Document 10Xe5NnaNXXokN2akZ2B2EXxX

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/23/2024 13:45 (CT) Announced: No 05/23/2024 16:15 (CT) RCRA Access: Granted Focused Compliance Inspection (FCI) Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Registered Generator Status NAICS Type of Operation Geographic Coordinates Valley Solvents & Chemicals TXD098827769 (generator ID) TXD026152637 (transporter ID used at all locations) 8215 Up River Rd Corpus Christi, TX 78409 Nueces County Very Small Quantity Generator (VSQG) None Valley Solvents & Chemicals is a chemical distributor who packages, blends, and distributes a variety of solvents and other chemicals. 27.8269, -97.52533 Additional Persons Participating in Inspection: Name Title Organization Cameron Tanaka Erin Young-Dahl Contractor Inspector Eastern Research Group (ERG) EPA REGION 6 John Penland Inspector EPA REGION 6 Email Cameron.Tanaka@erg.com YoungDahl.Erin@epa.gov Penland.John@epa.gov Phone (214) 665-8548 (214) 665-3166 (214) 665-9717 Lead Inspector: Brook McKeown ERG Brook.McKeown@erg.com 09/03/2024 (410) 459-5811 Page 1 of 7 Valley Solvents & Chemicals Inspection Date: 05/23/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection The Port of Corpus Christi and surrounding facilities were selected for inspection based on an Environmental Justice and Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG). This report is based on information supplied by the facility representatives, inspector observations, and other records, including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Name Phone Email Opening Closing Conf. Conf. Brook McKeown (410) 459-5811 Brook.McKeown@erg.com Yes No Cameron Tanaka (508) 314-6432 Cameron.Tanaka@erg.com Yes No Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes Yes John Penland (214) 665-9717 Penland.John@epa.gov Yes Yes Page 2 of 7 Valley Solvents & Chemicals Inspection Date: 05/23/2024 Facility General Description Tenant/Area Valley Solvents & Chemicals Inspection Date 05/23/24 Process Description Valley Solvents & Chemicals (Valley Solvents) is a chemical distributor who packages, blends, and distributes a variety of solvents and other chemicals. The company blends, packages, and distributes products in totes, tanker trucks, drums, 5-gallon cans, and 1-gallon cans. Occasionally, the company generates off-spec solvents or gets off-spec solvents returned to its facility. In these cases, Valley Solvents tests the material to see if it is still viable. The company will blend the off-spec solvent into on-spec solvents and resell the blend in almost every case. If Valley Solvents is unable resell the material, it profiles the material and disposes of it as either non-hazardous or hazardous waste. Valley Solvents is also a waste transporter and has a 10-day transfer area where it stores wastes prior to transportation to a disposal facility. The company transports hazardous waste, non-hazardous waste, used oil, e-waste, batteries, lightbulbs, and other universal wastes. The facility does not maintain a MARPOL COA. Area of Concern Yes Page 3 of 7 Valley Solvents & Chemicals Inspection Date: 05/23/2024 SECTION II - OBSERVATIONS - In chronological order. Tenant: Valley Solvents & Chemicals Section: 2.1 Date: 05/23/24, 1:45 PM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Therese Narup (Inventory Manager), Lauren Tovar (Waste Coordinator), Brian Tikkanen (Operations Manager) Valley Solvents is a chemical distributor who packages, blends, and distributes a variety of solvents and other chemicals. The company blends, packages, and distributes products in totes, tanker trucks, drums, 5-gallon cans, and 1-gallon cans. Generally, all the material that Valley Solvents brings on site is virgin product. Occasionally, the company will receive products that have been returned from customers, generate off-spec solvents on-site, or get off-spec solvents returned to its facility. In these cases, Valley Solvents contracts Eurofins or Univar to test the material to see if it is still viable. If the material is off-spec, they will blend the off-spec solvent into on-spec solvents and resell the blend in almost every case. If the company is unable to blend and resell the material, it profiles the material and disposes of it as either non-hazardous or hazardous waste. Valley Solvents also gets empty packages returned to its site from customers. Valley Solvents does not maintain a MARPOL COA. Valley Solvents is also a waste transporter and transfer facility with a 10-day transfer area where it stores wastes prior to transportation to a disposal facility. These materials include hazardous waste, non-hazardous waste, used oil, e-waste, batteries, lightbulbs, and other universal wastes. Valley Solvents does not transport medical or radioactive waste. Valley Solvents uses two different EPA IDs. EPA ID TXD026152637 acts as its transporter ID. This ID is associated with the headquarters of Valley Solvents in Harlingen, TX, but it is used as a transporter ID at all of the company's locations. The company uses EPA ID TXD098827769 as a VSQG ID specific to its Corpus Christi location. As a transporter, Valley Solvents' sales team puts together a profile to determine the disposal requirements of the waste to be picked up. They may also make lab arrangements on behalf of the generator to analyze the waste if Valley Solvents transports the materials. Valley Solvents labels and packages waste containers at the customers' facilities. After this process is completed, Valley Solvents will pick up the waste from the generator and bring it to the facility's 10-day transfer area. The company then creates an order to have the waste disposed of and schedules the transportation of the waste to a disposal facility. Valley Solvents keeps a log of transfer wastes that allows it to ensure wastes are transferred offsite within 10 days. Valley Solvents personnel try to send its whole inventory of transfer waste out within one to five days of arrival onsite. For certain customers, Valley Solvents will bring the material directly from the generator to the disposal facility. Valley Solvents uses its own trucks for transportation and mostly performs land to land transfers and transportation. Certain totes are pumped out by Alliance Oil Recovery, which acts as a second transporter for the waste in the totes. To the best of the Valley Solvents personnel's knowledge, there have not been any spills of hazardous waste at the facility. Facility personnel did state that they have had incidents with leaking drums or inadequate containment that required Valley to place containers into overpack drums. The inspection team reviewed Valley Solvents' transfer area log during the inspection, which included cells for confirming the waste has an EPA manifest, the manifest or Bill of Lading (BOL) number, the waste generator, a waste approval code, a waste description, the number and type of containers, the destination facility, the date received, the name of the inspector of each waste, the person or company the waste was shipped to, the number of days on-site for each transfer location, and the number of days the material was in transit. The inspection team reviewed the 2023 transfers in this log. The inspection team noted that the log did not include a date for when a red phosphorous container was shipped out in 2023. Every waste shipment transferred to the facility in 2023 had been shipped out within 10 days of receipt except for a shipment of Page 4 of 7 Valley Solvents & Chemicals Inspection Date: 05/23/2024 used oil and a shipment of used batteries that had been staged for 14 days. In terms of generated waste, Valley Solvents' aged inventory will become a waste once the material is no longer viable. Generally, the company's solvent products do not expire. Any material generated from flushing out hoses will usually be recycled back into its process. Corrosive wash water generated onsite is neutralized and sent off site as neutralized water. The company's non-hazardous waste streams consist of this neutralized water and surfactants. Off spec or non-conforming products and spilled materials are stored in the facility's non-conforming area. Spilled materials and products that are very off-spec will be characterized and transported off-site as waste. Valley Solvents personnel indicated that approximately 0.05% of their offspec or non-conforming solvents are shipped off as waste. In July 2023, Valley Solvents underwent a large effort to properly inventory and identify obsolete chemicals that were no longer usable. As a result of that effort, the facility had a series of episodic generation events of hazardous waste, which went out under several different manifests. Mr. Tikkanen explained that more obsolete waste continued to be discovered on their site after each one-time shipment, resulting in additional one-time shipments being required. Mr. Tikkanen indicated that he does not expect any more one-time shipments to be required, as they have improved their inventory practices. During the inspection, the inspection team visually inspected Valley Solvents' non-conforming area and truck bay/production area. Observations and areas of concern (AOCs) are organized by section below along with facility responses where relevant. Non-Conforming Area: Valley Solvents' non-conforming area was delineated with red lines on the floor (see Appendix 1 - Photo 5). A 55-gallon drum of mixed solvents was observed in the non-conforming chemical storage area with a hazardous waste label without an accumulation date (see Appendix 1 - Photos 1 and 2). Facility personnel stated that this drum had been incorrectly labeled as hazardous waste. Russell Ide, the Director of Environmental Services for Valley Solvents, provided a document with follow-up explanations to the inspection teams observations (see Appendix 2). Mr. Ide explained that the drum was accidentally labelled as hazardous waste due to a personnel error, and that it had not been evaluated for potential reuse yet. After the inspection, Mr. Ide indicated that Valley Solvents personnel have relabeled the drum correctly as nonconforming product and begun the evaluation process. He also indicated that warehouse personnel had been retrained on the company's procedures to help prevent this issue from reoccurring (see Appendix 2). The inspection team also observed three totes of mineral spirits that were blended with surfactants pending a waste determination. This waste was generated from a line flushing process, where mineral spirits are used to purge process lines and hoses when products are changed. In a follow-up email from 08/13/2024, Mr. Ide included a flashpoint analysis for this material (see Appendix 6). According to the analysis, two of the three totes were ignitable hazardous waste while the third tote did not exhibit the ignitability characteristic and is non-hazardous waste. Mr. Ide indicated that an investigation determined that the amount of flammable mineral spirits used in the flush process varied. As a result, the process waste had the potential to be either hazardous or non-hazardous depending upon the amount of flammable mineral spirits used (see Appendix 2). Following this discovery, Valley Solvents stated that they intend to change their flush process to use only nonflammable products as flushing agents, rather than the flammable mineral spirits (see Appendix 2). However, based on the quantity of hazardous waste stored on-site at the time of the inspection, the facility was operating as a large quantity generator (LGQ) of hazardous waste. [AOC #1 - Valley Solvents did not properly determine its generator category - 40 CFR 262.13]. There are various other requirements as an LQG that Valley Solvents may need to evaluate to achieve compliance, such as development of a contingency plan, submission of a biennial report, etc. Although Valley Solvents may change their process to eliminate Page 5 of 7 Valley Solvents & Chemicals Inspection Date: 05/23/2024 generation of this waste in the future, at the time of the inspection, this was a routinely generated waste stream. Additionally, the three totes of line flush waste observed at the time of the inspection were not labeled as "hazardous waste - pending analysis" [AOC #2 - Valley Solvents did not properly label their generated waste stream awaiting a hazardous waste determination - 40 CFR 262.17(a)(5)(i)(A)]. Mr. Ide indicated that the two totes of flammable flush would immediately be labeled as hazardous waste and disposed of as such (see Appendix 2). He indicated that the tote of non-hazardous flush would be disposed of accordingly as well (see Appendix 2). The inspection team also observed a 55-gallon drum containing water and a trace amount of perchloroethylene (PERC) catalyst that reportedly had been decanted from a tote of non-conforming PERC catalyst (see Appendix 1 - Photos 3 and 4). The inspection team requested waste determination documentation for the drum, which Mr. Ide included with his response (see Appendix 3). Valley Solvents received a tote of non-confirming PERC catalyst as a return from a customer. The off-spec material was able to be resold to another customer, however, when Valley Solvents was preparing it for shipment, they discovered that the off-spec product was contaminated with water. Valley Solvents had decanted the water into a drum while attempting to retain as much PERC catalyst within the tote as possible. The 55-gallon drum observed on-site is believed to contain water with trace PERC catalyst, with the label stating the material was transferred into the drum on 5/22/2024 and that the material weighed 471 pounds (see Appendix 1 - Photo 6). Mr. Ide explained that the drum was being evaluated to determine whether the water and trace PERC catalyst mixture could be reused or sold (see Appendix 2). He explained that if Valley Solvents determined that neither option was viable, the material would be deemed waste, and a hazardous waste determination would be made at that time. He added that the material would then be shipped offsite in accordance with EPA waste regulations (see Appendix 2). Mr. Ide also included Valley Solvents' policy "OP-2320," which describes the procedures related to non-conforming packages, containers, and products (see Appendix 4). Truck Bay: The inspection team observed incompatible waste stored in the truck bay. Oxidizing liquid waste totes containing phosphoric acid from a galvanizing operation were stored adjacent to flammable product totes (see Appendix 1 - Photos 7 and 8) [AOC #3 - Valley Solvents did not separate hazardous waste from other incompatible materials properly - 40 CFR 262.17(a)(1)(vii)(C)]. In his follow-up document, Mr. Ide explained that these materials were in the process of being loaded and were accidentally placed next to each other in the truck bay (see Appendix 2). He explained that Valley Solvents modified its storage area locations to incorporate dedicated areas for oxidizing liquids and trained employees on the new storage locations (see Appendix 2). He also included Valley Solvents' policy "OP-4110," regarding hazardous waste storage (see Appendix 5). A closing conference was conducted at approximately 3:35 PM with Valley Solvents personnel. The areas of concern (AOCs) and requested documents were communicated during the closing; however, further EPA review may change or add to Valley Solvent's potential AOCs. Page 6 of 7 Valley Solvents & Chemicals Inspection Date: 05/23/2024 SECTION III - RECORDS REVIEW No RCRA-regulated records were reviewed during this focused onsite inspection. SECTION IV - AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Valley Solvents & Chemicals AOC #1 - Valley Solvents did not properly determine Citation: 40 CFR 262.13 their generator category. Section: 2.1 AOC #2 - Valley Solvents did not properly label their generated waste stream awaiting a hazardous waste determination. Citation: 40 CFR 262.14(a)(5)(i)(A) Section: 2.1 AOC #3 - Valley Solvents did not separate hazardous Citation: 40 CFR 262.17(a)(1)(vii)(C) Section: 2.1 waste from other incompatible materials properly. SECTION V - FOLLOW UP Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to AOCs or provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 06/06/24 Valley Solvents email - Russell Ide sent an email including requested documents and their responses and corrections made to the AOCs noted during the inspection. 2. 08/13/24 Valley Solvents email - Russell Ide sent an email including the "Chem Arrow Flush" flashpoint analysis documentation. SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Document from Valley Solvents Appendix 3. Waste Determination for Drum with Water and Perchloroethylene Catalyst Appendix 4. Valley Solvents OP-2320 Non-Conforming Packages and Containers Appendix 5. Valley Solvents OP-4110 Hazardous Waste Storage Appendix 6. Valley Solvents Line Flushing Material Flashpoint Analysis Page 7 of 7 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1124 Date of Photo: 05/23/2024 Time of Photo: 14:58 hrs. Photographer: Cameron Tanaka Description: View of a 55-gallon drum of mixed solvents in the non-conforming area with a hazardous waste label and no accumulation date. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1125 Date of Photo: 05/23/2024 Time of Photo: 14:58 hrs. Photographer: Cameron Tanaka Description: View of the hazardous waste label on the drum of mixed solvents shown in Photo No. 1 in the nonconforming area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1126 Date of Photo: 05/23/2024 Time of Photo: 15:21 hrs. Photographer: Cameron Tanaka Description: View of a 55-gallon drum of water and trace amounts of perchloroethylene catalyst in the nonconforming area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1127 Date of Photo: 05/23/2024 Time of Photo: 15:21 hrs. Photographer: Cameron Tanaka Description: View of the label on top of the drum of water and trace amounts of perchloroethylene catalyst shown in Photo No. 3 in the non-conforming area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1128 Date of Photo: 05/23/2024 Time of Photo: 15:22 hrs. Photographer: Cameron Tanaka Description: Overview of Valley Solvents' non-conforming area, with red lines designating the area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1129 Date of Photo: 05/23/2024 Time of Photo: 15:24 hrs. Photographer: Cameron Tanaka Description: View of the label on the side of the drum of water and trace amounts of perchloroethylene catalyst shown in Photo No. 3 in the non-conforming area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1130 Date of Photo: 05/23/2024 Time of Photo: 15:26 hrs. Photographer: Cameron Tanaka Description: View of incompatible oxidizing liquid waste totes containing phosphoric acid adjacent to flammable product totes in the truck bay. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Valley Solvents & Chemicals City: Corpus Christi County/Parish: Nueces State: Texas Photo File Name: DSCN1131 Date of Photo: 05/23/2024 Time of Photo: 15:28 hrs. Photographer: Cameron Tanaka Description: View of a label on the incompatible oxidizing liquid waste totes containing phosphoric acid adjacent to flammable product totes in the truck bay. APPENDIX 2. FOLLOW-UP DOCUMENT FROM VALLEY SOLVENTS June 6, 2024 To: Ms. Brook McKeown Chemical Engineer ERG Re: Valley Solvents Corpus Christi - May 24 EPA Inspection Dear Ms. McKeown, We have reviewed the Area of Concern and Document Request based on the EPA's May 24 audit of our facility, and we are pleased to provide the following information. Document Request For the 55-gallon drum of off-spec separated perchloroethylene catalyst, please provide the following: o The life cycle of the generation of the drum, including how and why it was generated, the date it was generated and whether it is able to be sold as a commercial chemical product. o Any sampling available for the material. See attached Life Cycle documentation for this item. Any sampling available for the 5699 purge line waste totes. See attached analysis "Chem Arrow Flush" (5699 purge line) flashpoint analysis (3 samples). Based on the analysis, it has been determined that the Chem Arrow Flush has the potential to be hazardous (flammable) or non-hazardous. Investigation into the process has determined that the amount of odorless mineral spirits (flammable) used in the flush process can vary. In order to avoid producing hazardous flush in the future, we have immediately changed the flush process to use only non-flammable products as flushing agents (not odorless mineral spirits). The two totes of flammable flush will be immediately labeled as hazardous waste and disposed of accordingly. The tote of nonhazardous flush will be disposed of accordingly as well. Areas of Concern A 55-gallon drum of mixed solvents was observed in the non-conforming chemical storage area with a hazardous waste label without an accumulation date. Facility personnel stated that this drum was incorrectly labeled as hazardous waste. Valley has several customers that purchase solvent blends to be used as cleaning agents in various applications. In the process of creating specific blends, any materials that fail our quality control program are identified as "non-conforming product" and labelled as such. The non-conforming product is then evaluated for potential re-use into other products or sold as is. If it is determined that the product cannot be re-used or sold, it is then classified as a waste; a hazardous waste determination is made and the material is disposed of in accordance with all applicable regulations (see Valley policy OP-2320). This drum should have been labelled "non-conforming product" as it had not yet been evaluated for potential re-use. It was accidently mis-labeled as "hazardous waste" due to personnel error. We have re-labelled the drum and begun the evaluation process. We have also re-trained our warehouse personnel on the procedures to help prevent this from re-occurring. Appendix 2 Page 1 of 2  A 55-gallon drum of non-conforming perchloroethylene catalyst was observed in the non-conforming chemical storage area. The material was reportedly received from a customer and Valley attempted to recover as much PERC as possible. What was observed in the drum was what could no longer be recovered. This container may no longer be a viable commercial chemical product and should potentially be managed as a hazardous waste. The EPA inspection team is requesting additional information. See attached Life Cycle documentation for details on the source of this drum. As per Valley policy OP2320, the drum itself will be evaluated for potential re-use or re-sale; if Valley determines neither option is viable, the material will be deemed waste. A hazardous waste determination will be made at that time, and the material will be shipped in accordance with EPA waste regulations. Incompatible waste storage waste observed in the truck bay. Oxidizing liquid waste containing phosphoric acid from a galvanizing operation was stored adjacent to flammable product. The products in question were in the process of being loaded, and were accidently placed next to each other in the staging area. Valley has modified its storage area locations to incorporate dedicated areas for oxidizing liquids and has trained employees on the new storage locations (see attached OP-4110 Hazardous Waste Storage). Please let me know if you have any questions. Cordially, Russell Ide Director of Environmental Services 956-535-0446 Appendix 2 Page 2 of 2 APPENDIX 3. WASTE DETERMINATION FOR DRUM WITH WATER AND PERCHLOROETHYLENE CATALYST Off-Spec Perchloroethylene Catalyst (1 drum) Life Cycle As a chemical distributor, Valley sells various commercial chemicals to industrial customers. Occasionally a product is rejected by a customer due to the material being off-spec for their particular application (color, odor, strength, etc). When this occurs, Valley works with customer to confirm the issue, and if necessary, returns the product into stock with the appropriate documentation as to the reason for the return. Attempts are then made to either rework the product to bring it up to client specifications, or to resell the product into other industries that can use the product as is. In the case of the off-spec perchloroethylene catalyst, this product was found to be off-spec by our customer and returned to Valley Solvents. As per our procedures, we identified the reason for the product being off-spec, and offered the product to other customers who might be able to use the product as is. On May 1st, 2024, we sold the tote of off-spec perchloroethylene catalyst to a customer who was able to use it as-is in a laboratory application. In preparing the tote for resale, we found that the off-spec product contained water. In order to provide the customer with the best possible product, we decanted the water by pumping it off, and placed the water with trace amount of perchloroethylene catalyst into a 55g drum. As per Valley Solvents policy OP-2320, the drum was labelled as non-conforming product; as such, it will be further evaluated and determined if it can be re-used or re-sold; otherwise it will be sent for disposal. Appendix 3 Page 1 of 1 APPENDIX 4. VALLEY SOLVENTS OP-2320 NON-CONFORMING PACKAGES AND CONTAINERS Non-Conforming Packages, Containers, and Products Policy Number: OP-2320 rev.d Page Number: Page 1 of 6 Effective: 12/94 Revision: 5/22/23 Approved: D. Bates NON-CONFORMING PACKAGES, CONTAINERS, AND PRODUCTS Damaged packages, containers and/or contaminated/off-specification products are considered non-conforming. They typically cannot be sold at full price in a damaged or off-specification condition. Handling non-conforming packages in the following manner will prevent unnecessary loss, reduce hazards, maintain accurate inventories, improve quality, and keep customers satisfied. NON-CONFORMING DEFINITION BAGS A bag that is torn or open resulting in loss or contamination of product is classified as non-conforming. A bag that is dirty or soiled - beyond the ability to restore to a like-new, appearance is classified as non-conforming. DRUMS and CANS Punctured, severely dented, scraped or scratched, smashed, marred, rusted, faded, soiled, or poorly painted drums are all classified as non-conforming. CONTAMINATED or OFF-SPECIFICATION PRODUCT Off-color, off-odor, off-specification, dirty, hardened, etc. HANDLING CONTAMINATED or OFF-SPECIFICATION PRODUCT When a product is determined to be "non-conforming", a QC NONCONFORMING PRODUCT REPORT OP-2320a must be immediately completed and submitted to the Inventory Control Manager who in turn will submit the report to the Inventory Committee. The report must contain all the following information: Product Name: Container/Package: Quantity: Date Contaminated: Place Contaminated: Contaminant(s): Source of Contamination: Nature and Appearance: Temporary Storage Location: Remediation Plan: Remediation Deadline: Person Responsible for Remediation: * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 4 Page 1 of 6 Non-Conforming Packages, Containers, and Products Policy Number: OP-2320 rev.d Page Number: Page 2 of 6 Effective: 12/94 Revision: 5/22/23 Approved: D. Bates The Inventory Committee will review the report and make the final determination and approve the remediation plan. Once the report is approved, the QC NONCONFORMING LABEL OP-2320b must be attached to the package or container. The product will then be appropriately staged for remediation. A copy of the approved QC Non-Conforming Product Report OP-2320a shall be forwarded to HQ where: 1) an adjustment will be made to the computer files by electronically transferring the non-conforming product into the "QC Warehouse" file, and 2) the QC Non-Conforming Product Report OP-2320a will be electronically filed on the I:Drive until the product issue is resolved. EXAMPLE LABEL QC NON-CONFORMING PRODUCT Product Name: Container/Package: Quantity: Date Contaminated: Place Contaminated: Source of Contamination: Contaminant(s): Appearance: Temporary Storage Location: Remediation Plan: Remediation Deadline: Responsible Person: * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 4 Page 2 of 6 Non-Conforming Packages, Containers, and Products Policy Number: OP-2320 rev.d Page Number: Page 3 of 6 Effective: 12/94 Revision: 5/22/23 Approved: D. Bates Contaminated product shall not be sold as new. The product will be analyzed to determine if it can be utilized, sold, or discounted. All un-useable or un-saleable products will be labeled, stored, and properly disposed of as "WASTE". (See OP-4350 Waste Disposal.) HANDLING TORN BAGS (Uncontaminated) EQUIPMENT REQUIRED 1. Clear plastic oversized bags that can be heat-sealed. a. Uline has 6mil bags b. 18x30 in cartons of 200 (S-2930) c. 24X36 in cartons of 100 (S-2932) 2. Heat- Sealing equipment - Impak Corporation Phone 310-715-6600 Model 18HHI110 (www.impakcorporation.com) Search for 18HHI110 and scroll to the last line item on the page to find the Hand Help Impulse Heat Sealer we are using. Alternative WEB presence: (www.sorbentsystems.com) Search the same item 18HHI110. 3. Clear plastic 2" repair tape 4. These bags, covers, tape, and sealing equipment are stored in a stationary, convenient location near the receiving area in the bagged material warehouse. 5. Semi-automatic shrink-wrapping machine (Maillis Pkg. Systems MTO Series - Model SW1), or hand operated shrink-wrap device. * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 4 Page 3 of 6 Non-Conforming Packages, Containers, and Products Policy Number: OP-2320 rev.d Page Number: Page 4 of 6 Effective: 12/94 Revision: 5/22/23 Approved: D. Bates BAG REPAIR PROCEDURE (performed by person responsible for tear). 1. The torn bag must be immediately repaired with clear plastic tape, then over- wrapped and sealed in the clear plastic heat-sealed bag. 2. The bag must be labeled "Damaged Package" with a Valley Solvents label 3. If removed from a pallet, the pallet must be restacked, rewrapped, and covered. 4. The repaired bag must be placed on top of the wrapped and covered pallet of like product. 5. All spilled product must be reported to the Operations Manager who will determine the proper steps for clean up and / or disposal. The Operations Manager will determine if a significant loss of product occurred. If so, a partial sticker with the new weight will be applied next to the label on the bag. 6. Damaged or opened packages of USP or Food Grade Products must be downgraded to Technical Grade - properly labeled as "Technical Grade" and a Stock Adjustment Form (OF 80.41a) completed and submitted immediately. 7. Immediately notify the Office Warehouse Coordinator for the warehouse of the damaged package. * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 4 Page 4 of 6 Non-Conforming Packages, Containers, and Products Policy Number: OP-2320 rev.d Page Number: Page 5 of 6 Effective: 12/94 Revision: 5/22/23 Approved: D. Bates SELLING DAMAGED BAGS 1. Upon staging or loading a pallet containing a damaged bag for shipment, the loader will immediately inform the Office Warehouse Coordinator that a damaged bag is available. 2. The Office Warehouse Coordinator will contact Customer service who will call the customer to inquire if the customer would accept an additional (damaged) bag at a discounted price. 3. If agreed, Customer Service will create a separate line item on the Bill of Lading with an agreed upon price and containing the remark "Damaged Bag - Discounted". ORGANIZATION AND TRAINING The following organization and training must be in place: 1. One warehouseman must be assigned the responsibility and accountability of each material storage area. 2. All warehousemen and drivers must be trained in handling pallets, preventing torn bags, and repairing them. * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 4 Page 5 of 6 Non-Conforming Packages, Containers, and Products Policy Number: OP-2320 rev.d Page Number: Page 6 of 6 Effective: 12/94 Revision: 5/22/23 Approved: D. Bates 3. All warehousemen and drivers must be trained to inform Inventory Control and Customer Service of the presence of damaged bags. 4. Customer Service must be trained to call customers offering damaged bags and creating appropriate Bills of Lading. 5. HQ billing personnel must be trained to invoice the damaged packages appropriately. DAMAGED DRUMS OR PAILS If the product is liquid and is contained in a punctured, severely dented, marred, rusted, faded, or otherwise damaged drum or pail, the product must be transferred immediately to a new container and labeled appropriately. INVENTORY OF DAMAGED BAGS Damaged Bags will be counted as Full Packages. Maintaining an accurate inventory of damaged bags is essential for tracking, delivering, and invoicing these packages. SAFETY PRECAUTIONS Take all standard precautions when transferring and repackaging chemical products. Wear appropriate PPE (Personal Protective Equipment and clothing). Refer to the Material Safety Data Sheet for a particular product when seeking handling and protective equipment information. Warning! This heat sealing equipment is not explosion proof. Do not use near filling areas or flammable storage areas. WHAT NOT TO DO Experience has shown that separating torn bags from their original pallets, then combining a hodgepodge of various torn bags of products onto one central pallet will only result in a pallet of junk that will be overlooked until it becomes waste. Failure to repair and repackage damaged packages immediately will result in the package being overlooked for shipment time and time again (in the daily rush to get orders out) until the package becomes unsuitable for sale and/or becomes a waste. Either of the above scenarios will result in a hazard as well as a loss of revenues. * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 4 Page 6 of 6 APPENDIX 5. VALLEY SOLVENTS OP-4110 HAZARDOUS WASTE STORAGE Hazardous Waste Storage Policy Number: OP-4110 Page Number: Page 1 of 2 Effective: 11/94 Revision: 05/04/24 Approved: J. Cox HAZARDOUS WASTE STORAGE Hazardous waste materials are to be stored in containers that meet the DOT requirements for performance-oriented packaging for the material being stored. See OP-2510 Container Selection. Containers not in good condition or leaking must be transferred to containers that are in good condition. Containers must be compatible with the waste being stored. Containers must always be closed during storage except to add or remove waste. The container must not be opened, handled, or stored in a manner, which may rupture the container or cause it to leak. All containers must be marked and labeled according to existing State and Federal regulations. Hazardous waste will be stored in an area separated from existing raw material inventory. The area shall have containment and be impervious to the waste being stored. Ignitable or reactive waste must be located at least 50 feet from the facility property line. Incompatible waste must not be placed in the same container and must be stored and separated according to DOT segregation and separation tables 49 CFR 177.848. (See OP-2310 Storage Compatibility) All oxidizer waste streams must be segregated from incompatibles in designated area. (see mapping oxidizer waste storage) Hazardous waste can be accumulated for 90 days after the determination of hazardous characteristics and then must be shipped off site for disposal. The Hazardous waste storage area will be inspected daily. This policy complies with 40 CFR 265.171, 265.173, 265.176*. *CFR 265.171 Condition of containers. If a container holding hazardous waste is not in good condition, or if it begins to leak, the owner or operator must transfer the hazardous waste from this * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 5 Page 1 of 2 Hazardous Waste Storage Policy Number: OP-4110 Page Number: Page 2 of 2 Effective: 11/94 Revision: 05/04/24 Approved: J. Cox container to a container that is in good condition, or manage the waste in some other way that complies with the requirements of this part. *CFR 265.173 Management of containers. (a) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste. (b) A container holding hazardous waste must not be opened, handled, or stored in a manner, which may rupture the container or cause it to leak. *CFR 265.176 Special requirements for ignitable or reactive waste. Containers holding ignitable or reactive waste must be located at least 15 meters (50 feet) from the facility's property line. * Not a controlled copy when printed. Document is only adequate for 24 hours after printing. Appendix 5 Page 2 of 2 APPENDIX 6. VALLEY SOLVENTS LINE FLUSHING MATERIAL FLASHPOINT ANALYSIS 1 2 3 4 5 ANALYTICAL REPORT 6 7 8 9 PREPARED FOR 10 11 Attn: Mr. Russell Ide Valley Solvents Co., Inc PO BOX 18 2 1/2 MI West Hwy 107 Combes, Texas 78535 Generated 6/4/2024 3:46:10 PM JOB DESCRIPTION Valley Solvents (Corpus), 6/3/24 JOB NUMBER 560-118653-1 Eurofins Corpus Christi 1733 N. Padre Island Drive Corpus Christi TX 78408 See page two for job notes and contact information. Page 1 of 12 Appendix 6 Page 1 of 12 1 Eurofins Corpus Christi 2 Job Notes 3 samples tested. For questions please contact the Project Manager at the e-mail address or telephone number listed on this This report may not be reproduced except in full, and with written approval from the laboratory. The results relate only to the 4 page. 5 The test results in this report relate only to the samples as received by the laboratory and will meet all requirements of the methodology, with any exceptions noted. This report shall not be reproduced except in full, without the express written 6 approval of the laboratory. All questions should be directed to the Eurofins Environment Testing South Central, LLC Project Manager. 7 8 Authorization 9 10 Generated 6/4/2024 3:46:10 PM 11 Authorized for release by Sylvia Garza, Project Manager Sylvia.Garza@et.eurofinsus.com (832)544-2004 Eurofins Corpus Christi is a laboratory within Eurofins Environment Testing South Central, LLC, a company within Eurofins Environment Testing Group of Companies Page 2 of 12 6/4/2024 Appendix 6 Page 2 of 12 Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 Definitions/Glossary Glossary Abbreviation %R CFL CFU CNF DER Dil Fac DL DL, RA, RE, IN DLC EDL LOD LOQ MCL MDA MDC MDL ML MPN MQL NC ND NEG POS PQL PRES QC RER RL RPD TEF TEQ TNTC These commonly used abbreviations may or may not be present in this report. Listed under the "D" column to designate that the result is reported on a dry weight basis Percent Recovery Contains Free Liquid Colony Forming Unit Contains No Free Liquid Duplicate Error Ratio (normalized absolute difference) Dilution Factor Detection Limit (DoD/DOE) Indicates a Dilution, Re-analysis, Re-extraction, or additional Initial metals/anion analysis of the sample Decision Level Concentration (Radiochemistry) Estimated Detection Limit (Dioxin) Limit of Detection (DoD/DOE) Limit of Quantitation (DoD/DOE) EPA recommended "Maximum Contaminant Level" Minimum Detectable Activity (Radiochemistry) Minimum Detectable Concentration (Radiochemistry) Method Detection Limit Minimum Level (Dioxin) Most Probable Number Method Quantitation Limit Not Calculated Not Detected at the reporting limit (or MDL or EDL if shown) Negative / Absent Positive / Present Practical Quantitation Limit Presumptive Quality Control Relative Error Ratio (Radiochemistry) Reporting Limit or Requested Limit (Radiochemistry) Relative Percent Difference, a measure of the relative difference between two points Toxicity Equivalent Factor (Dioxin) Toxicity Equivalent Quotient (Dioxin) Too Numerous To Count 1 Job ID: 560-118653-1 2 3 4 5 6 7 8 9 10 11 Page 3 of 12 Appendix 6 Page 3 of 12 Eurofins Corpus Christi 6/4/2024 Client: Valley Solvents Co., Inc Project: Valley Solvents (Corpus), 6/3/24 Case Narrative 1 Job ID: 560-118653-1 2 Job ID: 560-118653-1 Job Narrative 560-118653-1 Eurofins Corpus Christi 3 4 Analytical test results meet all requirements of the associated regulatory program listed on the Accreditation/Certification Summary 5 Page unless otherwise noted under the individual analysis. Data qualifiers are applied to indicate exceptions. Noncompliant quality control (QC) is further explained in narrative comments. 6 demonstrate precision and accuracy at a batch level, a LCS/LCSD may be performed, unless otherwise specified in the Matrix QC may not be reported if insufficient sample or site-specific QC samples were not submitted. In these situations, to 7 method. Surrogate and/or isotope dilution analyte recoveries (if applicable) which are outside of the QC window are confirmed unless attributed to a dilution or otherwise noted in the narrative. 8 Regulated compliance samples (e.g. SDWA, NPDES) must comply with the associated agency requirements/permits. 9 Receipt 10 The samples were received on 6/3/2024 3:55 PM. Unless otherwise noted below, the samples arrived in good condition, and, where required, properly preserved and on ice. The temperature of the cooler at receipt time was 23.5C. 11 General Chemistry No additional analytical or quality issues were noted, other than those described above or in the Definitions/ Glossary page. Page 4 of 12 Appendix 6 Page 4 of 12 Eurofins Corpus Christi 6/4/2024 Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 Client Sample ID: VSC #1 Detection Summary Analyte Flashpoint Client Sample ID: VSC #2 Result Qualifier 136 RL MDL Unit 70.0 70.0 Degrees F Analyte Flashpoint Client Sample ID: VSC #3 Result Qualifier >212 RL MDL Unit 70.0 70.0 Degrees F Analyte Flashpoint Result Qualifier 113 RL MDL Unit 70.0 70.0 Degrees F 1 Job ID: 560-118653-1 2 Lab Sample ID: 560-118653-1 3 Dil Fac D Method 1 1010 Prep Type Total/NA 4 Lab Sample ID: 560-118653-2 5 Dil Fac D Method 1 1010 Total/NA Prep Type 6 Lab Sample ID: 560-118653-3 7 Dil Fac D Method 1 1010 Prep Type Total/NA 8 9 10 11 This Detection Summary does not include radiochemical test results. Page 5 of 12 Appendix 6 Page 5 of 12 Eurofins Corpus Christi 6/4/2024 Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 Client Sample ID: VSC #1 Date Collected: 06/03/24 14:45 Date Received: 06/03/24 15:55 Client Sample Results General Chemistry Analyte Flashpoint (SW846 1010) Client Sample ID: VSC #2 Date Collected: 06/03/24 14:45 Date Received: 06/03/24 15:55 Result Qualifier 136 RL MDL Unit 70.0 70.0 Degrees F General Chemistry Analyte Flashpoint (SW846 1010) Client Sample ID: VSC #3 Date Collected: 06/03/24 14:45 Date Received: 06/03/24 15:55 Result Qualifier >212 RL MDL Unit 70.0 70.0 Degrees F General Chemistry Analyte Flashpoint (SW846 1010) Result Qualifier 113 RL MDL Unit 70.0 70.0 Degrees F 1 Job ID: 560-118653-1 2 Lab Sample ID: 560-118653-1 Matrix: Water 3 4 D Prepared Analyzed Dil Fac 5 06/04/24 12:03 1 Lab Sample ID: 560-118653-2 6 Matrix: Water 7 8 D Prepared Analyzed Dil Fac 06/04/24 12:03 19 Lab Sample ID: 560-118653-3 10 Matrix: Water 11 D Prepared Analyzed Dil Fac 06/04/24 12:03 1 Page 6 of 12 Appendix 6 Page 6 of 12 Eurofins Corpus Christi 6/4/2024 Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 QC Sample Results 1 Job ID: 560-118653-1 2 Method: 1010 - Ignitability, Pensky-Martens Closed-Cup Method 3 Lab Sample ID: LCS 560-215755/1 Matrix: Water Analysis Batch: 215755 Analyte Flashpoint Spike Added 127 Client Sample ID: Lab Control Sample Prep Type: Total/NA 4 LCS LCS %Rec 5 Result Qualifier Unit D %Rec Limits 126.0 Degrees F 99 88 - 112 6 Lab Sample ID: 560-118653-1 DU Matrix: Water Analysis Batch: 215755 Sample Analyte Result Flashpoint 136 Sample Qualifier DU DU Result Qualifier Unit D 135.9 Degrees F Client Sample ID: VSC #1 Prep Type: Total/NA 7 RPD 8 RPD Limit 0.07 20 9 10 11 Page 7 of 12 Appendix 6 Page 7 of 12 Eurofins Corpus Christi 6/4/2024 Accreditation/Certification Summary Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 Laboratory: Eurofins Corpus Christi The accreditations/certifications listed below are applicable to this report. 1 Job ID: 560-118653-1 2 3 Authority Texas Program NELAP Identification Number Expiration Date 4 T104704210-22-30 03-31-25 5 6 7 8 9 10 11 Page 8 of 12 Appendix 6 Page 8 of 12 Eurofins Corpus Christi 6/4/2024 Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 Method Summary 1 Job ID: 560-118653-1 2 Method 1010 Method Description Ignitability, Pensky-Martens Closed-Cup Method Protocol Laboratory 3 SW846 EET CC 4 SW846 = "Test Methods For Evaluating Solid Waste, Physical/Chemical Methods", Third Edition, November 1986 And Its Updates. Protocol References: 5 Laboratory References: 6 EET CC = Eurofins Corpus Christi, 1733 N. Padre Island Drive, Corpus Christi, TX 78408, TEL (361)289-2471 7 8 9 10 11 Page 9 of 12 Appendix 6 Page 9 of 12 Eurofins Corpus Christi 6/4/2024 Client: Valley Solvents Co., Inc Project/Site: Valley Solvents (Corpus), 6/3/24 Sample Summary Lab Sample ID 560-118653-1 560-118653-2 560-118653-3 Client Sample ID VSC #1 VSC #2 VSC #3 Matrix Water Water Water Collected 06/03/24 14:45 06/03/24 14:45 06/03/24 14:45 Received 06/03/24 15:55 06/03/24 15:55 06/03/24 15:55 1 Job ID: 560-118653-1 2 3 4 5 6 7 8 9 10 11 Page 10 of 12 Appendix 6 Page 10 of 12 Eurofins Corpus Christi 6/4/2024 1 2 3 4 5 6 7 8 9 10 11 Page 11 of 12 Appendix 6 Page 11 of 12 6/4/2024 1 Login Sample Receipt Checklist 2 Client: Valley Solvents Co., Inc Job Number: 560-118653-1 3 Login Number: 118653 List Number: 1 Creator: Stacy, Taylor Question Radioactivity wasn't checked or is </= background as measured by a survey meter. The cooler's custody seal, if present, is intact. Sample custody seals, if present, are intact. The cooler or samples do not appear to have been compromised or tampered with. Samples were received on ice. Cooler Temperature is acceptable. Cooler Temperature is recorded. COC is present. COC is filled out in ink and legible. COC is filled out with all pertinent information. Is the Field Sampler's name present on COC? There are no discrepancies between the containers received and the COC. Samples are received within Holding Time (excluding tests with immediate HTs) Sample containers have legible labels. Containers are not broken or leaking. Sample collection date/times are provided. Appropriate sample containers are used. Sample bottles are completely filled. Sample Preservation Verified. There is sufficient vol. for all requested analyses, incl. any requested MS/MSDs Containers requiring zero headspace have no headspace or bubble is <6mm (1/4"). Multiphasic samples are not present. Samples do not require splitting or compositing. Residual Chlorine Checked. Answer N/A True True True True True True True True True True True True True True True True True True True True True True N/A List Source: Eurofins Corpus Christi 4 5 Comment 6 7 8 9 10 11 Check done at department level as required. Eurofins Corpus Christi Page 12 of 12 Appendix 6 Page 12 of 12 6/4/2024