Document 0gZOVm6BK1NyZYLdqG102rrKR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 RESOURCE CONSERVATION AND RECOVERY ACT GENERAL INFORMATION Facility Name: US Magnesium, LLC RCRA ID: UTD000690867 Facility Location: 12819 North Skull Valley Road, Rowley, UT 84029, Lat./Long.: 40.913756, -112.734511 Facility Contact: Jeffrey Mensinger, Environmental Manager, (801) 433-4086 Mailing Address: 238 N 2200 W, Salt Lake City, UT 84116-2921 RCRAInfo Notification Status: Large Quantity Generator Dates of Inspection: May 24, 2022 and May 25, 2022 Arrival Time: 9:00 a.m. on 5/24/2022 Departure Time: 2:00 p.m. on 5/25/2022 Lead Inspector & Report Author: Annette Maxwell, U.S. EPA RCRA Inspector Inspection Attendees: 1. Rob Hartman, Environmental Manager (since retired), US Magnesium (USM) 2. Roger Francom, Senior Environmental Coordinator, USM Type and Purpose of Inspection: Compliance Schedule Evaluation (CSE) and LQG Compliance Evaluation Inspection (CEI) Facility Type: Primary Magnesium, Biennial Report NAICS: 33141 - Nonferrous Metal (Except Aluminum) Smelting and Refining Applicable Regulations: Inspection Authority of RCRA 3007; Consent Decree, Case No. 2:01CV0040B, including projects underway pursuant to Section VI (RCRA Work Requirements) and Paragraph 12 re: compliance with applicable regulations including R315-260 to R315-273 of the Utah Administrative Code (UAC) and R315-15 of the UAC Inspection Type: Announced Inspection Disclaimer This report is a summary of observations and information gathered from the facility at the time of the inspection. The information provided does not constitute a final decision on compliance with RCRA regulations, nor is it meant to be a comprehensive summary of all activities and processes conducted at the facility. Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 OPENING CONFERENCE Upon arrival at the facility, an opening conference was conducted with Mr. Hartman and Mr. Francom. I presented my federal inspector credentials, explained the purpose of the inspection, and provided a reminder to clearly indicate confidential business information. I was not denied access to the facility and was allowed to inspect all areas that I selected for inspection. The following information was obtained verbally during the inspection from the above-listed facility personnel unless otherwise noted. DESCRIPTION OF INSPECTION Regulatory Status According to the RCRAInfo database, US Magnesium is a large quantity generator (LQG) of hazardous waste. During the inspection, Mr. Hartman and Mr. Francom confirmed this generator status. Facility and Process Description US Magnesium (USM or Facility) is a production facility for high purity magnesium. The basic processes used to generate magnesium are: x Transfer of water from Great Salt Lake through large solar ponds for evaporation and concentration of brine containing magnesium chloride, then x Transfer of the brine to a circular holding pond (the star pond) x Through desulfation (source of waste gypsum, slurried and piped to gypsum stack) and x Deboronation (boron removal; this operation is a source of acidic waste sent to waste pond) processes x Through spray dryers to produce powdered magnesium chloride x Through a melt-reactor x Through carbon anode electrolytic cells to separate magnesium and chlorine, and x Molten magnesium is then transferred to a foundry and casting house for production of magnesium ingots The facility has also produced for sale secondary products including liquid chlorine, hydrochloric acid, ferric and ferrous chloride, magnesium chloride, calcium chloride, and lithium carbonate. A limited amount of sodium chloride and brine are also sold for offsite use. At the time of the inspection, production of some secondary products was limited or temporarily halted due to reduced magnesium production rates and other factors. The facility includes shallow solar evaporation ponds designed to evaporate water from Great Salt Lake, deep brine holding ponds (referred to as the star pond) designed to limit evaporation, a hydrochloric acid plant, a chlorine plant, a boron removal plant, a ferric/ferrous chloride plant, three spray dryers (a fourth was largely constructed but not completed at the time of the site visit), a melt reactor, four electrolytic buildings, a foundry and casting house, multiple maintenance shops, a laboratory, a sanitary lagoon, a solid waste landfill, dredged salt pile storage, smut (metal oxides) pile storage, a gypsum stack, a large evaporation waste pond divided into two sections and connected via an overflow pipe, ditches used for Page 2 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 inflow of water from the Great Salt Lake and inflow/outflow of Great Salt Lake and fresh spring and rain water, and a historic (inactive) barium sulfate disposal area. Hill Brothers Chemical Co., a separate business entity, is located immediately south of the ferric/ferrous chloride plant on property leased from USM. The introduction of petroleum coke and chlorine in the melt reactor and the use of carbon anodes in the electrolytic process are sources of chlorinated hydrocarbons including hexachlorobenzene, dioxins & furans, and polychlorinated biphenyls. Recent changes to the facility included removal from service of open, unlined earthen ditches previously used to route waste to the evaporation waste pond; waste is now transported to the waste ponds via HDPE piping systems pursuant to RCRA Administrative Order Docket No. RCRA-08-2016-0004. Additional information regarding US Magnesium's magnesium manufacturing process is available in the document Tripp, Thomas G. (2009) "Production of magnesium from Great Salt Lake, Utah USA," Natural Resources and Environmental Issues: Vol. 15 , Article 10., available at: https://digitalcommons.usu.edu/nrei/vol15/iss1/10 and in the NIOSH Health Hazard Evaluation Report, HETA #2004-0169-2982, U.S. Magnesium Rowley, Utah, dated October 2005. Containerized hazardous waste is primarily stored in a gated, secured 90-day storage area located near the southwestern-most portion of the facility. Based on the facility-submitted 2019 and 2021 Biennial Reports, hazardous wastes recently generated at the facility include but are not limited to: x Anode dust (D004, D007, D032) x Waste carbon tetrachloride solution (D002, D019, D032, D033) x Waste flammable liquids (gasoline/diesel) D001 x Process equipment clean out rinse water (D002, D007) x Waste corrosive liquid - lab waste (D002, D005, D007, D009, D011) x Spent phosphoric acid (D002, D007) x Waste sodium hydroxide solution (D002) x Waste flammable compressed gas paint waste (D001) x Waste solids from process equipment cleanout (D007, D019, D022, D039) x Waste corrosive liquids (off-spec water treatment chemical, D002) Based on previously submitted analytical documentation and previously provided explanations, anode dust generated at Electrolytic Cell Buildings 1, 2 and 3 contain PCBs but do not appear to be RCRA hazardous wastes due to a previously made change in collection from the use of drag chains to the use of a wet collection system. At the time of the inspection, Electrolytic Cell Building 4 was still utilizing a drag chain collection system, and through this process chromium and arsenic are entrained into the anode dust, requiring that it be managed as RCRA hazardous waste. During the inspection, the facility personnel stated that anode dust is disposed by incineration due to the presence of PCBs. Page 3 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 The facility's hazardous waste generation rate at the time of the inspection was greater than 1,000 kg/month, placing the facility in Large Quantity Generator status. Hazardous wastes routinely generated at the facility include anode dust from Electrolytic Cell Building 4; anode dust from Buildings 1, 2, and 3 were TSCA-regulated PCB-containing waste but were not RCRA hazardous waste. Other routinely generated hazardous wastes include laboratory waste and carbon tetrachloride (CCl4) waste, although at the time of the inspection CCl4 waste was not being generated due to treatment of chlorine, which is used to make magnesium but is also normally generated at quantities sufficient to sell the gas, to meet customer specifications being temporarily halted pending an increase in overall facility magnesium production rates. A Class IIIb industrial solid waste landfill permit application was submitted to the Utah Department of Environmental Quality on December 16, 2021, in compliance with Consent Decree paragraph 22 and Appendix 14 (Project Compliance Schedule). The facility representatives stated they had received a letter of completeness of the application from UDEQ, and that they were continuing to work with UDEQ to complete the application process. Recent activity included UDEQ acceptance of a closure/post-closure cost estimate. Work was underway to select the form of financial assurance as well as preparation of a traffic impact study. The facility representatives further stated that UDEQ inspector Brian Wolf had visited the facility for a brief landfill inspection on May 17, 2022. An SPCC plan is maintained for both the plant area and for the solar pond area of the facility. An onsite sewage treatment system includes an aerobic digester. Following treatment, the wastewater is discharged to the sanitary lagoon or the waste ponds. At the time of the inspection, the emergency off-gas system was offline due to damage to a fan. A Consent Decree (CD), Case No. 2:01CV0040, United States of America v. Magnesium Corporation of America, et al., was entered and became effective on 6/30/2021. The status of certain projects performed pursuant to this CD was evaluated during the inspection and is discussed below. As referenced above, a RCRA 3008(h) Administrative Order, Docket No. RCRA-08-2016-0004, dated 8/3/2016, was issued to institute certain projects including closure and capping of earthen waste ditches. A five-year compliance monitoring period following project completion was ongoing at the time of the inspection. A February 2014 RCRA 7003 Administrative Order on Consent, Docket No. RCRA-08-2014-0001, was issued in response to large spills of acidic liquid waste caused by breaches in the Current Waste Pond berm onto land managed by the Bureau of Land Management (BLM). The 2014 AOC required the company to: 1) construct a fence with signage on affected BLM land to prevent public access, 2) stop further discharges onto BLM land, and 3) address residual soil contamination on BLM property. The Facility holds a groundwater discharge permit, Permit No. UGW450012, issued by the Utah Department of Environmental Quality under the Utah Administrative Code Rule 317-6. Activities to be performed pursuant to this permit and pursuant to the CERCLA Response Action of the Consent Decree, include installation of a hydraulic barrier wall encompassing the downgradient areas of the facility. Page 4 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 This Facility was added to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, aka Superfund) National Priorities List on November 4, 2009. Activities performed under CERCLA include work performed pursuant to an Administrative Settlement Agreement and Order on Consent for Remedial Investigation/Feasibility Study, Docket No. CERCLA008-2011-0013. The US Magnesium Superfund website is https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0802704. TOUR INFORMATION Mr. Hartman and Mr. Francom accompanied me during the Facility tour. All photographs collected during the inspection and referenced below are included in Attachment 1 - Photograph Log. Areas of the Facility included in the site tour were: x Ferric/ferrous chloride filtration building x Ferrous chloride pond x Star pond x HCl plant x Chlorine plant x 90-day central accumulation area (CAA) near chlorine plant x Calcium chloride production area x Used oil pad x Mobile maintenance shop x Paint booth x Quality Control lab satellite accumulation area (SAA) x Waste Yard 90-day CAA x CRB area x West and east packed tower areas x High energy scrubber area x Run-down tank x Courtyard area located between Electrolytic Cell Buildings 2 and 3 x Sand blast booth x Main shop The following narrative of this section includes areas listed above in which conditions of interest or potential deficiencies were noted. The information included below was obtained by my observation or by explanation provided by the accompanying facility personnel (Mr. Hartman and Mr. Francom) unless otherwise noted. In the Ferric/Ferrous Chloride Plant filtration building area I observed that a roll-off bin for collection of filtration solids was empty. See photo 1. The facility personnel stated that filter cake is non-hazardous when generated, and that no hazardous waste is generated in the ferric/ferrous chloride plant area of the Page 5 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 facility because wash water is reused for pre-coating and is not shipped for disposal. At the time of the inspection the plant was down for maintenance of the ferrous pit. I observed water in the secondary containment in Ferric/Ferrous Chloride Plant area, and the facility personnel stated that this water was not waste and that it was going to be reused but had accumulated because the sump pump was down. During normal operations the water is pumped into the ferrous/ferric storage ponds. Due to the ability of ferrous and ferric chloride to corrode carbon steel, such material may be D002 hazardous waste when disposed of or if released, for example due to leaks from the secondary containment. I observed the HCl plant from the driveway but did not approach or enter the area. The plant was not in operation at the time of the inspection, and the facility personnel stated that it hadn't been in operation for approximately one year. At the Chlorine Plant I observed a concrete central accumulation area (CAA) designated for 90-day storage of 55-gallon poly drums containing carbon tetrachloride-bearing hazardous waste generated in this area. Mr. Francom stated that typically approximately 6-8 drums were generated at a time, and that stabilization by neutralizing the chlorine is conducted in this CAA. However, at the time of the inspection, the reboilers weren't operating so this waste was not being generated. At the used oil storage pad I observed that a barely visible Used Oil label on the storage tank had been painted over, see photos 2 and 3. Pursuant to R315-15-2.3(c)(1), used oil containers must be marked with the words "Used Oil". Mr. Francom stated that he would re-label the tank. Similarly, outside of the auto/mobile maintenance shop I observed a tank used for storage of used oil. The tank was not labeled with the words "Used Oil" (see photo 5). On June 29, 2022, I received by email from Mr. Hartman photographs showing that both tanks had been properly labeled. See Attachment 2 - Facility Correspondence. Inside the auto/mobile maintenance shop I observed three parts washers. See photos 6, 7, and 8. The facility personnel stated that Safety Kleen comes out every two to three months to maintain the parts washers. Inside the Quality Control Lab, I observed two 55-gallon blue poly SAA drums labeled with the words "Hazardous Waste". However, the containers were not labeled with an indication of the hazards. See photos 9-12. Pursuant to R315-262-15(a)(5)(i) and (ii), respectively, SAA containers must be marked with the words "Hazardous Waste" and an indication of the hazards. One of the two drums was marked with a "container full date" of 5/23/2022, and the second was marked with a "collection start date" of 5/23/2022, indicating that one had become full and was awaiting transfer to a central accumulation area and the other had been added to replace it in the SAA. Also in the Quality Control Lab, I observed bench-top waste collection containers, which Mr. Francom stated are moved to the SAA at the end of each shift. See photo 13. SAAs may be used for accumulation of hazardous waste if they are located at or near the point of generation and are under the control of the operator. Pursuant to R315-262-15(a)(6), hazardous waste must be transferred from an SAA to a central accumulation area (CAA) or transported for disposal to an authorized offsite disposal facility and therefore cannot be transferred from one SAA to another SAA. Guidance issued by the Utah Department of Environmental Quality titled Satellite Accumulation Area (SAA) Guidance Document, dated July Page 6 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 2021, document number DSHW-2021-010963, indicates that in-process waste initially managed at collection points that meet the "integral to the process" condition before transfer to an SAA is not considered to be SAA-to-SAA transfered. However, the guidance clarifies that, "[t]o be considered "in- process" the container must be emptied into an SAA or CAA at the end of the work shift by the operator. If the [hazardous waste] container is not emptied at the end of the work shift, it is an SAA and is subject to the SAA requirements." Because the observed collection containers were being transferred to the SAA by the operator by the end of each shift, this appears to meet the conditions described in the UDEQ guidance. At the Waste Yard (see photos 14-20), which is the main 90-day central accumulation area, I observed 11 55-gallon drums, and that the yard was fenced, gated and locked, included a concrete pad for waste storage and a storage shed and a Conex for storage of absorbent and other spill equipment and supplies, and had signage marked with the Environmental Department phone number. The drums observed included: x Two drums of ferrous chloride-containing liquid hazardous waste; these containers were marked with the words "Hazardous Waste", DOT shipping information, the accumulation start date, and the EPA waste code D002, and an indication of the hazards of the contents (corrosive); x Three drums containing ferrous chloride sludge with liquids on top; similarly to the ferrous chloride liquid waste drums, these drums were labeled appropriately; x Three drums marked "pending characterization" that were water treatment chemicals and were not believed to be hazardous but were awaiting analysis for metals, semi-volatiles, volatiles, flash point, and pH; x One drum containing used sulfuric acid awaiting reuse; x One drum containing spent solvent hazardous waste, marked with the words "Hazardous Waste", the accumulation start date, and an indication of the hazards (ignitable); and x One open-top drum used to store non-hazardous trash. In the area of the plant related to the Reuse Project, facility engineer Brad Drayton participated in the portion of the inspection in which I observed the status of work being performed to implement the project. Areas viewed related to this project (see photos 29-33) included: x Head tank (WWC water to be pumped to Electrolytic buildings 1 and 2 quench tanks) x Chlorine reduction burner area x 20,000-gallon CRB water collection tank x Wash water column area x West and east packed towers area x High Energy Scrubber area x Run down tank Following the inspection on August 29, 2022, I received by email from Mr. Mensinger the Reuse Project Completion Report. A summary of work performed stated: On March 29, 2022 all work was begun on this project. A new head tank was installed to pump Chlorine Plant Water Wash Column (WWC) water and a field routed 3" CPVC pipeline was installed on the existing pipe rack to tie-in to the Electrolytics buildings 1 and 2 quench tanks. New piping was installed to route High Energy Scrubber (HES) liquor into the piping system for routing to the east and west packed towers that pump to the Main Reactor Acid Recirculation Tank. For the Chlorine Reduction Burner (CRB) water and CRB Seal Leg water, a Page 7 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 20,000 gallon tank and pump was installed for storage and reuse of those streams to the CRB absorber. All work on this project was mechanically complete as of May 27, 2022. The finished work may be further verified by the EPA during a future compliance schedule evaluation inspection. In the portion of the facility related to the Courtyard Capping Project located in between Electrolytic Cell Buildings 2 and 3, sometimes referred to as the Pentapure courtyard, I observed that, as reported in the March 22, 2022, Ducon Scrubber and Sump Plan Completion Report, piping had been installed to reconfigure the Ducon Scrubber as a pass-through unit. See photo 33. As documented in the report, the sump had been excavated and the area backfilled. The large steel lid was still present, and Mr. Hartman stated that due to its size, it would have to be cut down to be removed from the courtyard area. Also in this courtyard, I observed a large area of stained soil, and Mr. Hartman stated that he did not know what the source of the spill was, but that they would sample it and perform a hazardous waste determination. On June 17, 2022, I received by email from Mr. Hartman analytical results indicating that the contaminated soil did not exceed toxicity characteristic regulatory levels of UAC R315-261-24. In the main shop I observed an aerosol cans SAA, see photo 36. This container was not marked with an indication of the hazards as required by UAC R315-262-15(a)(5)(ii). Additional information: During a stop at the conference room during the inspection, with the permission from the facility representatives, I collected photographs of diagrams in the conference room showing a high-level view of the facility's magnesium production process. See photos 21-28. Record Review: Central Accumulation Area Inspection Records: during the inspection, I reviewed central accumulation area inspection logs, and no concerns were identified at that time. Hazardous Waste Manifests: during the inspection, I reviewed manifests for 2021 and 2022, and no concerns were identified at that time. Contingency Plan: During the inspection, I viewed the Emergency Response Plan (ERP) table of contents and requested a full copy in order to review it for the contingency plan requirements of UAC R315-262. On June 7, 2022, Mr. Hartman emailed me a copy of the ERP, revision date 02/2021. The ERP appeared to contain all content required by UAC R315-262-261. However, the plan did not include a Quick Reference Guide as required by UAC R315-262-262(b), including the associated hazard of each hazardous waste, the estimated maximum amount of each hazardous waste that may be present at the site, and a map showing where hazardous wastes are generated, accumulated and treated and routes for accessing these wastes. Training Records: On July 22, 2022, Mr. Hartman emailed me the training records. No concerns were identified for this documentation at the time of review. Page 8 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 CLOSING CONFERENCE During the closing conference, I discussed documentation that had been reviewed, initial findings, and requested additional documentation. The findings discussed included concerns regarding labeling of used oil tanks and satellite accumulation containers. I also stated that I would provide a follow-up email indicating the requested documentation. Post-Inspection Documentation Received Following the inspection, on 5/27/22, I sent the following by email as a follow-up to the closing conference: To follow up on Wednesday's closing conference, this is the list of information/documentation requested: x Photographs showing that labels have been added to the two used oil tanks; x An update on the stained soil located in the pentapure courtyard; x A copy of the Emergency Response Plan, which I'll compare to the contingency plan content requirements of 40 CFR 262 Subpart M, Section 262.261; x Documentation for personnel training per 40 CFR 262.17(a)(7)(iv); x Hazardous waste determination documentation (required for hazardous and non- hazardous solid wastes per 40 CFR 262.11(f)) for the lithium carbonate filter cake; and x An update on the status of the emergency offgas system. Regarding the "indication of the hazards" labeling requirement for hazardous waste containers in both satellite accumulation areas and in 90-day central accumulation areas, the wording can be found in 40 CFR at 40 CFR 262.15(a)(5)(i) for SAAs and at 40 CFR 262.17(a)(5)(i)(B) for large quantity generators (it's the same in both cites): An indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704). Additional discussion on the indication of the hazards labeling requirement can be found at https://www.federalregister.gov/d/2016-27429/p-407. For Quick Reference Guides (40 CFR 262.262(b)), a frequently asked questions (FAQ) memo is available here: https://rcrapublic.epa.gov/rcraonline/details.xhtml;jsessionid=6F30A1AA3F73312F465F96D1 FDD2CC99?rcra=14943. In regard to DOT training for individuals who sign hazardous waste manifests, an explanation can be found here: https://rcrapublic.epa.gov/rcraonline/details.xhtml?rcra=14687. Page 9 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 On June 7, 17, and 29 and July 22, Mr. Hartman provided by email the following (Attachment 2 - Facility Correspondence): x 6/7/22: hazardous waste determination information for wastes generated in the lithium carbonate plant, including filter cake, digester tank dregs, and wastewater; the following explanation of analytical results: o 20H0665-01 Li De-mag Filtercake 20200811-01: This is the filtercake we observed in the bunker ("dozer trap") outside the est side of the building. o 20H0665-02 Li Digester Tank 20200811-02: This is the undigested tank dregs from the digester tanks - mostly gravel introduced during material handling of smut to feed the digesters. o 20H0665-03 West Vault Waste Water 20200811-03: This is filter press wash water,steam blowdown and building area washdown from the lithium carbonate plant. x 6/7/22: a copy of the Emergency Response Plan x 6/7/22: a revised consent decree project schedule x 6/17/22: an explanation about sample collection of the stained soil in the Building 2/3 courtyard, a photograph of the sample, and analytical results x 6/29/22: photographs of the two used oil tanks properly labeled with the words "Used Oil" x 6/29/22: an update on the status of the emergency offgas system, stating: "Update on EOG repairs/maintenance: I talked to Troy Sullivan, Reactor and Maintenance Manager, yesterday and he provided a status update: the Zurn fan has been thoroughly checked and is ready to return to service, but replacement of the damaged chevrons and packing (the essential components of the scrubber) is still in progress. When the scrubber repairs are complete, the system will be restarted but Troy cautions there may still be debris in the upstream ducting and the scrubber will need to be down for re-inspection and potential maintenance shortly after restart." x 7/22/22: training records>QRWLQFOXGHGLQ$WWDFKPHQW@ Inspection Follow-up Water held in the ferric/ferrous chloride plant secondary containment described on page 6 of this report may be D002 hazardous waste if leaked or disposed. The status of this material will be included in future inspections in order to determine whether the material has been or will be reused and is therefore not a waste. The contents of the contingency plan, specifically, the Quick Reference Guide, will be reviewed during the next inspection if the facility is confirmed to be in an SQG or LQG status. Satellite accumulation containers must be marked with an indication of the hazards of the contents pursuant to pursuant to R315-262-15(a)(5)(ii). SAA containers will be reviewed for this marking during the next inspection if the facility is confirmed to be in an SQG or LQG status. As outlined in Paragraph 21 of the Consent Decree, the facility implemented an emergency off-gas system (EOG) redesign in the Melt/Reactor building. For an estimated minimum of three to four months, including at the time of the inspection, this system was offline while awaiting repairs. During the inspection Mr. Hartman stated that the system had been offline since March, and following the Page 10 of 11 Facility Name: US Magnesium (UTD000690867) Facility Location: 12819 North Skull Valley Road, Rowley, Utah Dates of Inspection: May 24, 2022 & May 25, 2022 inspection, on June 29, 2022, Mr. Hartman indicated by email that the system had not yet been returned to service. SIGNATURES ANNETTE MAXWELL Date: 2023.04.13 13:25:43 -06'00' Digitally signed by ANNETTE MAXWELL __________________________________________________________ Annette Maxwell, Lead RCRA Inspector Pearson, Janice Digitally signed by Pearson, Janice _______________________________D_a_t_e_:_2_0_2_3_._0_4_.1_4__1_0_:3__9_:2_2__-0_6_'_0_0' Janice A. 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