power utilization. Arnold AFB also pays required fees, performs dispersion modeling and monitors air to ensure safe working conditions and operations within the permit parameters.

The National Pollutant Discharge Elimination System permit program, created in 1972 by the Clean Water Act, addresses water pollution by regulating point sources that discharge pollutants to waters of the U.S. Under the act, the EPA authorizes TDEC Division of Water Resources to perform permitting, administrative and enforcement aspects of the NPDES permit program.

“All the water that is discharged from the industrial area is monitored and regulated through the NPDES permit,” Le said.

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Operation and control of the Arnold AFB sewage treatment plant, as well as the collection of flow measurements and measurements of the concentration of pollutant in the effluent discharges from the system, are required by the NPDES permit. Further, there are also permits for the recirculating sand filter at Arnold Village base housing and the FamCamp family camping ground and those for septic system field lines located in the remote areas of Arnold AFB for which Le and his team are responsible.

Facilities at Arnold with aboveground storage tanks holding oils of any kind are subject to the EPA Spill Prevention, Control and Countermeasure regulation. Petroleum oil and lubricants are inspected regularly to ensure no fuels or oils are being released into the environment. Inspections are required and the results are reported to the Air Force Civil Engineering Center monthly. Arnold AFB has maintained 100% compliance with this AFCEC monthly inspection requirement since August 2023.

Hazardous waste and materials

The Hazardous Waste Program at Arnold manages the generation, handling, treatment and disposal of wastes posing characteristics known to be hazardous to human health or the environment. The Hazardous Material Program outlines the procedures and provides guidance for the management of hazardous materials on Arnold AFB.

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“When used, hazardous materials have multifaceted impacts upon the likelihood of hazardous waste generation, human health exposure and potential environmental degradation,” said William Carpenter, who oversees the hazardous waste and hazardous materials programs at Arnold. “Therefore, reviewing processes, suggesting alternative products and tracking of these materials is very important.”

The Resource Conservation and Recovery Act of 1976 sets the framework by which Arnold must maintain compliance with its waste from “cradle to grave,” which runs from waste generation through transportation, storage and, ultimately, disposition.

The programs at Arnold are in place to assist with compliance of the RCRA among many other federal and state regulations.

As Carpenter pointed out, Arnold AFB is one of 11 installations in the entire Air Force operating a permitted waste management facility for hazardous waste storage. Such waste may be stored at Arnold for up to one year.

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“While operation of the facility is strictly regulated, it does offer Arnold Air Force Base some additional freedoms that other Large Quantity Hazardous Waste Generators are not permitted,” Carpenter said. “Connected to the same facility, hazardous material is stored for ultimate delivery by the HazMat [hazardous materials] pharmacy across many shops that utilize HazMat as part of their mission.”

Carpenter added the contractor and civilian environmental teams at Arnold are a knowledgeable resource to help base personnel understand how to navigate the challenges posed by compliance with various regulations. He encouraged those with questions or concerns to reach out to environmental specialists at Arnold.

“Protection of human health and the environment for the mission today becomes even more evident when our future generations support their upcoming missions tomorrow,” he said.

Cultural and natural resources

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Dr. Amy Turner shares this sentiment.

“One of our focuses is helping the Air Force meet its commitment to conserve and protect its natural and cultural resources but also meet its current and future mission requirements,” she said.

Turner, National Environmental Policy Act, Natural and Cultural Resources Planner, works with the Cultural Resources and Natural Resources programs at Arnold. Personnel involved with both programs facilitate relationships with federal, state and private partners to accomplish a wide range of goals and environmental compliance.

To protect species and their habitats from extinction, Congress passed the Endangered Species Act in 1973. Arnold AFB is home to three federally listed species – the gray bat, Indiana bat and northern long-eared bat. One species proposed for listing – the tricolored bat – and one under review – the little brown bat – can also be found at Arnold, along with a number of state-listed species and species considered to be of the greatest conservation need.

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The Natural Resources program at Arnold has been surveying these species and their habitats for well over 20 years. This work includes summer and winter bat surveys, plant and bird counts, as well as reptile and amphibian counts. Information gathered from such surveys supports existing knowledge of populations and provides a long-term view of what is occurring population-wise with a particular species or community, which helps the Natural Resource team make informed decisions.

Information about species and their habitats is also provided to partnering agencies and researchers as they make plans and decisions on how to aid imperiled species. Along with monitoring listed species, those in the Natural Resource program at Arnold work with partners, including the Tennessee Wildlife Resources Agency, Tennessee Department of Conservation and The Nature Conservancy, to preserve species and work toward their delisting.

Turner said an example of program success is the Eggert’s sunflower, a flowering plant native to this region of the country and one found on Arnold AFB property. The plant was once listed as endangered, but Turner said due to habitat management at Arnold AFB and conservation work done with partners, including the U.S. Fish and Wildlife Service, the plant has been delisted.

Program personnel also work with base partners to ensure the mission can be completed with minimal impact. An example Turner provided is the gray bat colony that has made its home at the Woods Reservoir dam.

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“Gray bats are an endangered species, but we also know fundamentally that [Woods Reservoir’s] main mission is to provide cooling water,” Turner said. “With our Programmatic Biological Opinion with the U.S. Fish and Wildlife Service, there are certain times of the year there is restricted access with the exception of emergencies. However, in cooperation with the U.S. Fish and Wildlife Service, during emergencies, we address the emergency as a priority to ensure that we maintain our mission of providing cooling water for the test mission.

“The work the Natural Resource program has been doing allows us to have a very robust knowledge of the species and habitats on base to inform our natural resource management.”

The natural resources throughout Arnold are integral to supporting the test mission, Turner added.

“We need our water and the air that supports the test facilities and, with that, the ecosystem services that the land provides that help keep the air and water clean,” she said. “The land is necessary to supporting the test mission and ensuring that the resources that are needed remain at optimal conditions.”

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The primary regulator drive of the Cultural Resource program is the National Historic Preservation Act intended to preserve historic and archeological sites.

“Here at Arnold Air Force Base, we have had the foresight to spend the last 20 years extensively surveying our cultural resources assets so that we can minimize the impact to the test mission if the need arises,” Turner said. “Our good relationships with our state partner, the Tennessee State Historic Preservation Office, and our 15 tribes with whom we regularly consult has made consultations on mission critical projects a success.”

Additional natural resources work

As the Natural Resources Manager at Arnold, Brandon Bailey provides strategic and operational oversight for the management of the natural resources that compose the total acreage of the installation. His primary areas of focus include the forest management program, the wildland fire management program, the barrens management program and the Arnold AFB hunting program.

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“All of Arnold’s natural resources programs and activities work together to create, improve, protect and maintain critical ecosystems while providing multiple use opportunities for a variety of users,” Bailey said.

The primary regulatory driver of the Natural Resources Program at Arnold AFB is the Sikes Act, enacted in 1960. According to Bailey, this law “directs the Secretary of Defense, in cooperation with the U.S. Fish and Wildlife Service and state fish and wildlife agencies, to carry out a program for the conservation and rehabilitation of natural resources on military installations,” and that the Sikes Act “allows for the sustainable, multipurpose use of natural resources subject to military security and safety requirements.”

As Natural Resources Manager, it is Bailey’s responsibility to ensure compliance with all natural resources laws and regulations, coordinate with installation components to assess the potential impacts on proposed activities on sensitive natural resources, and make recommendations to reduce, avoid or mitigate adverse effects to comply with applicable laws and regulations.

Natural resource management activities at Arnold include endangered species monitoring and management, forest inventories, timber sales, prescribed fire operations, nuisance wildlife control, wildlife management, ecosystem health protection, invasive species control, the installation hunting program, and cooperation with various state and federal agencies and universities.

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“It is critical to the Air Force mission that we have an adequate land base to accommodate current and future needs,” Bailey said. “It is the responsibility of the Natural Resources Program to manage this land base. A multiuse approach that accomplishes the mission and allows for the conservation and utilization of Arnold’s natural resources just makes sense.”

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