Document 1gr3adwGxV6KDNL4NjDyz22Go

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 November 17,2023 Ryan Goerl, EH&S Manager Pratt & Whitney 113 Wells Street North Berwick, ME, 03906 Re: U.S. EPA-Region 1 Inspection Report of Pratt & Whitney, September 25-26, 2023 Dear Mr. Goerl: In accordance with current policy, I am providing you with a copy of the final inspection report summarizing observations made during the September 25-26, 2023 Compliance Evaluation Inspection (CEI) of your facility. [Please note that the attachments referenced in the report are not being sent since they are already in your possession.] This inspection was conducted under the authority of RCRA. Please contact me at 617-918-1309 or maisano.ryan@epa.gov if you have any questions. Sincerely, RYAN MAISANO Digitally signed by RYAN MAISANO Date: 2023.11.21 16:16:24 -05'00' Ryan Maisano, Physical Scientist EPA Inspector, Waste and Chemical Compliance Section cc: Cherrie Plummer, Maine Department of Environmental Protection Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 RCRA Compliance Inspection of: Pratt & Whitney 113 Wells Street North Berwick, ME 03906 September 25-26, 2023 Date of Inspection November 20, 2023 Date Inspection Report Approved November 20, 2023 Date Inspection Report Finalized November 21, 2023 Date Inspection Report Transmitted to Facility Ryan Maisano, Physical Scientist Waste and Chemical Compliance Section _________________________ MARY ODONNELL Digitally signed by MARY ODONNELL Date: 2023.11.20 16:24:03 -05'00' Mary Jane O'Donnell, Manager Waste and Chemical Compliance Section Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Date: From: Thru: To: Subject: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 RCRA HAZARDOUS WASTE INSPECTION REPORT November 17, 2023 Waste and Chemical Compliance Section Lisa Papetti, Senior Enforcement Coordinator Waste and Chemical Compliance Section RCRA Enforcement File Environmental Protection Agency ("EPA") Resource Conservation and Recovery Act ("RCRA") Inspection of Pratt & Whitney I. GENERAL INFORMATION Facility Name: Pratt & Whitney Facility EPA Identification Number: Type of Inspection (CEI, FCI, CSI, etc.): Name(s) of inspector(s): Date(s) of inspection: MED000791681 CEI Ryan Maisano Craig Lutz, National Enforcement Investigations Center (NEIC) September 25-26, 2023 II. SITE INFORMATION Site Name: Complete Street Address: Complete Mailing Address: Pratt & Whitney Pratt & Whitney 113 Well Street North Berwick, ME 03906 Pratt & Whitney 113 Well Street North Berwick, ME 03906 Contact(s) (Name, Title, Phone Number, Email) Date of latest Notification of Hazardous Waste Activities (per RCRAInfo): Date of first Notification of Hazardous Waste Activities (per RCRAInfo): Date established at present location: NAICS Code: Ryan Goerl EH&S Manager Email: ryan.goerl@prattwhitney.com Phone:207-676-4103 7/20/2023 8/18/1980 Over 75 years at current location 336412- Aircraft Engine and Engine Parts Manufacturing Current Property Owner: RTX Corporation (formally Raytheon Technologies) Current Operator: Pratt & Whitney Waste codes generated (per most recent Biennial Report): D-Codes: D001 D002 D005 D006 D007 D008 D009 D035 D039 D040 F-Codes: F002 F003 F005 U-Codes: U002 U154 NOTIFICATION IN RCRAInfo: TSDF LQG SQG VSQG Universal Waste Handler (check one): SMALL Burner/Blender Transporter Receiving waste from off-site (if so, describe): Generator of State Waste Non-Notifier Other: Facility Operating Status if different from above: N/A Page 4 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Enforcement History: No recent enforcement history. The last EPA inspection was completed on 10/28/2020 and no violations were noted at the time of the inspection. III. IN-BRIEF Credentials Presented: Yes No Attendees (names/titles): EPA: Ryan Maisano, Physical Scientist, RCRA Inspector Craig Lutz, Environmental Engineer, RCRA Inspector, NEIC Pratt & Whitney: Gary Patnaude, Waste Technician Ryan Goerl, EH&S Manager During the inspection in-brief, the EPA inspection team provided an overview of the inspection and requested paperwork to be reviewed. The EPA inspection team provided the Small Business Resources Information Sheet to the facility personnel. The inspection team briefly discussed handling Confidential Business Information (CBI). Pratt & Whitney did not designate any material as CBI at the time of the inspection or designate any material as CBI after the inspection. Ryan Goerl, EH&S Manager, and Gary Patnaude, Waste Technician, provided an overview of the facility's history, process, waste generation, training of personnel, and personal protective equipment (PPE) required while in the facility. The inspection team provided information on the RCRA inspection program processes, including a summary of enforcement options. Number of Employees: 2,300 Size of Facility: 960,000 sq.ft. Length of Facility at Location: Over 75 years Operating Hours: 7 days a week/24 hour a day Number of Shifts: Three-8 hr shifts. Primary Emergency Coordinator: Alternate Emergency Coordinator: Type of Operation: Ryan Goerl Jeff Libby Aircraft engine manufacturing, mainly plasma spray booths for metal powders for engines. Page 5 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Facility Description (principal business, building and property layout, history of company, etc.): Pratt & Whitney is an aircraft engine manufacturing company which is a subsidiary of the RTX Corporation (formerly Raytheon Technologies Corporation). They supply aircraft engine parts to the military and commercial airlines. The North Berwick site focuses mainly on aircraft engine part coating but does include modular assembly. The North Berwick site includes one main building and multiple smaller buildings which includes a wastewater treatment plant. Hazardous waste management at the facility includes: Twenty (20) Hazardous Waste Accumulation Areas (HWAAs). Sixteen plasma booths are managed as HWAAs. Four (4) HWAAs are located outside the main building in three different smaller buildings. They are used for other wastes and waste consolidation. No treatment or recycling of materials occurs at the facility. Universal waste includes bulbs, used electronics, and batteries. Used oil is managed in a 5,000-gallon tank and it is sent for used oil recycling. Tradebe manages the facility's used oil. US Ecology is Pratt & Whitney's waste hauler. They perform waste profiling and lab packs. US Ecology picks up monthly. World Resource collects the metal powder for metal recycling. The metal that is recycled in mainly nickel. Process Description: The main process at the Pratt & Whitney North Berwick facility is coating of aircraft engine parts by use of the plasma spray booths. These plasma spray booths are mainly for new parts. The booths coat the new parts with metal. The paint booth waste is managed as hazardous waste accumulation areas due to the volume of waste generated. Pratt & Whitney North Berwick facility also repair, and coat used parts. The North Berwick site also includes a nickel-plating line which is also used to coat aircraft parts. The nickel-plating line includes eight (8) 1,250-gallon tanks. Tanks 1, 4, and 5 are tested and pumped into totes for disposal when needed. Tanks 3, 6, 7, and 8 discharge to waste water treatment. The North Berwick facility does some modular assembly of parts which generates little to no waste. Used oil is generated from grinding fluid from parts repair, lube oil, and coolants for machines. A small wastewater treatment plant is located on the property. Modular assembly is also done on site but little to no waste is generated in that area. Aerosol cans are managed as hazardous waste and are picked up by U.S. Ecology. The QA/QC labs generate lab packs. Page 6 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Types of Waste Handled: Ignitable (D001) F or K listed wastes Used Oil Corrosive (D002) P or U listed wastes State Regulated Wastes Reactive (D003) Precious Metals Unknown Wastes TCLP (D004 - D043) Hazardous Scrap Metals Universal Wastes (Types: Bulbs, used electronics, and batteries.) Other (specify): Comments (descriptions and constituents if known): Handling/Management Methods: Containers Wastewater Treatment ("WWTU") Drip pads HWSA (s) Other Tanks - aboveground Tanks - underground Containment building SAA(s) Comments: Plasma spray booths are managed as HWAA because each of the sixteen booths contain multiple 55gallon drums. IV. PHYSICAL INSPECTION Areas inspected (descriptions and locations): The walkthrough started around 12:35 on September 25, 2023, the EPA inspection team was led around the facility by Ryan Goerl. The inspection team donned safety glasses, safety shoes, and gloves. Page 7 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 WASTES OBSERVED: Waste Stream Chromic inert, solids, NA 3077 Chromic inert, solids, NA 3077 Chromic inert, solids, NA 3077 Flammable solvents-Acetone, mixed alcohols, methanol, xylene UN1993 Chromic inert, solids, NA 3077 Reclaimed hazardous solids, NA 3077 Hazardous solids with Alcohols, acetone- UN3175 Hazardous solids with chromium. UN3244 Aluminide Coating/Thermal Spray Solids Nonhazardous/NonRCRA solids wipes Hazardous wasteClass 8 Corrosive Liquid PGIII Hazardous waste Acid Sludge Brush Nickel Platting Non-hazardous aluminum oxide EPA/State Waste Code D007 D007 D007 D007 D001 D002 D007 D002 F006 Container 3-55gallon drums 3-55gallon drums 3-55gallon drums 55-gallon drum Location Comments Spray Booth 43 Spray Booth 44 Spray Booth 12 Inside Flammable Cabinet HWAA POG (Point of generation) 43 HWAA POG 44 HWAA POG 12 SAA POG 57 3-55gallon drums 55-gallon drum Spray Booth 46 HWAA POG 46 SAA POG 303 Eight (8) 55- Building 600 HWAA gallon drum 55-gallon drum Building 600 HWAA Sixteen (16)-55gallon drums Eight (8)-20gallon fiber cartons 55-gallon drum Building 600 Building 600 Building 510 HWAA HWAA POG 17 55-gallon drum Building 510 POG17 Sixteen (16)-55gallon drums Building 510 POG 17 Page 8 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Descant Beads for compressors Oil from transformers waiting for PCB test Hazardous Waste TCLP Chrome Inert Solids/Filters NA307 Metal Hydroxide Sludge with Free Liquid Acid Plating Rinse water F006 D002 D007 F006 Flammable Solvents, mixed Nickel Sulfates UN 3082 D001 D007 D035 F003 F005 Acid Sludge Brushed Nickel, UN 1906 NonHazardous/Non RCRA NonBurnable Solvent Dried Wipes/PPE D002 F006 Eight (8) 55gallon drums Seven (7) 55-gallon drums Building 510 Building 510 POG 17 POG 17 1-Covered Roll off- Building 13 Eight (8) 55gallon drums Two (2) 275gallon totes Two (2) 55gallon drums Two (2) 275-gallon totes Two (2) 55gallon drums Two (2) 55gallon drums Building 13 Building 13 Building 14 POG 272 POG 272 POG 272 HWAA- This was empty at the time of the inspection HWAA HWAA HWAA Flammables Shed Nickel Plating line Nickel Plating line Nickel Plating line HAZARDOUS WASTE DETERMINATIONS Requirements Determination conducted for all waste streams, by what method Determination updated, as needed (documentation on-site) Comments: Observations (Yes/NO/NA-Explain if needed) Yes Yes Page 9 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 IGNITABLES/REACTIVES/INCOMPATIBLES Requirements Ignitable & reactive wastes separated from sources of ignition or reaction No smoking signs (for ignitable & reactive wastes) Separation of all incompatibles (either incompatible wastes or wastes with incompatible containers) Storage > 50 feet from property line Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes PREPAREDNESS & PREVENTION Requirements: Wastes handled in a manner to minimize the potential for a fire, explosion or a release Arrangements with local authorities Immediate accessible to internal communications/alarm systems Telephone/hand-held two-way radio Emergency equipment (fire extinguishers, spill control decontamination equipment) Equipment maintenance Access to emergency equipment Adequate aisle space (each area) Adequate source of water in the event of a fire (federal regulations) Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes HWAA appear to be maintained Yes Yes Yes PRE-TRANSPORT REQUIREMENTS Requirements: Packaging Labeling (if applicable, DOT hazard class) Marking (words "Hazardous Waste", generator information if being shipped) Contents described Proper DOT shipping name Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Page 10 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 SATELLITE ACCUMULATION Requirements: Approximate number of satellite accumulation areas Amount of waste per waste stream per satellite accumulation area (describe each area) Appropriate amount of waste storage in SAA Containers labeled and marked with contents described SAA at or near point of generation Containers closed when not actively adding or removing waste Condition of containers Impermeable base Secondary Containment Spill Control material Comments: Observations (Yes/No/NA-Explain if Needed) 60 See the waste observed list for a description. Yes Yes Yes Yes Containers appeared to be in good condition at the time of the inspection. Yes Yes Yes CONTAINER STORAGE - HWSA Requirements: Number of container storage areas Location(s) Containers marked and contents described Containers marked with accumulation start date Approximate number & sizes of containers: Description: Floor drains/sumps Containers closed when not actively adding or removing waste Condition of containers (leaks, ruptures, dents, corrosion, heat, pressure) Impermeable base Secondary Containment Incompatibles separated by e.g., dike/wall Storage less than 90 days or 180 days for SQG (hazardous waste) Spill Control material Comments: Observations (Yes/No/NA-Explain if Needed) 20 At each of the 16 plasma spray booths and at smaller buildings outside the main building Yes Yes See the waste observed list for a description. No Yes Containers were not damaged or leaking at the time of the inspection. Yes Yes Yes Yes Yes Page 11 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 WASTE TANKS The facility does not have hazardous waste tanks. USED OIL Requirements: Does the facility generate used oil Is the generator's used oil mixed with other waste(s) What type of waste(s) is used oil mixed with Listed Characteristic Non-hazardous waste If mixture is with characteristic hazardous waste, is the combined waste tested for characteristics Testing for rebuttable presumption Total halogen content determination Total halogen content determined by testing or generator knowledge Are the total halogens less than 1,000 ppm or greater than 1,000 ppm F-listed halogen constituents above 100 ppm Used oil managed according to applicable standards Is used oil accumulated on-site in: Container(s) Aboveground tank(s) Underground tank(s) Describe type, method, and condition Comments: Observations (Yes/No/NA-Explain if Needed) Yes No N/A Not observed Not observed Not observed Not observed Not observed Not observed Not observed Used oil is accumulated in a 5,000-gal tank Used oil tank was not damaged and appeared to be in good condition see Photo # 23 INSPECTION SCHEDULE AND LOG Requirements: Does the facility claim inspections are conducted (tank and/or container inspections) Written inspection schedule Inspection log (adequacy of contents: date, time, items inspected, corrective actions, identity of inspector, signatures, etc.) Documentation Appropriate tank inspections, including containment, level detection, ancillary equipment Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Page 12 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Appropriate treatment equipment inspections All loading/unloading areas subject to spills (when in use) All hazardous waste storage areas (satellite and < 90 day where applicable), at all required frequencies All Safety and emergency equipment (monthly) where necessary Tanks cathodic protection (within six months, then yearly) where necessary Comments: Yes Yes Yes Yes Yes Inspection records are kept at each HWAA. Previous records were reviewed from 2020-2023 CONTINGENCY PLAN Requirements: Plan on-site Date of plan Emergency Coordinator(s) name, address, home and office phone numbers Number to call to report emergency (internal) Plan to local authorities with proof of distribution (police, fire, hospital, emergency response teams) Emergency procedures (fire, explosions, releases/spills) Emergency coordinator(s) on-site or within a short driving distance of the company at all times Emergency equipment list location, description, capabilities Evacuation plan (signal, primary and alternate routes) Has the contingency plan been amended All remaining applicable requirements addressed Comments: Observations (Yes/No/NA-Explain if Needed) Yes First issued May 15. 1979. Last update November 11, 2021 Yes Yes Yes Yes Yes Yes Yes Yes Yes Page 13 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 PERSONNEL TRAINING RECORDS Requirements: All facility personnel that require training identified All facility personnel that require training have been properly trained New employees trained within 6 months and documentation of OST Annual refresher training for all employees requiring training Last annual training date for each employee Written description of training course Adequate training for all employees Job title, job description, name of employee, and description of required training Job duties related to hazardous waste Records maintained on-site until closure or three years for former employees Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Training slides were reviewed. Ryan Goerl presents slides to new employees during orientation. Employees take an annual refresher online. MANIFESTS Requirements: Dates/months of shipping records reviewed Manifests maintained for three years Correct EPA ID numbers used All required parts completed Correct shipping names, numbers used Copies distributed correctly Exception reports filed, and available for review Manifests used for all hazardous waste shipments Appropriate copy(ies) on-site: Comments: Observations (Yes/No/NA-Explain if Needed) Manifests were reviewed from 2022-2023 Yes Yes Yes Yes Yes N/A Yes Yes The facility tracks each manifest on a paper log to ensure the signed facility copy is received. The log dates to 1991. Page 14 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Date 8/14/2022 9/7/2023 Manifest # 017439069FLE 024672138JJK 8/9/2023 0225227675JJK LAND DISPOSAL RESTRICTIONS Waste description and amount Non-DOT Sandblast Grit Thermal Spray Powder D007, NA3077 Hazardous Waste Non-DOT/Non RCRA Regulated Material Comments All copies present, signed/dated. All copies present, signed/dated. All copies present, signed/dated. Requirements: Generator has determined whether the waste meets treatment standard(s) If the waste or contaminated soil does not meet the treatment standard(s), the generator has sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility or the generator has sent individual notification(s) for each shipment of waste If the waste or contaminated soil meets the treatment standard(s) at the original point of generation, the generator has sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility The generator has identified all appropriate waste codes and/or underlying hazardous constituents (UHCs) on each shipment The generator retained on-site a copy of each LDR documentation for 3 years Comments: Observations (Yes/No/NA-Explain if Needed) Yes Not Observed Yes Yes Yes IMPORT/EXPORT ACTIVITIES The facility does not import or export hazardous waste. ANNUAL/BIENNIAL REPORT Requirements: The company has completed an annual or biennial report, when/if it is required Comments: Observations (Yes/No/NA-Explain if Needed) Yes Page 15 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 UNIVERSAL WASTE Requirements: Does the company/facility handle universal wastes What universal wastes are handled/generated by the facility Does the company/facility qualify as an LQH or SQH of universal waste Does the current handling of universal waste prevent breakage, leakage, spillage or damage that could cause leakage Are the containers of universal waste structurally sound and compatible with the contents Do the universal waste containers carry appropriate markings/labeling Does universal waste meet the requirements for accumulation start date Does the generator comply with the less than one year accumulation time limit Is the universal waste item or container dated from the earliest receipt of the item or when first placed in the container Does the company/facility keep appropriate manifests or shipping documents of universal wastes either received at or shipped from the facility to a destination facility Are records kept for at least three years from date of receipt to or transfer from the facility Comments: Observations (Yes/No/NA-Explain if Needed) Yes Bulbs, used electronics, and batteries. SQH Yes Yes Yes Yes Yes Yes Yes Yes Universal waste is stored in building 600. Page 16 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 OUT-BRIEF List Attendees (names/titles): EPA: Ryan Maisano, Physical Scientist, RCRA Inspector Craig Lutz, Environmental Engineer, RCRA Inspector Pratt & Whitney: Gary Patnaude, Waste Technician Ryan Goerl, EH&S Manager Jeff Libby, EH&S Senior Manager Summary of out-brief: (include a list of areas of concern that were discussed) The out-brief was conducted on September 26, 2023, on-site before the inspection team left the facility. The inspection team provided an overview of the observations made including: 1. There were no "No Smoking" signs on any of the spray booth hazardous waste accumulation areas. Signs were added and observed during second day of the inspection. 2. At POG 13, the evacuation map, emergency contact numbers, and "Warning Hazardous Waste" sign were all missing at the time of the inspection. This signage was added before the inspection team left the site. 3. At POG 15, the emergency contact list and evacuation map signage were missing at the time of the inspection. These signs were added before the inspection team left the site. Documents still in need of review as of end of inspection: Jason Petrin training documents were provided by email on 10/2/2023. See APPENDIX 1: Digital Images taken by EPA Region 1 during the inspection. Page 17 of 17 EPA RCRA Inspection Checklist Version 1a - November 17, 2015