Document 6BErw34Y9Rb3q4MgNVxZKQ8RE

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT WRR Environmental Services, Eau Claire, WI Jason Schenandoah, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: WRR Environmental Services (WRR) Facility Location: 5200 Ryder Road, Eau Claire, WI 54701 Date of Inspection: May 2, 2023 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Brittany Cobb, Environmental Engineer Other Attendees: 1. Mark Gasser, Mechanical Engineer, WRR 2. Preston Gingras, Compliance Assistant, WRR 3. Jim Hager, President, WRR 4. Jake Center, Chemical Engineer, WRR 5. Becky Anderson, Director of Compliance, WRR Contact Email Address: andersrl@WRRES.com Purpose of Inspection: Leak Detection and Repair (LDAR) comparative monitoring Facility Type: Waste recycling and management facility Regulations Central to Inspection: National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks at 40 C.F.R. Part 63, Subpart H Facility Name: WRR Environmental Services Facility Location: 5200 Ryder Road, Eau Claire, WI 54701 Date of Inspection: May 2, 2023 Arrival Time: 8:00 am Departure Time: 3:45 pm Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from WRR Personnel unless otherwise noted. Process Description: WRR's facility processes hazardous waste in solvent recovery, solvent recycling, and fuel blending processes and maintains storage operations. Wastes are received by the facility in one of the several truck loadout areas and, after acceptance, are pumped and stored in one of the hazardous waste storage tanks, or sludge tanks. Solvents are recovered from the wastes in thin film evaporation units and solvent distillation columns. Recovered solvent is stored in the facility's product tanks, which will unload recycled solvents into trucks for shipping. The facility also receives wastes that are not suitable for solvent recovery. Many of these wastes are blended into waste fuels for use in cement kilns. Waste blending involves mixing wastes of different energy contents, into a mixture with suitable properties for use as fuel. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA Method 21 (Method 21) measurements were conducted via 1 Toxic Vapor Analyzer (TVA) 2020. Method 21 was conducted in the following facility process areas: F-3*, F-2, R-2, R-4, E23, E-4, LMS, Delta-T, E-1, E-2, E-1 sludge dike, E-2 sludge dike, and product dike. Background measurements of volatile organic compounds (VOC) inside of the process unit building ranged up to 25 parts per million (ppm). A collection container was stored near the R-1 and Delta-T process units. The collection container had a lidded funnel on top it; there was no gasket associated with the funnel lid. One leak was observed at process unit E-23 with tag number E23-198. While inspectors were still onsite, the leak was repaired, and a subsequent Method 21 measurement was taken. A visual leak was detected on a connector in the Delta-T Page 2 of 4 Facility Name: WRR Environmental Services Facility Location: 5200 Ryder Road, Eau Claire, WI 54701 Date of Inspection: May 2, 2023 process unit; there was a repair tag already on the connector because it was detected by WRR personnel prior to the observation. *The process was not operating at the time of measurement Photos and/or Videos: were not taken during the inspection. Field Measurements: were taken during this inspection. Method 21 monitoring observations have been tabulated in Appendix A: Field Measurement Data. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility DIGITAL SIGNATURES JASON Digitally signed by JASON SCHENANDOAH SCHENANDOAH Date: 2023.06.22 Report Author: _____________1_5:_45_:5_6 -_05_'0_0'_____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2023.06.28 _N_a_t_h_a_n_______1_3_:19_:0_7_-0_5'0_0_' _____________ Page 3 of 4 Facility Name: WRR Environmental Services Facility Location: 5200 Ryder Road, Eau Claire, WI 54701 Date of Inspection: May 2, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Field Measurement Data Page 4 of 5 Facility Name: WRR Environmental Services Facility Location: 5200 Ryder Road, Eau Claire, WI 54701 Date of Inspection: May 2, 2023 APPENDIX A: FIELD MEASUREMENT DATA 5/2/2023 Calibration TVA #B37055 Calibration Gas Hydrocarbon TVA 2020 Results (ppm) Concentration (ppmv) Initial Calibration Drift Check 8:00 am 12:25 pm 550 552 554 2,000 1,960 2,012 10,000 10,000 9,900 A total of 603 components were monitored throughout the facility. Equipment Identifier E23-198 Collection container near R1 and Delta-T Leaks Identified Measurement Notes (ppm) 1,350 7,400 Measurement confirmed by WRR personnel; After the component was repaired a measurement of 190 ppm was made by inspectors Page 5 of 5