Document 5DrJDXwb4XQEeLXzx3VJorjp0

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At MORGAN COLLISION AND TIRE CENTER 210 West Park Street 101 West 8th Street Sheldon, Iowa 51201 Sheldon, Iowa 51201 (712) 324-3600 (712) 324-3600 EPA ID Number: None EPA ID Number: None On August 9, 2023 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division (ECAD), I conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Morgan Collision and Tire Center, located in Sheldon, Iowa, on August 9, 2023. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. During the inspection, I collected the information and data necessary to determine compliance with the applicable regulatory and statutory requirements. This inspection report and attachments present the results of the CEI. 2.0 PARTICIPANTS Morgan Collision and Tire Center: Rich Morgan, Owner (46 years) Paula Morgan, Office Manager (30 years) EPA: Mark Holcomb, Civil Investigator/Inspector (SEE) 3.0 INSPECTION PROCEDURES On August 9, 2023, I arrived unannounced at the facility's (210 West Park Street) main entrance at about 0930 hours. Initially, I conducted a visual reconnaissance of the facility searching for areas of concern observable from the adjacent public roadways and parking lots. I identified no environmental issues or concerns during this preliminary examination. I entered the facility through the main entrance and stopped at the front desk. I introduced myself and asked for the owner or manager. I was introduced to Rich Morgan, the owner, and his wife Paula Morgan, the office manager. At the opening conference, I presented my EPA ID and credentials to Mr. Morgan. I next explained the purpose and procedures of the inspection. I then presented Mr. Morgan with a copy of RCRA Section 3007(a), which provides inspection authority. I explained my need to collect accurate information and presented him with a copy of Title 18 U.S. Code, Sections 1001 and 1002. He was made aware of his confidentiality rights, and I informed him that a Confidentiality Notice would be provided at the end of the inspection to make a confidentiality claim if he so desired. Mr. Morgan acted as the official facility representative during the inspection. The CEI consisted of a discussion of facility operations, waste generation, and waste management; a visual inspection of active waste generation and management areas; and a review of waste management records and documents. I conducted a visual inspection of the following areas: Main Shop Outside East Lot Back Room Body Shop (101 West 8th Street) See Attachment #1 for the aerial/map views. Document photocopies and photographs were collected as inspection documentation (see Attachments #1-9 and Photos 1-19). The photo log is included as Attachment #2. Information collected during the inspection is documented on an inspection checklist, a hazardous waste stream matrix, and in a notebook. I reviewed documents including the following: Safety Data Sheets (SDS), invoices. I followed the inspection procedures detailed in the RCRA CEI Standard Operating Procedure 2321.01E, unless noted otherwise. At the conclusion of the inspection, I summarized my findings and recommendations with Mr. Morgan. I provided Mr. Morgan with a Receipt for Documents (see Attachment #3), a Confidentiality Notice (see Attachment #4), and a Notice of Preliminary Findings (NOPF) (see Attachment #5), which he signed as acknowledgement of receipt. No claim of confidential business information was made by Mr. Morgan. I provided inspection and compliance assistance documents to Mr. Morgan during the inspection, some as paper versions and some in electronic PDF via email post-inspection, that included the following: x RCRA Section 3007(a) (EPA Handout) x Title 18 U.S. Code, Sections 1001 and 1002 (EPA Handout) x Confidentiality Notice (Top page of the completed carbonless transfer set) x Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA In Connection with Inspections (EPA Handout) x Receipt for Documents and Samples (Top page of the completed carbonless transfer set) x NOPF with Instructions for Responding on back of form (top page of the completed carbonless transfer set) x Instructions for Responding to a NOPF (EPA Handout) x U.S. EPA Small Business Resource Information Sheet (EPA Handout) x Solvent-Contaminated Wipes Final Rule Chart (EPA Handout) 2 x Recycling Electronics (Iowa Department of Natural Resources - IDNR Handout) x Lead-Based Paint Activities (IDNR Handout) x Excluded Solvent-Contaminated Wipe Rule (IDNR Handout) x Battery Recycling/Disposal (IDNR Handout) x Management of Fluorescent Lamps for Businesses (IDNR Handout) x Incompatible Chemicals (IDNR Handout) x Universal Wastes Including Aerosol Cans (IDNR Handout) x TCLP Waste Determination Testing (IDNR Handout) x Industry Sector Notebooks (EPA Handout) x Environmental Compliance Assistance Centers (EPA Handout) x e-Manifest Fact Sheet (EPA Handout) x RCRA Online a Quick Reference Guide (EPA Handout) x Requirements for Used Oil Management Standards (EPA Handout) x Emergency Response Program (EPA Handout) x Commercial Motor Vehicle Transportation System Security & Safety x Security Awareness (EPA Handout) x Chemical Facility Anti-Terrorism Standards (Homeland Security Handout) x Iowa Life/Changing Iowa Department of Economic Development - Iowa Environmental Guide for Business x How to Register for RCRAInfo Industry Application for Iowa Facilities On August 10, 2023, I contacted Mr. Morgan via phone to clarify additional questions. 4.0 FINDINGS AND OBSERVATIONS 4.1 Facility Information and Operations Morgan Collision and Tire Center is an automotive service center with a remotely located body shop. The facility is privately owned by Mr. Morgan. Mr. Morgan stated that this facility was founded in 1977. The main service shop and office is about 6,500 square feet, and the body shop is about 3,600 square feet. He mentioned that their original location is now the remote body shop location and that they outgrew that location and expanded to the current service center/office location at the 210 West Park Street address. Morgan Collision and Tire Center operates a body shop at a secondary location at 101 West 8th Street, about two to three blocks south of the main facility, or about 1,270 feet direct line distance (via Google Maps). Since the secondary location is not immediately adjacent to the main location, it would most likely need a separate EPA ID number if required. The facility has about seven employees and operates Monday-Friday, 07301730 hours. Mr. Morgan stated that the facility services about 70 vehicles per week in the service center and about two vehicles per week in the body shop. See Attachment #1 for the facility aerial map views. 4.2 RCRA Status Morgan Collision and Tire Center had not been inspected for RCRA compliance prior to this inspection. According to RCRAInfo, Morgan Collision and Tire Center had not notified or obtained an EPA number. I verified the facility address and the site contact information with Mr. 3 Morgan and updated the EPA RCRA Notification Acknowledgement/Verification Report (see Attachment #6) to indicate the primary contact's name and contact information. At the time of this inspection, I determined the 210 West Park Street location to be a very small quantity generator (VSQG) of D001 hazardous waste with less than 100 kg, or 220 lbs, of non-acute hazardous waste generated per month, and a generator of waste batteries, and a used oil generator. In addition, I determined the 101 West 8th Street (Body Shop) location to be a VSQG of D001 and F003 hazardous waste with less than 100 kg, or 220 lbs, of non-acute hazardous waste generated per month. 4.3 Facility Waste Streams and Management Mr. Morgan stated that the following waste streams are managed by Morgan Collision and Tire Center: Waste Paint and Thinner - Morgan Collision and Tire Center generates less than one gallon per month of waste paint and thinner during the facility's body shop auto painting processes. Mr. Morgan stated that he uses PPG brand enamel paint, and PPG Lacquer thinner to clean the paint gun, but his goal is to waste as little as possible. The facility has determined this waste to be D001 and F003 hazardous waste (based on process and product knowledge). The SDS (see Attachment #7) indicates the thinner is primarily 20-50% toluene and 20-40% naphtha. Onsite this waste is stored in a small two-gallon can in the Body Shop and then transferred to a 270gallon used oil tote for later burning in the space heater during colder weather. Spent Lead-Acid Batteries - Morgan Collision and Tire Center (210 West Park Street location) generates about two lead-acid batteries per week from vehicle maintenance. The batteries are treated under 40 CFR 266 Subpart G and picked up every two weeks by Interstate Battery (Sioux Falls, South Dakota) for recycling. Mr. Morgan stated that they occasionally also core exchange batteries with Arnold's Auto Parts (Sheldon, Iowa). During the visual inspection I observed seven waste batteries in the Back Room (see Photo 10). They appeared to be in good condition with no obvious damage or leaks. Parts Washer Solvent - Morgan Collision and Tire Center generates about 20-gallons per year of parts washer solvent from vehicle maintenance operations. Mr. Morgan stated that the solvent used in the single parts washer unit (see Photo 6) is from Arnold's Auto Parts store (Sheldon, Iowa). During the inspection, Mr. Morgan contacted Arnolds Auto Parts and had a SDS for Northland Norsolv hand delivered (see Attachment # 9). The SDS lists the contents as 100% distillates (or petroleum, or mineral spirits) with a flash point of 108 degrees F. The facility has determined this waste to be D001 hazardous waste (based on product and process knowledge). Mr. Morgan stated that he self-manages the servicing of the parts washer and changes out the solvent every six months. He stated that each solvent change fills about two five-gallon containers of spent solvent every six months, or about 20-gallons per year total. Mr. Morgan stated that he collects the spent solvent and adds it one of the 270-gallon used oil totes for burning in the space heater during the winter. Used Oil - Morgan Collision and Tire Center generates about 30-gallons per week of used oil from vehicle maintenance operations. The used oil is managed as used oil. Onsite the used oil is 4 drained into a 30-gallon container and then transferred to either a used oil tote or the used oil fuel tank attached to the space heater. During the visual inspection, I observed the used oil collection equipment located in the Main Shop (see Photos 2-3), the 250-gallon used oil fuel tank feeding the space heater (see Photo 5), five full 270-gallon totes stored in the Outside East Lot (see Photos 1, 14 and 15), a 75% full 270-gallon tote in the Back Room (see Photo 9), and 40% full used oil tote in the Body Shop (see Photo 18). All the used oil totes, tanks, and containers appeared to be in good condition and free of obvious damage or leaks. None of the used oil containers I observed, had any labeling and did not have the words "Used Oil" on them. Mr. Morgan stated that he gets a small amount of used oil from local farmers that do their own oil changes on their farm vehicles and equipment. Mr. Morgan stated that all the used oil generated is used as fuel for the space heater during the colder months. The space heater is a 235,000 BTU Shenandoah unit (see Photo 4). NOPF 1: Failure to mark the used oil tanks and totes with "Used Oil" as required in 40 CFR 279.22(c)(1). Spent Gas - Morgan Collision and Tire Center generates about 10-20 gallons per year of spent gas from vehicle maintenance operations. The facility has determined this waste to be D001 hazardous waste (based on product and process knowledge). Mr. Morgan stated that onsite the spent fuel is collected and added to the used oil and is eventually burned in the space heater. The mixture of fuel and used oil is being managed as used oil under 40 CFR 279.10(d)(1). During the visual inspection, I did not observe any spent fuel gas stored onsite (outside of the used oil). Soiled Cloth Shop Rags - Morgan Collision and Tire Center generates about 50 cloth rags per month from vehicle maintenance operations. Mr. Morgan stated that the rags are contaminated with oil and grease and occasionally small amounts of parts cleaning solvent, typically Parts Master Non-Chlorinated Brake and Parts Cleaner (see Photo 11). There was no SDS available for the Brake and Parts Cleaner. Onsite the soiled rags were stored in a closed step can. The rented rags are collected weekly and laundered at City Laundering (Oelwein, Iowa), a commercial laundry. For a copy of an invoice see Attachment #8. During the visual inspection, I observed a 20-gallon yellow steel step can with a closed top, about 20% full of dry appearing soiled rags (see Photo 7). There were no obvious liquids present. I did not observe any labeling on the step can. I asked Mr. Morgan if he had conducted a hazardous waste determination on the shop rags in the 20-gallon step can containers. Mr. Morgan stated "No." NOPF 2: Failure to make a hazardous waste determination on the solvent contaminated shop rags as required in 40 CFR 262.11(a) Disposable Paper Wipes - Morgan Collision and Tire Center generates about one roll every two weeks of disposable paper wipes as part of their vehicle maintenance process. Mr. Morgan stated that they use the disposable paper wipes for cleaning glass, and they are not used with any solvents. Mr. Morgan stated that they consider the waste to be non-hazardous waste (based on process knowledge). Mr. Morgan stated that once used the wipes are disposed of in the general trash. During the visual inspection, I did not observe any spent disposable wipes. 5 Used Antifreeze - Morgan Collision and Tire Center generates about one gallon per week of waste antifreeze as part of their vehicle maintenance process. Mr. Morgan stated that they consider the waste to be non-hazardous waste (based on process knowledge). Onsite the waste is stored in five-gallon containers. Mr. Morgan stated that he donates the used antifreeze to local farmers to use as equipment antifreeze during the winter. During the visual inspection, I observed a five-gallon plastic container, about 2/3 full, of waste antifreeze in the Body Shop (see Photo 19). Used Oil Filters - Morgan Collision and Tire Center generates about three to four used oil filters per day as part of their vehicle maintenance process. Onsite the oil filters are crushed in a hydraulic oil filter crusher (see Photo 2). The used oil is collected in a used oil tote and the filters are collected and recycled as scrap metal. Floor Absorbents / Pig Mats - Morgan Collision and Tire Center generates about 10-20 pig mats per three months. The pig mats, that are changed out quarterly, are used to collect oil drippage from the new product oil containers in the Back Room (see Photo 8). The facility has determined this waste to be non-hazardous (based on product and process knowledge). The pig mats are disposed of in the general trash. Spent Tires - Morgan Collision and Tire Center generates about 80-100 per month from maintenance operations. The facility has determined this waste to be non-hazardous (based on product and process knowledge). During the visual inspection, I observed about 80-100 tires Outside East Lot (see Photo 16). These waste tires are picked up monthly by Liberty Tires (Sheldon, Iowa) for recycling. Paint Booth Air Filters - Morgan Collision and Tire Center generates four 20-inch by 30-inch paint booth filters every two months from paint booth operations. The facility has determined this waste to be non-hazardous (based on process knowledge). Mr. Morgan stated that the filters are dry and changed out every two months (see Photo 17). The spent filters are disposed of in the general trash. Scrap Metal - Morgan Collision and Tire Center generates several hundred pounds of nonhazardous scrap metal each month from vehicle maintenance operations. Onsite, the scrap metal is stored in two 40-gallon plastic drums in the Shop (see Photo 12). When full they are donated for recycling to a neighbor who is a junk dealer. Cardboard Recycling - Morgan Collision and Tire Center generates about two plastic 50gallon recycling containers per week of nonhazardous cardboard from maintenance and facility operations (see Photo 13). The cardboard is picked up weekly by Schwartz Service for recycling. General Trash - Morgan Collision and Tire Center generates nonhazardous general trash from maintenance, facility, and business office operations. The facility estimates about one full sixcubic yard dumpster per week. The trash is picked up twice a week by Schwartz Service (Sheldon, Iowa) and transported to the Northwest Iowa Landfill. 6 4.4 Other Areas Reviewed Outside Facility Perimeter - I conducted a limited inspection of the outside perimeter of the facility and observed no hazardous waste storage tanks and containers except as noted above. See the aerial and map views in Attachment #1. 5.0 SUMMARY OF FINDINGS NOPF 1: Failure to mark the used oil tanks and totes with "Used Oil" as required in 40 CFR 279.22(c)(1). NOPF 2: Failure to make a hazardous waste determination on the solvent contaminated shop rags as required in 40 CFR 262.11(a). Other than the items specifically noted in this narrative, I observed no additional issues or potential findings. However, further EPA review may change or add to my findings. MARK HOLCOMB HOLCOMB (Affiliate) Digitally signed by MARK (Affiliate) Date: 2023.10.06 17:41:23 -05'00' __________________________________________ Mark Holcomb Civil Investigator, SEE Whisnant, Digitally signed by Whisnant, Amber Date: 2023.10.06 18:34:59 _A_m__b__e_r___________-0_5'_00_' _____________________ Amber Whisnant RCRA Section Chief, ECAD/Chemical Branch Attachments: 1) Facility Aerial Map Views (4 pages) 2) Photo Log (19 photos and 20 pages) 3) Receipt for Documents (1 page) 4) Confidentiality Notice (l page) 5) NOPF (1 page) 6) EPA RCRA Notification Acknowledgement/Verification Report (1 page) 7) SDS-Paint Thinner (15 pages) 8) Receipt-Shop Rags Laundering (1 page) 9) SDS-Parts Washer Solvent (8 pages) 7