Document 8ajVjVw7RMk20myk4gb0G8Dy
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 7 Enforcement Division INSPECTION REPORT
05/14/2024 09:59 AM (CT)
Announced: No
05/16/2024 10:45 AM (CT)
Access: Granted
Resource Conservation and Recovery Act (RCRA)
Compliance Evaluation Inspection (CEI)
Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates
University of Kansas Medical Center KSD076274737 3901 Rainbow Blvd Kansas City, KS 66160 Wyandotte Large Quantity Generator (LQG) 541715 and 611310 Medical university that conducts research and development. 39.05726, -94.61181
Permit Number (If Applicable) Not Applicable
Lead Inspector:
Mike Martin
[Signature]
EPA REGION 7
Additional EPA Staff Participating in Inspection:
Name
Name
Koba Butkovich
Koba Butkovich
martin.mike@epa.gov
Name Koba Butkovich
[Date]
Name Koba Butkovich
Supervisor Review: Amber Whisnant
[Signature] AMBER WHISNANT Date: 2024.07.25 13:55:48 -05'00' Digitally signed by AMBER WHISNANT [Date]
EPA REGION 7
whisnant.amber@epa.gov
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
Type of inspection: CEI
At the request of the Enforcement and Compliance Assurance Division, I conducted a RCRA CEI at the University of Kansas Medical Center (KUMC). The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. During the CEI, I collected the information and data necessary to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI. Upon arriving unannounced at KUMC at 9:59 a.m., Mr. Butkovich and I met with Mr. Ryan Lickteig, Director of EHS. We presented him with our EPA credentials and explained the purpose and procedures of the inspection.
Inspection Date(s):
05/14/2024 - 05/16/2024
The CEI consisted of a discussion of facility operations, waste generation, and waste management; a review of waste management records; and a visual inspection of waste generation and management areas (see attachment 1 for the Site Overview).
Mr. Butkovich and I conducted a visual inspection of the following areas at KUMC:
Applegate Energy Center (2nd Floor Tool/Parts Storage Area) Breidenthal Entrepreneur Research Institute (Rooms 1011, 1016 and 2009) Building 25 (Hazardous Waste Storage Area) Delp (Room G076-Key Shop, Universal Waste Storage Area, and Old Paint Storage Area) Easton (Room G010) Hemenway (Rooms G010, G024, 1015, 1015A, 1016, 1023, 1036, 1039, 1052, 1058, 2000, 2004, 2005, 2008, 2016, 2022, 2036, 2039, 2056, 3000, 3001, 3004, 3008, 3010, 3030, 3036, 3038, 3051, 3052, 3056, 4008, 4010, 4012, 4022, 4036, 4050, 4052 and Penthouse) Hixon (Rooms GC01A, G013, 1000, 2000, 3001, 3012 and 4004) Lied (Rooms B015F, B021, B033, G021, G025, 1003, 1009, 1021, 2003, 2007, 2025, 3003 and 3025) Shop Services Facility (Landscaping Department) Smith East (Rooms 1004, 1008, 1016, 2006, 2016, 2019, 3014, 3016, 3017, 4005, 4008, 4010 and 4018) Smith West (Rooms G015 and G017) Support Services Dock Wahl East (Rooms G001B, G002, 1005C, 1005F, 1020C, 1020L, 2005C, 2005F, 2020C, 2020L, 3005C, 3005G, 3005J 3020L, 3036, 4005F, 4005J, 4040L, 5020A, 5020D, 5040, 5044, 5051, 6001 and 6020) Wahl West (Rooms G012-G019, G022, 1001, 1002, 1003, 1027, 2027, 3001, 3011, 3018, 3019, 4003, 4006, 4021, 4023, 5007, 5012, 5021 and 5027) Wesco (Rooms G007, G009, G026 and G026B)
Document photocopies and photographs were collected as inspection documentation (Appendix 1). A total of 49 photographs were collected and a photolog was prepared (Appendix 1). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.1E), unless noted differently. Any authorized Federal regulatory citations noted in this report are adopted by reference in the authorized Kansas regulations.
Attendees Title/Organization Lead Inspector/EPA
Physical Scientist/EPA
Director of Environment Health & Safety/KUMC
Hazardous Materials Coordinator/KUMC
Biohazard Technician/KUMC Assistant Radiation Safety Officer/KUMC Biosafety Officer /KUMC
Name Mike Martin (913) 551-7149 martin.mike@epa.gov Koba Butkovich (913) 551-7674 butkovich.koba@epa.gov Ryan Lickteig (913) 588-5163 rlickteig@kumc.edu Emily Mattwaoshshe (913) 588-5194 emattwaoshshe@kumc.edu Jerry Spring
Genevieve Ojala
Alexander Dekonenko
Opening Conf. Yes
Yes
Yes
No
No No No
Closing Conf. Yes
Yes
Yes
Yes
Yes Yes Yes
Inspection Date(s):
05/14/2024 - 05/16/2024
Occupational Safety Coordinator/KUMC
David Shaw
No
Yes
Radiation Safety Officer/KUMC
Rick Sundell
No
Yes
Director of Facility Operations/KUMC
Ian Saxton
No
Yes
Director of
James Hawthorne
No
Yes
Maintenance/KUMC
Associate Vice Chancellor of Natalie Holick
No
Yes
Integrity/KUMC
Executive Director of
Nathan Culley
No
Yes
R.A.B.S/KUMC
General Counsel/KUMC
Kimberly Gibbens
No
Yes
Director of Engineering & Infrastructure/KUMC
Jeff Gilliland
No
Yes
Associate Director of
Dennis Lyons
No
Yes
Applegate/KUMC
Program Coordinator/KUMC Monique Imair
No
Yes
Industrial Hygienist/KUMC Andrea Mulvenon
No
Yes
Post Doc/KUMC
Raul Neri
No
Yes
Opening Conference
I presented Mr. Lickteig with my EPA credentials and explained the purpose and procedures of the inspection. I next presented him with a copy of RCRA Section 3007(a), which provides inspection authority. I explained my need to collect accurate information and presented them with a copy of Title 18 U.S. Code, Sections 1001 and 1002. He was made aware of their confidentiality rights and was informed that a Confidentiality Notice would be provided at the end of the inspection to make or not to make any confidentiality claims. The CEI focused on RCRA compliance at KUMC and not at the University of Kansas Hospital Authority (EPA ID #KSR000018440, 3901 Rainbow Boulevard - Campus B, Kansas City, Kansas 66160).
KUMC had been last inspected for RCRA compliance on July 19-21, 2011, by the EPA.
During the July 2011 EPA inspection, KUMC was cited for:
1. Failure to conduct a hazardous waste determination. 2. Hazardous waste accumulation container not marked with the accumulation start date. 3. Hazardous waste accumulation container not labeled with the words "Hazardous Waste." 4. Hazardous waste satellite containers not labeled with the words "Hazardous Waste." 5. Hazardous waste satellite container not closed. 6. Weekly hazardous waste inspections not conducted. 7. Used oil storage container not labeled with the words "Used Oil."
According to the Hazardous Waste Site Info Verification Report (Attachment 2), KUMC operates as a LQG of D001-D009, D010, D022, F002, F003, F005, F0027, P005, P012, P105, P106, U002, U003, U028, U031, U044, U080, U112, U117, U122, U123, U154, U174, U188, U201, U211, U219, U236, U239 and U404 hazardous waste. No changes were noted for the Hazardous Waste Site Info Verification Report. From my review of the 20202024 uniform hazardous waste manifests, it appears that KUMC oscillates between a LQG and a Small Quantity
Inspection Date(s):
05/14/2024 - 05/16/2024
Generator (SQG). See attachment 3 for the E-Manifest Spreadsheet. KUMC routinely generates non-acute hazardous waste at the SQG level (220 pounds to 2,200 pounds per calendar month). KUMC generates acute hazardous waste at the LQG level on an infrequent basis (varies based on lab cleanouts). KUMC generated 412 pounds of acute hazardous waste in 2020, 12 pounds in 2021, 340 pounds in 2022, none in 2023 and none so far in 2024. Mr. Lickteig stated that KUMC chose to operate as a LQG due to the generation of greater than 2.2 pounds of acute hazardous waste generated during any given calendar month. KUMC was inspected as a LQG, a small quantity handler, and a used oil generator.
Facility/Site Information
Number of employees Length of Facility at Location Operating Hours
Safety Training Provided to Inspector(s)? Size of Facility What type of generator facility notified and verified as? Weather Conditions
4,000 1920'S 8:00 a.m. to 4:30 p.m., Monday thru Friday - some R&D studies can have extended hours N/A 80 acres LQG
Days 1 - Sunny, Day 2 - Partially Cloudy and Day 3 Sunny
Process Description
KUMC generates numerous hazardous waste streams (flammables, corrosives, reactives, spent solvents, lab pack, etc.) from their research activities. Their lab waste is stored in 500 ml to 4-liter hazardous waste satellite accumulation containers (located inside fume hoods and inside cabinets under fume hoods) at each individual research lab. Full hazardous waste satellite accumulation containers of lab waste are transferred to Building 25 (Hazardous Waste Storage Area) within three days. The hazardous waste remains in Building 25 prior to off-site disposal. The lab waste is disposed by Hertiage Environmental Services (Kansas City, Missouri, Indianapolis, Indiana, and East Liverpool, Ohio) and Veolia ES Technical Solutions (Beaumont, Texas and Menomonee Falls, Wisconsin). See attachment 4 for Lab Listing by Building and see attachment 5 for the Building 25 Inventory. At the time of the CEI, the less than 90-day hazardous waste accumulation containers in Building 25 were in good condition, labeled with the words "Hazardous waste," marked with the date of accumulation and inspected weekly (IMG-20240514114723472365756.jpg, IMG-20240514114728472875484.jpg, IMG20240514114942494273160.jpg, IMG-20240514115130513069738.jpg, IMG-20240514115255525567038.jpg, and IMG-20240514115323532374912.jpg). Mixed waste (waste flammable liquids and radioactive materials) is generated from research activities on-site and is managed under the 40 CFR 266 Subpart N requirements. See attachment 6 for the KDHE Mixed Waste Exemption Letter. The mixed waste is stored in Lied B033 (Mixed Waste Storage Area) until it is decayed, then it is transferred to Building 25 and disposed by Perma-Fix (Gainesville, Florida) (IMG-2024051509494649461290301.jpg). See attachment 7 for the Mixed Waste Inventory. Radioactive waste generated from research activities is stored in Lied B033 and disposed by Bionomics (Oak Ridge, Tennessee).
Inspection Date(s):
05/14/2024 - 05/16/2024
Facility Waste Streams and Management
Waste Description
and Generation
Process Lab Waste
Mixed Waste
Radioactive Waste Animal Waste Universal WasteLamps Universal WasteBatteries Waste Latex Paint Unknown Paint and Aerosol Cans Lead Acid Batteries
Waste Type HW
HW NH NH UW UW SW ND ND
Generation Rate
If HW, list all Waste
Waste
Oldest
codes Determination Amount Accumulation
Method Presently in Start Date
Storage
Waste Disposal Location
Varies (700 to 1,400 pounds per month)
D001-D009, D010, D022, F002, F003, F005, F0027, P005, P012, P105, P106, U002, U003, U028, U031, U044, U080, U112, U117, U122, U123, U154, U174, U188, U201, U211, U219, U236, U239,
U404
Varies
Varies
Varies
NA
Varies
NA
Varies
NA
Process Knowledge
Process Knowledge
Process Knowledge
Process Knowledge
Process Knowledge
19 containers (ml, kg, liters, gallon units)
05/10/2024
Heritage (Kansas City, Missouri, Indianapolis, Indiana, and East Liverpool, Ohio) and Veolia ES Technical Solutions (Beaumont, Texas and Menomonee Falls, Wisconsin)
Five 4-liter containers and one 500 ml container
NA Perma-Fix (Gainesville, Florida
NA Bionomics (Oak Ridge, Tennessee)
NA
NA Stericycle
(Kansas City,
Kansas)
12 boxes
NA Heritage
Varies Varies Varies Varies
NA
Process 48 batteries
NA Heritage
Knowledge and four 5-
gallons pails
NA
Process 4 wooden
NA Allied Waste
Knowledge pallets
(Kansas City,
Kansas)
NA
NA
13 1-gallon
NA NA
pails and 2
aerosol spray
cans
NA
NA
3 batteries
NA NA
Inspection Date(s):
05/14/2024 - 05/16/2024
Waste Description and Generation Process
Used Oil
Waste Type
UO
Scrap Metal
EX
General
SW
Trash
AD = Analytical Data EX = Exempt HW = Hazardous Waste
Generation Rate
If HW, list all Waste
Waste
Oldest Waste
codes Determination Amount AccumulationDisposal
Method Presently in Start Date Location
Storage
Varies
NA
Varies
NA
NA
One 15-
gallon
container
NA
NA
NA
NA
NA
NA
ND = Not Determined SW = Solid Waste UW = Universal Waste
UO = Used Oil
NA NA
NA Twelfth Street Recycling (Kansas City, Missouri)
NA Allied Waste (Kansas City, Kansas)
Buildings - Area of Concern
Building/Area/Sub-area
Delp - Basement
Breidenthal Entrepreneur Research Institute - Room 1016
Hemenway - Rooms 1039, 1058, 2016, 2056, 3036, 4008 and 4036
Support Services Facility
Wahl East - Rooms 2005C, 2020C and 6001
Process Description Universal Waste (UW) Storage Area and Old Paint Storage Area R&D Labs
R&D Labs
Landscaping and Maintenance R&D Labs
Area of Concern (AOC) Yes Yes Yes
Yes Yes
SECTION II - OBSERVATIONS
Building: Delp/Basement - UW Storage Area
Observation #: MM1-OB-004 Date: 05/14/2024
Contains AOC: Yes
Contains CBI: No
Person Interviewed: James Hawthorne
Title: Director of Maintenance Services
Mr. Butkovich and I observed 11 cardboard boxes of UW-lamps. Ten of the 11 boxes of UW-lamps (storing an estimate of 151 total lamps) were open and unlabeled. One box of UW-lamps was closed and labeled with the words "Universal Waste-Lamps." Mr. Hawthorne stated that the universal waste-lamps had been accumulating since March 20, 2024, and staff are provided with UW training.
UW-lamps not stored in a closed container - 40 CFR 273.13(d)(1) (Notice of Preliminary Finding - NOPF 8). UW-lamps not labeled with words "Universal Waste - Lamps," or "Waste Lamps" or "Used Lamps" - 40 CFR 273.14(e) (NOPF 10).
Inspection Date(s):
Photo(s) 1. IMG-202405141323062361674854.jpg 2. IMG-2024051413231523151733788.jpg 3. IMG-2024051413211521151809242.jpg 4. IMG-2024051413264926491705785.jpg 5. IMG-2024051413285828581639483.jpg 6. IMG-202405141329062961869462.jpg
05/14/2024 - 05/16/2024
Building: Delp/Basement - UW Storage Area
Observation #: MM1-OB-005 Date: 05/14/2024
Contains AOC: Yes
Contains CBI: No
Person Interviewed: James Hawthorne
Title: Director of Maintenance Services
Mr. Butkovich and I observed 48 unlabeled UW-batteries stored on a plastic rolling cart. Mr. Hawthorne stated that at the UW-batteries had been accumulating since March 20, 2024.
UW-lamps not labeled with words "Universal Waste - Batteries," or "Waste Batteries" or "Used Batteries" - 40 CFR 273.14(a) (NOPF 9).
Photo(s)
1. IMG-2024051413384238421573431.jpg
Building: Delp/Basement - Old Paint Storage Area
Observation #: MM1-OB-006 Date: 05/14/2024
Contains AOC: Yes
Contains CBI: No
Person Interviewed: James Hawthorne
Title: Director of Maintenance Services
Mr. Butkovich and I observed four wooden pallets storing 47 1-gallon pails of waste paint and 50 5-gallon pails of waste paint. Mr. Hawthorne stated that the waste paint is latex, non-hazardous waste (based on process and product knowledge) and was generated from the cleanout of the Paint Shop. Mr. Hawthorne was not aware of the length of time of accumulation of the waste paint. Thirteen of the 47 1-gallon pails of waste paint were unlabeled and had a rust-like/corroded exterior (including a 4-inch hole on the side of one pail). Mr. Butkovich and I also observed two aerosol spray cans labeled with the word "Bad." I asked Mr. Hawthorne if the 13 unlabeled 1-gallon pails of waste paint and the two aerosol spray cans were hazardous waste. Mr. Hawthorne stated that he did not know. I asked Mr. Hawthorne if he had conducted a hazardous waste determination on the 13 unlabeled 1-gallon pails of waste paint and the two aerosol spray cans. Mr. Hawthorne stated "No."
Failure to conduct a HW determination - 40 CFR 262.11(a) (NOPF 1B).
Photo(s)
1. IMG-2024051413574057401833853.jpg
2. IMG-2024051413564256421918197.jpg
3. IMG-2024051413564756471798860.jpg
4. IMG-202405141400370371909226.jpg
Inspection Date(s):
05/14/2024 - 05/16/2024
Building: Wahl East/Rooms 2005C, 2020C, 6001
Observation #s: MM1-OB-008 MM1-OB-010 MM1-OB-011
Date: 05/14/2024
Contains AOC: Yes Contains CBI: No
Persons Interviewed and Title: Rishi Man - Senior Scientist (Room 2020C) Morgan Cosgrove - Research Assistant (Room 6001) Stephen Parnell - Principal Investigator (Room 6001)
The following HW satellite accumulation containers (SACs) were not labeled with the words "Hazardous Waste":
Wahl East/Room 2005C - One 4-liter SAC of waste formalin (IMG-202405150921052151256246.jpg and IMG-2024051509211721171297510.jpg). Prior to the conclusion of the visual inspection, the SAC was labeled with the words "Hazardous Waste" (IMG-2024051509215121511266061.jpg). NOPF 5B-1
Wahl East/Room 2020C - One 4-liter SAC of waste xylene (IMG-2024051509162816281224355.jpg). Prior to the conclusion of the visual inspection, the SAC was labeled with the words "Hazardous Waste" (IMG2024051509174817481293752.jpg). NOPF 5B-2
Wahl East/Room 6001 - One 4-liter SAC of waste xylene and one open 4-liter SAC of waste formaldehyde (IMG-2024051415401240121575286.jpg). Prior to the conclusion of the visual inspection, both SACs were labeled with the words "Hazardous Waste" and the 4-liter SAC of waste formaldehyde was closed (IMG2024051415405740571592060.jpg). NOPF 5B-3 and NOPF 6.
HW SACs not labeled with the words "Hazardous Waste" - K.A.R. 28-31-262(c)(7) (NOPFs 5B-1, 5B-2, and 5B-3).
HW SAC not closed - 40 CFR 265.173(a) (NOPF 6).
Photo(s) 1. IMG-202405150921052151256246.jpg 2. IMG-2024051509211721171297510.jpg 3. IMG-2024051509215121511266061.jpg 4. IMG-2024051509162816281224355.jpg 5. IMG-2024051509174817481293752.jpg 6. IMG-2024051415401240121575286.jpg 7. IMG-2024051415405740571592060.jpg
Building: Breidenthal Entrepreneur Research Institute/Room 1016
Observation #: MM1-OB-014 Date: 05/15/2024
Contains AOC: Yes
Contains CBI: No
Person Interviewed: Raul Neri
Title: PhD Post Doc/Lab Manager
The following HW SACs were not labeled with the words "Hazardous Waste":
- Breidenthal Entrepreneur Research Institute/Room 1016 - One full 4-liter SAC of waste solvent (IMG202405151101311311698571.jpg) and one full 4-liter SAC of waste solvent (IMG202405151101461461725460.jpg). Prior to the conclusion of the visual inspection, the SACs were labeled with the words "Hazardous Waste" (IMG-20240515110405451698258.jpg and IMG202405151104134131791415.jpg).
Failure to label HW SACs with the words "Hazardous Waste" - K.A.R. 28-31-262(c)(7) (NOPF 5A).
Inspection Date(s):
Photo(s) 1. IMG-202405151101311311698571.jpg 2. IMG-202405151101461461725460.jpg 3. IMG-20240515110405451698258.jpg 4. IMG-202405151104134131791415.jpg
05/14/2024 - 05/16/2024
Building: Support Services Facility/Shop Services Facility (Landscaping)
Observation #: MM1-OB-015 Date: 05/15/2024
Contains AOC: Yes
Contains CBI: No
Person Interviewed: Ian Saxton
Title: Director of Facility Operations/KUMC
Mr. Butkovich and I observed one unlabeled 15-gallon used oil collection container of used oil (the funnel at the top of the container was open and half-full) (IMG-2024051512285428541399348.jpg and IMG2024051512315131511123269.jpg).
Used oil storage container not labeled with the words "Used Oil" - 40 CFR 279.22(c) (NOPF 11).
At the Upper Level Miscellaneous Parts Area, Mr. Butkovich and I observed one open cardboard box storing eleven fluorescent lamps (covered with dust) (IMG-2024051512393739371336748.jpg and IMG2024051512395039501247345.jpg). I asked Mr. Saxon if the fluorescent lamps were waste. Mr. Saxon stated that he did not know. I asked Mr. Saxon if he had conducted a hazardous waste determination on the fluorescent lamps. Mr. Saxon stated "No."
Failure to conduct a HW determination - 40 CFR 262.11(a) (NOPF 1A).
Mr. Butkovich and I observed three lead-acid batteries covered with sawdust on the concrete floor (IMG2024051512425142511461594.jpg). I asked Mr. Saxon if the lead-acid batteries were waste. Mr. Saxon stated that he did not know. I asked Mr. Saxon if he had conducted a hazardous waste determination on the lead-acid batteries. Mr. Saxon stated "No."
Failure to conduct a HW determination - 40 CFR 262.11(a) (NOPF 1C).
Photo(s)
1. IMG-2024051512285428541399348.jpg
2. IMG-2024051512315131511123269.jpg
3. IMG-2024051512393739371336748.jpg
4. IMG-2024051512395039501247345.jpg
5. IMG-2024051512425142511461594.jpg
Inspection Date(s):
05/14/2024 - 05/16/2024
Building: Hemenway/Rooms 1039, 1058, 2016, 2056, 3036, 4008, 4036
Observation #s: MM1-OB-017 MM1-OB-018 MM1-OB-019 MM1-OB-020 MM1-OB-021 MM1-OB-022 MM1-OB-023
Date: 05/15/2024
Contains AOC: Yes
Contains CBI: No
Persons Interviewed and Titles: Tara McQuillan - Graduate Research Assistant (Room 2016) Xiamon Hong - Senior Research Associate (Room 3036) Sireesha Yerrathota - Research Assistant (Room 4008)
Andrew Lutkewitte - Principal Investigator (Room 4008)
The following less than 90-day hazardous waste accumulation containers (HW storage containers) were not marked with the words "Hazardous Waste," not marked with the accumulation start date and not inspected weekly:
Hemenway/Room 2016 - Nine full/unlabeled 500 ml HW storage containers of waste paraformaldehyde (IMG-2024051514275927591209396.jpg). Ms. McQuillian was not aware of the length of time of accumulation of the HW storage containers. Prior to the conclusion of the visual inspection, the HW storage containers were labeled with the words "Hazardous Waste" (IMG202405151433013311198897.jpg). I asked Ms. McQuillian if she conducts inspections on the HW storage containers. Ms. McQuillian stated "No."
HW storage containers not labeled with the words "Hazardous Waste" - 40 CFR 262.34(a)(2) (NOPF 2).
HW storage containers not marked with the accumulation start date - 40 CFR 262.34(a)(3) (NOPF 3).
Weekly HW inspections not conducted - 40 CFR 265.174(a)(3) (NOPF 7B).
More than one waste stream per container was being accumulated in the following satellite accumulation areas:
Hemenway/Room 3036 - One full 1-lter SAC of waste xylene (IMG-2024051513561156112034839.jpg). This SAC was accumulating the same waste stream (waste xylene) in the same satellite accumulation area with one full 700 ml SAC of waste xylene (labeled with the words "Used Xylene"). Ms. Hong that that both SACs had been accumulating for greater than two weeks. NOPF 4A
Hemenway/Room 4008 - One unlabeled full 150 ml SAC of paraformaldehyde (PFA) waste (IMG202405151314081481331046.jpg and IMG-202405151318091891517264.jpg). This SAC was accumulating the same waste stream (PFA waste) in the same satellite accumulation area with one full 250 ml SAC of PFA waste. Ms. Hong was not aware of the length of time of accumulation of the SACs of PFA waste. NOPF 4B
More than one waste stream per container being accumulated in the same satellite accumulation area - K.A.R. 28-31-262(c)(3) (NOPFs 4A and 4B). *NOPFs 4A and 4B were inadvertently cited as 40 CFR 262.34(c)(2) (containers not managed as HW storage containers within three days of no longer meeting the definition of hazardous waste satellite accumulation containers).
The following HW SACs were not labeled with the words "Hazardous Waste":
Hemenway/Room 1039 - One unlabeled full 4-liter SAC of waste acetone (IMG20240515151727172757382.jpg). Prior to the conclusion of the visual inspection, the SAC was labeled with the words "Hazardous Waste" (IMG-20240515151828182859817.jpg). NOPF 5C-1
Inspection Date(s):
05/14/2024 - 05/16/2024
Hemenway/Room 1058 - One unlabeled 4-liter SAC of waste acetone (IMG2024051515072772760155.jpg). Prior to the conclusion of the visual inspection, the SAC was labeled with the words "Hazardous Waste" (IMG-20240515151021102147642.jpg). NOPF 5C-2
Hemenway/Room 2056 - One unlabeled 4-liter SAC of waste xylene and one unlabeled 4-liter SAC of waste formaldehyde (IMG-2024051514423242321209751.jpg). Prior to the conclusion of the visual inspection, the SACs were labeled with the words "Hazardous Waste" (IMG202405151444074471178237.jpg). NOPF 5C-3
Hemenway/Room 3036 - One full 700 ml SAC of waste xylene (labeled with the words "Used Xylene") and one full 1-lter SAC of waste xylene (IMG-2024051513561156112034839.jpg). Prior to the conclusion of the visual inspection, the SACs were labeled with the words "Hazardous Waste" (IMG20240515140102121171769.jpg). NOPF 5C-4a and 5C-4b *NOPF 5C-4b (one full 1-liter SAC of waste xylene) was inadvertently left off the NOPF form.
Hemenway/Room 4008 - One unlabeled full 150 ml SAC of Oil Red O (07/07/24 accumulation date), one full 150 ml SAC of deocalcification waste (04/01/2024 accumulation date), one full 150 ml SAC of PFA waste (02/07/24 accumulation date) and one full 250 ml SAC of PFA waste (03/28/24 accumulation date) (IMG-202405151314081481331046.jpg and IMG-202405151318091891517264.jpg). Prior to the conclusion of the visual inspection, the SACs were labeled with the words "Hazardous Waste" (IMG2024051513243224321187221.jpg). NOPF 5C-5 *The full 250 ml SAC of PFA waste was inadvertently left off the NOPF form. Hemenway/Room 4036 - One unlabeled full 150 ml SAC of hematoxylin waste (IMG2024051513344434441145855.jpg). Prior to the conclusion of the visual inspection, the SAC was labeled with the words "Hazardous Waste" (IMG-2024051513352735271163181.jpg NOPF 5C-6
HW SACs not labeled with the words "Hazardous Waste" - K.A.R. 28-31-262(c)(7) (NOPFs 5C-1, 5C-2, 5C-3, 5C-4a, 5C4b, 5C-5 and 5C-6).
Photo(s)
1. IMG-202405151314081481331046.jpg 2. IMG-202405151318091891517264.jpg 3. IMG-2024051513243224321187221.jpg 4. IMG-2024051513344434441145855.jpg 5. IMG-2024051513352735271163181.jpg 6. IMG-2024051513561156112034839.jpg 7. IMG-20240515140102121171769.jpg 8. IMG-2024051514275927591209396.jpg 9. IMG-202405151433013311198897.jpg 10. IMG-2024051514423242321209751.jpg 11. IMG-202405151444074471178237.jpg 12. IMG-2024051515072772760155.jpg 13. IMG-20240515151021102147642.jpg 14. IMG-20240515151727172757382.jpg 15. IMG-20240515151828182859817.jpg
Inspection Date(s):
05/14/2024 - 05/16/2024
SECTION III - RECORDS REVIEW
Record: Contingency Plan
AOC: No
Ref #: MM1-RR-001 Reviewed By: Mike Martin
Reviewed Date: 05/14/2024
KUMC maintains a contingency plan and it was up to date. See attachment 8 for the Contingency Plan.
Record: Inspections
AOC: Yes
Ref #: MM1-RR-002 Reviewed By: Mike Martin
Reviewed Date: 05/14/2024
Weekly HW inspections are conducted on HW storage containers in Building 25. From my review of the 20202024 weekly HW inspection logs, it appears that KUMC had greater than seven days between weekly inspections in December 2020, 2021, 2022 and 2023. See attachment 9 for the Hazardous Waste Inspection Logs. HW inspections were not conducted during the weeks of 12/20/2020, 12/26/2021, 12/25/2022 and 12/24/2023. I asked Ms. Mattwaoshshe if hazardous waste had been stored in Building 25 during the weeks of 12/20/2020, 12/26/2021, 12/25/2022 and 12/24/2023. She stated `Yes." Ms. Mattwaoshshe stated that the campus was closed during Christmas break 2020-2023 and hazardous waste inspections were conducted during the week prior to and after the Christmas break.
Weekly hazardous waste inspections not conducted - 40 CFR 265.174(a)(3) (NOPF 7A).
Record: Personnel Training
AOC: No
Ref #: MM1-RR-003 Reviewed By: Mike Martin
Reviewed Date: 05/14/2024
Required staff had received appropriate training on hazardous waste management and the training records appeared to be satisfactory.
Record: Manifests and Annual Reports
AOC: No
Ref #: MM1-RR-004 Reviewed By: Mike Martin
Reviewed Date: 05/15/2024
The past three years uniform hazardous waste manifests and annual monitoring reports were on file and appeared to be satisfactory.
SECTION IV - AREAS OF CONCERN
The presentation of Areas of Concern does not constitute a formal compliance determination or violation.
Building: Support Services Facility/Shop Services Facility (Landscaping) MM1-OB-015 Failure to conduct a HW determination on one open cardboard box storing eleven fluorescent lamps - 40 CFR 262.11(a) (NOPF 1A). Building: Delp Basement - Old Paint Storage MM1-0B-006 Failure to conduct a HW determination on 13 unlabeled 1-gallon pails of waste paint and the two aerosol spray cans - 40 CFR 262.11(a) (NOPF 1B). Building: Support Services Facility/Shop Services Facility (Landscaping) MM1-OB-015 Failure to conduct a HW determination on three lead-acid batteries - 40 CFR 262.11(a) (NOPF 1C).
Inspection Date(s):
05/14/2024 - 05/16/2024
Building: Hemenway/Room 2016
MM1-OB-020
Nine 500 ml HW storage containers of waste paraformaldehyde not marked with the words "Hazardous Waste" - 40 CFR 262.34(a)(2) (NOPF 2).
Building: Hemenway/Room 2016
MM1-OB-020
Nine 500 ml HW storage containers of waste paraformaldehyde not marked with the accumulation start date - 40 CFR 262.34(a)(3) (NOPF 3).
Building: Hemenway/Rooms 3036 and 4008
MM1-OB-017 and MM1-OB-019
More than one waste stream per container being accumulated in the same satellite accumulation area - K.A.R. 28-31-262(c)(3) (NOPFs 4A and 4B):
- Hemenway/Room 3036 - One full 1-lter container of waste xylene (NOPF 4A). - Hemenway/Room 4008 - One unlabeled full 150 ml container of PFA waste (NOPF 4B). *NOPFs 4A and 4B were inadvertently cited as 40 CFR 262.34(c)(2) (containers not managed as HW storage containers within three days of no longer meeting the definition of hazardous waste satellite accumulation containers).
Building: Wahl East/Rooms 2005C, 2020C, and Room 6001 Hemenway/Rooms 1039, 1058, 2056, 3034, 4008, and 4036
MM1-OB-008, MM1-OB-010, MM1-OB-011, MM1-OB-014, MM1-OB-017, MM1-OB-018, MM1-OB-019, MMOB-021, MM1-OB-022, and MM1-OB-023
HW SACs not labeled with the words "Hazardous Waste" - K.A.R. 28-31-262(c)(7) (NOPFs 5A, 5B-1, 5B-2, 5B-3, 5C-1, 5C-2, 5C-3, 5C-4a, 5C-4b, 5C-5 and 5C-6):
- Breidenthal Entrepreneur Research Institute/Room 1016 - One full 4-liter SAC of waste solvent and one full 4-liter SAC of waste solvent (NOPF 5A).
- Wahl East/Room 2005C - One 1-liter SAC of waste formalin (NOPF 5B-1). - Wahl East/Room 2020C - One 4-liter SAC of waste xylene (NOPF 5B-2). - Wahl East/Room 6001 - One 4-liter SAC of waste xylene and one open 4-liter SAC of waste formaldehyde
(NOPF 5B-3). - Hemenway/Room 1039 - One unlabeled 2/3 full 4-liter SAC of waste acetone (NOPF 5C-1). - Hemenway/Room 1058 - One unlabeled 4-liter SAC of waste acetone (NOPF 5C-2). - Hemenway/Room 2056 - One unlabeled 4-liter SAC of waste xylene and one unlabeled 4-liter SAC of
waste formaldehyde (NOPF 5C-3). - Hemenway/Room 3036 - One full 700 ml SAC of waste xylene (labeled with the words "Used Xylene")
(NOPF 5C-4a) and one full 1-lter SAC of waste xylene (NOPF 5C-4b). *NOPF 5C-4b was inadvertently left off the NOPF form. - Hemenway/Room 4008 - One unlabeled full 150 ml SAC of Oil Red O, one full 150 ml SAC of deocalcification waste, one full 150 ml SAC of PFA waste and one full 250 ml SAC of PFA waste (NOPF 5C-5). *The full 250 ml SAC of PFA waste was inadvertently left off the NOPF form. - Hemenway/Room 4036 - One unlabeled 1/4 full 150 ml SAC of hematoxylin waste (NOPF 5C-6).
Building: Wahl East/Room 6001
MM1-OB-008
One 1-liter HW SAC of waste formalin not closed - 40 CFR 265.173(a) (NOPF 6).
Inspection Date(s):
05/14/2024 - 05/16/2024
Records: Weekly HW Inspections MM1-RR-002 and MM1-OB-020 Weekly HW inspections not conducted during the weeks of 12/20/2020, 12/26/2021, 12/25/2022 and 12/24/2023 (Building 25) and on nine 500 ml HW storage containers of waste paraformaldehyde (Hemenway 2016) - 40 CFR 265.174 (NOPFs 7a and 7b). Building: Delp Basement - UW Storage Area MM1-OB-004 Ten cardboard boxes of UW-lamps (storing an estimate of 151 total lamps) not stored in closed containers - 40 CFR 273.13(d)(1) (NOPF 8).
Building: Delp Basement - UW Storage Area MM1-OB-005 Forty-eight unlabeled UW-batteries not labeled with words Universal Waste - Batteries," or "Waste Batteries" or "Used Batteries" - 40 CFR 273.14(a) (NOPF 9).
Building: Delp Basement - UW Storage Area MM1-OB-004 Ten carboard boxes of UW-lamps (storing an estimate of 151 total lamps) not labeled with words "Universal Waste - Lamps," or "Waste Lamps" or "Used Lamps" - 40 CFR 273.14(e) (NOPF 10).
Building: Support Services Facility/Shop Services Facility (Landscaping) MM1-OB-015 One unlabeled 15-gallon used oil collection container of used oil (the funnel at the top of the container was open and half-full) not labeled with the words "Used Oil" - 40 CFR 279.22(c) (NOPF 11).
Closing Conference
At the conclusion of the CEI, I summarized my findings and recommendations to Mr. Lickteig, Ms. Mattwaoshshe and other KUMC personnel (see Attachment 10 for the Exit Briefing Attendees List). I provided Mr. Lickteig with a Confidentiality Notice (Attachment 10), a Receipt for Documents and Samples (Attachment 11), and a Notice of Preliminary Findings (Attachment 12), which he signed as acknowledgement of receipt. No confidentiality claims were made by KUMC.
The following inspection documents and compliance assistance handouts were left with KUMC:
Notice Regarding Proprietary/Confidential Business Information (EPA Handout) Confidentiality Notice (Top page of the completed carbonless transfer set) Receipt for Documents and Samples (Top page of the completed carbonless transfer set) NOPF (Top page of the completed carbonless transfer set) Instructions for Responding to an NOPF (EPA Handout) U.S. EPA Small Business Resources (EPA Handout) Hazardous Waste Determinations and Documentation (Kansas Department of Health and Environment -KDHE Technical Guidance Document) Characteristic and Listed Hazardous Wastes (KDHE Technical Guidance Document) Container Management for Hazardous Waste Generators (KDHE Technical Guidance Document) Solvent-Contaminated Wipes (KDHE Technical Guidance Document) Recycling and Disposal of Aerosol Cans (KDHE Technical Guidance Document) Spent Fluorescent Lamps Containing Mercury (KDHE Technical Guidance Document) Used Oil Generators (KDHE Technical Guidance Document)
Inspection Date(s):
05/14/2024 - 05/16/2024
Follow Up No follow-up at the time of the CEI.
Communication Log The following information was received by REGION 7 on/after exiting the Facility on 05/16/2024.
Type Email Email Phone Call
Point of Contact
Job
Description
Title/Organization
Contains PII Date
Ryan Lickteig Director EHS/KUMC
Email to Inspector about NOPF No corrective actions.
05/28/2024 12:56 AM (CT)
Ryan Lickteig Director of EHS/KUMC
NOPF response transmittal to No Inspector.
05/30/2024 11:17 AM (CT)
Emily
Hazardous
Inspector's phone call to Emily No
Mattwaoshshe Materials
regarding confirmation of
Coordinator/KUMC waste venders.
06/12/2024 9:50 AM (CT)
SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted.
SECTION VII - LIST OF APPENDICES
1. Photo Log 2. Report Attachments