Document 859g5qaLezrOq9LbG7RoBoMao

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 08/17/2022 Announced: No Entry: 9:28 AM (PT) Exit: 11:13 AM (PT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY; WASHINGTON STATE REGULATIONS N/A Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) Contact Information: County: Paneltech International, LLC Paneltech 2999 John Stevens Way Hoquiam, WA 98550 Manufacturing of overlay products using a combination of resin, paper, and other materials. 4 acres Since 1998 46.969462, -123.855145 Same as above Raeanne Wolfley, Environmental Manager rwolfley@paneltechintl.com (360) 538-1480 Grays Harbor Facility/Site Identifier: NAICS: WAH000027813 325211 - Plastics Material and Resin Manufacturing Lead Inspector: Katie Bradshaw KATRINA BRADSHAW Date: 2022.09.21 11:45:50 -07'00' Digitally signed by KATRINA BRADSHAW REGION 10 bradshaw.katrina@epa.gov (206) 553-6318 Peer Review: Matthew Quarterman MATTHEW QUARTERMAN REGION 10 Digitally signed by MATTHEW QUARTERMAN Date: 2022.09.21 13:31:53 -07'00' Supervisor Review: Jen Sullivan Jennifer A Sullivan Date: 2022.09.22 09:59:17 -07'00' Digitally signed by Jennifer A Sullivan REGION 10 Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 6 PANELTECH INTERNATIONAL LLC Inspection Date(s): 08/17/2022 - 08/17/2022 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection conducted pursuant to Washington's federally authorized RCRA regulations found at Washington Administrative Code (WAC) 173-303. The facility was inspected to ensure compliance with standards for hazardous waste generators, universal waste management, and used oil management. The inspection was conducted as part of a Core Program requirement for FY 2022. The facility was also inspected to evaluate compliance with the organic air emissions standards found in 40 CFR Part 265, Subparts AA, BB, and CC, as incorporated by reference into WAC 173-303-690 through -692. The inspection was also conducted as part of the FY 2022 National Compliance Initiative for organic air emissions from RCRA facilities. Prior to arrival at the facility, I performed a calibration and function check on the Toxic Volatile Analyzer (TVA2020), which measures non-specific Volatile Organic Compounds (VOCs) in parts per million (ppm). Attendees Title Name Phone Lead Inspector Environmental Manager Ecology TR Engineer Katie Bradshaw 2065536318 Raeanne Wolfley Imran Khan 3605381480 Stephanie Gase Email Present in Present in Opening Conf. Closing Conf. bradshaw.katrina@epa.gov Yes Yes rwolfley@paneltechintl.com Yes Yes Yes Yes stga461@ecy.wa.gov Yes Yes Opening Conference I, EPA Lead Inspector Katie Bradshaw, and Stephanie Gase, Washington Department of Ecology Toxics Reduction Engineer, arrived at the Paneltech facility at 9:28 AM (PT) on 08/17/2022 for an inspection. I presented my credentials to Raeanne Wolfley, Environmental Manager, and informed her that this was an EPA RCRA inspection. The table above presents all the inspection participants. The inspection team conducted an opening conference at 9:35 AM. Joining us at this time was Raeanne Wolfley, and later, Imran Khan. I explained that we would be inspecting their hazardous waste management activities, gathering information, viewing different areas of the operations, taking photographs, and gathering data from the use of a TVA2020 to detect organic air emissions from hazardous wastes. Unless otherwise noted, the following information was obtained by facility representatives during the inspection. 2 of 6 PANELTECH INTERNATIONAL LLC Inspection Date(s): 08/17/2022 - 08/17/2022 Facility/Site Description According to the 2021 Dangerous Waste Annual Report received by the Department of Ecology on 02/16/2022, the landowner and site operator is listed as Paneltech International, LLC. According to their website (www.paneltechintl.com), the products manufactured at the facility include overlays (medium density, high density, and general purpose), films, saturated media, and FortrexTM. Facility Info Number of employees 55 Weather Conditions Sunny, dry, 70s Operating Hours Monday through Friday, 24 hours per day; some weekends, depending on workload What type of generator facility notified? Large Quantity Generator (LQG) What type of generator facility verified as? LQG, according to Raeanne Wolfley during opening conference Process Description The manufacturing process includes water, methanol, phenol and formaldehyde, which cook 13-18 hours (depending on product type), then pumped into storage tanks. At the wet end department, they pump a certain amount of resin into mix tanks (dyes, pigments, wetting, fentac compounds, etc.), which is then pumped into a run tank. Paper product is then dipped into a pan for saturation. The saturation ovens cure the overlay. In the middle containments, the product is added glue and sometimes additional time in oven (depending on the product). The chiller rolls stop the curing process, and the product is then wound up into a roll, which goes to a sheeter, on a pallet, and shipped off to the customer. Most of the hazardous waste is generated at the wet end. If the facility makes too much, it goes to a tote. The facility has made some process improvements since the last inspection, and they are able to reuse everything in the totes, which has significantly reduced the amount of hazardous waste. However, if shelf life expires, it becomes hazardous waste, and is shipped offsite to a hazardous waste treatment storage and disposal facility (TSDF). The most recent shipment was June 27, 2022, which was approximately 2,500 pounds. Imran Khan said that by the end of the year, with more process improvements, they are hoping to become a medium or small quantity generator. At the time of the inspection, there was no hazardous waste on site, but Raeanne Wolfley said that they still considered themselves to be a large quantity generator and could be generating more hazardous waste soon with current manufacturing processes. The facility has a Title V (Major Source) air permit, which is currently in the renewal process. They also have a National Pollutant Discharge Elimination System (NPDES) permit, which allows discharge into the Hoquiam Publicly Owned Treatment Works (POTW), and an industrial storm water permit issued by the Washington Department of Ecology. Distillate from the resin cooking process is mostly water, but contains trace amounts of phenol and formaldehyde, which is collected into tanks and treated prior to discharge to the sewer system. During the tour, we looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. We also observed the facility's universal waste and used oil management. Specifically, we inspected the following areas of the facility listed below. Only those areas in which we observed areas of concern or noted other pertinent issues are discussed in this inspection report. 3 of 6 PANELTECH INTERNATIONAL LLC Inspection Date(s): 08/17/2022 - 08/17/2022 Building(s) Building/Area/Sub-area A5 Warehouse Process Description Hazardous Waste Central Accumulation Area SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: A5 warehouse Observation #: KB1-OB-001 Contains CBI: No Date: 08/17/2022 Area Of Concern Yes Universal waste did not have accumulation start date. During the inspection, Brent Phillips wrote accumulation date of February 17, 2022, which was later verified. Records Review I reviewed the following records on site: Hazardous waste manifests from 2021 to present Training records for Raeanne Wolfley and Brent Phillips (hazardous waste handler) Contingency Plan 2022 weekly inspections SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: A5 Warehouse KB1-OB-001 Area: Sub-area: Universal waste did not have accumulation start date. During the inspection, Brent Phillips wrote accumulation date of February 17, 2022, which was later verified. Citations: WAC 173-303 SECTION IV - FOLLOW UP I observed no follow up necessary at the time of the inspection. Closing Conference During the closing conference, I told Raeanne Wolfley and Imran Khan that I did not see any areas of concern during the records review. I said that the only area of concern during the tour of the facility was the lack of an accumulation start date on the universal waste, but that was corrected while on site. I explained that I was not making a compliance determination on site, and that any follow up would likely come from a compliance officer. I thanked them for their time and cooperation and departed the facility at 11:13 AM. 4 of 6 PANELTECH INTERNATIONAL LLC Inspection Date(s): 08/17/2022 - 08/17/2022 Communication Log No additional information received by REGION 10 after exiting the Facility on 08/17/2022. SECTION V - EPA METHOD 21 MONITORING ACTIVITIES I used a ThermoFisher Toxic Vapor Analyzer 2020 (TVA2020), designated as TVA SB7986. The EPA TVA2020 response time is approximately five seconds. I sampled the components on the tanks in the resin plant area and did not get any reading above background level of 2 ppm. SECTION VI - LIST OF APPENDICES Photo Log Document Type Field Inspection Notes Document Name Contains Contains Uploaded By CBI PII Date Received Field_Notes_WAH000027813v1.0.pdf No No Katie Bradshaw 08/18/2022 5 of 6 PANELTECH INTERNATIONAL LLC Inspection Date(s): APPENDIX 1: PHOTO LOG 08/17/2022 - 08/17/2022 Contingency Plan page 1 08/17/2022 10:05 AM IMG-20220817100527527129289.jpg Photographer: Katie Bradshaw No CBI No PII Contingency Plan page 2 08/17/2022 10:05 AM IMG-2022081710053853876994.jpg Photographer: Katie Bradshaw No CBI No PII 6 of 6