Document DDoyQJ7dED0MJpxBrwV5g6rMM

Compliance Evaluation Inspection Report Pico Electronics, Inc. Pelham, New York March 24, 2022 Written by: Digitally signed by James James Sullivan Date: 2022.04.29 09:27:50 Sullivan X -04'00' Enforcement Officer ECAD-CAPSB-CAS USEPA R2 Approved by: KATHLEEN X MALONE-BOGUSKY Digitally signed by KATHLEEN MALONE-BOGUSKY Date: 2022.04.29 10:01:10 -04'00' Chief - Compliance Assurance Section ECAD-CAPSB-CAS USEPA R2 1 Pico Electronics CEI Report FY22 This page has intentionally been left blank 2 Pico Electronics CEI Report FY22 COMPLIANCE EVALUATION INSPECTION REPORT U.S. Environmental Protection Agency, Region 2 Enforcement and Compliance Assurance Division 290 Broadway, 21st floor New York, New York 10007-1866 Locational Information: Facility Name: Pico Electronics, Inc. Facility Address: 143 Sparks Ave, Pelham, N.Y. 10803-1837 Latitude & Longitude: 40.909198; -73.81338 Environmental Sensitivity Information: Potential EJ Concerns: Yes (See Appendix B: EJ SCREEN) Potential Flood-Prone Area: Yes (See Appendix C: Flood Map) Sole Source Aquifer: No (See Appendix D: Sole Source Aquifer Map) Sector Information: Federal Facility: No NAICS Code: 423690 - Other Electronic Parts and Equipment Merchant Wholesalers ICIS & other Program ID Codes: FRS ID: 110004527049 RCRA ID: NYR000027359 Date of Inspection: March 24, 2022 Inspector(s): Jim Sullivan Facility Representative(s): Name Title Steve Kapitula Plant Manager Phone 914-738-1400 Email S.Kapitula@picoelectronics.com Updates for EPA Databases: None. 3 Pico Electronics CEI Report FY22 Table of Contents 1. INTRODUCTION..................................................................................................................... 5 2. FACILITY TOUR .................................................................................................................... 5 3. RECORD REVIEW.................................................................................................................. 7 4. REGULATORY CONCERNS ................................................................................................ 8 5. ENVIRONMENTAL ASSISTANCE ...................................................................................... 9 APPENDICES:............................................................................................................................ 10 A: Figures & Photographs ............................................................................................. 10 B: EJ Screen .................................................................................................................... 10 C: FEMA Flood Map...................................................................................................... 10 D: Sole Source Aquifer Map .......................................................................................... 10 4 Pico Electronics CEI Report FY22 1. INTRODUCTION On March 24, 2022, the Region 2 Office of the Environmental Protection Agency (EPA) inspected the Pico Electronics, Inc. facility located at 143 Sparks Ave, Pelham, New York. The purpose of this inspection was to evaluate the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management. The inspection was unannounced. I arrived at Pico Electronics, Inc. ("Pico") facility at approximately 9:00 AM. I was informed that the Plant Manager, Mr. Steve Kapitula, would not be in until around 10:30 AM. I asked if anyone else could help me and the answer from the administrative personnel was that Mr. Kapitula was the only one who could properly take me around and explain the operations. I left the facility to conduct other local inspections and returned at 10:30 AM to meet with Mr. Kapitula. I informed Mr. Kapitula that I had a camera and would likely be taking pictures. Thus, if there were any areas that contained Confidential Business Information, he should let me know prior to my taking the picture. Pico has been at this location since 1994. The building was constructed for ESSO/Exxon in 1953. Pico does not use the entire space and has a couple of tenants in the north building. One of which is Gretchen Scott, LLC, a women's clothes designer, which I encountered having originally entered through the north building. Mr. Kapitula described Pico Electronics as being engaged in the manufacture of miniature transformers, inductors, and converters. The company's website1 lists the main products as ACDC Power Supplies, Audio Transformers, Brick Type DC-DC Converters, Electrical Equivalents, EMI Inductors, High Voltage Power Supplies, Interface Transformers, Industrial/Military DC-DC Converters, Low Profile DC-DC Converters, Miniaturized Power Inductors, Power Inductors, Power Transformers, Pulse Transformers and QPL Transformer MIL PRF 21037/38. When asked about what sectors the company serves, Mr. Kapitula indicated mainly aerospace and that the company has parts that are on the moon and Mars. Through its operations Pico generates one ongoing hazardous waste stream, spent solvent from a vapor degreaser. This waste is shipped in 55-gallon drums to Veolia ES Technical Solutions of Flanders, New Jersey. The rate at which Pico generates hazardous waste indicates that they are a Small Quantity Generator (SQG). 2. FACILITY TOUR Mr. Kapitula and I began the facility tour at the point of hazardous waste generation for the spent vapor degreaser solvent. The unit was a Baron Blakeslee MLR-120 located in the general workspace (See, Photograph #6) where there are dozens of women working on small parts (See, Photographs #1 & #2). Pico has two vapor degreasers, but only one is currently in service. Parts 1 (https://www.picoelectronics.com/) 5 Pico Electronics CEI Report FY22 are taken by employees to the degreaser, placed in a mesh basket and spray-washed with liquid trichlorethylene in a vapor zone of the same solvent (See, Photograph #7). The unit has cooling coils which condense the trichlorethylene vapors and the condensate drips from the coils into small collection gutters that returns the solvent back to service in the degreaser (See, Photograph #8). Every Friday, an employee drains "the dirty side" of the degreaser into a one-gallon plastic container via a spigot at the bottom of the vapor degreasing unit (see, Photograph #9) and takes the container to the hazardous waste storage area for discharge into a 55-gallon drum. The plastic containers that are used for this transfer are repurposed containers that had held some chemical prior and not the more typical dedicated and labeled safety can. They are not conspicuously colored like a lab can or labeled as hazardous waste. It was clear that there have been releases associated with this operation as the floor tiles beneath the spigot were stained and degraded. There were also two (2) pans of what Mr Kapitula called rosin waste on the floor beside the degreaser. One of the pans was clearly acting as containment in case the valve that is part of the spigot started to leak (See, Photograph #9). It was not clear how the rosin waste was removed from the vapor degreaser. Next, we proceeded to the hazardous waste storage area, which is in an attached garage in the back of the building. At that time, there were three 55-gallon drums of spent degreaser solvent being stored (See, Photograph #10). One drum, the one with an accumulation start date of October 26, 2021, was on a spill pallet (See, Photograph #11). The other two drums were on the floor and dated January 12, 2022, and February 15, 2022, respectively (See, Photographs #12 & 13). All the drums were in good condition and closed. There was also a 55-gallon drum of used oil being accumulated (See, Photograph #14). It was on a spill pallet and labeled as "waste oil" instead of the proper labeling of "used oil." There were also four 55-gallon drums that were receiving metals destined for reclamation at Electrum2 in Rahway NJ (See, Photograph #15). The drums were dedicated to collecting nickel, copper, aluminum, and lead for reclamation. There was a no smoking sign; however, the name and telephone number of the emergency coordinator; location of fire extinguishers and spill-control material, and telephone number of the fire department was not posted. Although the position of the fire extinguisher was obvious (i.e., on the wall to the right of the hazardous waste storage). We then reentered the main building and walked toward the north building to get down to the basement. To get to the north building we passed through the work area again. There are numerous stations where cleaning, hand working, and soldering are taking place. Many of these stations have ductwork that is intended to capture any fumes associated with manual parts working or cleaning and to induce the fumes away from the worker. There are also hooded spaces dedicated for specific work (See, Photograph #3 & #5). Soldering waste, such as dross, was encountered along the way (See, Photograph #4). In the northern portion of the basement there were storage areas for raw materials and spare parts. There was some groundwater weeping into the basement and some pipe wrap that may be asbestos (See, Photograph #20). We then went back upstairs and inspected the testing area where there is equipment that simulates the environments that Pico's products may encounter. There was testing equipment from Cincinnati Sub-Zero and Thermotron (See, Photograph #16). 2 (https://electruminc.com/) 6 Pico Electronics CEI Report FY22 After passing through the Engineering Department, from the lobby at the southern end of the building, we walked down to the basement. Besides the lunchroom, this area housed a large machine shop (See, Photographs #17 - #19). This shop is the source of all the scrap metal that doesn't emanate from soldering, such as dross. There were turnings and shavings being collected at all the workstations, as well as floor sweepings. This is also the source of the used oil, as the parts being machined need lubrication (See, Photograph #18). 3. RECORD REVIEW Based on a review of the manifests, Pico is a SQG of hazardous waste. While reviewing the manifests, I did find several that were missing the copy signed by the treatment, storage, and disposal facility (TSDF). These were Manifest Tracking Numbers: #001502624VES (9/14/2020), #001493115VES (1/7/2021), and # 001498989VES (10/31/2019). Mr. Kapitula said he was not sure why the TSDF, Veolia ES Technical Solutions, had not sent them the signed copies, but he would investigate. Veolia also receives Pico's used oil. Pico has replaced its fluorescent lighting with light emitting diodes, so they do not generate universal waste. I asked Mr. Kapitula if there was one employee who served as emergency coordinator and is onsite and on-call in the event of an emergency. He indicated that the alarm system at the facility notifies four key managers, with him being one of them, of emergencies. If the emergency was environmental in nature, like a spill, he would be involved in the response. I then ask if employees with hazardous waste responsibilities had proper training and whether they had been trained in emergency response procedures in case something went wrong while they are carrying out their duties. To this Mr. Kapitula explained that all the employees involved with the vapor degreaser know what they are dealing with. They sign paperwork to that effect as part of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard and that information is kept with the binder of Safety Data Sheets. The employee who has the most hazardous waste responsibility is named Francisco. I asked to see Francisco; however, he could not be located. I asked for some documentation of training for Francisco, so we went back into the work area and reviewed the "Material Safety Data Sheets" binder for the "Potting and Encapsulation" Department. There was a sign-in sheet for "The Training for The Proper Use of Epoxy | Silicone | Chemicals" which had twenty-one (21) attendees, none of which were named Francisco. This training took place April 23, 2011. The binder also had "Vapor Degreaser Cleaning Procedures;" however, these procedures are not tightly followed since during my inspection, one woman was cleaning parts without wearing goggles or waiting the required one-minute before taking the parts out of the degreaser. While taking the plant tour, I noticed that several tags on the fire extinguishers were from 2020. Mr. Kapitula indicated that that had to be an error as he knew the inspection company visited Pico during 2021. He was able to locate an invoice dated October 20, 2021, from the Interstate Fire & Safety Equipment Company of Harrison, New York, so the fire extinguishers are likely up to date. 7 Pico Electronics CEI Report FY22 4. REGULATORY CONCERNS Based on observations made during the inspection and/or a review of records related to the inspection, the following regulatory concerns were identified: REGULATORY, STATUTORY OR PERMIT REFERENCE Pursuant to 6 NYCRR 373-3.3(b), a facility must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil or surface water which could threaten human health or the environment. Pursuant to 6 NYCRR 374-3.2 (d)(4)(i), every container and aboveground used oil tank used to store used oil at a generator facility must be clearly labeled or marked with the words "Used Oil". In addition, every aboveground tank used to store oil at a generator facility must be labeled with the design capacity and working capacity of the tank. Pursuant to 6 NYCRR Part 373-3.9(d)(3), as referenced by 6 NYCRR Part 372.2(a)8(iii)(b), containers holding hazardous waste must be marked with the words "Hazardous Waste" and with other words identifying their contents. Pursuant to 6 NYCRR Part 372.2(a)8(i)(a)(2), a generator may accumulate up to 55-gallons of hazardous waste or one quart of acutely hazardous waste listed in section 371.4(b), (c) and (d)(5) of this Title in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with subparagraph (ii) of this paragraph, provided the generator: FIELD OBSERVATION At the time of the inspection, there was evidence of releases beneath the floor level spigot of the vapor degreaser (See, Photograph #9). At the time of the inspection, the drum of used oil was labeled as "waste oil" (See, Photograph #14). Three drums that were in the 180-day Hazardous Waste Storage Area were lacking words identifying their contents (See, Photograph #10 #13). At the time of the inspection, Pico was using unlabeled containers to collect hazardous waste from the vapor degreaser and transport it to the 180-day Hazardous Waste Storage Area. (2) marks the containers with the words "hazardous waste" and with other words that identify the contents of the containers. Pursuant to 6 NYCRR Part 372.2(a)8(iii)(e)(2), a generator must post the following information next to a telephone where hazardous waste is At the time of the inspection, Pico was missing the required posting of this information at the 180-day Hazardous Waste Storage Area. 8 Pico Electronics CEI Report FY22 REGULATORY, STATUTORY OR PERMIT REFERENCE accumulated: (i) the name and telephone number of the emergency coordinator; (ii) location of fire extinguishers and spill-control material, and if present, fire alarm; and (iii) the telephone number. FIELD OBSERVATION Pursuant to 6 NYCRR Part 372.2(a)8(iii)(e)(3), a generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. Pursuant to 6 NYCRR Part 372.2(c)(1)(i) a generator must keep a copy of each complete manifest document as a record for at least three years from the date the waste was accepted by the initial transporter. At the time of the inspection, Pico was relying on a 2010 sign in sheet related to a training on the proper use of epoxy, silicone, and chemicals to meet this requirement. The sign in sheet did not include the name of the employee with primary hazardous waste management responsibility (i.e., Francisco). At the time of the inspection, Pico did not have copies of manifests signed by the TSDF for the following shipments: Manifest Tracking Numbers: #001502624VES (9/14/2020), #001493115VES (1/7/2021), and # 001498989VES (10/31/2019). 5. ENVIRONMENTAL ASSISTANCE Based on the observations made during the inspection, the facility should consider the following resources to increase their understanding and compliance with applicable environmental requirements and/or go `beyond compliance' to reduce its overall environmental footprint: Review NYSDEC's "Managing Your Hazardous Waste, A GUIDE FOR SMALL BUSINESSES IN NEW YORK," which has an excellent description of the small quantity generator requirements, including a template of what information should be posted in a 180-day hazardous waste storage area on page 18. This publication can be found at: https://www.dec.ny.gov/docs/materials_minerals_pdf/nyshazwasteguide.pdf Review EPA's Small Business Resources Information Sheet for relevant resources to help understand and comply with federal and state environmental laws. In addition, these resources will also help businesses find cost-effective ways to comply through pollution prevention techniques and innovative technologies: https://www.epa.gov/compliance/small-business-resources-information-sheet Bookmark the virtual Hazardous Waste Portal, which catalogs over 800 hazardous waste compliance resources, including guidebooks, fact sheets, reports, checklists, web sites, contacts, and regulations. Various features are available to assist users in finding the best guidance materials and answers to specific questions. https://www.hazwasteportal.org/ 9 Pico Electronics CEI Report FY22 APPENDICES: A: Figures & Photographs B: EJ Screen C: FEMA Flood Map D: Sole Source Aquifer Map 10 Pico Electronics CEI Report FY22 Appendix A Photograph #1 - View of general work area Photograph #2 - View of general work area 11 Pico Electronics CEI Report FY22 Photograph #3 - Hot solder for hand dipping of parts Photograph #4 - Dross from soldering operations 12 Pico Electronics CEI Report FY22 Photograph #5 - Pan of rosin Photograph #6 - Vapor degreaser 13 Pico Electronics CEI Report FY22 Photograph #7 - Work area in vapor degreaser Photograph #8 - Vapor degreaser cooling coils capturing & returning solvent 14 Pico Electronics CEI Report FY22 Photograph #9 - Pans of waste rosin at vapor degreaser Photograph #10 - Hazardous waste storage area 15 Pico Electronics CEI Report FY22 Photograph #11 - Label on drum at hazardous waste storage area Photograph #12 - Label on drum at hazardous waste storage area 16 Pico Electronics CEI Report FY22 Photograph #13 - Label on drum at hazardous waste storage area Photograph #14 - Used oil drum 17 Pico Electronics CEI Report FY22 Photograph #15 - Drums of nickel, copper, aluminum, and lead. Photograph #16 - Product testing area 18 Pico Electronics CEI Report FY22 Photograph #17 - Machine shop in building basement Photograph #18 - Reuse of oil in machine shop 19 Pico Electronics CEI Report FY22 Photograph #19 - Machine shop in building basement Photograph #20 - Parts storage in basement 20 Pico Electronics CEI Report FY22 EJScreen Report (Version 2.0) 1 mile Ring Centered at 40.909296,-73.813566, NEW YORK, EPA Region 2 Approximate Population: 37,061 Input Area (sq. miles): 3.14 Pico Electronics - Appendix B - EJSCREEN Report Selected Variables Environmental Justice Indexes EJ Index for Particulate Matter 2.5 EJ Index for Ozone EJ Index for 2017 Diesel Particulate Matter* EJ Index for 2017 Air Toxics Cancer Risk* EJ Index for 2017 Air Toxics Respiratory HI* EJ Index for Traffic Proximity EJ Index for Lead Paint EJ Index for Superfund Proximity EJ Index for RMP Facility Proximity EJ Index for Hazardous Waste Proximity EJ Index for Underground Storage Tanks EJ Index for Wastewater Discharge State Percentile 68 68 70 69 69 73 73 62 67 66 67 82 EPA Region Percentile 70 70 74 65 66 73 76 57 62 69 68 79 USA Percentile 72 72 84 73 74 81 89 73 69 83 77 87 This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports. April 29, 2022 1/3 EJScreen Report (Version 2.0) 1 mile Ring Centered at 40.909296,-73.813566, NEW YORK, EPA Region 2 Approximate Population: 37,061 Input Area (sq. miles): 3.14 Pico Electronics - Appendix B - EJSCREEN Report Sites reporting to EPA Superfund NPL Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF) April 29, 2022 0 1 2/3 EJScreen Report (Version 2.0) 1 mile Ring Centered at 40.909296,-73.813566, NEW YORK, EPA Region 2 Approximate Population: 37,061 Input Area (sq. miles): 3.14 Pico Electronics - Appendix B - EJSCREEN Report Selected Variables Pollution and Sources Particulate Matter 2.5 (g/m3) Value State %ile in EPA %ile in USA %ile in Avg. State Region EPA Avg. USA Avg. Region 8.81 7.9 70 8.03 70 8.74 55 Ozone (ppb) 43.7 41.6 89 41.8 91 42.6 64 2017 Diesel Particulate Matter* (g/m3) 0.797 0.646 61 0.558 70-80th 0.295 95-100th 2017 Air Toxics Cancer Risk* (lifetime risk per million) 33 29 75 29 80-90th 29 80-90th 2017 Air Toxics Respiratory HI* 0.5 0.39 74 0.37 80-90th 0.36 90-95th Traffic Proximity (daily traffic count/distance to road) 910 870 71 840 73 710 81 Lead Paint (% Pre-1960 Housing) 0.8 0.55 75 0.46 81 0.28 93 Superfund Proximity (site count/km distance) 0.065 0.23 23 0.28 19 0.13 51 RMP Facility Proximity (facility count/km distance) Hazardous Waste Proximity (facility count/km distance) 0.23 0.5 48 3.9 6.2 55 0.62 45 4.9 63 0.75 42 2.2 84 Underground Storage Tanks (count/km2) 2.4 8.1 47 9.3 46 3.9 62 Wastewater Discharge (toxicity-weighted concentration/m distance) DSoecmiooegcroanpohmiciIcnIdnidcaictaotrosrs Demographic Index People of Color 0.025 3.9 64 49% 74% 37% 66 44% 71 2.3 67 41% 62 49% 66 12 76 36% 72 40% 80 Low Income 23% 30% 45 32% 46 31% 41 Unemployment Rate Linguistically Isolated Less Than High School Education 6% 6% 14% 5% 64 8% 62 13% 63 6% 60 14% 58 13% 63 5% 65 5% 76 12% 68 Under Age 5 Over Age 64 6% 15% 6% 56 16% 52 6% 58 16% 51 6% 52 16% 55 *Diesel particular matter, air toxics cancer risk, and air toxics respiratory hazard index are from the EPA's 2017 Air Toxics Data Update, which is the Agency's ongoing, comprehensive evaluation of air toxics in the United States. This effort aims to prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that the air toxics data presented here provide broad estimates of health risks over geographic areas of the country, not definitive risks to specific individuals or locations. Cancer risks and hazard indices from the Air Toxics Data Update are reported to one significant figure and any additional significant figures here are due to rounding. More information on the Air Toxics Data Update can be found at: https://www.epa.gov/haps/airtoxics-data-update. For additional information, see: www.epa.gov/environmentaljustice EJScreen is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJScreen documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJScreen outputs should be supplemented with additional information and local knowledge before taking any action to address potential EJ concerns. April 29, 2022 3/3 Appendix C: Federal Emergency Management Agency (FEMA) 100 Year Flood Zone and EPA's Region 2 Composite Flood Risk Layer Facility Name: Pico Electronics, Inc. The facility is located within a FEMA 100-year flood zone area. The facility is located within a high potential risk area based on the EPA's Region 2 Composite Flood Risk layer. Appendix D: Sole Source Aquifer Map Facility Name: Pico Electronics, Inc. The facility is not located within a Sole Source Aquifer area.