Document 99n7r4mJj4GXwBqV8ZQBRp7nq
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
08/18/2021 RCRA Hazardous Waste
Custom Building Products, Inc. Custom Building Products, Inc. 1713 109th Street Grand Prairie, TX 75050 --Dallas 972-641-6996 Tim Spencer
Plant Manager
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
NA TX0000116376 NA 32739 - OTHER CONCRETE PRODUCT MANUFACTURING (20 Staff) --
Personnel participating in inspection:
Debra Pandak
EPA Region 6
Inspector
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
DEBRA PANDAK Digitally signed by DEBRA PANDAK DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=DEBRA PANDAK, 0.9.2342.19200300.100.1.1=68001003655850 Date: 2021.08.24 13:53:46 -05'00'
Debra Pandak
JEFFREY
YURK
Digitally signed by JEFFREY YURK DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=JEFFREY YURK, 0.9.2342.19200300.100.1.1=68001003652717 Date: 2021.08.24 11:12:02 -05'00'
Jeff Yurk
8/24/2021 Date
8/24/21 Date
6ENFORM-019-R8.2 (02/12/2020)
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Section I - INTRODUCTION
Custom Building Products Inc.
Inspection Date 08/18/2021
PURPOSE OF THE INSPECTION EPA Region 6 inspector Debra Pandak arrived at Custom Building Products, Inc. at 1:30 pm on 08/18/2021 for an unannounced inspection. I met with Tim Spencer, Plant Manager of Custom Building Products, Inc. (Custom) for an opening conference. I presented my credentials to Mr. Spencer and informed him that this was an EPA inspection to evaluate the facilities compliance with the Resource Conservation and Recovery Act (RCRA) regulations.
The scope of the inspection is a Compliance Evaluation Inspection (CEI) and includes evaluation of the facility's hazardous waste management activities.
FACILITY DESCRIPTION Custom Building Products is North America's industry leader in flooring preparation products and tile and stone installation systems for residential and commercial projects.
The facility is registered as Very Small Quantity Generator (VSQG) since 2003.
Section II - OBSERVATIONS EPA's review of RCRAinfo online records show Custom generates the following hazardous wastes:
Characteristic: D001 D002 D003 D005 D006 D007 D008 D009 D018 D039 Listed Waste: U019 U188
Texas Commission on Environmental Quality (TCEQ) registration data show 27 active wastes registered. TCEQ Annual Waste Summaries (AWS) were also reviewed for hazardous waste generation volumes.
Based on waste generation in 2018, 2019 and 2020, Custom potentially generated quantities of hazardous waste triggering Small Quantity Generator status requirements (greater than 100 kgs/month generation rate).
2018 TCEQ AWS 2019 TCEQ AWS 239 kgs/month 265.5 kgs/month Manifest Data:
3/12/2019 019878456JJK 5/2/2019 020239346JJK 5/2/2019 020239344JJK 1/3/2020 021376434JJK
2/13/2020 016045944JJK 2
2020 TCEQ AWS 129 kgs/month Kgs reported 1814 45 1269 113 317
10/14/2020 021046485JJK 10/14/2020 022083039JJK
11 1088
Custom Building Products Inc.
Inspection Date 08/18/2021
Section III - AREAS OF CONCERN I provided a Notice of Potential Violation and Opportunity to Confer (NOPVOC) letter to Tim Spencer. The NOPVOC identified the following concerns:
Notification - Failure to notify the EPA or authorized state adequately describing the hazardous waste generating activity at the Facility pursuant to Section 3010(a) of RCRA, 42 U.S.C. 6930(a), and the regulation at 30 TAC 335.6.
Hazardous Waste Determination - Failure to accurately characterize solid waste/hazardous waste pursuant to 40 CFR Part 261 Subpart C, 40 CFR Part 262.11.
EPA requested information specific to facility operations and hazardous waste management as part of the NOPVOC letter.
Section IV - FOLLOW UP EPA extended Custom the opportunity to advise the Agency, via a conference call, or in writing via email, of any further information the EPA should consider with respect to the potential violations of the RCRA and the implementing regulations.
Custom has 14 days to notify EPA if interested in participating in an opportunity to confer with the Agency.
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