Document 4abOBzGBQ0aa3LDzx5Z12NnEp
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8
RESOURCE CONSERVATION AND RECOVERY ACT
SEPTEMBER 10, 2020
BASIC INFORMATION
Facility Name: Safety-Kleen Systems, Inc. - Facility Location: 2801 S Tejon St.
Englewood
Englewood, Colorado 80110
Resource Conservation and Recovery Act (RCRA) ID: COD000716621
Notification Status: Treatment, storage, and disposal facility(TSDF); 10-day transfer facility
Facility Contact: Rocky Gray, Branch Manager 303-761-8614
Opening Conference: 1-3 p.m., July 21, 2020 (via MS Teams) Monitoring and Sampling: July 22, 2020 (on-site) Closing Conference: 2-3 p.m., July 23, 2020 (via MS Teams) Lead Inspector: Cindy Schafer, Environmental Engineer, EPA Region 8
Other Attendees: 1. Kristie McNeill, Environmental Scientist, EPA Region 8 (July 21 and 23 only) 2. Craig Lutz, Environmental Engineer, EPA National Enforcement Investigations Center (NEIC) 3. Laura Kanopkin, Environmental Engineer, EPA NEIC 4. Jeremy Deyoe, Environmental Engineer, EPA NEIC 5. David Foster, Environmental Protection Specialist, Colorado Department of Public Health and Environment (CDPHE) 6. Nick Culian, Site Compliance Manager, Safety-Kleen (July 21 and 23 only) 7. Mori Sorenson, Vice President of Environmental Compliance, Safety-Kleen (July 21 and 23 only) 8. Rocky Gray, Branch Manager, Safety-Kleen 9. Brent Craig, District Manager, Safety-Kleen (July 21 and 23 only) 10. Beau Wildenhain, Service Manager (July 22 only) 11. Justin McCall, Material Handler (July 22 only)
Type and Purpose of Inspection: Focused Compliance Inspection Inspection focused on compliance with RCRA air regulations in 40 C.F.R. Part 264, Subparts AA, BB and CC [6 CCR 1007-3 Part 264, Subparts AA, BB and CC]
Facility Type: Hazardous Waste Storage Facility
Inspection Type: Announced Inspection Joint EPA and State Inspection with CDPHE
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
OPENING CONFERENCE Credentials Presented
Small Business Resources Information Sheet provided to facility contact
Confidential business information (CBI) warning to facility provided
CBI was provided or discussed during the inspection
The following information was obtained verbally during the inspection from Safety-Kleen representatives unless otherwise noted.
Company Ownership: The facility has been owned and operated by Safety-Kleen since 1973. In 2013, Safety-Kleen became part of Clean Harbors, Inc.
General Facility and Process Description: The Safety-Kleen Englewood facility has a 12,000-gallon hazardous waste storage tank for storing spent solvent prior to sending the spent solvent off-site for reclamation. Safety-Kleen Englewood has a return and fill station where containers of spent solvent are dumped, cleaned and re-filled with product solvent and reloaded onto service trucks. The spent solvent is pumped from the dumping station to the hazardous waste storage tank.
The Safety-Kleen Englewood facility also operates as a 10-day transfer facility for shipments of hazardous waste. The 10-day storage area is located in the main building in an area called the flam room.
Safety-Kleen Englewood also stores product solvents in three storage tanks onsite including a methanol tank, a glycol tank and a 150-flash point product solvent tank.
Staff Interview: Safety-Kleen Englewood supplies customers with numerous products that are stored at the facility including: oil and grease products, antifreeze, aqueous cleaners, parts cleaning solvents and parts washer stations. Used oil and waste antifreeze containers are collected by Safety-Kleen Englewood and transported to a different facility for recycling and/or disposal. Safety-Kleen Englewood stores the used oil retain samples collected from the used oil containers that they transport. Safety-Kleen Englewood distributes two parts washer solvents, a 150-flash point product solvent and a 105-flash point product solvent. The spent 150-flash point solvent containers are collected by Safety-Kleen Englewood, the containers are emptied and cleaned in the return and fill station and the waste is collected in a 12,000-gallon hazardous waste tank and then sent to a Safety Kleen facility in Illinois for reclamation. The spent 105-flash point solvent is sent to a Clean Harbors facility for disposal and it is not reclaimed.
Safety-Kleen Englewood has a continued use program (CUP) for some 150-flash point solvent customers. Safety-Kleen Englewood uses spent 150-flash point solvent from customers that do not significantly contaminate the spent 150-flash point solvent to clean spent 150-flash point solvent containers. The spent 150-flash point solvent from CUP customers is not considered waste by SafetyKleen Englewood until it is used to clean a spent 150-flash point solvent container in the return and fill station.
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Safety-Kleen Englewood has two return and fill stations; only one was in use at the time of the inspection. The second (south) return and fill station does not have a CUP tank and it is only used when the first (north) return and fill station is not operational.
Safety-Kleen Englewood collects used solvent from customers that are registered as large quantity generators (LQG), small quantity generators (SQG), and very small quantity generators (VSQG).
The 12,000-gallon hazardous waste tank was emptied about every two-three weeks this year. Last year the tank was emptied about every 10-14 days. The spent 150-flash point solvent is in heavy liquid service. The facility conducts daily tank inspections under Subpart J and annual visual inspections of the tank as required by CC. The staff at the Safety-Kleen Englewood facility have not reported any leaking components in the seven years that Rocky Gray has been working at the facility.
Staff at Safety-Kleen Englewood do not conduct testing at the facility to demonstrate that the spent 150flash point solvent is in heavy liquid service. Instead, staff at the facility rely on testing conducted at other Safety Kleen facilities around the country. Staff at Safety-Kleen Englewood use a similar process for its hazardous waste determination for the 150-flash point solvent and for its non-hazardous waste determination for the spent aqueous cleaner.
TOUR INFORMATION
Areas of the facility toured: The on-site inspection team toured the following areas:
x Main warehouse where used parts cleaning stations are dismantled and new or refurbished parts cleaning stations are stored.
x Aqueous cleaner containers are stored. The facility empties waste aqueous cleaner containers using a vac truck which takes the waste to a wastewater treatment plant for disposal.
x Oil room where retain samples are stored. Used oil is not stored at the Safety-Kleen Englewood facility; Safety-Kleen Englewood trucks that pick up used oil bring it to Thermofluids for recycling. Safety-Kleen Englewood does distribute semi-synthetic and full-synthetic oil.
x South storage room where non-hazardous wastes are stored. x Shipping area where products and wastes are staged before being loaded onto trucks. There was
no waste in the shipping area at the time of the inspection. x 10-day area or flam room where hazardous wastes and flammable products are stored. This area
is also permitted for storage up to one year, but staff at Safety-Kleen Englewood do not currently store hazardous wastes in this area for more than 10 days. x Upper warehouse where the aqueous cleaner and aqueous waste is stored. x Return and fill area where the spent 150-flash point solvent containers are dumped, cleaned and refilled. x Tank farm area where the 12,000-gallon hazardous waste tank for storing spent 150-flash point solvent and three product tanks are located.
Sampling Results: The inspection team collected samples of spent 150-flash point solvent from three different containers from three different Safety-Kleen Englewood customers. The results of the sampling confirm that the spent 150-flash point solvent is in heavy liquid service. (See the analytical report summary in Appendix A.)
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Data Collected and Observations: As part of the on-site portion of the inspection, the inspection team conducted a comparative monitoring campaign using Method 21 and audio, visual and olfactory inspections for equipment associated with the return and fill station and the hazardous waste tank that is subject to 6 CCR 1007-3 Part 264, Subpart BB. The inspection team identified one leaking component, a check valve with tag number 028. The leak was identified visually. (See photos 2-4 in Appendix B.)
Records Review: The inspection team reviewed the following records:
x RCRA permit Part IV: Storage in Tank x Subpart BB tagging plan x Tank inspection results for June 22, 2020 and July14, 2020 x BB inspection results for June 23, 2020 and July 16, 2020 x Container storage area inspection results for June 22, 2020 and July 16, 2020 x Return and fill area inspection results for June 25, 2020 and July 8, 2020 x CC container inspection results for June 26, 2020, July 10, 2020, July 21, 2020, January 4, 2019,
and January 3, 2018 x Safety data sheet for the 150-flash point solvent x Heavy liquid service determination for the 150-flash point solvent x List of used 150-flash point solvent shipments from April 1-June 30, 2020 x Shipping documents for VSQG, SQG, non-haz, and CUP customer solvent waste streams
provided as examples of how each solvent waste stream is shipped x Analytical results for hazardous waste determination for the spent 150-flash point solvent x Analytical results for the non-hazardous waste determination for the spent aqueous solvent x Haz and non-haz waste spent 150-flash point solvent and spent aqueous cleaner profiles x Shipping documents for the three containers that were sampled by the EPA inspection team x Shipping documents from June 29, 2020 for generators without a generator ID x Repair document for leak identified by the EPA inspection team
Inspection Logbook No.: 2020-0004 Pages: 1-10
CLOSING CONFERENCE
The closing conference was held via MS Teams on July 23, 2020 from 2-3 p.m.
Compliance Assistance: A link to the EPA's Small Business Assistance worksheet was provided at the beginning of the inspection.
Deficiencies or Concerns: During the on-site portion of the inspection, the EPA inspection team noted that there are four valves inside both the north and south return and fill station that are not included on the Subpart BB monitoring component list. These components are in heavy liquid service and should be monitored per to 6 CCR 1007-3 264.1058. (See Attachment 1.)
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020 SIGNATURES
Lead Inspector: __C__Y_N__T__H__IA___S_C__H__A_F__E_R_____D_a_t_e:_2_02D0.0a9t.e10: 1_5_:5_7_:3_3_-0_6_'0_0'______ Digitally signed by CYNTHIA SCHAFER RCRA Branch Chief: ___J_a_n_i_c_e__P__e_a_r_s_o__n_________D_a_te_: 2_0_2_0.0D9.1a0te16::2_1_:2_7_-0_6_'0_0'________ Digitally signed by Janice Pearson
APPENDICES AND ATTACHMENT Appendix A: Sampling Data Appendix B: Photo Log Attachment 1: Valves Missing from Subpart BB Monitoring Plan
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
APPENDIX A: SAMPLING DATA
Table 1. Summary of Analytical Results for Volatile Organic Compounds (mg/kg1)2,3
Safety-Kleen Systems, Inc. - Region 8
Englewood, Colorado
Compound
SK01A4 SK01B5
Acetone Benzene Bromodichloromethane Bromoform 2-Butanone (MEK) Carbon disulfide Carbon tetrachloride Chlorobenzene Chloroform 1,2-Dichlorobenzene Dibromochloromethane 1,2-Dibromo-3-chloropropane 1,2-Dibromoethane 1,3-Dichlorobenzene 1,4-Dichlorobenzene 1,1-Dichloroethane 1,2-Dichloroethane 1,1-Dichloroethene cis-1,2-Dichloroethene trans-1,2-Dichloroethene 1,2-Dichloropropane cis-1,3-Dichloropropene trans-1,3-Dichloropropene Ethylbenzene Hexachlorobutadiene Hexane 2-Hexanone Isobutylbenzene Isopropylbenzene Methylene chloride 4-Methyl-2-pentanone (MIBK) Naphthalene n-Propylbenzene
<916
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
<91
<100
SK02
<98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98 <98
SK03
<99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99 <99
Page 1 of 2
Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Table 1. Summary of Analytical Results for Volatile Organic Compounds (mg/kg1)2,3
Safety-Kleen Systems, Inc. - Region 8
Englewood, Colorado
Compound
SK01A4 SK01B5
Styrene
<91
1,1,2,2-Tetrachloroethane
<91
Tetrachloroethene
<91
Tetrahydrofuran
<91
Toluene
<91
1,2,3-Trichlorobenzene
<91
1,2,4-Trichlorobenzene
<91
1,1,1-Trichloroethane
<91
1,1,2-Trichloroethane
<91
Trichloroethene
<91
1,2,4-Trimethylbenzene
<91
1,3,5-Trimethylbenzene
<91
m- &/or p-Xylene
<91
o-Xylene
<91
1 mg/kg = milligram per kilogram. 2 SW-846 Methods 5030B, 5035, and 8260D were performed on each sample. 3 Measurement uncertainty was estimated to 46%. 4 C. Lutz determined sample numbers. 5 Sample Nos SK01A and SK01B were sampled in duplicate. 6 Compound not detected above the minimum reporting limit (MRL). 7 Reported average, n=2.
<100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100
SK02
<98 <98 <98 <98 <98 <98 <98 <98 <98 <98 1117 <98 <98 <98
SK03
<99 <99 <99 <99 <99 <99 <99 <99 <99 <99 1147 <99 <99 <99
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
APPENDIX B: PHOTO LOG
Title Subject
Description
Date/Time File Name Photographer Make/Model Equipment ID
Attributes Photo 1 Safety-Kleen Englewood Hazardous waste drum for used oil samples 7/22/2020 9:22:35 AM RIMG0001.JPG Laura Kanopkin Ricoh G700SE S83543
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Facility Name: Safety-Kleen Systems Inc. - Englewood
Facility Location: 2801 S Tejon St, Englewood, Colorado 80110
Date of Inspection: July 21-23, 2020
Attributes
Title
Photo 2
Subject
Safety-Kleen Englewood
Loading and
unloading area: left
two valves connect
to product tanks,
Description
right goes to waste tank. Inspection
team identified a
leaking component
on the waste tank
connection line.
Date/Time
7/22/2020 9:39:55 AM
File Name
RIMG0002.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Page 2 of 7
Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Attributes
Title
Photo 3
Subject
Safety-Kleen Englewood
Description
Loading and unloading area: left two valves connect to product tanks, right goes to waste tank. Inspection team identified a leaking component on the waste tank connection line.
Date/Time
7/22/2020 9:40:19 AM
File Name
RIMG0003.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Attributes
Title
Photo 4
Subject
Safety-Kleen Englewood
Description
Loading and unloading area: left two valves connect to product tanks, right goes to waste tank. Inspection team identified a leaking component on the waste tank connection line.
Date/Time
7/22/2020 9:41:00 AM
File Name
RIMG0004.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Attributes
Title
Photo 5
Subject
Safety-Kleen Englewood
Description
Dirty solvent hazardous waste tank
Date/Time
7/22/2020 9:47:15 AM
File Name
RIMG0005.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Attributes
Title
Photo 6
Subject
Safety-Kleen Englewood
Description
Drum spritzer
Date/Time
7/22/2020 10:18:47 AM
File Name
RIMG0006.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Attributes
Title
Photo 7
Subject
Safety-Kleen Englewood
Description
Drum spritzer
Date/Time
7/22/2020 10:19:02 AM
File Name
RIMG0007.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Page 4 of 7
Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Attributes
Title
Photo 8
Subject
Safety-Kleen Englewood
Description
Capped line on dirty solvent hazardous waste tank
Date/Time
7/22/2020 11:04:05 AM
File Name
RIMG0008.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Attributes
Title
Photo 9
Subject
Safety-Kleen Englewood
Description
Sample SK01 overview
Date/Time
7/22/2020 4:33:50 PM
File Name
RIMG0009.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Title Subject
Description
Date/Time File Name Photographer Make/Model Equipment ID
Attributes Photo 10 Safety-Kleen Englewood Sample SK01 close-up 7/22/2020 4:34:05 PM RIMG0010.JPG Laura Kanopkin Ricoh G700SE S83543
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Facility Name: Safety-Kleen Systems Inc. - Englewood
Facility Location: 2801 S Tejon St, Englewood, Colorado 80110
Date of Inspection: July 21-23, 2020
Attributes
Title
Photo 11
Subject
Safety-Kleen Englewood
Description
Sample SK02 overview
Date/Time
7/22/2020 4:41:51 PM
File Name
RIMG0011.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Title Subject
Description
Date/Time File Name Photographer Make/Model Equipment ID
Attributes Photo 12 Safety-Kleen Englewood Sample SK02 close-up 7/22/2020 4:42:00 PM RIMG0012.JPG Laura Kanopkin Ricoh G700SE S83543
Page 6 of 7
Facility Name: Safety-Kleen Systems Inc. - Englewood
Facility Location: 2801 S Tejon St, Englewood, Colorado 80110
Date of Inspection: July 21-23, 2020
Attributes
Title
Photo 13
Subject
Safety-Kleen Englewood
Description
Sample SK03 overview
Date/Time
7/22/2020 4:46:53 PM
File Name
RIMG0013.JPG
Photographer
Laura Kanopkin
Make/Model
Ricoh G700SE
Equipment ID
S83543
Title Subject
Description
Date/Time File Name Photographer Make/Model Equipment ID
Attributes Photo 14 Safety-Kleen Englewood Sample SK03 close-up 7/22/2020 4:47:02 PM RIMG0014.JPG Laura Kanopkin Ricoh G700SE S83543
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020 ATTACHMENT 1: VALVE MISSING FROM SUBPART BB MONITORING PLAN
Figure 1: Inside the north return and fill station at the Safety-Kleen Englewood facility. Arrows point to valves that are in heavy liquid service and should be included in the Subpart BB monitoring plan. The south return and fill station is identical and has the same valves missing from the Subpart BB monitoring plan.
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Facility Name: Safety-Kleen Systems Inc. - Englewood Facility Location: 2801 S Tejon St, Englewood, Colorado 80110 Date of Inspection: July 21-23, 2020
Figure 2: Snippet of the Subpart BB monitoring plan from the Safety-Kleen Englewood RCRA permit, Attachment 3 which shows the locations of the valves included on the Subpart BB monitoring plan. The red ovals indicate the general location of the valves missing from the Subpart BB monitoring plan.
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