Document 5kQ6kzVDb7EaDxm61xvgrYmN

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At MIDWEST METAL PRODUCTS 800 66th Avenue SW Cedar Rapids, Iowa 52404 319-366-6264 ext. 174 EPA ID Number: IAD042192401 On May 23, 2022 By TOEROEK ASSOCIATES, INC. For U. S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division INTRODUCTION At the request of the Enforcement and Compliance Assurance Division/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U. S. Environmental Protection Agency (EPA) Region 7, Toeroek Associates, Inc., and its subcontractor CLAENE Group (Toeroek team) conducted a hazardous waste compliance evaluation inspection (CEI) at Midwest Metal Products (Midwest), at 800 66th Avenue SW in Cedar Rapids, Iowa. The CEI was conducted under the authority of Section 3007 of the Resource Conservation and Recovery Act (RCRA), as amended. The CEI covered hazardous waste generator requirements, used oil management, and universal waste requirements, as applicable. This report and its attachments present the results of the CEI. PARTICIPANTS Midwest: Scott Britcher, Maintenance/Process Improvement Paul Warren, Supervisor/Coach Toeroek Team: Clifford Nelles, Inspector, 816-213-5192 INSPECTION PROCEDURES Prior to the CEI at Midwest on May 23, 2022, I conducted a drive-by visual inspection. I did not observe any areas of concern during the drive-by. At approximately 0740 hours, I entered the office and informed the receptionist that I was there to conduct a CEI. The receptionist contacted Mr. Britcher, who arrived with Mr. Warren approximately five minutes later. I introduced myself and explained that I was there to conduct a CEI at Midwest. We went to a conference room where I conducted an entry briefing with Messrs. Britcher and Warren. During the entry briefing, I presented my business card and EPA credentials to Messrs. Britcher and Warren. I explained the scope and procedures for the CEI. I explained the facility's right to make confidentiality claims for any or all the information obtained and provided a Notice Regarding Proprietary/Confidential Business Information. I stated that at the conclusion of the CEI, Mr. Warren would be presented with a Confidentiality Notice (Notice) with which he could make or not make a claim of confidentiality for the facility. I also provided Messrs. Britcher and Warren a copy of U. S. Federal Codes 1001 and 1002, concerning communication of false statements and documents to federal inspectors, and RCRA Section 3007, explaining EPA's inspection authority, both of which they read. A copy of each of the following documents was left with Mr. Warren during the inspection: x RCRA Facility Access Information Sheet x Mr. Trevor Urban's business card x RCRA Section 3007 x U.S. Federal Codes 1001 and 1002 x Instructions for Responding to a Notice of Preliminary Findings x Notice Regarding Proprietary/Confidential Business Information x E-Manifest Fact Sheet: Generators x Managing your Hazardous Waste: A Guide for Small Businesses x U.S. EPA Small Business Resources Information Sheet x Industry Sector Notebooks x Environmental Compliance Assistance Centers x Solvent-Contaminated Wipes Final Rule Summary Chart x IDNR Excluded Solvent-Contaminated Wipes Rule: Management Practices for Wipes, Rags, and Shop Towels x Recycling Electronics: A Guide for Businesses x Lead-Based Paint Activities: Handling and Disposal x Battery Recycling/Disposal x Management of Fluorescent Lamps for Businesses x Incompatible Chemicals x Universal Wastes - Including Aerosol Cans x TCLP - Toxicity Characteristic Leaching Procedure x RCRA Online: A Quick Reference Guide x Part 279 Requirements: Used Oil Management Standards x EPA Region 7 Emergency Response Program 2 x Commercial Motor Vehicle Transportation System Security and Safety x Security Awareness x Chemical Facility Anti-Terrorism Standards I reviewed the Hazardous Waste Site Info Verification Report (Verification Report) with Messrs. Britcher and Warren (Attachment 1). Based on this review, I updated the site contact information on the Verification Report to reflect Mr. Warren as the site contact. I also deleted the D006 waste code from the Hazardous Wastes Handled section of the Verification Report. I conducted the visual inspection of the facility, accompanied by Messrs. Britcher and Warren. Following the visual inspection, I reviewed facility records including hazardous waste manifests with land disposal restriction (LDR) notifications, Safety Data Sheets (SDS), contingency plan, and training documentation. Facility information gathered during the CEI is documented on the Data Gathering Worksheets and Checklists (Attachment 2). At the conclusion of the CEI, I conducted an exit briefing with Messrs. Britcher and Warren. During the exit briefing, I provided a Receipt for Documents and Samples, which Mr. Warren signed, acknowledging receipt (Attachment 3). I provided Mr. Warren the Notice, which he signed indicating no confidential business information had been provided (Attachment 4). I also provided Mr. Warren a Notice of Preliminary Findings (NOPF), which he signed to acknowledge receipt (Attachment 5). Maps of the facility obtained during the CEI are included in Attachment 6, and a Google Earth aerial photograph of the facility is included as Attachment 7. The 15 photographs taken during the CEI are included in Attachment 8. FINDINGS AND OBSERVATIONS 1. Facility Description and General Information According to Mr. Warren, the facility fabricates and stamps metal boxes and brackets for a variety of customers. The products are primarily used to house and protect radio parts for the aerospace industry. The process involves placing aluminum, steel, or stainless steel sheets into stamping, bending, and cutting machines and developing various parts. Once the parts are initially shaped, they can be further processed by grinding, sanding, and spot welding. The parts are sent through the iriditing coating line which is a dip process through a series of baths. Painting, coating, or printing can be performed on parts depending on customer needs. The finished parts are then packaged for shipment to customers. Painting and printing processes generate waste paint-related materials (WPRM) and flammable waste solids (FWS). WPRM consists of solvent and paint waste generated during cleaning of paint guns and paint lines, and FWS consists of waste rags and wipes used for cleaning of silk screens and paint guns exteriors, as well as spent paint filters. The facility considers these wastes to be hazardous based on product and process knowledge. The wastes are accumulated in satellite accumulation containers (SAC) and full SACs are transferred to a hazardous waste central accumulation area (HWCAA). 3 The iriditing coating line is cleaned out approximately every 3 months. This process generates waste corrosive liquids, waste iriditing solution, and waste filters. The facility considers these wastes to be hazardous based on product and process knowledge. The wastes are collected in SACs at the time of generation and transferred to a HWCAA. Wastewater is generated from rinsing finished parts at the iriditing line. All of the wastewater from the iriditing line is discharged to the Midwest wastewater pretreatment system and eventually into the City of Cedar Rapids (City) publicly owned treatment works (POTW). The wastewater system flows through a series of tanks for testing and pH adjustment if needed. No sludge is generated during the wastewater treatment. The industrial wastewater is discharged to the POTW under an Industrial Waste Discharge Permit (Attachment 9). Facility maintenance generates aerosol can residue, used oil, used oil filters, and general trash. Aerosol can residue generated from puncturing and draining waste aerosol cans is considered to be hazardous based on product and process knowledge, and is accumulated in a SAC. Used oil and used oil filters are managed as used oil per Title 40 Code of Federal Regulations (40 CFR) Part 279, and are collected by Hydrite Chemical for recycling. Used oil and used oil filters from the maintenance of the facility's fork trucks by Altorfer are removed by Altorfer at the time the maintenance is performed. Midwest converted all of their lighting to light emitting diode (LED) fixtures in 2019, and therefore, does not generate universal waste lamps. General trash is considered to be nonhazardous based on product and process knowledge, and is collected for landfill disposal. Midwest began operations at the current facility in 1965. Midwest is located in an industrial area along the west side of Interstate 380 in southwestern Cedar Rapids, Iowa. The facility consists of several interconnected buildings with approximately 65,000 square feet under roof that house offices, shipping, receiving, and production areas. Midwest presently employs approximately 100 full time and 17 part time employees who work one of three shifts (0630-1500, 1430-2300, and 2230-0800) Monday-Friday. Additional information is available at www.mwestmp.com. Midwest's primary North American Industrial Classification System (NAICS) code is 332439 (Other Metal Container Manufacturing). Midwest was previously inspected by an EPA contractor, Booz Allen Hamilton, on April 4, 2017. The following preliminary findings were identified during the previous inspection: x Failure to keep a universal waste lamps container closed x Failure to train employees annually x Failure to label an SAC with the words "hazardous waste" x Failure to label an SAC with an indication of the nature of the primary hazard x Failure to affix the accumulation start date on a hazardous waste accumulation container (HWAC) Three of the preliminary findings from the previous inspection (failure to label an SAC with an indication of the nature of the primary hazard, failure to train employees annually, and failure to affix the accumulation start date on a HWAC) were repeated during this CEI. 4 2. RCRA Status Midwest is identified as a large quantity generator (LQG) of hazardous waste (generating more than 1,000 kilograms [kg] of hazardous waste per month) on the Verification Report provided by EPA (Attachment 1). I determined the facility's hazardous waste generation rate based on the quantity of hazardous waste generated during cleanout of the iriditing coating line approximately every 3 months. During each cleanout event, the facility generates approximately 3,000 pounds of waste corrosive liquid, 1,400 pounds of waste iriditing solution, and 1,320 pounds of waste filters. The hazardous waste generation rate per cleanout event is approximately 5,720 pounds (2,600 kg) per month. Since this quantity of hazardous waste is greater than the LQG threshold of 1,000 kg per month and it is generated approximately four months per year, I concluded that Midwest is currently operating as a LQG of hazardous waste and inspected the facility as such. I also inspected the facility as a generator of used oil. The facility operates two less-than-90-day HWCAAs--one located outside of the facility by the paint booth and the other in the Chemical Shed. 3. Waste Streams This section of the CEI report describes waste streams generated by the facility, including the facility's waste determination and waste codes, generation process and rate, management at the facility, and ultimate disposition. The following discussion of waste streams is based on conversations with Messrs. Britcher, and Warren, the visual inspection, and my review of waste shipping documents. Messrs. Britcher, and Warren accompanied me throughout the CEI. WPRM consists of waste paint and spent solvent generated from cleaning paint guns and paint lines. The facility considers the waste to be hazardous (D001, D018, D035, F003, F005) based on product and process knowledge. Based on the 2021 Biennial Report (Attachment 10) and interviews, the facility generates approximately 321 pounds (146 kg) of WPRM per month. Copies of the SDS for paints and solvent used in the paint booths, including MIL-PRF-23377K Green, 005-8277-000 Part 1 Black, 005-8277-000 Part II Catalyst, POLANE Reducer-84, and R7K119 Lacquer Thinner are included as Attachments 11 through 15. The waste is accumulated in 5-gallon SACs upon generation and full SACs are transferred to a 55-gallon HWAC in a HWCAA. WPRM is collected by Hydrite Chemical and transported to Tradebe Treatment in East Chicago, Indiana, for energy recovery. The waste was last collected on March 21, 2022 (Attachment 16, Page 1). During the CEI, I observed a 5-gallon SAC at the paint booth that held approximately 3 gallons of WPRM (Attachment 8, Photograph 3). The SAC was under control of the operator, near the point of generation, structurally sound, closed, labeled with an indication of the nature of the hazard (flammable liquid), and labeled with the words "hazardous waste." I noted no deficiencies regarding WPRM during the CEI. I observed a 55-gallon HWAC of WPRM in the HWCAA adjacent to the paint booth (Attachment 8, Photographs 4 and 5). The HWAC was structurally sound, closed, labeled with the words "hazardous waste," labeled with an indication of the nature of the hazard, held approximately 40 gallons of waste. However, the HWAC was not marked with an accumulation 5 start date as required by 40 CFR 262.17(a)(5)(i)(c) (NOPF No. 6). I asked Mr. Warren how long the HWAC had been in accumulation. He stated that the accumulation start date could not have been earlier than March 22, 2022, as the last pickup of hazardous waste was on March 21, 2022, and all HWACs were removed at that time. A copy of the waste authorization from Hydrite Chemical for waste pickup on March 21, 2022, which includes WPRM (authorization number 18786-MK-378018) is included as Attachment 17. Copies of the March 21, 2022 manifest and LDR are in Attachment 16, pages 1 and 2. I provided compliance assistance regarding management of HWACs during the CEI. I also observed seven full 55-gallon HWACs of WPRM and FWS in the Chemical Shed HWCAA (Attachment 8, Photographs 9 and 10). The HWACs were structurally sound, closed, labeled with the words "hazardous waste," and labeled with an indication of the nature of the hazard (flammable liquid). The HWACs were marked with accumulation start dates ranging from March 14 to May 19, 2022. FWS are generated through the replacement of paint booth filters, and cleaning of the silk screens and the exterior of paint guns with xylene. A copy of the SDS for Xylene is included as Attachment 18. The facility considers the waste to be hazardous (D001, F003) based on product and process knowledge. Based on the 2021 Biennial Report, the facility generates approximately 109 pounds (50 kg) per month. FWS is accumulated in SACs at the point of generation, and full SACs are transferred to a HWCAA. FWS is collected by Hydrite Chemical and transported to WRR Environmental in Eau Claire, Wisconsin for bulking and offsite transfer. The waste was last collected on March 21, 2022 (Attachment 16, Page 6). During the CEI, I observed a SAC of FWS in the silk screen area (Attachment 8, Photographs 1 and 2). The 55-gallon SAC was structurally sound, closed, near the point of generation, under control of the operator, labeled with the words "hazardous waste," labeled with an indication of the nature of the hazard (flammable solids), and held approximately 20 gallons of FWS. I observed a second SAC of FWS adjacent to the paint booth (Attachment 8, Photographs 12 and 13). The 55-gallon SAC was structurally sound, closed, near the point of generation, under control of the operator, labeled with the words "hazardous waste," labeled with an indication of the nature of the hazard (flammable solids), and held approximately 10 gallons of FWS. I noted no deficiencies regarding FWS during the CEI. I also observed seven HWACs of WPRM and FWS in the Chemical Shed HWCAA (Attachment 8, Photographs 9 and 10). The HWACs were structurally sound, closed, labeled with the words "hazardous waste," and labeled with an indication of the nature of the hazard (flammable liquid). The HWACs were marked with accumulation start dates ranging from March 14 to May 19, 2022. Waste corrosive liquid consists of spent nitric and sulfuric acid solutions used for cleaning the iriditing coating line approximately every 3 months. The iriditing coating line is a series of dip tanks containing chemicals that parts are dipped into for cleaning and adhesion purposes. Copies of the SDS for dip tank chemicals Bonderite M-CR 1500 AERO, Isoprep 184, and Iridite 14-2 are included as Attachments 19 through 21. The facility considers waste corrosive liquid to be 6 hazardous (D002, D005, D007) based on product and process knowledge. Approximately 3,000 pounds of waste corrosive liquid are generated during each cleaning event. The waste is accumulated in SACs at the point of generation and transferred to a HWCAA. Waste corrosive liquid is collected by Hydrite Chemical and transported to Evoqua Water Technologies in Roseville, Minnesota for treatment. The waste was last collected on March 21, 2022 (Attachment 16, Page 4). During the CEI, I observed eight full 55-gallon HWACs of waste corrosive liquid in the Chemical Shed HWCAA (Attachment 8, Photograph 11). The HWACs were structurally sound, closed, labeled with the words "hazardous waste," and labeled with an indication of the nature of the hazard (corrosive). The HWACs were marked with accumulation start dates ranging from March 28 to May 21, 2022. Waste filters are generated during the cleaning of the iriditing coating line. At the time of cleaning, the filters are connected to the iriditing tanks and then removed as waste after the cleaning is complete. Approximately 1,320 pounds (600 kg) of waste filters are generated every 3 months. The facility considers the waste to be hazardous (D007) based on product and process knowledge. Waste filters are accumulated in SAC upon generation and transferred to a HWCAA. Waste filters are collected by Hydrite Chemical and transported to Tradebe Treatment in East Chicago, Indiana, for metals recovery. The waste was last collected on March 21, 2022 (Attachment 16, Page 1). I observed one 55-gallon HWAC of waste filters in the Chemical Shed HWCAA (Attachment 8, Photograph 8). The HWAC was structurally sound, closed, labeled with the words "hazardous waste," labeled with an indication of the nature of the hazard, and was full. However, the HWAC was marked with a date of January 11, 2022. According to Mr. Warren, the date on the HWAC was the date the container was started for satellite accumulation, and not the accumulation start date. He also stated that the actual accumulation start date could not have been earlier than March 22, 2022, as the last pickup of hazardous waste was on March 21, 2022, and all HWACs were removed at that time. I determined the facility had failed to mark an accumulation start date on a HWAC, as required by 40 CFR 262.17(a)(5)(i)(c) (NOPF No. 6). I provided compliance assistance regarding management of HWACs during the CEI. I observed an additional two full 55-gallon HWACs of waste filters in the Chemical Shed HWCAA. The HWACs were structurally sound, closed, labeled with the words "hazardous waste," and labeled with an indication of the nature of the hazard. The HWACs were marked with accumulation start dates and the earliest date was March 28, 2022. Aerosol can residue is generated during the puncturing and draining of aerosol cans. The facility considers aerosol can residue to be hazardous (D001) based on product and process knowledge. The aerosol can residue is accumulated in a SAC beneath the puncturing unit, and the empty cans are disposed in the general trash. The generation rate for aerosol can residue is minimal, and no aerosol can residue has been collected for offsite disposal. During the CEI, I observed 55-gallon SAC of aerosol can residue in the Chemical Shed (Attachment 8, Photographs 6 and 7). The SAC was structurally sound, under the control of the 7 operator, near the point of generation, labeled with the words "hazardous waste," and held approximately 1 gallon of aerosol can waste. However, the SAC was not labeled with an indication of the nature of the hazard, as required by 40 CFR 262.15(a)(5)(ii) (NOPF No. 3). The SAC was also not closed, as required by 40 CFR 262.15(a)(4) (NOPF No. 4). I provided compliance assistance regarding management of an SAC during the CEI. Used oil is generated during maintenance of facility machinery. The facility manages as used oil per requirements of 40 CFR Part 279. Machinery maintenance generates approximately 40 gallons of used oil per month. Used oil is stored in 250 and 55-gallon used oil storage containers in the Hawk building. The waste is collected by Hydrite Chemical for recycling. During the CEI, I observed two used oil storage containers in the Hawk building (Attachment 8, Photographs 14 and 15). Both used oil storage containers appeared to be full and in good shape with no apparent leaks or damage. Both used oil storage containers were labeled with the words "used oil." I observed no deficiencies related to used oil during the CEI. Used oil and used oil filters (fork trucks) are generated by Altorfer servicing the fork trucks approximately every three months. As part of the service, Altorfer removes all used oil and used oil filters at the time of servicing. A copy of a service invoice from Altorfer, dated January 11, 2022, is included as Attachment 22. I did not observe used oil or used oil filters from fork truck servicing in accumulation during the CEI. Wastewater is generated by the washing of finished parts from the iriditing coating line. All of the wastewater from the iriditing coating line is discharged to the Midwest wastewater pretreatment system. Wastewater pretreatment includes testing and pH adjustment if needed. No sludge is generated during pretreatment. The facility considers wastewater to be nonhazardous based on product and process knowledge. Mr. Britcher estimated the facility generates approximately 1,000,000 gallons of wastewater per year, or approximately 4,000 gallons per day. Pretreated wastewater is discharged to the City of Cedar Rapids POTW under an Industrial Waste Discharge Permit (Attachment 9). I noted no deficiencies related to wastewater during the CEI. General trash consists of nonhazardous production wastes, punctured and drained aerosol cans, packaging wastes, and general office-type refuse. The facility considers general trash to be nonhazardous based on product and process knowledge. The waste is accumulated in roll-off containers outside the facility. General trash is collected by A-1 Disposal and transported to the Linn County Landfill for disposal. I did not observe any deficiencies related to general trash during the CEI. 4. Required Response Equipment and Hazard Management Per 40 CFR 262.15(a)(8) and 262.17(a)(6), a LQG must operate to minimize the possibility of a fire, explosion, or spill, and must maintain emergency response equipment. During the visual inspection, I observed spill response equipment comprised of mats, absorbent materials, shovels, and brooms, as well as the presence and availability of fire extinguishers. I determined that the spill and fire response equipment was adequate for the hazardous wastes generated and accumulated at the facility. 8 5. Container Accumulation Areas Midwest maintains one HWCAA outside of the building adjacent to the paint booth, and another in the Chemical Shed (Attachment 6). I observed one HWAC in the HWCAA adjacent to the paint booth, and 18 HWACs (holding eight drums of waste corrosive liquid, seven drums of WPRM and FWS, and three drums of waste filters) in the Chemical Shed HWCAA. The HWACs in the Chemical Shed HWCAA were on adjacent pallets stacked two containers high, with no minimal space between the pallets or HWACs (Attachment 8, Photographs 9 through 11). I determined the facility failed to maintain adequate aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment as required by 40 CFR 262.17(a)(6)--262.255 (NOPF No. 5). I provided compliance assistance on the management of hazardous waste in a HWCAA. I observed that the eight waste corrosive liquids were on one pallet and the 10 other drums with organic wastes were on another pallet or on the floor, separate from the corrosives. According to Mr. Warren, the HWCAAs are inspected weekly and a log of the inspections is maintained. I reviewed inspection logs for the last 3 years during the CEI and noted no missed inspection weeks. A copy of the inspection log for the week of May 2 through 6, 2022, is included as Attachment 23. However, based on the number of preliminary findings associated with HWACs in the HWCAAs, it appears that the inspections are not adequate. Therefore, I determined the facility failed to conduct adequate weekly inspections as required by 40 CFR 262.17(a)(1)(v) (NOPF No. 7). NOPF No. 7 was not on the NOPF left with the facility but was added on June 3, 2022. Messrs. Warren and Britcher were notified on June 3, 2022 by email and telephone. I asked Mr. Warren how someone would summon emergency assistance if needed. He stated that all employees who handle hazardous waste are required to carry company-supplied cellular telephones. 6. Manifests Midwest generated manifests for 46 hazardous waste shipments from May 23, 2019, to May 23, 2022. During the CEI, I reviewed manifests and LDR notifications for five shipments in 2019, five in 2020, five in 2021, and three in 2022. Copies of the manifests and LDRs for shipments on March 21, 2022, are included in Attachment 16. I noted no deficiencies during my review of manifests. 7. Preparedness and Prevention Plan LQG facilities are required by 40 CFR 262.17(a) to meet the emergency preparedness, prevention, and procedures requirements including documented arrangements with response agencies. According to Mr. Warren, Midwest is the subject of a regular inspection by the Cedar Rapids Fire Department hazardous materials team. During those inspections, he said the fire department is shown the layout of the facility, the location of the hazardous waste HWCAAs, and other facility features. 9 During the CEI, I reviewed the facility's Contingency Plan and noted that Midwest had last updated their contingency plan on February 19, 2018. Mr. Kevin Urban is listed as the emergency coordinator and all pertinent contact information and emergency evacuation procedures were included. During initial review, it appeared that Midwest had not created a Quick Reference Guide as required by 40 CFR 262.17(a)(6)--262.262(b) (NOPF No. 1). As a result of further review before leaving the facility, I rescinded NOPF No.1 as a Quick Reference Guide had been prepared. The Contingency Plan and Quick Reference Guide appeared to meet all content requirements of 40 CFR 262.261 and 262.262. A copy of the Emergency Call List from the Midwest Contingency Plan is included as Attachment 24. 8. Personnel Training Requirements Personnel training is required by LQG regulations specified in 40 CFR 262.17(a)(7) to ensure that employees are thoroughly familiar with proper waste handling procedures relevant to their responsibilities. During the CEI, I asked Mr. Warren if hazardous waste training is provided to employees. He stated that hazardous waste management training is provided to all employees who handle hazardous waste within six weeks of hiring or being assigned to a job that handles hazardous waste. He also stated that annual refresher training is conducted. I asked Mr. Warren who conducts the training. He stated that the training is conducted by Environet Services. I reviewed training records for Messrs. Warren, Britchet, and Bill Lewis for the last three years and noted that no training was conducted in 2020. I asked Mr. Warren why no training was conducted in 2020. He stated that due to COVID-19, they were unable to schedule any training with Environet Services. I determined that the facility had failed to conduct annual training as required by 40 CFR 262.17(a)(7)(iii) (NOPF No. 2). Copies of training documents for Messrs. Warren, Britchet, and Bill Lewis are included in Attachment 25 as examples of the training documentation maintained at the facility. I reviewed the written job descriptions for Messrs. Warren, Britchet, and Bill Lewis and noted that the job descriptions and titles appeared to be adequate. A copy of the Job Description for a Production Manager is included as Attachment 26. 9. Summary of Preliminary Findings In summary, as part of the CEI, I made the following preliminary findings: (1) Failure to prepare a Quick Reference Guide to the RCRA Contingency Plan as required by 40 CFR 262.17(a)(6)--262.262(6) (NOPF No. 1) RESCINDED (2) Failure to train annually for hazardous waste as required by 40 CFR 262.17(a)(7)(iii) (NOPF No. 2) (3) Failure to label a satellite accumulation container with an indication of the nature of the hazard as required by 40 CFR262.15(a)(5)(ii) (NOPF No. 3) (4) Failure to keep a satellite accumulation container closed except when adding or removing waste as required by 40 CFR 262.15(a)(4) (NOPF No. 4) (5) Failure to maintain adequate aisle space in a hazardous waste container accumulation area as required by 40 CFR 262.17(a)(6)--262.255 (NOPF No. 5) 10 (6) Failure to mark a hazardous waste container with an accumulation start date as required by 40 CFR 262.17(a)(5)(i)(c) (NOPF No.6) (7) Failure to have adequate weekly inspections of a Hazardous Waste Container Accumulation Area as required by 40 CFR 262.17(a)(1)(v) (NOPF No. 7) Other than items specifically noted in the narrative, I observed no additional issues. However, further review by EPA may change or add to my findings. Digitally signed by Clifford A. Clifford A. Nelles Nelles _____________________D_a_te_: 2_0_2_2._07_.1_5_0_9_:2_2:_29_-_0_5'_00_' _____ Date:___________________ Clifford A. Nelles, Inspector CLAENE Group Digitally signed by AMBER AMBER WHISNANT WHISNANT _______________________D_a_te_: _20_2_2_.0_7._2_6 _15_:_07_:5_9_-_05_'0_0_' __ Date: ___________________ Amber Whisnant, Section Chief ECAD/CB/RCRA, EPA Region 7 Attachments: 1. Hazardous Waste Site Info Verification Report for Inspector (1 page) 2. Worksheets and Checklist (25 pages) 3. Receipt for Documents and Samples (1 page) 4. Confidentiality Notice (1 page) 5. Notice of Preliminary Findings (1 page) 6. Site Map (1 page) 7. Google Earth Photograph of Facility (1 page) 8. Photographic Documentation (Photolog and 15 Photographs) (11 pages) 9. Industrial Waste Discharge Permit (1 page) 10. 2021 Biennial Report (13 pages) 11. SDS for MIL-PRF-23377K Green (6 pages) 12. SDS for 005-8277-000 Part 1 Black (12 pages) 13. SDS for 005-8277-000 Part II Catalyst (11 pages) 14. SDS for POLANE Reducer-84 (15 pages) 15. SDS for R7K119 Lacquer Thinner (20 pages) 16. Copies of Manifests and LDRs for shipments on March 21, 2022 (7 pages) 17. Copy of Waste Authorization from Hydrite Chemical (1 page) 18. SDS for Xylene (9 pages) 19. SDS for Bonderite M-CR 1500 AERO (6 pages) 20. SDS for ISOPREP 184 (12 pages) 21. SDS for IRIDITE 14-2 (14 pages) 22. Copy of Invoice from Altorfer (1 page) 11 23. Copy of Inspection Log dated May 2-May 6, 2022 (3 pages) 24. Copy of Call Sheet from RCRA Contingency Plan (1 page) 25. Copies of Training Documents for Paul Warren, Scott Britcher, and Bill Lewis (3 pages) 26. Copy of Job Description for Production Manager (3 pages) 12 Attachment 5, Page 1 of 1