Document 5LeqXYBBz9QoJE3vYD4opJqo8

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At Elementis Specialties Inc. 5548 MANCHESTER AVE St. Louis, MO 63110 (314) 768-6119 EPA ID Number: MOD006292296 On September 26 and 27, 2023 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 Elementis Specialties Inc (Elementis), located in St. Louis, Missouri, on September 26 and 27, 2023. 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, a small quantity handler of universal waste, and a used oil generator. Elementis was last inspected for RCRA compliance on March 20, 2019, by the Missouri Department of Natural Resources (MoDNR). Nine potential findings or violations were observed or cited as a result of the 2019 MoDNR RCRA inspection. 2.0 PARTICIPANTS Elementis: Jim Moore, HSE Manager Claire Backer, Process Engineer Khama Jeffrey, Plant Manager (Exit Briefing) MoDNR: Miranda Cason, Environmental Program Analyst (In-briefing and Visual Inspection on September 26, 2023) Patrick Glass, Environmental Assistant (In-briefing and Visual Inspection on September 26, 2023) U.S. Environmental Protection Agency (EPA): Timothy Evans, Life Scientist, ECAD (Lead Inspector) 3.0 INSPECTION PROCEDURES On September 26, 2023, Ms. Cason, Mr. Glass, and I arrived at the facility at approximately 8:57 a.m. A drive-by inspection was only possible on the east, west, and north sides of the facility. No apparent issues were observed. Ms. Cason, Mr. Glass, and I then proceeded to the facility main access gate where I used an intercom to call and ask for Bryan Fuhr, who was listed as site contact on the Notification Acknowledgement/Verification Report form (Attachment 6). Ms. Cason, Mr. Glass, and I were allowed into the facility general parking area and told to proceed to the facility administration building. On our way to the administration building, we were greeted by Jim Moore, who stated that Mr. Fuhr was no longer with the company and that he was the new EH&S Manager. Mr. Moore then escorted us to a conference room in the administrative building for the in-briefing. I provided Mr. Moore with my business card, and I presented my EPA credentials. During the in-briefing, I presented Mr. Moore with a copy of the Notification Acknowledgement/Verification Report form and asked if all information appeared to be accurate. I then presented Mr. Moore with the RCRA Facility Access Information Sheet, March 2013, which provides inspection authority. I also explained my need to collect accurate information and presented Mr. Moore with a copy of Title 18 U.S. Code, Sections 1001 and 1002. As part of the in-briefing, Messrs. Moore and Lemmons were made aware of Elementis' 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. Ms. Backer joined the inspection at approximately 10:30a.m. Ms. Backer and Mr. Moore acted as the facility representatives during the on-site inspection activities. During the inspection, discussions consisted of wastes generated and waste management practices. Document photocopies and photographs were collected as inspection documentation (see Attachments 1-14, including Photos 1-20). Ms. Cason, Mr. Glass, and I conducted a visual inspection of the following areas: 9/26/23 QC Lab Back Lab Maintenance Electrical Shop Main Boiler Room Less Than 90-Day Accumulation Area, West End of Building 7 Paste and Gel Area 2 Second Floor of Paste and Gel Area Dry Blends Area - West and Outside of Amine Room Amine Room Amine Unloading Room Rheolate Room Bentone Packaging Area Outdoor Area, Between Buildings 8 and 9 Shipping Warehouse 16 9/27/23 Facility Entrance, Parking Lot Information collected during the inspection was documented in a bound field note logbook and as discussed below. At the conclusion of the inspection on September 27, 2023, I summarized the findings and recommendations with Ms. Backer and Messrs. Moore and Jeffrey. I provided Mr. Moore with a Confidentiality Notice (Attachment 3) which he signed as acknowledgement of receipt. Mr. Moore made no confidentiality claims. I provided Mr. Moore with a Receipt for Documents and Samples (Attachment 4) and Notice of Preliminary Findings (NOPF) (Attachment 5), which Mr. Moore signed as acknowledgement of receipt. The following inspection documents were provided to Elementis: Inspection Documents Confidentiality Notice Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA In Connection with Inspections Receipt of Documents and Samples NOPF EPA Compliance Assistance Handouts (Provided by e-mail on September 29, 2023) U.S. EPA Small Business Resources EPA Industry Sector Notebooks List EPA Compliance Assistance Centers Security Awareness Chemical Facility Anti-Terrorism Standards RCRA Organic Air Emission Standards for TSDFs and Large Quantity Generators, December 2022, EPA 530-F-22-007 I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.1E), 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 According to the company website, Elementis manufactures rheological additives for the following industries and applications: Personal Care x Antiperspirant / Deodorant x Bath & Soap x Color Cosmetics x Hair Care x Skin Care Coatings x Industrial Finishes x Architectural Coatings x Construction x Adhesives & Sealants x Inks x Specialty Applications x Colorant Dispersions Energy x Stimulation x Drilling Fluid Additives x Lubricant Additives Talc x Plastics x Paints & Coatings x Ceramics x Polyester Putties x Paper x Pulp x Food & Pharma Other Markets x Pharmaceuticals x Dental The facility has several production lines (i.e., dry organoclay, wet organoclay, anticorrosion pigment, and paste products) that are shown on the facility diagram (See Attachment 2 for facility diagram and aerial photo). According to Ms. Backer, the facility manufactures approximately 60 different rheological additives. The facility operates 24 hours a day, 7 days a week, and employs approximately 61 people. 4 Raw material used in manufacturing, cleaning, and testing include, but are not limited to, bentonite/clay, Amine (beef tallow and ethanol), Toluene, Xylene, Isopropyl Alcohol (IPA), Butanol, Mineral Spirits, Styrene, Sulfuric Acid, and activated carbon. Clay and xylene are received at the facility by railcar. According to Ms. Backer, use of toluene is being phased out. IPA is received in 55-gallon drums. Aside from the discontinued use of toluene and dismantling of the Nalzin Line, processes at the facility have not changed since the MoDNR 2019 RCRA inspection. Hazardous waste generated at the facility includes, but is not limited to: x Lead-Contaminated Debris (Soil and Concrete from Construction Projects); x Ignitable Solvent and Quaternary Amine Mixture from Bulk Raw Material Unloading and Handling x Ignitable Samples, Batch Flushing, and Off-Specification Product from Paste and Gel Manufacturing x Ignitable Laboratory Test Paint (Test Paint Used For Routine Analytical Testing/ Product Quality) x Ignitable Solvent from Cleaning Bentone Manufacturing Equipment (Petroleum Distillates - Bentone Pastes/Gels and Mineral Spirits) x Ignitable Filters from Bentone Paste and Gel Packaging x Ignitable Laboratory Testing Wastes Containing Toluene and Isopropanol x Various waste commercial chemical products See Attachment 7 for additional information related to waste streams generated at the facility. 4.2 RCRA Status According to the RCRAInfo database, Elementis has notified as an LQG of D001, D002, D004, D005, D007, D008, D011 characteristic hazardous waste and F003, F005, U147, U190, U223 listed hazardous waste, last notifying on February 25, 2022. I provided Mr. Moore with a Notification Acknowledgement/Verification Report form for review (Attachment 6). Mr. Moore made no changes to the form, even though the form still lists Bryan Fuhr as the EH&S Manager. See Section 4.6.5 for additional information related to the Notification Acknowledgement/ Verification Report form. Based upon the amount and type of hazardous waste generated at Elementis, I inspected the facility as an LQG of hazardous waste (generation of 2,200 pounds or more of hazardous waste per month). In addition, I determined Elementis to be a small quantity handler of universal waste and a used oil generator. 4.3 Previous Inspection and Related Findings Elementis was previously inspected by the MoDNR on March 20, 2019. The 2019 MoDNR inspection report (Attachment 8) described the following potential findings or violations: 1. Generator did not determine if waste is hazardous pursuant to methods referenced in 40 CFR 262.11- 10 CSR 25-5.262(1) incorporating 40 CFR 262.11. 2. Facility did not use a licensed hazardous waste transporter - Section 260.380.1(5) RSMo. 5 3. Facility did not use authorized hazardous waste treatment, storage or disposal facility or resource recovery facility - Section 260.380.1(7) RSMo. 4. Satellite containers not stored at or near any point of waste generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste - 10 CSR 25-5.262(2)(C)3 referencing 40 CFR 262.34(c)(1). 5. Facility did not use the manifest system, or the wastes were not reclaimed under a contractual agreement - Section 260.380.1(6) RSMo and 10 CSR 25-5.262(2)(B) or 10 CSR 25-5.262(1) incorporating 40 CFR 262.20(e)(1) and (2). 6. The generator did not test the waste or use knowledge of the waste to determine if the waste is restricted from land disposal - 10 CSR 25-7.268(1) incorporating 40 CFR 268.7(a). 7. Contingency plan not submitted to all local police departments, fire departments, hospitals and state and local emergency response teams that may be called upon to provide emergency services - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.53(b). 8. All employees who manage universal waste not provided with information describing proper handling and emergency procedures appropriate for universal wastes handled at the facility. - 10 CSR 25-16.273(1) incorporating 40 CFR 273.16. 9. Each lamp or lamp container or package not marked or labeled clearly as "Universal Waste Lamps" or "Waste Lamp(s)" or "Used Lamps" - 10 CSR 25-16.273(1) incorporating 40 CFR 273.14(e). 4.4 Changes Since Previous Inspection Changes that have occurred at Elementis since the previous inspection include, but are not limited to: x Jim Moore became the new EH&S Manager in May of 2023; the previous site contact and EH&S Manager, Bryan Fuhr, left Elementis in February of 2023 x Khama Jeffrey became the new Plant Manager on September 25, 2023 x According to Ms. Backer, the Nalzin Line was dismantled in 2020 x Toluene is no longer stored in the 8,000-gallon tank, within the product tank farm; there are currently two empty 8,000-gallon tanks in the product tank farm 4.5 Waste Streams and Waste Management Information related to waste streams is listed in the Waste Stream Table (Attachment 7). It should be noted that Elementis had previously notified the MoDNR of their intent to manage Satellite Accumulation Area (SAA) containers under the Missouri regulations. SAA container management regulations can be found in the 2019 MoDNR inspection report, which includes the Hazardous Waste Large Quantity Generator Inspection Checklist (Attachment 8). A request for additional information, related to waste streams, was sent through e-mail on October 13, 2023 (Attachment 9). To date, Elementis has not provided the requested waste stream information. 6 4.6 Areas Visually Inspected and Related Preliminary Findings 4.6.1 QC Lab Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) referencing 40 CFR 262.11. (NOPF 1) - During inspection of the QC Lab, I observed the following containers and chemicals: x One, 1-liter brown glass bottle, ~3/4-full labeled "BAD", and one brown glass ~.5-liter empty brown glass bottle with dried unknown white material on the outside, among other bottles of chemicals, located under the Lab-15 West Hood (Photo 1). x One, 1-liter poly/Nalgene bottle, ~1/10-full and one ~4-liter brown glass bottle labeled "Hardness Buffer Solution", among other bottles of chemicals (Photo 2). x Multiple containers of chemicals located under the east island/counter in the QC Main Lab. According to facility personnel, the chemicals were associated with a discontinued analytical procedure for QC clay capacity chemical and activity testing (Photo 3). I asked Ms. Backer and Mr. Moore if a hazardous waste determination needed to be conducted for the material described above. Ms. Backer and Mr. Moore stated that a hazardous waste determination needed to be conducted for the material in the QC Lab. 4.6.2 Less Than 90-Day Accumulation Area, West End of Building 7 Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) referencing 40 CFR 262.11. (NOPF 1) - During inspection of the Less Than 90-Day Accumulation Area, I observed the following drum: x One blue, full 55-gallon metal drum of mixed amine and alcohols located in the less than 90-day accumulation area (Photos 4 and 5). According to Mr. Moore and Ms. Backer, the waste mixed amine and alcohols in the drum had been cleaned up from the floor of the Amine Room. The waste mixed amine and alcohols was assumed to be characteristic for ignitability, based upon information listed within the Safety Data Sheet (SDS) (Attachment 10). However, according to Ms. Backer and Mr. Moore, the waste mixed amine and alcohols would likely not be characteristic for ignitability after being spilled on, and cleaned up from, the floor, due to rapid evaporation of the ethanol contained within the amine product. According to Mr. Moore and Ms. Backer, a hazardous waste determination would need to be made for the waste mixed amine and alcohols in the drum. Aisle Space Not Maintained to Allow Unobstructed Movement of Personnel and Equipment, 10 CSR 25-5.262(1) referencing 40 CFR 265.35. (NOPF 2) - During inspection of the Less Than 90-Day Accumulation Area, I observed multiple drums containing hazardous waste that were difficult to inspect on all sides or were completely inaccessible (Photos 9-11). A lack of aisle space between drums prevented clear visibility of drum labels. 7 Accumulation Start Date Not Marked on Hazardous Waste Containers, 10 CSR 255.262(1) referencing 40 CFR 262.34(a)(2). (NOPF 3) - During inspection of the Less Than 90Day Accumulation Area, I observed the following drum: x One blue, 55-gallon metal drum of hazardous waste mixed paste and gels sample containers (Photos 6 and 7). The drum was closed and labeled with the words "Hazardous Waste." The drum was also marked with an accumulation start date for satellite accumulation, according to State of Missouri-specific, hazardous waste satellite accumulation area container regulations. However, the drum was not labeled with an accumulation start date when it was placed in the less than 90day accumulation area. Mr. Moore marked the drum with an accumulation start date, addressing NOPF 3 at the time of the inspection (Photo 8). 4.6.3 Amine Room and Outside and West of Amine Room Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) referencing 40 CFR 262.11. (NOPF 1) - During inspection of the Amine Room and Outside and West of the Amine Room, I observed the following containers: x Two, approximately 1/3-full, 5-gallon open poly buckets containing amine and alcohol waste, located outside and west of the Amine Room (Photos 12 and 13). x One blue, 55-gallon metal drum and one 5-gallon open poly bucket of mixed amine and alcohols located in the amine room (Photo 14). According to Mr. Moore and Ms. Backer, the waste mixed amine and alcohols in the containers had been cleaned up from the floor of the Amine Room. The waste mixed amine and alcohols was assumed to be characteristic for ignitability, based upon information listed within the Safety Data Sheet (SDS) (Attachment 10). However, according to Ms. Backer and Mr. Moore, the waste mixed amine and alcohols would likely not be characteristic for ignitability after being spilled on, and cleaned up from, the floor, due to rapid evaporation of the ethanol contained within the amine product. According to Mr. Moore and Ms. Backer, a hazardous waste determination would need to be made for the waste mixed amine and alcohols in the drum. 4.6.4 Outside, North Side of Facility, in between Facility Administrative Building/Offices and QC Lab Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) referencing 40 CFR 262.11. (NOPF 1) - During inspection of the area outside, on the north side of the facility, in between the facility administrative building/offices and the QC Lab, I observed the following containers: x Four, yellow poly, 4-drum capacity, outdoor storage buildings, containing various amounts of material within the secondary containment of the buildings (Photos 18-20). 8 I asked Mr. Moore if he knew what the material was within the secondary containment of the buildings. Mr. Moore stated that he wasn't sure what the material was in the secondary containment of the buildings. Mr. Moore estimated there to be approximately 10 gallons of material within the secondary containment among the buildings. I asked Mr. Moore if a hazardous waste determination needed to be conducted for the material within each of the building secondary containment areas. Mr. Moore stated that a hazardous waste determination would need to be conducted for the material in the building secondary containment areas. 4.6.5 Records Review and Related Preliminary Findings Weekly Inspections During review of records, Mr. Moore provided me "Weekly Hazardous Waste Inspection" forms, dated November 4, 2022, through September 20, 2023. I asked Mr. Moore if Elementis had any additional weekly inspection forms for the three-year span, prior to my inspection. According to Mr. Moore, Elementis has a records retention policy which involves storage of facility documents off-site through the St. Louis Records Center. Mr. Moore stated that the weekly inspection forms may be in storage through the St. Louis Records Center, indicating that weekly inspections had been conducted for the past three years. Mr. Moore also provided me with "Hazardous Waste Storage and Tracking Log" forms for the past three years. "Hazardous Waste Storage and Tracking Log" forms document the amount of waste in the less than 90-day accumulation area and when waste was transported off-site. No apparent issues were observed during review of "Weekly Hazardous Waste Inspection" forms, dated November 4, 2022, through September 20, 2023, and "Hazardous Waste Storage and Tracking Log" forms. Uniform Hazardous Waste Manifests and Land Disposal Restriction (LDR) Notification Forms Prior to arriving at the facility, I had conducted an inspection of electronic manifests from November 2020 through July 2023, using RCRAInfo. During the inspection, I reviewed the following LDR notification forms associated with hazardous waste generated at, and shipped from, the facility: x Waste Flammable Liquids (Ethanol, IPA - Mixed Amines and Alcohol) - D001 (Treatment Method H141) x Waste Solids Containing Flammable Liquids (Mixed Xylenes and Toluene - Filter Socks) - D001, F003, and F005 (Treatment Method H141) x Waste Flammable Solid Organic (Mixed Xylenes and Toluene - Sample Containers of Mixed Paste and Gels) - D001, F003, and F005 (Treatment Method H141) x Paint Loose Pack - D001 (Treatment Method H141) No apparent issues were observed during review of manifests and LDR notification forms. 9 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 Contingency Plan Not Updated to Include New Emergency Coordinators, 10 CSR 255.262(1) referencing 40 CFR 265.152(d) (NOPF 4) - During review of the facility's contingency plan, I noted that David Ahillen, the former Plant Manager, was listed as an Alternate Emergency Coordinator and Brian Fuhr, former EH&S Manager, was listed as the First Backup Emergency Coordinator (Attachment 11). According to Mr. Moore, Bryan Fuhr's employment with Elementis ended in February of 2023. Khama Jeffries became the new Plant Manager as of September 25, 2023. During review of the facility's contingency plan the following information was noted: x The contingency plan was last updated on May 17, 2022. x A description of emergency response equipment, their capabilities, and locations is listed in Appendix J. x Location of Printed Copies of the Integrated Contingency Plan - 14 locations throughout facility x A diagram listing locations of emergency alarms, contingency plan activation, evacuation, and headcount is found within Appendix D. The Contingency Plan was made available to the St. Louis Fire Department and Police Department through an exterior lock box located at the facility. The St. Louis Fire Department audits/tours the facility annually. The Contingency Plan has also been shared with the local emergency planning committee and the BarnesCare Midtown Clinic. Aside from the need to update the Emergency Coordinators, the facility contingency plan appeared to be complete with no apparent issues. Facility Registration with MoDNR Updated Generator Information Not Filed/Communicated with MoDNR, 10 CSR 255.262(2)(A)3.B. (NOPF 5 Added After Inspection) - As part of the inspection in briefing, I provided a Notification Acknowledgement/Verification Report form to Mr. Moore for review (Attachment 6). I asked Mr. Moore if all the information appeared to be accurate. Mr. Moore stated that he had assumed the position formerly filled by the listed site contact, Bryan Fuhr. According to Mr. Moore, he became the new Environmental Health and Safety Manager and site contact on May 1, 2023. According to the MoDNR guidance document entitled "Hazardous Waste Generator Status Guidance - PUB2224", businesses are required to complete and file an updated Notification of Regulated Waste Activity form whenever there is a change in the facility contact person. Mr. Moore stated that he had contacted Heather Lehmann at MoDNR by telephone to request a change for the facility contact person, sometime in late May of 2023. However, to date, Elementis has not updated the site contact name with MoDNR. An e-mail was sent to the facility on November 2, 2023, informing the facility of the additional NOPF (Attachment 12). 10 Personnel Training Documentation that training had been given to, and completed by, facility personnel not available - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.16(d)(4) (NOPF 6 Added After Inspection) - During review of personnel training records, Mr. Moore provided me with a signature sign-off sheet dated April 23, 2019, and April 30, 2019. The training consisted of annual review of EH&S and waste management (including RCRA training, non-hazardous waste, and universal waste management). The training had been conducted for 51 employees. However, the only training documentation available for 2020 through 2023 was a certificate of achievement for Luke Bonnel, dated October 18, 2022. Training for Mr. Bonnel consisted of a hazardous waste management workshop designed for Small Quantity and Large Quantity Generator requirements. Mr. Bonnel's training was provided by Lion Technology, Inc., and instructed by Philip De Rea. Mr. Moore believed that facility employee training documentation was in storage, off-site, through their contractor, St. Louis Record Center. Mr. Moore stated that he would check with St. Louis Records Center to locate training records. However, to date, Elementis has not provided personnel training documentation for 2020 through 2023, aside from the 2022 training documentation for Mr. Bonnel. An e-mail was sent to the facility on November 2, 2023, informing the facility of the additional NOPF (Attachment 12). Preparedness and Prevention During the inspection, I observed several ABC-rated and sodium bicarbonate fire extinguishers throughout the facility. The extinguishers had been inspected by Fire Walker, St. louis, Missouri, in January of 2023. Fire extinguishers are also inspected monthly by facility personnel. According to Mr. Moore, Fire Walker also inspects facility emergency lighting. Mr. Moore stated that there are approximately 107 fire extinguishers located throughout the facility. The facility is equipped with a fire suppression sprinkler system. According to Ms. Backer and Mr. Moore, Fire Tech, LLC, located in St. Louis, inspects the facility sprinkler system. The sprinkler system was last inspected on September 12, 2023. Mr. Moore stated that the St. Louis Fire Department is invited to walk through the facility, annually. 4.6.6 Additional Observations Spilled Off-Specification Material and Clay Outside on Asphalt During the visual inspection, I observed what was described by facility personnel as incidental spilling of off-specification Bentone and waste clay on the asphalt, outside, in the general parking area, adjacent to the facility main entry (Photos 15-17). 11 According to Ms. Backer and Mr. Moore there was approximately 500 pounds of waste clay and approximately 50 pounds of damaged off-specification/waste bagged Bentone (clay and amine) that had been spilled on the asphalt. According to Ms. Backer and Mr. Moore, the waste Bentone and clay spilled on the asphalt would not be a hazardous waste, based upon Safety Data Sheets (Attachment 13). During the inspection, I mentioned to Ms. Backer and Mr. Moore that although waste clay and off-specification Bentone waste may not be hazardous waste when spilled, the material would still be considered a solid waste, potentially susceptible to migrating offsite through storm drains, like the one shown in Photo 17. I asked Ms. Backer if she knew what the final disposition for material emptying into the storm drain would be. Ms. Backer stated that all storm water at the facility flows through the Metropolitan St. Louis Sewer District combined storm water and sewer system. Subsequent to the inspection, I shared an aerial photo of the facility and information about the material on the asphalt with EPA Region 7 ECAD Water Branch staff (Attachment 14). 5.0 SUMMARY I inspected Elementis as an LQG of hazardous waste, small quantity handler of universal waste, and used oil generator. The following preliminary findings were noted as discussed above: 1. Hazardous Waste Determination Not Conducted, 10 CSR 25-5.262(1) referencing 40 CFR 262.11. (NOPF 1) 2. Aisle Space Not Maintained to Allow Unobstructed Movement of Personnel and Equipment, 10 CSR 25-5.262(1) referencing 40 CFR 265.35. (NOPF 2) 3. Accumulation Start Date Not Marked on Hazardous Waste Containers, 10 CSR 255.262(1) referencing 40 CFR 262.34(a)(2). (NOPF 3) 4. Contingency Plan Not Updated to Include New Emergency Coordinators, 10 CSR 255.262(1) referencing 40 CFR 265.152(d) (NOPF 4) 5. Updated Generator Information Not Filed/Communicated with MoDNR, 10 CSR 255.262(2)(A)3.B. (NOPF 5 Added After Inspection) 6. Documentation that training had been given to, and completed by, facility personnel not available - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.16(d)(4) (NOPF 6 Added After Inspection) 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. TIMOTHY Digitally signed by TIMOTHY EVANS Date: 2023.11.20 _E_V__A_N__S_______11_:0_3:4_8_-0_6'_00_' _____ Timothy R. Evans Life Scientist ECAD/CB/RCRDAig,itaEllyPsigAnedRbyegion 7 Whisnant, Whisnant, Amber Date: 2024.01.29 _A_m__b_e_r________12_:3_0:_34_-0_6'_00_' _______ Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 12 Attachments 1. Digital Image Log (23 pages/20 photos) 2. Aerial Photo and Facility Diagrams (2 pages) 3. Confidentiality Notice (1 page) 4. Receipt for Document (1 page) 5. NOPF (2 pages) 6. Notification Acknowledgement/Verification Report Form (2 pages) 7. Waste Stream Table (11 pages) 8. 2019 MoDNR Report Including Hazardous Waste Large Quantity Generator Inspection Checklist (89 pages) 9. E-Mail Request for Additional Information Related to Waste Streams (2 pages) 10. Amine Safety Data Sheet (18 pages) 11. Integrated Contingency Plan (71 pages) 12. Additional NOPFs E-Mail (2 pages) 13. Bentone and Clay Safety Data Sheets (17 pages) 14. Information Shared with EPA Region 7 ECAD Water Branch Staff (2 pages) 13