Document 6R3kBVDoNzk34O3vwKgqwVBq9

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 1445 ROSS AVENUE, SUITE 1200 DALLAS, TEXAS 75202-2733 February 21,2019 CERTIFIED MAIL: RETURN RE~EIPT REQUESTED: 7 008 0 IS0 00 0 3 o'IJ/ S J..83 Craig Smethie Plant Manager Henry Company 3802 Miller Park Road Garland, Texas 75042 Re: EPA RCRA Compliance Evaluation Inspection - October 30, 2018; EPA ID# TXR000084812 - Henry Company- Garland, Texas Dear Mr. Smethie, On October 30,2018, the United States Environmental Protection Agency (EPA) conducted an announced Compliance Evaluation Inspection (CEI) at the Henry Company located in Garland, Texas. I would like to thank you for the time and the courtesy you ~d your staff extended to our inspectors. Enclosed, please find a copy of the CEI Report which chronicles the inspection findings. A copy of this CEI Report will be transmitted separately to the Texas Commission on Environmental Quality (TCEQ). Based on the information contained in the enclosed inspection report, EPA will not be pursuing enforcement action under the Resource Conservation and Recovery Act (RCRA). If you have any questions regarding this matter, please contact Mr. Bill Mansfield of my staff at (214) 665-8321 or email to Mansfield.william@epa.gov. Enclosure Sincerely, -17o H. Troy Stuckey Ph.D. Chief Waste Compliance III Section (6EN-H3) Waste Enforcement Branch ec: James Gradney, james.gradney@tceq.texas.gov ec: Casey Grunnet, casey.grunnet@tceq.texas.gov Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Med1a: Regulatory Program(s) 10/30/2018 RCRA Hazardous Waste Company Name: Facility Name: Facility Physical Location: (city, st ate, zip code} Mailing address: (city, state, zip code} County/Parish: Facility Contact: Henry Company Henry Company 3802 Miller Park Road Garland, TX Same Same Dallas Craig Smethie csmethie@henry.com I Plant Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: None None TXR000084812 -- 324122 Asphalt Shingle and Coating Materials Manufacturing None Personnel participating in inspection: Bill Mansfield EPA/6EN-H3 EPA Lead Inspector Signature/Date /~ 2 Bill Mansfield I Inspector .... .__ - . -~ ------ 214-665-8321 Date 02/21/19 Supervisor Signature/Date -;q::;~~ H. Troy"stuckey Ph.D. :2 2(( 1 Date 6ENFORM-019-R7 (2/ 15/2017) 1 Section I-INTRODUCTION Henry Company, LLC Inspection Date 10/30/ 18 ----------euR20S~OXHL~CDILIDL------------------------------------------------------- I, Bill Mansfield, EPA Region 6 inspector, arrived at the Henry Company facility at 9:25AM o n 10/30/18 for an announced inspect ion. I met with Michael De La Cruz/Operations Manager and David Vives/Environmental Healt h and Saf ety Coordinator for an opening conference. I presented my credentials to Michael and told him this was an EPA inspection to determine compliance w it h the Resource Conservat io n and Recovery Act (RCRA). The scope ofthe inspection is a full Compliance Evaluation Inspectio n {CEI). FACILITY DESCRIPTION Henry Company in Garland, Texas is a manufacturing facility that produces asphalt roofing m aterials and coatings. The facility employees approximately 30 people. Section 11- OBSERVATIONS I o bserved tank T58 (Attachment 1, photo 2), which was t he former reused m ineral spirits tank and tank 61 (Attachment 1, photo 1), which is an oil tank. Reused mineral spirits were used to make products in the past, however the facility discontinued the use of reused mineral spirits in 2016 and tan k T58 was empty during the inspection. I then observed 12 totes (Attachment 1, photo 3) containing a bad batch of product awaiting disposal as waste. Michael said t hey use process knowledge to determine the waste is non ~hazardous and provided me with safety data sheets as part of the determination. Michael also said the facility produces a bad batch 3-4 times a year, which consists of 6 to 8, 275-gallon totes each time. I then observed drip buckets that collect asphalt leaks at pum p connections. Michael said when the mat erial in the bucket s is dry, it is disposed of in the trash . During the inspection I reviewed shipping documents for waste and some products coming in to the facility. I also reviewed hazardous waste determinations. Section Ill -AREAS OF CONCERN I observed no areas of concern at the time of the inspect ion. Section IV- FOLLOW UP No information was received by EPA after exiting the Facility on 10/30/18. Section V -LIST OF APPENDICES Appendix 1- Photograph log 2