Document 9JqnGdeXm8RJnGRzQvbvpkkOL

RCRA Compliance Branch INSPECTION REPORT Inspection Date(s): Facility or Site Name: Facility/Site Physical Location: (City, state, zip code) Mailing address (if different from above): Facility/Site Contact: RCRA ID Number: Inspector: Areeba Khan Supervisor: Derval Thomas 9/14/2023 Inspection Announced: No Utrecht Manufacturing Corp 4014 1st Avenue Building 26 Space 26-5 North Brooklyn, NY 11232 Mardik Sarkissian M.Sarkissian@utrecht.com (718) 687 - 6739 NYR000232637 Production Manager AREEBA KHAN Digitally signed by AREEBA KHAN Date: 2023.11.21 10:50:28 -05'00' DERVAL THOMAS Digitally signed by DERVAL THOMAS Date: 2023.11.20 14:33:42 -05'00' SECTION I - INTRODUCTION Purpose of the Inspection Objective The purpose of the inspection was to perform a Resource Conservation and Recovery Act (RCRA) comprehensive evaluation inspection (CEI) at this facility. The inspection was conducted by EPA RCRA inspector Areeba Khan. Opening Conference EPA Region 2 RCRA inspector Areeba Khan arrived at Utrecht Manufacturing Corp on September 14, 2023, for an unannounced inspection. I was greeted by Mardik Sarkissian the Production Manager at the front door. I presented my credentials to Mr. Sarkissian and informed him that this was an EPA inspection to determine the facility's compliance with RCRA regulations. The scope of the inspection was to conduct a compliance evaluation inspection (CEI). 1 Facility/Site Description Utrecht Manufacturing Company is an art manufacturing company based in Brooklyn, NY. Utrecht Manufacturing Company creates and manufactures art materials. Utrecht Manufacturing Company has two locations in Brooklyn, NY. The facility I went is located in Brooklyn and its address is 4014 1st Avenue. At this location, the facility manufactures provisional art paint. At this facility, Mr. Sarkissian stated the art paint is divided into two sections: oil-based paint and acrylic paint. The acrylic paint does not contain any metal and therefore is considered nonhazardous, while the oil-based paint is hazardous. The oil paint contains chromium, cadmium, and selenium. Mr. Sarkissian explained they do not manufacture any lead paint. Mr. Sarkissian explained that because one paint is hazardous, and the other paint is not; the two types of paint are made in separate containers and tanks to prevent mixtures of hazardous and non-hazardous paint. Hazardous waste is generated from the following: machine cleanout containing the oil-based paint, wrong product paint batch, lab waste, and customer complaint paints. Mr. Sarkissian said the facility makes a hazardous waste determination for each paint batch. He explained that each batch of paint have different ingredients (selenium, chromium, and cadmium) based on the product they are making so for each batch of paint a hazardous waste determination is done. The facility has one central storage area and three satellite accumulation area. The facility uses Veolia as its authorized waste handler. The facility generates universal waste from general upkeep and 5 gallons of used oil every two weeks. All the florescent lamps were changed to LED. Veolia also collects the facility's empty drums. All the wastes (hazardous, non-hazardous, empty, universal waste and used oil) are picked up biweekly by Veolia. After review of the manifest information and statements made by Mr. Sarkissian, the facility was determined to be a Small Quantity Generator (SQG) of hazardous waste at the time of the inspection. The hours of operation are Monday through Friday 7 am to 3:30 pm. At this location, there are 15 employees. SECTION II - OBSERVATIONS Lab Mr. Sarkissian explained the lab generates hazardous waste from quality checks of the paint. Mr. Sarkissian stated that employees poured the hazardous waste into the sink. The sink's drainpipe is connected to a drum located on the opposite side of the wall. At the time of the inspection, the following was observed: One 55 gallon satellite accumulation drum of hazardous waste that was being filled was not labeled. One 55 gallon drum of hazardous waste that was filled, was closed and labeled but had no date. 2 Tank Cleaning Area Mr. Sarkissian explained that after the facility creates the paint. Each tank used to make the paint is cleaned out. Depending on the type of paint, if it contains metals or not, the waste from the tank cleanout is categorized into the drums accordingly. At the time of the inspection, there was no hazardous waste drums. Drum Cleaning Area Mr. Sarkissian explained that after each product drum that is used. The facility would have the drum cleaned out. Depending on the type of paint, if it contains metals or not, the cleanout waste is put into hazardous waste or nonhazardous waste drums accordingly. At the time of the inspection, the following was observed: One 55 gallon drum of liquid hazardous waste in the satellite accumulation area that was labeled and closed. Three 55 gallon drum of solid hazardous in the satellite accumulation area that was labeled and closed. Central Storage Area Mr. Sarkissian stated that the facility has one central storage area that holds all of its wastes (hazardous waste, and non-hazardous waste). In the central storage area, there was a sign labeled central storage area near a phone with no phone numbers of the emergency contacts. There was a fire extinguisher present. At the time of the inspection the following was observed: Three 55 gallon hazardous waste drums that were labeled, dated and closed. Records Review Basic Plan At the time of the inspection, there was a plan in place. Manifests and Land Disposal Restrictions At the time of the inspection, there were manifests record on site. Personnel Training At the time of the inspection, there were records showing the facility's employees were trained. Arrangement with Local Authority 3 At the time of the inspection, the facility only had an arrangement with the local fire department and not with the local police or local hospital. The facility representative stated that they will contact local authorities to make arrangements. SECTION III - AREAS OF CONCERN Regulatory Concerns 1. Pursuant to 6 NYCRR 372.2(a)(8)(i)(a)(2), Containers are marked with the words "Hazardous Waste" and with other words that identify the contents of the containers. At the time of the inspection, there was one 55 gallon drum that contained hazardous waste located in the lab area, that had no label on it. On November 14, 2023, Mr. Sarkissian followed up in an email regarding the area of concerns. Mr. Sarkissian stated: "Yes, we labeled and put date on the drum in the lab area. " 2. Pursuant to 6 NYCRR 372.2(a)(8)(ii), The date upon which each period of accumulation begins is clearly marked and visible for inspection on each container. At the time of the inspection, there was one 55 gallon drum that contained hazardous waste located in the lab area, that had no date on it. On September 14, 2023, Mr. Sarkissian followed up in an email regarding the area of concerns. Mr. Sarkissian stated: "We mark all drum with the date." 3. Pursuant to 6 NYCRR 372.2(a)(8)(iii)(e)(2)(i), The name and phone number of the emergency coordinator must be posted next to the telephone. At the time of the inspection, there was no phone number of the emergency coordinator posted next to the telephone in the central storage area. On September 14, 2023, Mr. Sarkissian followed up in an email regarding the area of concerns. Mr. Sarkissian stated: "We put the sign for Central Storage Area with emergency contact list see the attachment (see figure 1 below)." 4 (Figure 1: Picture of emergency phone number list) 4. Pursuant to 6 NYCRR 373-3.3(g)(1)(i), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (i) arrangements to familiarize police, fire departments and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to and roads inside the facility, and possible evacuation routes. At the time of the inspection, the facility had not made arrangements with the local police department about the type of waste handled at the owner or operator's facility and the potential need for the services. On November 14, 2023, Mr. Robert Markus (Mr. Sarkissian's Supervisor) followed up in an email regarding the area of concerns. Mr. Markus stated: "Please see the attached certified mail receipts for envelopes being sent to the local authorities. I just figured out what you were looking for, so these just went out today, I truly apologize for the delay. Once we have the return receipts we will send those as well." 5. Pursuant to 6 NYCRR 373-3.3(g)(1)(iv), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (iv) arrangements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility. 5 At the time of the inspection, the facility had not made arrangements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility. On November 14, 2023, Mr. Robert Markus (Mr. Sarkissian's Supervisor) followed up in an email regarding the area of concerns. Mr. Markus stated: "Please see the attached certified mail receipts for envelopes being sent to the local authorities. I just figured out what you were looking for, so these just went out today, I truly apologize for the delay. Once we have the return receipts we will send those as well." General Concerns There were no general concerns at the time of the inspection. Closing Conference The closing conference was conducted by EPA inspector Areeba Khan and the facility representative Mardik Sarkissian. Inspector Khan explained to the facility representative the areas of concerns. The facility representative stated that they will follow up and tend to the areas of concern immediately. 6