Document 91mrQvMEgNwjJnpwz63x9RzZV

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/20-21/2022 and 09/29-30/2022 RCRA Compliance Evaluation Inspection RCRA Large Quantity Generator Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Printpack, Inc. Printpack Converting Plant 2005 S Great Southwest Pkwy Grand Prairie, TX 75051 same same Tarrant (972) 641-4424 x41586 Melissa Birt-Gonzales mbirt@printpack.com EHS Manager 1 FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a NSR Permit # 9981 (exp. 2/12/2024) Title V Permit # O1502 (exp. 10/31/2023) EPA ID # TXR000016493 326112 - PLASTICS PACKAGING FILM AND SHEET (INCLUDING LAMINATED) MANUFACTURING n/a Personnel participating in inspection: John Penland EPA R6/ECD-SR Gabriel Salinas EPA R6/ECD-SR Erin Young-Dahl EPA R6/ECD-SR Courtney Newman Texas Commission on Environmental Quality R4 Melissa Birt-Gonzales Printpack Robert A. Cullom Printpack Lead Inspector Sr. Inspector Inspector Environmental Inspector EHS Manager 1 Corporate Environmental Engineer EPA Lead Inspector Signature/Date ERIN YOUNGDAHL Digitally signed by ERIN YOUNGDAHL Date: 2022.11.30 13:48:03 -06'00' John Penland - Lead Inspector Date Supervisor Signature/Date Digitally signed by JEFFREY JEFFREY YURK YURK Date: 2022.12.01 16:01:09 -06'00' Jeff Yurk - Waste Enforcement Section Chief Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Printpack Grand Prairie Converting Facility 09/20-21/2022 and 09/29-30/2022 PURPOSE OF THE INSPECTION On September 20-21 and 29-30, 2022, I, John Penland, conducted an unannounced inspection of the Printpack facility (Printpack) located at 2005 S. Great Southwest Pkwy in Grand Prairie, Texas. The inspection focused on compliance with the Resource Conservation and Recovery Act (RCRA). I was assisted by Environmental Protection Agency inspectors Gabriel Salinas and Erin Young-Dahl, in addition to Texas Commission on Environmental Quality (TCEQ) inspector Courtney Newman. The inspection included a walkthrough of the facility's production process and waste generation and management units as well as a review of facility records related to hazardous waste management. The Printpack facility was targeted for inspection as part of Environmental Justice as well as Regional and National investigation initiatives to evaluate facilities subject to RCRA Subparts AA, BB, and CC regulations, which are related to air emissions from hazardous waste management units. This report serves as documentation of all onsite activities and observations during the inspection of the Printpack facility. A summary of all areas of concern identified during the inspection is provided in Section III. FACILITY DESCRIPTION The Printpack facility was issued the EPA ID # TXR000016493. At the time of the inspection, Printpack was operating as a Large Quantity Generator (LQG) of hazardous waste. The Printpack facility manufactures printed plastic packaging for use in a variety of consumer markets and operates from 8 am - 5 pm Monday through Friday. The facility production operations include a photo etching process and three high-volume printing presses. The photo etching process includes a solvent reclamation unit to recycle the mask removal agent. The printing presses generate a spent solvent that is accumulated in a series of 2 spent solvent tanks prior to reclamation in a distillation unit. The distilled solvent is recycled into the printing process. Distillation column bottoms are accumulated in a third tank. Section II - OBSERVATIONS Gabe Salinas, Erin Young-Dahl, Courtney Newman, and I conducted the onsite inspection during normal business hours from September 20-21 and September 29-30, 2022. The inspection spanned two weeks due to an employee emergency at the facility. During the inspection, the facility was conducting normal operations and all areas of the facility were in use. Throughout the two weeks, we visited each of the facility's waste generation, accumulation, and management areas, and reviewed the facility's operating records pertaining to the facility's RCRA applicability and compliance requirements. 2 Printpack Grand Prairie Converting Facility 09/20-21/2022 and 09/29-30/2022 This section provides an abbreviated description of our daily activities (see Appendix 2). Appendix 1 provides photographs of these observations. Unless otherwise specified, the statements cited in this section reflect those claims made by facility personnel or documents reviewed during the inspection. September 20, 2022 Gabe Salinas, Erin Young-Dahl, Courtney Newman, and I entered the facility at 0940 hrs., where I presented my credentials to Ms. Melissa Birt-Gonzales (EHS Manager 1) and informed her that we were there to conduct an inspection of the facility under the authority of Section 3007 of RCRA. I explained the right of Printpack to assert a Confidential Business Information claim for records requested by the EPA, followed by a presentation of EPA Region 6's Confidentiality Notice (40 C.F.R. Section 2.203). I then facilitated an opening briefing at 1000 hrs. with Melissa Birt-Gonzales, where we discussed the purpose of EPA's inspection: assessment of Printpack's compliance with its requirements under RCRA. Printing Press Area Each of the three printing presses had two 55-gallon drums staged for the satellite accumulation of hazardous waste (Photo 1). One drum of each pair is dedicated to liquid phase ink/solvent waste from the printers, and the other is dedicated to ink- and solvent-contaminated solid media. During the inspection, I observed one funnel with its lid not secured in the closed position, one drum with its lid not secured in the closed position, and one drum with a lid that was incorrectly attached and did not provide a vapor-tight seal (Photos 2 & 3). We observed the satellite accumulation drums were correctly labeled as hazardous waste, though each satellite accumulation area appears designed to exceed the 55-gallon limit for hazardous waste accumulation in a satellite accumulation area. Ink Room The Ink Room houses the ink manufacturing and blending processes. I found this area to be well-marked with all containers in good condition. This area additionally contains the central accumulation area and the separate distillation room. The storage area met aisle spacing requirements. Two 55-gallon drums were staged for the satellite accumulation of hazardous waste from the ink manufacturing and blending processes. One drum is dedicated to excess liquid phase ink/solvent waste from the printers and one drum is dedicated to ink and solvent contaminated solid media. The satellite accumulation area appears designed to exceed the 55-gallon limit for the satellite accumulation of hazardous waste. Distillation Room The distillation room is located within the ink room, near the entrance from the printing press area, and contains a spent solvent distillation unit. The distillation unit is equipped with a dedicated feed tank. At the time of the inspection, the feed tank was not marked as a hazardous waste tank. I observed an open 55-gallon drum of spent solvent next to the tank with one end of a flex hose inserted (Photos 5 & 6). The 3 Printpack Grand Prairie Converting Facility 09/20-21/2022 and 09/29-30/2022 other end of the flex hose connected to the distillation tank. The open spent solvent container was also unlabeled, and no operators were present (Photo 7). I also identified three open-ended lines on the distillation bottoms waste lines, plus one active leak from a line associated with the reclaimed solvent tank (Photo 8). Solvent odors were present in the area. The facility stated line caps are on order. Printpack made a claim of secondary hazardous materials for spent solvent being reclaimed in the distillation area. External Tank Farm Tank 5 Tank 5 receives spent solvent from the printing presses and accumulates it prior to solvent reclamation in the solvent recovery unit. Printpack claims the spent solvent accumulated in Tank 5 is a hazardous secondary material. I identified one open-ended line associated with this tank and noticed the tank was not marked as a hazardous waste tank (Photo 9). Tank 5 had recently experienced a pump failure. While staining was still present, no other indications of the spill remained. After we ended the inspection for the day, Printpack labeled the tank and capped the open-ended line. Tank 6 Tank 6 receives distillation column bottoms from the solvent reclamation still. It was marked as a solvent waste tank but is not marked with the words "Hazardous Waste" (Photo 10). I identified one open-ended line associated with this tank. As I inspected the top of the tank, I noticed solvent odors present. After we ended the inspection for the day, Printpack labeled the tank and capped the openended line. I confirmed this the following day. Photolithography Area The facility has two mask removal units which use solvent to remove the mask agent from printing plates. Each is piped to a single solvent reclamation unit located in the distillation area. At the time of the inspection, I noticed a sorbent boom located underneath one of the two mask removal units that had been placed there in advance of a maintenance activity (Photo 11). Anilox Cleaning Area The facility has an anilox washing unit with an attached solvent tank. We departed the facility at 1230 hrs. 4 September 21, 2022 Printpack Grand Prairie Converting Facility 09/20-21/2022 and 09/29-30/2022 The inspection team and I arrived at the facility at 1230 hrs. and conducted preliminary document review on this day, including a review and discussion of the facility's waste profiles, waste determinations, and air emissions standards and applicability. We departed the facility at approximately 1400 hrs. September 29, 2022 The inspection on this day started at approximately 0920 hrs. On this day, the team and I conducted air emissions monitoring at Tank 6 and in the distillation area. I identified a 20,000 ppm leak at the connection between the flame arrestor and conservation vent for the closed vent system on top of Tank 6 (see 40 C.F.R. 265.1083 (c)(1)). A first attempt at repair was made by Printpack shortly after this leak was detected, and I verified the repair in the afternoon. In lieu of monitoring under Method 21, Printpack applies the alternate screening standard identified in 8.3.3 of Method 21, wherein the formation of bubbles in a soap solution may be used in certain circumstances to identify leaks. We departed the facility at 1530 hrs. Section III - AREAS OF CONCERN I observed multiple instances of unlabeled, open, or unsecured drums containing hazardous waste throughout the satellite accumulation areas and distillation area. Based on EPA's monitoring, an emissions leak from the connection between the flame arrestor and conservation vent on top of Tank 6 was detected with a reading of 20,000 ppm. Based on a CC applicability determination memo provided by the facility, Tank 6 is subject to Subpart CC requirements. Tank inspections are not conducted on the weekends. I observed multiple instances of open lines in the distillation area and in the external tank farm. The dirty solvent tank, Tank 5, and Tank 6 were not labeled as "Hazardous Waste." Training records for RCRA-applicable employees will be reviewed and assessed for their completeness and compliance with LQG training and recordkeeping requirements. Requested a written Subpart BB procedure and diagram of components subject to Subpart BB. None was available depicting piping and ancillary equipment between distillation unit and Tank 6. On September 30, 2022, we conducted a closing conference with Printpack employees Melissa BirtGonzales and Robert Cullom. The conference was held remotely over Microsoft TEAMs. We reviewed the above areas of concern noted during the inspection. 5 Section IV - FOLLOW UP Printpack Grand Prairie Converting Facility 09/20-21/2022 and 09/29-30/2022 Actions taken by Printpack to resolve any areas of concern were documented by the facility with photographs or other documentation medium and submitted to the EPA via a shared OneDrive folder. Any information received from the facility after the inspection was also received in this way. These documents are accessible to the assigned EPA Enforcement Officer as applicable. Section V - LIST OF APPENDICES Appendix 1: Photographs taken 09/20/2022 Appendix 2: Daily Summaries 6 Printpack Grand Prairie Converting Plant 09/20-21 and 09/29-30/2022 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0809.jpg Date of Photo: 09/20/2022 Time: 1108 hrs Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: View of two satellite accumulation containers next to one of the printing presses. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0810.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Closeup of a satellite accumulation drum with an unsecured lid. Time: 1109 hrs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0811.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Closeup of a satellite accumulation drum with an unsecured funnel. Time: 1109 hrs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0812.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: View of equipment leak from piping carrying clean solvent. Time: 1122 hrs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0813.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Overview of solvent reclamation area. Note open dirty solvent drum. Time: 1125 hrs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0814.jpg Date of Photo: 09/20/2022 Time: 1125 hrs Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Closeup of open, unlabeled container that holds dirty solvent. Hose inserted into the drum feeds to the dirty solvent tank for reclamation. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0815.jpg Date of Photo: 09/20/2022 Time: 1125 hrs Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Closeup of dirty solvent tank in the solvent reclamation area. The tank is missing a "Hazardous Waste" marking. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0816.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Open-ended lines in the solvent reclamation area. Time: 1134 hrs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0817.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Open-ended line in piping under Tank 5. Time: 1159 hrs UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0818.jpg Date of Photo: 09/20/2022 Time: 1204 hrs Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: View of Tank 6 label. There are no "Hazardous Waste" markings on the tank. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Printpack Converting Plant City: Grand Prairie County/Parish: Tarrant State: Texas Photo File Name: DSCN0819.jpg Date of Photo: 09/20/2022 Photographer: Gabe Salinas, EPA Inspector Witness: Erin Young-Dahl, EPA Inspector Description: Boom in photolithography area under a mask removal unit. Time: 1216 hrs Printpack Grand Prairie Converting Plant 09/20-21 and 09/29-30/2022 Appendix 2 Daily Summaries Young-Dahl, Erin From: Sent: To: Cc: Subject: Penland, John Tuesday, September 20, 2022 6:35 PM Young-Dahl, Erin; Salinas, Gabriel; Courtney Newman; mbirt@printpack.com Yurk, Jeffrey; Erin Gorman Daily Summary for FY2022 RCRA CEI - Printpack Grand Prairie, TX (TXR000016493) September 20, 2022 All, Here is a summary of my notes from today's inspection. If there are any errors or omissions please let me know. Introduction During the week of September, 2022, I, John Penland, will be conducting an unannounced inspection of the Printpack Grand Prairie Converting facility (Printpack) located at 2006 South Great Southwest Parkway in Grand Prairie, Texas for compliance with the Resource Conservation and Recovery Act (RCRA). I will be assisted on this inspection by Environmental Protection Agency (EPA) inspectors Gabe Salinas and Erin Young-Dahl, and Texas Commission for Environmental Quality (TCEQ) investigator Courtney Newman. The inspection will include walkthroughs of the facility's hazardous waste generation and management units; a review of the facility records related to hazardous waste management; and a specific evaluation of the facility's compliance with the RCRA air pollution control requirements. Purpose The Printpack facility was targeted for inspection as part of an ongoing National Compliance Initiative for air emissions from hazardous waste management units. Inspection Attendees: NAME John Penland Gabe Salinas Erin Young-Dahl Courtney Newman Melissa Gonzales TITLE Sr. Environmental Scientist - Lead Inspector Sr. Environmental Scientist - Asst. Inspector Environmental Scientist - Asst. Inspector Environmental Investigator EHS Manager 1 REPRESENTING US EPA Region 6 US EPA Region 6 US EPA Region 6 TCEQ Region 4 Printpack PHONE 214-665-9717 214-665-8483 214-665-3166 817-588-5809 972-641-4421 ext. 41586 EMAIL Penland.john@epa.gov Salinas.gabriel@epa.gov Youngdahl.erin@epa.gov Courtney.newman@tceq.texas.gov mbirt@printpack.com Daily Summary Initial Entry to the facility - 09:40am Opening meeting start - 10:00am o I presented my credentials to Mrs. Gonzales and informed her that we were there to conduct an inspection of the facility under the authority of section 3007 of the Resource Conservation and Recovery Act 1 o We discussed the authority for the inspection - RCRA Section 3007 - For purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, any person who generates, stores, treats, transports, disposes of, or otherwise handles or has handled hazardous wastes shall, upon request of any officer, employee or representative of the Environmental Protection Agency, duly designated by the Administrator, or upon request of any duly designated officer, employee or representative of a State having an authorized hazardous waste program, furnish information relating to such wastes and permit such person at all reasonable times to have access to, and to copy all records relating to such wastes. For the purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, such officers, employees or representatives are authorized-- (1)to enter at reasonable times any establishment or other place where hazardous wastes are or have been generated, stored, treated, disposed of, or transported from; (2)to inspect and obtain samples from any person of any such wastes and samples of any containers or labeling for such wastes. o We discussed the purpose of EPA's inspection - Assessment of Printpack's compliance with its requirements under RCRA, including, but not limited to, the requirements for: waste determination and counting; waste marking; waste container management; use of the hazardous waste manifest; emergency planning; personnel training; and air pollution control requirements for hazardous waste units. o Discussed the right of Printpack to assert a Confidential Business Information claim for records requested by EPA (see attachment) o Discussed the process for transferring electronic records - EPA has set up a Microsoft OneDrive folder with access limited to the inspection participants ( LINK). o Discussed the inspection process - the inspection will be conducted September 20 through September 23, 2022. The participants will meet at the facility at 9:00am each day to conduct the onsite portion of the inspection and discuss the findings of the ongoing records review. The records review will be conducted by the inspectors independently offsite throughout the week. Daily summaries will be provided by the inspectors at the end of each day to ensure a clear communication of questions and findings. The meeting Friday, September 23, 2022 will be reserved for a closing conference, where EPA will summarize the overall findings of the inspection to that point and provide a plan for concluding any unfinished evaluation. General Facility Process - The Printpack facility manufactures printed plastic packaging for use in a variety of consumer markets. The facility production operations include a photo etching process and three, high-volume printing presses. The photo etching process includes a solvent reclamation unit) to recycle the mask removal agent. The printing presses generate a spent solvent which is accumulated in a series of 2 spent solvent tanks prior to reclamation in a distillation unit. The distilled solvent is recycled into the printing process. Distillation column bottoms are accumulated in a third tank. Initial request for compliance records, including: o Hazardous waste notification form: 8700-12 or equivalent (NOR) o A current Hazardous Waste Contingency Plan including records of distribution o Facility Maps identifying solid waste management units, if available o A facility process Diagram for spent solvent management, if available o Facility waste profiles for any solid waste generated since 2019. Include documentation relevant to the waste determination made for each waste (i.e. analytical reports or documentation to support generator knowledge) o Any Hazardous Waste Manifests since 2019 not previously uploaded to E-manifest o Any currently effective contract or agreement between the facility and any waste management company or TSDF o Facility SOPs related to the generation or management of hazardous waste o RCRA Unit inspection records since 2019 for tanks and container storage areas 2 o Currently effective CAA Title V and NSR permits for hazardous waste management units o Safety Data Sheets for the solvent used in press and anilox cleaning and photoetching Facility Walkthrough o Beginning at approximately 10:45am o Printing press area - We physically inspected the 3 individual presses. Each press has a pair of 55-gallon drums staged for the satellite accumulation of hazardous waste. One drum is dedicated to liquid phase ink/solvent waste from the printers and one drum is dedicated to ink and solvent contaminated solid media. During our inspection of these waste accumulation areas we identified: 1 funnel with its lid not secured in the closed position 1 drum lid with its lid not secured in the closed position 3 drums with open bungs 1 drum lid with its lid not correctly attached to provide a vapor tight seal In general the drums were properly labeled as hazardous waste In general each satellite accumulation area appears designed to exceed the 55-gallon limit for the accumulation of hazardous waste in a satellite accumulation area o Ink Room We physically inspected the <90-day container accumulation area. The area was well marked and each container appeared to be in goof condition and appropriately labeled. Aisle spacing requirements were met A pair of 55-gallon drums was staged for the satellite accumulation of hazardous waste. One drum is dedicated to liquid phase ink/solvent waste from the printers and one drum is dedicated to ink and solvent contaminated solid media. In general the satellite accumulation area appears designed to exceed the 55-gallon limit for the accumulation of hazardous waste in a satellite accumulation area o Distillation Room The Spent Solvent distillation Unit is equipped with a dedicated feed tank. At the time of this inspection the tank was not marked as a hazardous waste tank. An open container of spent solvent was present in this area with a flex hose prepared to empty the container into the distillation feed tank. No operators were present. The open spent solvent container was also unlabeled. We identified 2 open-ended lines on the distillation bottoms pump for the column. We identified one active leak from a line associated with the reclaimed solvent tank. o External Tank Farm Tank 5 receives spent solvent from the printing presses and accumulates it prior to reclamation in the solvent recovery unit. We identified one apparent open-ended line associated with this tank This tank is not marked as a hazardous waste tank The tank had recently experienced a pump failure. While staining was still present, no other indications of the spill remained. Tank 6 receives distillation column bottoms from the solvent reclamation still We identified one open-ended line associated with this tank This tank is marked as a solvent waste tank but is not marked with the words "Hazardous Waste" o Photolithography area The facility has two mask removal units which use solvent to remove the mask agent from printing plates. Each is piped a single solvent reclamation unit located in the distillation area. 3  At the time of this inspection we found sorbent boom located underneath one of the two mask removal units from a prior spill. This spill cleanup residue had been left in place following the repair of the leak. o Anilox Cleaning Area The facility has an anilox washing unit with an attached solvent tank. Daily Wrap up meeting Departed Facility at approximately 12:30pm Topics for discussion on September 21, 2022 o Waste Profile Review o Tank evaluation o A discussion on the applicability of definitions for Universal Wastes and Hazardous Secondary Materials John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 4 Young-Dahl, Erin From: Sent: To: Subject: Attachments: Penland, John Wednesday, September 28, 2022 9:58 PM Salinas, Gabriel; Young-Dahl, Erin; Courtney Newman; Robert Arthur Cullom; Melissa Birt Gonzalez Daily Summary for FY2022 RCRA CEI - Printpack Grand Prairie, TX (TXR000016493) September 21, 2022 cbi form RCRA 2-19-20.pdf All, Here is a summary of my notes from last Wednesday's inspection. If there are any errors or omissions please let me know. Inspection Attendees: NAME TITLE REPRESENTING PHONE John Penland Sr. US EPA Region 6 214-665-9717 Environmental Scientist - Lead Inspector Gabe Salinas Sr. US EPA Region 6 214-665-8483 Environmental Scientist - Asst. Inspector Erin Young-Dahl Environmental US EPA Region 6 214-665-3166 Scientist - Asst. Inspector Courtney Newman Environmental TCEQ Region 4 817-588-5809 Investigator Melissa Gonzales EHS Manager 1 Printpack 972-641-4421 ext. 41586 Robert A. Cullom Corporate Printpack Environmental Engineer EMAIL Penland.john@epa.gov Salinas.gabriel@epa.gov Youngdahl.erin@epa.gov Courtney.newman@tceq.texas.gov mbirt@printpack.com bcullom@printpack.com Daily Summary Inspection start - approximately 9:00am Review of inspection notes from September 20, 2022 o Attached CBI form o Address cited in notes needs street number to be revised to 2005 o Additional operations at the facility are: laminate application and extrusion; product sizing; and warehousing o An additional SAA is used for the management of waste from the application of laminate using solvent based adhesives o The SAA drums located next to the presses did have all bungs caps installed but these were obscured by tape o The leak at the distillation unit was repaired after we identified it. o The boom identified beneath the mask removal machine in the plate manufacturing area was not spill residue but instead had been placed in advance of a maintenance activity. o Printpack has made a claim of hazardous secondary materials for spent solvent being reclaimed in the distillation area and accumulated in Tank 5. See 40 CFR 261.4(a)(23) 1  According to Mr. Cullom appropriate notice has been submitted. Need Copy. o Hazardous waste tanks have been labeled and OELs closed. Air Emissions standards and applicability o In lieu of Monitoring under Method 21, the facility applies the alternate screening standard identified in section 8.3.3 of method 21 o As part of our review we are trying to identify waste determination records for compliance with 40 CFR 261.1083 Initial review of one of the waste profiles appears to record this information inaccurately Inspection End o Inspection ended early due to employee emergency John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2 Young-Dahl, Erin From: Sent: To: Cc: Subject: Penland, John Thursday, September 29, 2022 10:40 PM Young-Dahl, Erin; Salinas, Gabriel; Melissa Birt Gonzalez; Courtney Newman; Robert Arthur Cullom Erin Gorman; Yurk, Jeffrey Daily Summary for FY2022 RCRA CEI - Printpack Grand Prairie, TX (TXR000016493) September 29, 2022 All, Here is a summary of my notes from today's inspection. If there are any errors or omissions please let me know. Inspection Attendees: NAME TITLE REPRESENTING PHONE EMAIL John Penland Sr. US EPA Region 6 214-665-9717 Penland.john@epa.gov Environmental Scientist - Lead Inspector Gabe Salinas Sr. US EPA Region 6 214-665-8483 Salinas.gabriel@epa.gov Environmental Scientist - Asst. Inspector Erin Young-Dahl Environmental US EPA Region 6 214-665-3166 Youngdahl.erin@epa.gov Scientist - Asst. Inspector Courtney Newman Environmental TCEQ Region 4 817-588-5809 Courtney.newman@tceq.texas.gov Investigator Melissa Gonzales EHS Manager 1 Printpack 972-641-4421 mbirt@printpack.com ext. 41586 Robert A. Cullom Corporate Printpack bcullom@printpack.com Environmental Engineer Daily Summary Inspection start - approximately 9:20am Review of inspection notes from September 21, 2022 o Robert Cullom presented a CC applicability determination memo. Requested a copy o Requested Subpart J records for Tank 6 o Requested a written Subpart BB procedure and diagram of components subject to Subpart BB. None available depicting piping and ancillary equipment between distillation unit and tank 6 Air Emissions Monitoring o Visited the distillation area and tank farm to monitor piping and ancillary equipment; and closure devices for the hazardous secondary material and hazardous waste tank systems. o 3 OELs observed on tank bottoms waste lines at the distillation unit. According to Mr. Cullom the line caps are on order. o 20,000ppm leak identified at the connection between the flame arrestor and conservation vent for the closed vent system on tank 6. A first attempt at repair was made shortly after this leak was detected and I verified the repair in the afternoon. 1  Contingency plan o The facility's hazardous waste contingency plan is incorporated in to the facility-wide ERP. o The plan's currently active version dates back to 2018 and does not include an updated list of emergency coordinators. o The plan is currently undergoing revision and will include the quick reference guide required by 40 CFR 262.262 o I have also requested a record of distribution for the contingency plan o The plan will be reviewed in more detail following the conclusion of the onsite portion of the inspection Training Records o Discussed the review standards for the training requirements of 40 CFR 262.17(a)(7) o Requested training records for the following personnel: Jarvis Curley Barry Long Melissa Birt Bill Roper Roni Hartfield Facility Inspection Records o Tank inspections are not conducted on weekends. o Inspectors do not typically inspect the top of the tanks Additional Record requested o Operating records showing a <90-day thru-put for the contents of Tank 6 Departed facility around 1530 John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2