Document 3Nvqn3w3vzMNzGn8y5xGpB3Vn

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At Oregon Tool, Inc. 4840 East 12th Street Kansas City, Missouri 64127-1716 816-642-6367 EPA ID Number: MOD055445860 On September 28 and 29, 2022 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement & Compliance Assurance Division (ECAD) 1.0 INTRODUCTION I performed a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Oregon Tool, Inc. (Oregon Tool), located in Kansas City, Missouri, on September 28 and 29, 2022. I conducted the inspection under the authority of RCRA Section 3007(a), as amended. During the inspection, I collected the information necessary to determine compliance with the applicable regulatory and statutory requirements. This report and attachments present the results of the inspection. Based on the information obtained during the inspection, I inspected the facility as a Large Quantity Generator (LQG) of hazardous waste, generator of universal waste lamps and batteries, and used oil generator. 2.0 PARTICIPANTS Oregon Tool: Carl Conrad, EHS Manager (approximately 1 year and 2 months at facility) Winston Theodore, General Manager (approximately 1 year and 4 months at facility) Rodney Sorensen, Technical Trades Manager (approximately 18 years at facility) Jason Smith, Global Director Environment & Safety (Exit Briefing) Missouri Department of Natural Resources (MoDNR): Mark Urbanek, Environmental Specialist U.S. Environmental Protection Agency (EPA): Timothy Evans, Life Scientist, ECAD (Lead Inspector) 3.0 INSPECTION PROCEDURES On September 28, 2022, Mark Urbanek and I arrived at the facility at approximately 8:45 a.m. A drive-by inspection was only possible on the west and south sides of the facility. No apparent issues were observed. Mr. Urbanek and I then proceeded to the facility office and asked for Mr. Conrad, listed as site contact on the Hazardous Waste Site Information Verification Report for Inspectors form (Attachment 5). Mr. Urbanek and I met Messrs. Conrad and Winston and signed in as visitors. After checking in, Messrs. Conrad and Winston escorted Mr. Urbanek and me to a conference room for the in briefing. We were introduced to Mr. Sorensen, who joined us for the in briefing. I presented Messrs. Conrad, Winston, and Sorensen with our business cards and I presented my EPA credentials. Messrs. Conrad, Winston, and Sorensen were informed that Mr. Urbanek was accompanying me as an observer. During the in-briefing, I presented Messrs. Conrad and Winston with a copy of the RCRA Facility Access Information Sheet, March 2013, which provides inspection authority. I explained my need to collect accurate information and presented Messrs. Conrad and Winston with a copy of Title 18 U.S. Code, Sections 1001 and 1002. As part of the in-briefing, Messrs. Conrad, Winston, and Sorensen were made aware of Oregon Tool's confidentiality rights and informed that a Confidentiality Notice would be provided at the end of the inspection to make, or not to make, any claims. Messrs. Conrad, Winston, and Sorensen acted as the facility representatives during the on-site inspection activities. During the inspection, discussions consisted of wastes generated and waste management practices. Mr. Urbanek and I conducted a visual inspection of the following areas: Form/Forming Area Foyer/Employee Entrance Heat Treat Building - Heat Treat Lines 1-3; Less Than 90-Day Hazardous Waste Storage; Salt Storage Rack; Water Jet Table; Maintenance Area; Test Room Maintenance Oil Storage Room - Used Oil Storage, Universal Waste Lamp, and Battery Storage Hot Form Shot Blast Area Straightening Line Hot Form/Hot Forming Area North Ramp - Cardboard Storage; Wash Bay Steel Storage Room (Used and New Parts Storage) Tool & Die Shop, including CNC Machines Outside on the North, West, and South Sides of the Facility Information collected during the inspection was documented on the following MoDNR checklists: Hazardous Waste Large Quantity Generator Inspection Checklist, Used Oil Attachment, and Universal Waste Attachment - Small Quantity Handler. Additional information was documented on field notes, and as discussed below. 2 At the conclusion of the inspection, I summarized the findings and recommendations with Messrs. Conrad, Winston, Sorensen, and Smith. I provided Mr. Theodore with a Confidentiality Notice (Attachment 1) which he signed as acknowledgement of receipt. Mr. Theodore made no confidentiality claims. I provided Mr. Conrad with a Receipt for Documents and Samples (Attachment 2) and Notice of Preliminary Findings (NOPF) (Attachment 3), which Mr. Conrad signed as acknowledgement of receipt. The following inspection documents were provided to Oregon Tool: Inspection Documents Confidentiality Notice Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA In Connection with Inspections (Provided by e-mail on May 27, 2022) Receipt of Documents and Samples Notice of Preliminary Findings Instructions for Responding to a Notice of Preliminary Findings MoDNR Compliance Assistance Handouts Missouri Universal Waste Attachment, SQH MO780-2523 (12-14) Missouri Used Oil Generators and Burners, 07/2014 PUB 134 Missouri Aerosol Cans, 04/2016 PUB 1084 EPA Compliance Assistance Handouts EPA Industry Sector Notebooks List EPA Compliance Assistance Centers EPA E-Manifest Fact Sheet A Method for Determining the Compatibility of Hazardous Wastes Managing Used Oil - Advice for Small Businesses Requirements, Used Oil Management Standards Environmental Fact Sheet, Properly Managing Used Oil Filters Subpart G - Spent Lead-Acid Batteries Being Reclaimed Compliance Assistance Handout Land Disposal Restrictions, Lead-Acid Battery Notification 268.7(a)(2) (Template Obtained from Internet Search) I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.1D), unless noted differently. Any federal regulatory citations noted in this report are as adopted by reference in the authorized Missouri regulations. 3 4.0 FINDINGS AND OBSERVATIONS 4.1 General Information/Facility Description and RCRA Status The Oregon Tool facility in Kansas City, Missouri manufactures steel lawn mower blades. Blade Making Process Rolls of steel are received at the facility. The steel is stamped out and notched with a press. The working (sharpened) edge is created. Blades are then formed, heat treated, straightened, and painted (powder coating). Heat Treat Process In 2018, Oregon Tool began operating three heat treat lines to treat mower blades in order to increase their durability. The process involves, but is not limited to, a two-part salt bath. The heat treat process includes tanks to clean blades; a high temperature salt bath (1,500-1,700F) which contains Potassium Chloride (Photo 7). The next step is a low temperature salt bath (550F to 650F) of Potassium Nitrate, Sodium Nitrite, and Sodium Nitrate. The salt is then rinsed from the blades and a hot oil dip/rust inhibitor is applied. The Heat Treat Lines are housed in an approximately 10,00 square foot building. See diagrams and a description of the heat treat line process included in this report as Attachment 7. All other manufacturing and offices are housed in an approximately 70,000 square foot building adjacent to the Heat Treat Building (See Attachment 4 for facility diagram and aerial photos). Oregon Tool has approximately 130 employees at the Kansas City, Missouri facility. Globally, Oregon Tool operates and manufactures in a total of 10 countries. Among the locations, other than Kansas City, Oregon Tool also manufactures products such as chain saw blades for various applications (cutting steel, concrete, and wood) and battery-operated lawn equipment. Hazardous waste generated at the facility consists of a spent sodium nitrite, sodium nitrate, and potassium nitrate mixture, determined to be a D001 oxidizer hazardous waste, characteristic for ignitability. According to information available in the EPA E-Manifest system, within RCRAInfo, Oregon Tool has generated and shipped D001 oxidizer hazardous waste since at least July of 2018 and would have been considered a LQG of hazardous waste since that time. The facility is also a small quantity handler of universal waste lamps and batteries and a used oil generator. See Attachment 6 for additional information related to waste streams generated at the facility. 4 4.2 RCRA Status According to the RCRAInfo database, Oregon Tool has notified as an LQG of D001 characteristic hazardous waste, last notifying on March 1, 2022. I provided Messrs. Conrad and Winston with a Hazardous Waste Site Info Verification Report for Inspector form (Attachment 5). Messrs. Conrad and Winston made no updates to the form. Based upon the amount and type of hazardous waste generated at Oregon Tool, I inspected the facility as a LQG of hazardous waste, small quantity handler of universal waste, and used oil generator. I added and highlighted "Small Quantity Handler of Universal Waste" and "Used Oil Generator" under the Additional Regulated Waste Activities portion of the form. 4.3 Previous Inspection and Related Findings Oregon Tool was previously inspected by the MoDNR on February 14, 2019. The following violations were cited: 1. 2. 3. 4. 5. 6. 7. 8. 9.-18. 19.-26. Failure to determine if waste is hazardous, in violation of 10 CSR 25-5.262(1) Incorporating 40 CFR 262.11. Failure to file an updated generator registration form when information has changed, in violation of 10 CSR 25-5.262(2)(A)3.B. Failure to conduct weekly inspections where containers are stored, looking for leaking containers and for deterioration of containers caused by corrosion or other factors, in violation of 10 CSR 25-5.262(2)(C)2.C(I)&(II) incorporating Failure to attempt to make arrangements designating primary emergency authority to a specific police and a specific fire department and place agreements with any others to provide support to the primary emergency authority where more than one police and fire department might respond to an emergency, in violation of 10 CSR 25-5,262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.37(a)(2). Failure to attempt to make agreements with state emergency response teams, emergency response contractors and equipment suppliers, in violation of 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.37(a)(3). Failure to attempt to make arrangements with local hospitals, in violation of 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.37(a)(4). Failure to document where state or local authorities decline to enter into such agreements, in violation of 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.37(a)(4)(b). Failure to enter the generator's EPA ID number on the manifest (Item #1), in violation of 10 CSR 25-5.262(1) incorporating 40 CFR 262.20(a)(1). Failure to create and maintain a personnel training plan including information as described in 40 CFR 265.16. Failure to maintain a contingency plan on site, which includes information as described in 40 CFR 265.52 and 40 CFR 265.53. 5 4.4 Changes Since Previous Inspection Carl Conrad became the new Environmental Health and Safety Manager in July of 2021, replacing Dwayne Coleman. Winston Theodore became the new General Manager in May of 2021, replacing Matt Huber. Jon Bigo, Technical Operations Manager, is no longer employed at Oregon Tool. Messrs. Bigo and Huber were listed in the facility Hazardous Waste Management Plan as the Primary Emergency Coordinator and Secondary Emergency Coordinator, respectively (Attachment 8). See Section 4.7.5 for additional information related to facility emergency coordinator positions. 4.5 Waste Streams and Waste Management Information related to waste streams is listed in the Waste Stream Table (Attachment 6). 4.6 Areas Visually Inspected and Related Preliminary Findings 4.6.1 Heat Treat Building Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) 40 CFR 262.11 (NOPF 1) - During inspection of the Heat Treat Building, I observed white-colored material described as salt precipitate accumulating on the heat treat line equipment, walls, floor, ceiling, exhaust fan housings, and exterior roof (Photos 1-5, 9-11, 14, and 24-26). Aside from known spent Thermo-Quench W/O, D001 oxidizer hazardous waste being accumulated in drums next to the ausquenching (Photos 1, 9, and 11), salt precipitate observed throughout, and on the roof of, the heat treat building. During the exit briefing, Mr. Smith stated that since the (Potassium chloride), used in the austenitizing (high heat) bath, and the Thermo-Quench W/O (potassium nitrate, sodium nitrite, and sodium nitrate), used in the ausquenching bath, could mix when forming and accumulating as a precipitate, Oregon Tool could not confirm that precipitate observed throughout the facility would all be considered a D001, oxidizer hazardous waste. NU- SAL and Thermo-Quench W/O Safety Data Sheets are included in this report as Attachment 9. Spent Thermo-Quench W/O analytical results are included in this report as Attachment 10. Potassium Chloride-Contaminated Steel Scale During inspection of the Heat Treat Building, I observed a black-colored material described as steel scale (Photo 8). Steel scale is removed from the austenitizing (high heat) baths on Heat Treat Lines 1-3 using, what Mr. Sorensen described as, clam shells (Photos 6 and 12). Each heat treat line employs a clam shell to remove potassium chloride-contaminated steel scale from the austenitizing (high heat) salt baths. The steel scale is managed along with the D001 oxidizer hazardous waste generated at each heat treat line (Photo 13). I asked Mr. Sorensen if he knew whether the steel scale would be a hazardous waste. Mr. Sorensen stated that he thought that the steel scale may not be a hazardous waste, and is only managed along with the D001 oxidizer hazardous waste as a convenient way for heat treat building personnel to dispose of the steel scale. The NU-SAL (potassium chloride) safety data sheet (SDS) and the SDS for steel used at the facility are included in this report as Attachments 9 and 11, respectively. 6 Facility Not Maintained and Operated to Minimize Release of Hazardous Waste, 10 CSR 25-5.262(1) 40 CFR 265.31 (NOPF 6) - During inspection of Heat Treat Line 3, within the Heat Treat Building, Mr. Urbanek and I observed spent Thermo-Quench W/O, D001 oxidizer hazardous waste (potassium nitrate, sodium nitrite, and sodium nitrate) being accumulated in a 55-gallon hazardous waste drum (Photo 11). Oregon Tool has equipped the hazardous waste satellite accumulation area (SAA) drums, on heat Treat Lines 1-3, with what appeared to be stainless steel shields. The shields are employed to help funnel waste coming out of the ausquenching tanks into the 55-gallon SAA drums. As Mr. Urbanek and I were watching hazardous waste being added to the Heat Treat Line 3 SAA drum, an approximately 6-ounce chunk of spent Thermo-Quench W/O landed on the floor next to the drum. The floor under the SAA drum was coated with a thin layer of water which allowed the spent Thermo-Quench W/O to dissolve into the water. Because the floor in and around Heat Treat Lines 1-3 was coated with water, it was not possible to determine how much spent hazardous waste Thermo-Quench W/O was landing on the floor. It should be noted that multiple floor drains exist within the heat treat building. Floor drains discharge to the sanitary sewer. Industrial wastewater generated at Oregon Tool is regulated under an industrial wastewater permit issued by the City of Kansas City, Missouri. Hazardous Waste Storage Containers Not Marked with an Accumulation Start Date, 10 CSR 25-5.262(1) 40 CFR 261.34(a)(2) (NOPF 3) - During inspection of the less than 90- day storage area, within the Heat Treat Building, I observed seven 55-gallon drums of D001 oxidizer hazardous waste (Photo 15). All the drums were closed and labeled with the words "Hazardous Waste." However, two of the seven drums were not labeled with accumulation start dates (Photos 16 and 17). Mr. Sorensen added an accumulation start date to the drums, addressing NOPF 3 at the time of the inspection (Photos 18 and 19). It should be noted that all drums observed in this area had been stored for less than 90 days. Hazardous Waste Satellite Accumulation Container Not Closed, 10 CSR 25-5.262(1) 40 CFR 265.173(a) (NOPF 4) and Hazardous Waste Satellite Accumulation Container Not Labeled with the Words "Hazardous Waste", 10 CSR 25-5.262(2)3 40 CFR 265.16(c) (NOPF 5) - During inspection of the Heat Treat Building, I observed a 55-gallon drum equipped with a wet/dry vacuum lid/top (Photo 20). The drum was approximately -full of salt precipitate. I asked Mr. Sorensen if the salt precipitate would be considered hazardous waste. Mr. Sorensen stated that the material would be considered a hazardous waste. The drum was not labeled with the words "Hazardous Waste." Also, the openings on the wet/dry vac for the hose and exhaust were open. Mr. Sorensen capped/closed the openings on the drum and added a label with the words "Hazardous Waste," addressing NOPF 4 and NOPF 5 at the time of the inspection (Photos 21-23). 4.6.2 Used Oil Storage Room Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) 40 CFR 262.11 (NOPF 1) - During inspection of the Used Oil Storage Room, I observed a cardboard box containing 24, 8-foot, spent fluorescent lamps (Photo 36). Facility personnel were not able to verify, through use of an SDS (Attachment 13), that the spent fluorescent lamps were or were not characteristic hazardous waste, due to the amount of mercury within each lamp. 7 Fire Extinguisher Located Outside Used Oil Storage Not Inspected, 10 CSR 25-5.262(1) 40 CFR 265.33 (NOPF 7) - During inspection of the Used Oil Storage Room, I observed that the fire extinguisher, located just outside the door, had last been inspected in April of 2020 by Johnson Controls Fire Protection LP (Photo 35). Batteries Not Labeled "Universal Waste Batteries", "Waste Batteries", or "Used Batteries", 10 CSR 25-16.273(1) 40 CFR 273.14(a) (NOPF 12) - During inspection of the Used Oil Storage Room, I observed a cardboard box containing six D-size and 8 AA-size spent nickel cadmium batteries. The box wasn't labeled with the words "Universal Waste Batteries", "Waste Batteries", or "Used Batteries" (Photo 27). Mr. Sorensen labeled the box, addressing NOPF 12 at the time of the inspection (Photo 28). 4.6.3 Hot Forming Area Fire Extinguishers Located Inside Hot Forming Area Not Inspected, 10 CSR 25-5.262(1) 40 CFR 265.33 (NOPF 7) - During inspection of the Hot Forming Area, I observed that the fire extinguisher, located just inside the south door, had last been inspected in April of 2020 by Johnson Controls Fire Protection LP (Photo 34). 4.6.4 Tool and Die Shop Used Oil Containers Not Marked or Labeled with the Words "Used Oil", 10 CSR 2511.279(1) 40 CFR 279.22(c)(1) (NOPF 13) - During inspection of the CNC side of the Tool and Die Shop, I observed one approximately 4-quart yellow plastic bin containing approximately three quarts of used oil (Photo 31) and one approximately 4-quart blue plastic bin containing approximately three quarts of used oil (Photo 33); the 4-quart yellow bin was located behind the Fadal CNC machine, and the 4-quart blue bin was located behind the Haas VF-1 CNC machine. The containers were not labeled with the words "Used Oil." Mr. Sorensen labeled the bins with the words "Used Oil", addressing NOPF 13 at the time of the inspection (Photos 32 and 33). 4.6.5 Records Review and Related Preliminary Findings Weekly Inspections Weekly Inspections of Hazardous Waste Containers Not Conducted, 10 CSR 25-5.262(1) 40 CFR 265.174 (NOPF 2) - During review of weekly, less than 90-day hazardous waste accumulation area inspections, Mr. Urbanek noted that only one inspection had been conducted in 2020; six inspections in 2021; and 32 inspections in 2022 (Attachment 14). According to Mr. Urbanek's review of weekly inspections, Oregon Tool did not conduct the following number of inspections: 2020 - 51 inspections not conducted 2021 - 46 inspections not conducted 2022 - 8 inspections not conducted September 28, 2019 through December 30, 2019 weekly inspection documentation was not reviewed. 8 Manifests and Shipping Documents Prior to arriving at the facility, I had conducted an inspection of electronic manifests from September 2020 through September 2022, using RCRAInfo. During the inspection, I reviewed recent manifests not yet signed and returned by the designated facility. All manifests appeared to be complete and were accompanied by land disposal restriction (LDR) notification forms. At the facility, I reviewed three paper manifests (016715448FLE, 016715540FLE, and 016723811FLE). No apparent issues were observed during review of manifests and LDRs. 2021 Comprehensive Biennial Report Prior to arriving at the facility, I was able to review the facility 2021 biennial report using RCRAInfo. No apparent issues were observed during review of the 2021 comprehensive biennial report. Contingency Plan Emergency Coordinators Not Updated in Contingency Plan, 10 CSR 25-5.262(1) 40 CFR 265.52(d) (NOPF 11) - During review of the facility's April 16, 2019, Hazardous Waste Management Plan, I noted that Jon Bigo and Matt Huber were listed as the Primary Emergency Coordinator and Secondary Emergency Coordinator, respectively (Attachment 8). According to Messrs. Conrad and Theodore, Jon Bigo is no longer employed at Oregon Tool and Mr. Theodore became the new General Manager in May of 2021, replacing Matt Huber. Aside from the need to update the emergency coordinator names, the Hazardous Waste Management Plan/Contingency Plan appeared to be complete with no other apparent issues. Personnel Training Mr. Urbanek reviewed personnel training documentation. According to Mr. Conrad, iSi Environmental developed the training material for Oregon Tool employees. Topics covered within the training material include, but are not limited to: x Environmental Law Timeline x Typical Waste Streams x Solid and Hazardous Waste Definitions x Characteristic and Listed Wastes x Hazardous Waste Mixture Rule and Derived from Rule x Managing Solvent-Contaminated Wipes x Satellite Accumulation Rules x 90-Day Storage Rules x Weekly Inspections x Universal Waste x Emergency Response Spills x Hazardous Waste Disposal x DOT Hazardous Materials General Awareness, Safety, and Security Awareness 9 Training documentation was reviewed for the following employees: Heat Treat Hazardous Waste Area Pierce Jackson David Finley Joseph Trombe Johnathan Borisen Oby Ry Zane Shaddox James Ford Bruce Sevell Jr. Luis Diaz Chris Curtis RCRA 8-Hour Refresher and *HAZWOPER Annual Training Marcus Wedlow Bank Idaeho Andrew Morrow Abdikarim Jeilani Clarence Brown Edward Evans Tim Wilson *Carl Conrad Training documentation appeared to be complete with no apparent issues. Preparedness and Prevention During the inspection, I noted several ABC-rated fire extinguishers throughout the facility had been inspected by National Fire Suppression (NFS). According to Mr. Conrad, NFS last inspected fire extinguishers and fire sprinkler system headers on April 28, 2022. Pressure for the facility water sprinkler system was tested on July 18, 2022. A spill kit, located against the east wall of the Heat Treat Building, contained a scoop, absorbent pigs, and pH strips (Photo 14). According to Appendix E, Emergency Equipment List, within the April 16, 2019, Hazardous Waste Management Plan, facility spill kits should contain absorbent pads, sorbent socks, nitrile gloves, and a disposal bag. At the time of the inspection, I did not confirm the contents inside the spill kit. Aside from the two ABC-rated fire extinguishers discussed in Sections 4.6.2 and 4.6.3, no other apparent issues were observed during review of emergency equipment testing and inspection records. Familiarize Local Authorities According to an e-mail provided to me by Mr. Conrad on October 13, 2022, Oregon Tool had previously submitted the facility's April 16, 2019, Hazardous Waste Management Plan to the following authorities: TMC Health Sciences District (Hospital) - 4/19/19 Jackson County Emergency Management - Submitted in either March or April of 2019 Crew Shuster, MoDNR Hazardous Waste Unit - 4/19/19 Officer Clint French, Homeland Security Unit, KCMO East Patrol (KCMO Police) - 4/19/19 Mark Owen, Platte County Emergency Preparedness (Sheriff) - 3/4/19 KCFD Stations 16 and 23 - Submitted in either March or April of 2019 Oregon Tool maintains certified mail domestic return receipts as documentation of delivery. According to Mr. Conrad, Kansas City, Missouri Fire Battalion Chief, Daniel McGrath, conducted a visit at Oregon Tool on December 10 and 13, 2021. No apparent issues were observed. 10 4.7 Additional Observations Containers and Material in Used Oil Storage Room During inspection of the used oil storage room, I observed the following containers or material: x Five, 5-gallon containers of synthetic oil. x One 6-gallon bucket, containing approximately one gallon of two-part epoxy. x One container of Loctite two-part epoxy (container size not documented). x One approximately -full 4.5-gallon capacity container of Plus 3 sheetrock spackle. x One 3.5-gallon capacity Marlite Solvent-Free FRP Adhesive - approximately two gallons full. x One approximately -full and one approximately -full Ace Adhesive Remover (container size not documented). x One approximately -full Klean Strip Adhesive Remover (container size not documented). x One approximately -full 2-quart container of Kingsford Lighter Fluid. x One approximately 1.5-quart glass jar containing what Mr. Sorensen thought was gasoline, in use to clean a filter. The jar was dated July 2, 2006. I asked Mr. Sorensen if any of the material within the containers, listed above, would be considered waste. Mr. Sorensen stated that the material appeared to be unused product. However, Mr. Sorensen stated that Oregon Tool would go through the material to determine what is still in use, could be used, or might need to be disposed. No photos were taken of the product material or product containers. Outside, North of Hot Forming Area During the inspection outside, north of the Hot Forming Area, I noticed approximately 10 pounds of what was described as spent steel shot and dust on the asphalt (Photos 29 and 30). I also noticed rust staining on the asphalt and on the walls in this area. Mr. Sorensen stated that the staining was from steel shot that hadn't made it into a 55-gallon drum used to accumulate spent shot and blasted steel dust. I asked Mr. Sorensen if the steel shot blast media would be used on anything with a coating, such as painted items. Mr. Sorensen stated that the steel shot is only used on bare, uncoated steel. The SDSs for steel used to make mower blades and steel shot blast media used at the facility appear to indicate that spent steel shot and dust would not be a hazardous waste when generated (Attachments 11 and 12, respectively). During the exit interview, I mentioned to Messrs. Conrad, Theodore, Sorensen, and Smith that although the material on the asphalt may not be a hazardous waste, it would still be considered a solid waste, potentially susceptible to migrating offsite through wind or storm water. Further EPA review may be needed to ensure that the steel shot blast media collection system is designed to adequately collect all spent shot and blasted steel dust generated, when operated. 5.0 SUMMARY I inspected Oregon Tool as a Large Quantity Generator of hazardous waste, small quantity handler of universal waste, and used oil generator. 11 Hazardous waste requirements reviewed during this inspection are discussed above and are noted on the MoDNR checklists: Hazardous Waste Large Quantity Generator Inspection Checklist, Used Oil Attachment, and Universal Waste Attachment - Small Quantity Handler. Additional information was documented on field notes, included in the facility file. The following preliminary findings were noted as discussed above: 1. Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) 40 CFR 262.11. (NOPF 1) 2. Weekly Inspections of Hazardous Waste Containers Not Conducted, 10 CSR 25- 5.262(1) 40 CFR 265.174. (NOPF 2) 3. Hazardous Waste Storage Containers Not Marked with an Accumulation Start Date, 10 CSR 25-5.262(1) 40 CFR 261.34(a)(2). (NOPF 3) 4. Hazardous Waste Satellite Accumulation Container Not Closed, 10 CSR 25-5.262(1) 40 CFR 265.173(a). (NOPF 4) 5. Hazardous Waste Satellite Accumulation Container Not Labeled with the Words "Hazardous Waste", 10 CSR 25-5.262(2)3 40 CFR 265.16(c). (NOPF 5) 6. Facility Not Maintained and Operated to Minimize Release of Hazardous Waste, 10 CSR 25-5.262(1) 40 CFR 265.31. (NOPF 6) 7. Fire Extinguishers Located Outside Used Oil Storage and Inside Hot Form Area Not Inspected, 10 CSR 25-5.262(1) 40 CFR 265.33. (NOPF 7) 8. Arrangements Not Made with Police, 10 CSR 25-5.262(1) 40 CFR 265.37(a)(1). ( NOPF Rescinded. Documented compliance provided by Mr. Conrad, subsequent to the inspection. Documented in Appendix D of facility April 16, 2019, Hazardous Waste Management Plan, report Attachment 8). Also, see Section 4.5.5). (NOPF 8) 9. Contingency Plan Not Provided to Police, 10 CSR 25-5.262(1) 40 CFR 265.53(b). ( NOPF Rescinded. Documented compliance provided by Mr. Conrad, subsequent to the inspection. Documented in Appendix D of facility April 16, 2019, Hazardous Waste Management Plan, report Attachment 8). Also, see Section 4.5.5). (NOPF 9) 10. Contingency Plan Does Not Describe Arrangements with Police or Hospital, 10 CSR 25-5.262(1) 40 CFR 265.52(c). (NOPF Rescinded. Documented compliance provided by Mr. Conrad, subsequent to the inspection. Documented in Appendix D of facility April 16, 2019, Hazardous Waste Management Plan, report Attachment 8). (NOPF 10) 11. Emergency Coordinators Not Updated in Contingency Plan, 10 CSR 25-5.262(1) 40 CFR 265.52(d). (NOPF 11) 12. Batteries Not Labeled "Universal Waste Batteries", "Waste Batteries", or "Used Batteries", 10 CSR 25-16.273(1) 40 CFR 273.14(a). (NOPF 12) 13. Used Oil Containers Not Marked or Labeled with the Words "Used Oil", 10 CSR 25- 11.279(1) 40 CFR 279.22(c)(1). (NOPF 13) Other than the items specifically noted in this narrative, I observed no additional issues or potential finding. However, further EPA review may change or add to my findings. 12 TIMOTHY Digitally signed by TIMOTHY EVANS EVANS Date: 2022.11.21 13:58:36 -06'00' _________________________ Timothy R. Evans Life Scientist ECAD/CB/RCRA, EPA Region 7 Digitally signed by AMBER WHISNANT Date: 2022.11.21 AMBER WHISNANT _____________14_:1_3:_53_-0_6_'00_' ________ Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 Attachments 1. Confidentiality Notice (1 page) 2. Document of Receipt (1 page) 3. NOPF (4 pages) 4. Facility Diagram and Aerial Photos (3 pages) 5. Hazardous Waste Site Info Verification Report for Inspector (2 pages) 6. Waste Stream Table (13 pages) 7. Description of Heat Treat Line Process, Including Diagrams (2 pages) 8. Hazardous Waste Management Plan (45 pages) 9. NU-SAL and Thermo-Quench W/O SDS (12 pages) 10. Spent Thermo-Quench W/O Analytical Results (8 pages) 11. Steel SDS (15 pages) 12. Amasteel Steel Shot Blast Media SDS (7 pages) 13. GE Fluorescent Lamps SDS (2 pages) 14. Mark Urbanek, MoDNR, Notes (4 pages) Photo Log (8 pages) Photos (18 pages/36 photos) 13