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RCRA Inspection Report 1) Inspector and Author of Report Laurie Benton DiGaetano, Environmental Engineer RCRA Enforcement Section Chemical Safety and Land Enforcement Branch Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency, Region 4 61 Forsyth Street, S.W. Phone: (404) 562-8948 Atlanta, Georgia 30303 Email: benton-digaetano.laurie@epa.gov 2) Facility Information AkzoNobel Specialty Plastics 1872 Highway 9 Bypass West Lancaster, South Carolina 29720 EPA ID# SCD000608331 3) Responsible Officials Mr. Joe Hinkle, HSE Manager joe.hinkle@akzonobel.com Steve LaBarge, Site Manager steve.labarge@akzonobel.com 4) Inspection Participants Joe Hinkle, AkzoNobel Steve LaBarge, AkzoNobel Tom Richmond, SCDHEC Laurie Benton DiGaetano, USEPA 5) Date of Inspection January 13, 2022 6) Applicable Regulations Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927), South Carolina Hazardous Waste Management Regulations (SCHWMR) R.61-79, 260 through 270, 273, 278, & 279; and 40 Code of Federal Regulation (C.F.R.), Parts 260 - 270, 273, 278, & 279. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near the 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 without having interim status, as required by Section 44-56-60(a)(2) and (b)(3) of the SCHWMA, S.C. Code Ann. 44-56-60(a)(2) and (b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with 25 S.C. Code Ann. Regs. 61-79.262.16(b) or R.61-79.262.17(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 25 S.C. Code Ann. Regs. 61-79.262.15(a)(7) and (8) [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in 25 S.C. Code Ann. Regs. 61-79.262.15(a) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17 [40 C.F.R. 262.17], a large quantity generator may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 44-56-60(a)(2) and (b)(3) of the SCHWMA, S.C. Code Ann. 44-56-60(a)(2) and (b) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in 25 S.C. Code Ann. Regs. 61-79.262.17 [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to 25 S.C. Code Ann. Regs. 61-79.273.9 [40 C.F.R. 273.9], a Small Quantity Handler of Universal Waste (SQHUW) is a universal waste handler who does not accumulate 5,000 kilograms or more total of universal waste (batteries, pesticides, mercury-containing equipment, or lamps, calculated collectively) at any time. 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine AkzoNobel's compliance with the applicable requirements of RCRA and the corresponding SCDHEC regulations. This was an EPA lead inspection. 8) Previous Inspection History SCDHEC has conducted four RCRA compliance evaluation inspections (CEIs) at the subject facility since calendar year 2000. The most recent RCRA CEI was conducted on 06/29/2015, and SCDHEC found apparent violations of RCRA recordkeeping and universal waste management requirements during that inspection. SCDHEC issued a warning letter to AkzoNobel on 07/17/2015, and later verified that the facility had returned to compliance on or before 08/19/2015. 9) Facility Description AkzoNobel is a global paint and coatings company that produces decorative paints, automotive and specialty coatings, industrial coatings, marine, protective and yacht coatings, and powder coatings. The 26-acre subject facility in Lancaster, South Carolina, houses one 100,000 square foot building, which was erected in 1979. AkzoNobel manufactures film coatings from traditional paint manufacturing ingredients using two coating machines and two laminating machines at this location. Operations run 24 hours per day, Monday-Friday using three shifts, and may include an additional one-or-two shifts on Saturdays. The company has approximately 100 employees at this location, and the facility operates under the NAICS codes 326113 for Unlaminated Plastics Film and Sheet (Except Packaging) Manufacturing and 32613 for Laminated Plastics Plate, Sheet (Except Packaging) and Shape Manufacturing. This facility has been operating as a large quantity generator (LQG) of hazardous waste for over thirty years, and first notified under the name Soliant, LLC in 1995. AkzoNobel acquired Soliant, LLC in 2008, and this facility first notified as an LQG under the name AkzoNobel in 2011. The facility most recently notified as an LQG of hazardous waste on 09/28/2021 when Mr. Hinkle was named as the site contact person. The facility has identified the following hazardous waste EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 2 of 19 streams in their quarterly reporting for calendar year 2019: Stream A - D001 / U112 / U159 hazardous waste from a solvent coating cleanup; Stream A High Water - D001 high water hazardous waste solvent from solvent coating cleanup; Stream E - D001 hazardous waste chlorinated solvent from solvent coating cleanup; Stream G - D001 / F001 / F005 hazardous waste rags, filters, gloves etc.; D001 hazardous waste paint related material; D001 Waste Oil; D005 waste barium compounds; and F005 hazardous waste still bottoms. The facility manages hazardous waste satellite accumulation areas (SAAs) in the Mix Room, the Liquid Laboratory, the Film Laboratory, the Color Laboratory, the Mix Room Laboratory and the In-Process Laboratory and one hazardous waste central accumulation area (CAA) in the Drum Storage Area 2. In addition, the facility manages universal waste in the Warehouse and used oil in the Mechanical Room. Methyl ethyl ketone (MEK) and toluene solvents are delivered to the facility in bulk shipments and stored in on-site storage tanks. All other solvents arrive and are stored in 55-gallon drums. The facility does not manage or store hazardous waste in containers larger than 55-gallons. 10) Opening Conference On January 13, 2022, EPA inspector Laurie Benton DiGaetano, accompanied by SCDHEC inspector Tom Richmond, arrived at AkzoNobel at approximately 9:00 a.m. Mr. Joe Hinkle, HSE Manager, immediately received the inspectors. Mr. Hinkle and the inspectors were joined by Mr. Steve LaBarge, Site Manager, for the opening conference. The inspectors introduced themselves, showed their credentials, and explained the purpose of the visit. The inspectors described the anticipated use of equipment (digital camera) during the inspection and provided a request for records. The inspectors discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to the EPA. The company did not assert a business confidentiality claim. The inspection participants also discussed health and safety protocols and required personal protective equipment before Mr. Hinkle and Mr. LaBarge led the inspectors on a tour of the Facility operations. Mr. Hinkle and Mr. LaBarge provided an overview of the facility's history and current operations during the opening conference. The company does not appear to meet the Small Business Regulatory Enforcement Fairness Act's classification of a "small business," which is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. Therefore, the EPA inspector did not provide a copy of the agency's information sheet for small businesses, which can be found at https://www.epa.gov/sites/production/files/2017-06/documents/smallbusinessinfo.pdf. 11) Findings Mix Room SAAs: Employees prepare batch loads of traditional paint manufacturing ingredients using mix tanks in the Mix Room. After mixing and preparation, the batch load is transferred into a portable green vat which is taken to the Coating Line area. The contents of the vat are transferred from the portable green vat into the Coating Line process, and the empty vat is returned to the Mix Room where it is washed and used again. AkzoNobel manages SAAs in the Mix Room for accumulating Stream A - D001 / U112 (Ethyl Acetate) / U159 (MEK) hazardous waste cleanup solvent, Stream A High Water - D001 high EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 3 of 19 water hazardous waste cleanup solvent Stream E - D001 hazardous waste chlorinated cleanup solvent Stream G - D001 / F001 / F005 hazardous waste rags, filters, gloves etc., and F005 hazardous waste still bottoms. Discussions with facility personnel indicated that Stream A hazardous waste includes spent solvents rather than discarded commercial chemical products. In that case, the facility has assigned inaccurate applicable hazardous waste codes to this waste stream. In addition, the facility failed to identify all applicable hazardous waste codes for the Stream A High Water, Stream E and still bottom hazardous waste streams. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.11 [40 C.F.R. 262.11], a person who generates a solid waste, as defined in 25 S.C. Code Ann. Regs. 61-79.261.2 [40 C.F.R. 261.2], must use the steps articulated in 25 S.C. Code Ann. Regs. 6179.262.11 [40 C.F.R. 262.11] to make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. The inspectors observed three SAAs for accumulating Stream G hazardous waste solids in the Mix Room: one near the CMX-200 Tank Washer (Photo 1), one in the far corner of the room (Photo 2), and one in the middle of the room (Photo 3). One 55-gallon drum with a flip-top lid was observed in each SAA. The lid on the container near the middle of the room was damaged and left a partial gap between the lid and the top of the drum. The container in the CMX-200 Tank Washer SAA was labeled for accumulating hazardous waste solid filters; the container in the corner SAA was labeled for accumulating hazardous waste solid chips; and the container in the middle SAA was labeled for accumulating hazardous waste solids. All of the containers were marked with a flammable solid DOT hazard placard, but none were marked with an indication that the contents are toxic. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(4) [40 C.F.R. 262.15(a)(4)], which is a condition of the SAA Permit Exemption, a generator is required to keep containers of hazardous waste closed at all times during accumulation, except when adding, removing, or consolidating waste; or when temporary venting of a container is necessary for the proper operation of equipment, or to prevent dangerous situations, such as build-up of extreme pressure. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that all damaged lids have been discarded and replaced with a new lid and provided a photograph documenting an example of the new lids. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. The facility manages another SAA for accumulating Stream A hazardous waste MEK near the CMS-2000 Tank Washer in the Mix Room (Photo 4). Facility personnel explained that MEK is used in the CMX-200 Tank Washer to clean green vats for reuse on-site. All spent solvents leaving the CMX-200 Tank Washer are accumulated in the associated rinse tank, where they are stored and then recirculated through the system for use during the initial vat wash cycle(s). The vat's final rinse is done using virgin MEK solvent. When the rinse tank fills, spent solvents are EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 4 of 19 drained from the tank into a 55-gallon drum in this SAA. The inspectors observed one 55-gallon drum in this SAA. The drum was closed and labeled hazardous waste Stream A MEK. It was also marked with a flammable liquid DOT hazard placard, but it was not marked with an indication that the contents are toxic. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. The facility recycles spent MEK solvent in an on-site distillation system in the Mix Room. Personnel explained that the system is loaded with spent MEK solvent from a 55-gallon drum. The unit recycles spent solvents into clean solvent, which is used for cleaning activities onsite, and it generates hazardous waste still bottoms, which are accumulated in the Distillation Unit SAA. The distillation unit was not in operation at the time of the inspection, and the inspectors did not observe a hazardous waste container in this SAA. Although the facility had not identified the Mix Room as a CAA for managing hazardous waste at the time of the inspection, personnel stated that hazardous wastes generated in the Liquid Laboratory, the Film Laboratory, the Color Laboratory, the Mix Room Laboratory and the InProcess Laboratory are all brought to the Mix Room for consolidation into 55-gallon drums. This process, known as "satellite-to-satellite" transfer, is not listed as one of the conditions in the SAA Permit Exemption. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near the 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 without having interim status, as required by Section 44-5660(a)(2) and (b)(3) of the SCHWMA, S.C. Code Ann. 44-56-60(a)(2) and (b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with 25 S.C. Code Ann. Regs. 61-79.262.16(b) or R.61-79.262.17(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 25 S.C. Code Ann. Regs. 61-79.262.15(a)(7) and (8) [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the conditions listed in the SAA Permit Exemption. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the facility has reclassified the Mix Room as a hazardous waste CAA. In addition to the containers observed in the SAAs noted above, the inspectors also observed approximately ten 55-gallon drums of hazardous waste on portable secondary containment pallets lined up near the Distillation Unit (Photos 5 and 6) and six 55-gallon drums of hazardous waste on portable secondary containment pallets near the middle of the room (Photos 7, 8, and 9). The first set of ten 55-gallon drums were labeled as: Stream G - hazardous waste filters with a flammable solid DOT hazard placard and dated 12/28/2021 EPA-RCRA CEI Report Page 5 of 19 AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Stream A - hazardous waste with a flammable liquid DOT hazard placard and dated 01/13/2022 Stream A - hazardous waste with a flammable liquid DOT hazard placard and dated 12/27/2021 Stream G - hazardous waste filters with a flammable solid DOT hazard placard and dated 01/07/2022 Steel drum identical to the hazardous waste drums in this area, but with no label Fiber drum with no label Stream G - hazardous waste filters with a flammable solid DOT hazard placard and dated 01/13/2022 Stream G - hazardous waste filters with a flammable solid DOT hazard placard and dated 01/13/2022 Stream G - hazardous waste filters with a flammable solid DOT hazard placard and dated 01/13/2022 Stream A - hazardous waste with a flammable liquid DOT hazard placard without a visible accumulation start date. None of these containers were marked with an indication that the contents are toxic. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(6)(i) and (ii) [40 C.F.R. 262.15(a)(6)(i) and (ii)], a generator who accumulates an excess of 55-gallons of hazardous waste at or near any point of generation must comply within three consecutive calendar days with the applicable CAA regulations or remove the excess form the SAA within three consecutive calendar days to either a CAA, an on-site interim status or permitted treatment, storage, or disposal facility, or an off-site designated facility. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(6)(iii) [40 C.F.R. 262.15(a)(6)(iii)], the generator must mark or label the container(s) holding the excess accumulation of hazardous waste with the date the excess amount began accumulating and continue to comply with the requirements of the SAA Permit Exemption during the three-consecutive-calendar-day period. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the facility has reclassified the Mix Room as a hazardous waste CAA. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. Facility personnel stated that six additional 55-gallon drums, located on another set of portable secondary containment pallets, contained hazardous waste. One of these drums was labeled hazardous waste and marked with a flammable liquid DOT hazard placard (Photo 7). Another was not labeled as hazardous waste but was marked with a flammable liquid DOT hazard placard (Photo 7). Three of these drums were not labeled as hazardous waste or marked with an indication of the hazards of their contents (Photos 7 and 8). The final drum was not labeled as hazardous waste, but it was marked with an NFPA fire diamond (Photo 9). However, the ink had run on this label, causing the values marked on the NFPA fire diamond to be illegible. None of these containers were marked with an indication that the contents are toxic. EPA-RCRA CEI Report Page 6 of 19 AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5) [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers (i) with the words "Hazardous Waste" and (ii) with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the Mix Room has been reclassified as a hazardous waste CAA, and that containers in the Mix Room have been labeled as hazardous waste and with an indication that the contents are flammable. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(6)(i) and (ii) [40 C.F.R. 262.15(a)(6)(i) and (ii)], a generator who accumulates an excess of 55-gallons of hazardous waste at or near any point of generation must comply within three consecutive calendar days with the applicable CAA regulations or remove the excess form the SAA within three consecutive calendar days to either a CAA, an on-site interim status or permitted treatment, storage, or disposal facility, or an off-site designated facility. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(6)(iii) [40 C.F.R. 262.15(a)(6)(iii)], the generator must mark or label the container(s) holding the excess accumulation of hazardous waste with the date the excess amount began accumulating and continue to comply with the requirements of the SAA Permit Exemption during the three-consecutive-calendar-day period. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and EPA in which he stated that the facility has reclassified the Mix Room as a hazardous waste CAA. In addition, the inspectors observed hazardous waste liquid inside the portable secondary containment pallet (Photo 10). As a result, the secondary containment pallet appeared to be a container holding hazardous waste at the time of the inspection, and that container was neither closed nor labeled. Personnel stated that this material will be mopped up with rags when the drums are sent off-site for disposal. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(4) [40 C.F.R. 262.15(a)(4)], which is a condition of the SAA Permit Exemption, a generator is required to keep containers of hazardous waste closed at all times during accumulation, except when adding, removing, or consolidating waste; or when temporary venting of a container is necessary for the proper operation of equipment, or to prevent dangerous situations, such as build-up of extreme pressure. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5) [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers (i) with the words "Hazardous Waste" and (ii) with an indication of the hazards of the contents. Coating Lines: AkzoNobel operates two coating lines within a clean-room environment at the facility. Once the material created in the Mix Room has been transferred from the portable green vat into the Coating Line process, the empty vat is returned to the Mix Room where it is washed and used again. Facility personnel stated that no hazardous waste is generated during the coating EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 7 of 19 process, and any cleaning solvents used in this area are either volatilized into the air handling system or returned to the Mix Room for accumulation and further management. Lamination Machines: AkzoNobel operates two lamination machines within a second cleanroom environment at the facility. Facility personnel stated that no chemicals are used in this process and no hazardous waste is generated in this area. Slitter Area: The final product is cut into the desired size in the Slitting Area before it is prepared for shipment to the customer. No hazardous waste is generated in this area. Liquid Laboratory SAAs: AkzoNobel manages one SAA in the Liquid Laboratory for accumulating hazardous waste Stream A High Water that is generated as excess sample material. The inspectors observed one basin container in this SAA (Photo 11). The container was located at the end of a laboratory bench, and it was equipped with a step-activated lid. Emissions from the solvent waste are captured by an air handling system that is connected to the basin lid. The basin was labeled "hazardous waste," but it was not marked with an indication of the hazards of its contents. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he indicated that the facility has labeled each container in the SAAs with an indication that the contents are flammable. When the lid of the basin was opened, the inspectors observed one 5-gallon bucket inside the basin. The bucket contained excess sampling material, which is managed as hazardous waste Stream A High Water. Personnel explained that a lid is crimped onto the bucket when it becomes full, so that the bucket may be carried to the Mix Room and its contents may be emptied into another 55-gallon drum in the Mix Room. This practice is referred to as "satellite-to-satellite transfer," and was discussed in the Mix Room Section of this report. AkzoNobel manages a second SAA in the Liquid Laboratory for accumulating hazardous waste Stream G that is generated as used rags, wipes, cups, and solids contaminated with solvents. The inspectors observed six 14-gallon step-to-open flammable cans in this SAA (Photo 12). Each of these cans was labeled as "Stream G hazardous waste solids," but none were marked with an indication of the hazardous of its contents. In addition, the original "oily rags" and "empty every night" labels, which did not apply to the containers, were still visible. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and EPA in which he stated that the facility has labeled each can of Stream G hazardous waste solids as hazardous waste EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 8 of 19 and flammable solids and has covered all oily waste labels so that they are no longer visible. Although it did not appear that the facility had exceeded 55-gallons of waste in this SAA, please note that the six 14-gallon step-to-open flammable cans have a combined capacity of 84 gallons, which is well over the limit of 55-gallons of hazardous waste in a SAA. The inspectors observed a sign on the cans which read, "empty by end of shift Friday or when full." The facility must create a standard operating procedure to ensure that the appropriate steps are taken if or when the total volume of hazardous waste in this SAA reaches 55 gallons. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that some of the red waste containers were removed from this laboratory, and the total capacity of the remaining containers is less than 55-gallons. Personnel explained that the Stream G hazardous waste solids that are accumulated in this SAA along with the spray booth filters and contaminated foil is also brought to the Mix Room SAA. This practice is referred to as "satellite-to-satellite transfer," and was discussed in the Mix Room Section of this report. Film Laboratory SAAs: AkzoNobel manages one SAA in the Film Laboratory for accumulating Stream A hazardous waste liquids. The inspectors observed one 2-gallon container in this SAA (Photo 13). The container was located under a laboratory hood. It was labeled as hazardous waste and marked with a National Fire Protection Association (NFPA) fire diamond. However, the numbers marked on the fire diamond had smudged off and were no longer legible. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the facility has labeled each can of Stream G hazardous waste solids as hazardous waste and flammable solids and has covered all oily waste labels so that they are no longer visible. The facility manages a second SAA in the Film Laboratory for accumulating Stream G that is generated as used rags, wipes, cups, and solids contaminated with solvents. The inspectors observed four 14-gallon step-to-open flammable cans in this SAA (Photo 14). The cans were not labeled as hazardous waste or marked with an indication of the hazardous of their contents. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5) [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers (i) with the words "Hazardous Waste" and (ii) with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the facility has labeled each can of Stream G hazardous waste solids as hazardous waste and flammable solids and has covered all oily waste labels so that they are no EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 9 of 19 longer visible. Personnel explained that the Stream A and Stream G hazardous wastes that are accumulated in the Film Laboratory SAAs are brought to the Mix Room where they are placed into containers in the Mix Room SAAs. This practice is referred to as "satellite-to-satellite transfer," and was discussed in the Mix Room Section of this report. Color Laboratory SAAs: AkzoNobel manages one SAA in the Color Laboratory for accumulating Stream A High Water hazardous waste liquids. The inspectors observed one 5gallon container in this SAA (Photo 15). The container was located on a laboratory bench. It was labeled as hazardous waste MEK acrylic fluorex and marked with an NFPA fire diamond. The facility manages a second SAA in the Color Laboratory for accumulating Stream G that is generated as used rags, wipes, cups, and solids contaminated with solvents. The inspectors observed two 14-gallon step-to-open flammable cans in this SAA (Photo 16). The cans were not labeled as hazardous waste or marked with an indication of the hazardous of their contents. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5) [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers (i) with the words "Hazardous Waste" and (ii) with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the facility has labeled each can of Stream G hazardous waste solids as hazardous waste and flammable solids and has covered all oily waste labels so that they are no longer visible. Personnel explained that the Stream A and Stream G hazardous wastes that are accumulated in the Color Laboratory SAAs are brought to the Mix Room where they are placed into containers in the Mix Room SAAs. This practice is referred to as "satellite-to-satellite transfer," and was discussed in the Mix Room Section of this report. Mix Room Laboratory SAA: Laboratory testing to evaluate paint mixture parameters such as viscosity and color is performed in the Mix Room Laboratory. The facility manages one SAA in the Mix Room Laboratory for accumulating Stream G that is generated as used rags, wipes, cups, and solids contaminated with solvents. The inspectors observed one 30-gallon step-to-open flammable cans in this SAA (Photo 17). The can was labeled as hazardous waste. It was also identified as containing a flammable solid, but it was not marked with an indication that the contents are toxic. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. Personnel explained that the hazardous waste that is accumulated in the Mix Room Laboratory SAA is brought to the Mix Room where it is placed into containers in the Mix Room SAAs. This practice is referred to as "satellite-to-satellite transfer," and was discussed in the Mix Room EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 10 of 19 Section of this report. In-Process Laboratory SAA: For every product line that is being manufactured at the facility, AkzoNobel creates a solvent standard in the In-Process Laboratory. The standards are used every week to verify characteristics such as density, weight, thickness and color of production material samples. Waste solvents generated in the laboratory testing are returned to the Mix Room SAAs and used rags, wipes, cups, and solids contaminated with solvents are accumulated in the InProcess Laboratory SAA. The inspectors observed one 14-gallon step-to-open flammable can in this SAA (Photo 18). The can was labeled as hazardous waste, but it was not marked with an indication of the hazardous of its contents. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5)(ii) [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and EPA in which he stated that the facility has labeled each can of Stream G hazardous waste solids as hazardous waste and flammable solids and has covered all oily waste labels so that they are no longer visible. Personnel explained that hazardous waste solvents that are generated in the In-Process Laboratory and hazardous waste Stream G that is accumulated in the In-Process Laboratory SAA is brought to the Mix Room where it is placed into containers in the Mix Room SAAs. This practice is referred to as "satellite-to-satellite transfer," and was discussed in the Mix Room Section of this report. Certification Lab: AkzoNobel performs quality control inspections on incoming film and final product film in the Certification Lab. These inspections include some semi-destructive testing activities such as a scratch test and tape test, but no hazardous wastes are generated in this laboratory. Environmental Lab: AkzoNobel performs testing on final products in the Environmental Lab. These tests are designed to show how the final product withstands aging and environmental extremes such as cold temperatures and humidity. No hazardous wastes are generated in this laboratory. Drum Storage Area 1: The inspectors observed containers of liquid raw materials and work-inprogress inventory in Drum Storage Area 1. Work-in-progress inventory includes portable vessels of traditional paint raw materials, which have been mixed together in the Mix Room and brought to this area until they are used in the coating line production process. No hazardous waste was observed in Drum Storage Area 1. Drum Storage Area 2 CAA: AkzoNobel manages a hazardous waste CAA in Drum Storage Area 2 (Photo 19). This area is identified with a "hazardous waste storage area" sign, and the floor has been painted to define individual rows for storing pallets of hazardous waste containers. At the time of the inspection, the facility was storing two types of hazardous waste in this area: Stream A D001 / D035 / F003 / F005 hazardous waste flammable liquid solvent mix and Stream G D001 EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 11 of 19 / D035 / F003 / F005 hazardous waste solids containing flammable liquids. The inspectors observed 55-gallon drums of hazardous waste on three rows of wooden pallets in this area. Each pallet contained four 55-gallon drums, and most pallets were stacked two high. The first row contained approximately eighteen 55-gallon drums of Stream A hazardous waste and fourteen 55-gallon drums of Stream G hazardous waste; the second row contained approximately twenty-two 55-gallon drums of Stream A hazardous waste and eighteen 55-gallon drums of Stream G hazardous waste; and the third row contained approximately nineteen 55gallon drums of Stream A hazardous waste and five 55-gallon drums of Stream G hazardous waste. Each container was labeled as hazardous waste and marked with an accumulation start date. None of the containers had been on-site greater than 90 days. One 55-gallon drum of Stream A hazardous waste liquids in Row 2 was not marked with an indication of the hazards of its contents. Every other container of Stream A hazardous waste in this area was marked with a flammable liquid DOT hazard placard, and every container of Stream G hazardous waste was marked with a flammable solid DOT hazard placard. None of these containers were marked with an indication that the contents are toxic. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(5)(i) [40 C.F.R. 262.17(a)(5)(i)], which is a condition of the LQG Permit Exemption, a generator is required to mark or label containers with the words "Hazardous Waste;" with an indication of the hazards of the contents; and with the date upon which each period of accumulation begins clearly visible for inspection on each container. The area is equipped with an internal communications or alarm system capable of providing immediate emergency instruction to facility personnel; it is equipped with a telephone capable of summoning emergency assistance from local police departments, fire departments, or state or local emergency response teams; and it is equipped with portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment. Although the facility manages ignitable waste in this CAA, the inspectors did not observe a "No Smoking" sign in this area. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(1)(vi)(B) [40 C.F.R. 262.17(a) (1)(vi)(B)], which is a condition of the LQG Permit Exemption, "no smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and EPA in which he included a photograph documenting that a "no smoking" sign has been added to this area. Warehouse UHW: Personnel stated that most chemical storage is found in Drum Storage Area 1 and Drum Storage Area 2, and the inspectors observed raw materials, semi-finished goods, finished goods, and universal waste lamps in the Warehouse. The inspectors observed one box of 2-foot universal waste lamps, one box of 4-foot universal waste lamps, one box of 6-foot universal waste lamps, and one box of 8-foot universal waste lamps in this area (Photo 20). All of these boxes were open. The boxes of 6-foot and 8-foot lamps were labeled as universal waste lamps, but no labels were affixed to the boxes of 2-foot and 4-foot lamps. Instead, these labels were located on a clipboard that had been placed on top of EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 12 of 19 each container. The oldest universal waste label was dated 11/04/2021. Pursuant to 25 S.C. Code Ann. Regs. 61-79.273.13(d)(1) [40 C.F.R. 273.13(d)(1)], a SQHUW must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he provided a photograph documenting how the UHW storage area has been re-organized. Pursuant to 25 S.C. Code Ann. Regs. 61-79.273.14(e) [40 C.F.R. 273.14(e)], a SQHUW must label or mark each lamp or container or package in which such lamps are contained clearly with one of the following phrases: "Universal Waste Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he provided a photograph documenting how the UHW storage area has been re-organized and that labels have been affixed to each container. Mechanical Room: The inspectors observed one 55-gallon drum of used oil in the Mechanical Room. The drum was labeled as "used oil," it was equipped with a closed funnel lid, and it was located on a portable secondary containment pallet. Contingency Plan: The actions that facility personnel should take in response to an emergency are described in the facility's Contingency Plan. A copy of the plan was most recently submitted to the county office, SCDHEC, the local Sherriff's office, the local fire department, and hospital on 02/14/2017. The plan was last updated on 08/13/2020, but a copy of the revised plan was not resubmitted to the local emergency response entities and no quick reference guide was created with the revision. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.262(a) [40 C.F.R. 262.262(a)], and is a condition of the LQG Permit Exemption, a generator is required to submit a copy of the contingency plan and all revisions to all local emergency responders. This document may also be submitted to the Local Emergency Planning Committee, as appropriate. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.262(b) [40 C.F.R. 262.262(b)], and is a condition of the LQG Permit Exemption, a generator that is amending its contingency plan must at that time submit a quick reference guide of the contingency plan to the local emergency responders or, as appropriate, the Local Emergency Planning Committee. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and EPA in which he stated that a quick reference guide was developed and included in the latest revision of the site's plan. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 13 of 19 The contingency plan describes actions facility personnel must take in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility. The plan lists the names and emergency telephone numbers for persons identified as emergency coordinators. The plan includes an evacuation plan for personnel with a map of evacuation routes. The plan does not describe arrangements agreed to with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals or the Local Emergency Planning Committee. The plan does not include a list, with the location and a physical description, of all emergency equipment at the facility, and a brief outline of its capabilities. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.261(c) [40 C.F.R. 262.261(c)], and is a condition of the LQG Permit Exemption, the contingency plan must describe arrangements agreed to with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals, or, if applicable, the Local Emergency Planning Committee. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.261(e) [40 C.F.R. 262.261(e)], and is a condition of the LQG Permit Exemption, the contingency plan must include a list of all emergency equipment at the facility where this equipment is required. This list must be kept up to date. In addition, the plan must include the location and a physical description of each item on the list, and a brief outline of its capabilities. Training Records: Mr. Hinkle displayed the facility's tracking matrix for employee training, which is kept electronically. The matrix indicates that Mixing Operators, Coating Operators and Laboratory Personnel are required to complete initial and annual hazardous waste training. The inspectors reviewed facility job descriptions and employee names that were provided for Mixing Operators and Coating Laboratory Personnel, but no other job descriptions were provided. The job descriptions included the requisite skill, education, or other qualifications, but did not include the hazardous waste related duties of facility personnel assigned to that position. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(7)(iv) [40 C.F.R. 262.17(a)(7)(iv)], which is a condition of the LQG Permit Exemption, the LQG must maintain the following documents and records at the facility: the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; a written job description for each position at the facility related to hazardous waste management; a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position at the facility related to hazardous waste management; and records that document that the training or job experience, required in this section, has been given to, and completed by, facility personnel. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 14 of 19 that job descriptions for employees handling hazardous waste have been revised to include duties involving hazardous waste management. Although he provides in-house hazardous waste training to facility personnel, Mr. Hinkle had not received outside hazardous waste training during the three years preceding the inspection. The inspectors reviewed training records for a total of fourteen employees, who received hazardous waste training in October or November 2020, and for a total of nine employees, who received hazardous waste training in December 2021. At least one employee did not receive hazardous waste training in 2020 (K. Schultz), and Mr. Hinkle and Mr. LaBarge stated that hazardous waste training in 2021 was delayed due to Covid. Additional employees were scheduled to receive hazardous waste training later in January 2022. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(7)(i)(A) and (iii) [40 C.F.R. 262.17(a)(7)(i)(A) and (iii)], which is a condition of the LQG Permit Exemption, facility personnel must successfully complete a program of classroom instruction, online training, or on-the-job training that teaches them to perform their duties in a way that ensures compliance with this part; and must take part in an annual review of the initial program of classroom instruction, online training, or on-the-job training that teaches them to perform their duties in a way that ensures compliance with this part. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that the HSE Manager has enrolled to complete a RCRA Hazardous Waste Management Online Course during week six of 2022, and that he will train all employees who handle hazardous waste starting week seven of 2022. Waste Manifest Records: The inspectors reviewed available hazardous waste manifest records and land disposal restriction forms for shipments of hazardous waste sent during the second and third quarters of 2019, first and third quarters of 2020, and during the second quarter of 2021. Hazardous waste manifest records show that the facility typically initiates one shipment of hazardous waste each month. Most shipments were received by GRR Sumter (SCD036275626), but some hazardous waste was also received by Allworth (ALD094478799). Each hazardous waste shipment included approximately 15,000 pounds of Stream A D001 / D035 / F003 / F005 Waste flammable liquid (MEK toluene), 5,500 pounds of Stream A High Water D001 / D035 / F003 / F005 Waste flammable liquid (MEK toluene), 2,900 pounds of Stream E D001 / D035 / F003 / F005 Waste flammable liquid (MEK toluene), and 7,000 pounds of Stream G D001 / D035 / F003 / F005 Waste flammable solid (MEK toluene). Some information included on the quarterly reports which were submitted to SCDHEC did not match the information found on the corresponding hazardous waste manifests. Hazardous waste manifest 000282002GRR indicated that a total of 1,140 pounds of Stream A D001 / D035 / F003 / F005 waste flammable liquid (MEK toluene) was shipped to GRR (SCD036275626) on 08/05/2020, but the corresponding quarterly report indicated that 5,595 pounds of this waste stream was shipped on this manifest. Also, hazardous waste manifest 00272887GRR for a shipment to GRR (SCD036275626) was dated 01/20/2020, but the corresponding quarterly report indicated that this manifest was dated 03/12/2020. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.41(a)(5) and (6) [40 C.F.R. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 15 of 19 262.41(a)(5) and (6)], each LQG who ships any hazardous waste offsite to a treatment, storage or disposal facility within the Unites States must prepare and, no later than thirty days after the end of each calendar quarter, submit a written report to the Department including a description, the EPA hazardous waste number, DOT hazardous class, and quantity of hazardous waste shipped offsite for shipments to a treatment, storage, or disposal facility within the United States; and the types and quantities of such wastes shipped offsite for treatment and disposal. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and the EPA in which he stated that a revised copy of the quarterly report, which included the correct weight, was mailed to SCDHEC on 01/14/2022. Inspection Records: The inspectors reviewed AkzoNobel's available records of inspections of the hazardous waste CAA since January 2019. The inspection log includes a checklist to indicate whether the inspector has observed "problems" or "leakers," any action taken on leakers, any drums over 90 days, and any other required actions. The records include the date and time of the inspection and the signature of the employee conducting the inspection. The inspectors recommended that the facility revise the inspection checklist to more clearly direct employees regarding what types of observations to document. On 01/28/2022, Mr. LaBarge sent a letter to SCDHEC and EPA in which he provided a copy of the new weekly inspection form, which was created and implemented following the inspection. 12) Closing Conference The inspectors conducted the exit meeting with Mr. LaBarge and Mr. Hinkle. During this meeting, the inspectors stated their preliminary conclusions of the inspection. 13) Inspection Findings Based on the observations made during the inspection, AkzoNobel was apparently deficient with the following RCRA requirements: Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.11 [40 C.F.R. 262.11], a person who generates a solid waste, as defined in 25 S.C. Code Ann. Regs. 61-79.261.2 [40 C.F.R. 261.2], must use the steps articulated in 25 S.C. Code Ann. Regs. 6179.262.11 [40 C.F.R. 262.11] to make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near the 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 without having interim status, as required by Section 44-5660(a)(2) and (b)(3) of the SCHWMA, S.C. Code Ann. 44-56-60(a)(2) and (b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with 25 S.C. Code EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 16 of 19 Ann. Regs. 61-79.262.16(b) or R.61-79.262.17(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 25 S.C. Code Ann. Regs. 61-79.262.15(a)(7) and (8) [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the conditions listed in the SAA Permit Exemption. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(4) [40 C.F.R. 262.15(a)(4)], which is a condition of the SAA Permit Exemption, a generator is required to keep containers of hazardous waste closed at all times during accumulation, except when adding, removing, or consolidating waste; or when temporary venting of a container is necessary for the proper operation of equipment, or to prevent dangerous situations, such as build-up of extreme pressure. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(5) [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers (i) with the words "Hazardous Waste" and (ii) with an indication of the hazards of the contents. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(6)(i) and (ii) [40 C.F.R. 262.15(a)(6)(i) and (ii)], a generator who accumulates an excess of 55-gallons of hazardous waste at or near any point of generation must comply within three consecutive calendar days with the applicable CAA regulations or remove the excess form the SAA within three consecutive calendar days to either a CAA, an on-site interim status or permitted treatment, storage, or disposal facility, or an off-site designated facility. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.15(a)(6)(iii) [40 C.F.R. 262.15(a)(6)(iii)], the generator must mark or label the container(s) holding the excess accumulation of hazardous waste with the date the excess amount began accumulating and continue to comply with the requirements of the SAA Permit Exemption during the three-consecutive-calendar-day period. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(1)(vi)(B) [40 C.F.R. 262.17(a) (1)(vi)(B)], which is a condition of the LQG Permit Exemption, "no smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(5)(i) [40 C.F.R. 262.17(a)(5)(i)], which is a condition of the LQG Permit Exemption, a generator is required to mark or label containers with the words "Hazardous Waste;" with an indication of the hazards of the contents; and with the date upon which each period of accumulation begins clearly visible for inspection on each container. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.261(c) [40 C.F.R. 262.261(c)], and is a condition of the LQG Permit Exemption, the contingency plan must describe arrangements agreed to with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals, or, if applicable, the Local Emergency Planning Committee. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 17 of 19 Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.261(e) [40 C.F.R. 262.261(e)], and is a condition of the LQG Permit Exemption, the contingency plan must include a list of all emergency equipment at the facility where this equipment is required. This list must be kept up to date. In addition, the plan must include the location and a physical description of each item on the list, and a brief outline of its capabilities. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.262(a) [40 C.F.R. 262.262(a)], and is a condition of the LQG Permit Exemption, a generator is required to submit a copy of the contingency plan and all revisions to all local emergency responders. This document may also be submitted to the Local Emergency Planning Committee, as appropriate. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(6) [40 C.F.R. 262.17(a)(6)], which incorporates 25 S.C. Code Ann. Regs. 61-79.262.262(b) [40 C.F.R. 262.262(b)], and is a condition of the LQG Permit Exemption, a generator that is amending its contingency plan must at that time submit a quick reference guide of the contingency plan to the local emergency responders or, as appropriate, the Local Emergency Planning Committee. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(7)(i)(A) and (iii) [40 C.F.R. 262.17(a)(7)(i)(A) and (iii)], which is a condition of the LQG Permit Exemption, facility personnel must successfully complete a program of classroom instruction, online training, or on-the-job training that teaches them to perform their duties in a way that ensures compliance with this part; and must take part in an annual review of the initial program of classroom instruction, online training, or on-the-job training that teaches them to perform their duties in a way that ensures compliance with this part. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.17(a)(7)(iv) [40 C.F.R. 262.17(a)(7)(iv)], which is a condition of the LQG Permit Exemption, the LQG must maintain the following documents and records at the facility: the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; a written job description for each position at the facility related to hazardous waste management; a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position at the facility related to hazardous waste management; and records that document that the training or job experience, required in this section, has been given to, and completed by, facility personnel. Pursuant to 25 S.C. Code Ann. Regs. 61-79.262.41(a)(5) and (6) [40 C.F.R. 262.41(a)(5) and (6)], each LQG who ships any hazardous waste offsite to a treatment, storage or disposal facility within the Unites States must prepare and, no later than thirty days after the end of each calendar quarter, submit a written report to the Department including a description, the EPA hazardous waste number, DOT hazardous class, and quantity of hazardous waste shipped offsite for EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 18 of 19 shipments to a treatment, storage, or disposal facility within the United States; and the types and quantities of such wastes shipped offsite for treatment and disposal. Pursuant to 25 S.C. Code Ann. Regs. 61-79.273.13(d)(1) [40 C.F.R. 273.13(d)(1)], a SQHUW must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. Pursuant to 25 S.C. Code Ann. Regs. 61-79.273.14(e) [40 C.F.R. 273.14(e)], a SQHUW must label or mark each lamp or container or package in which such lamps are contained clearly with one of the following phrases: "Universal Waste Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." 14) List of Appendices Appendix 1 - Photo Log: 20 Photos taken on: January 13, 2022 Photos taken by: Laurie Benton DiGaetano Photos taken with: Panasonic DMC TS-5 Digital Camera EPA Property Tag: S09533 15) Signed Digaetano, Laurie Date: 2022.02.15 19:28:28 -05'00' Digitally signed by Digaetano, Laurie _____________________________________________________ Laurie Benton DiGaetano Senior Enforcement and Compliance Specialist Concurrence ARACELI CHAVEZ Date: 2022.02.17 17:08:45 -05'00' Digitally signed by ARACELI CHAVEZ _____________________________________________________ Araceli B. Chavez Chief RCRA Enforcement Section EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 19 of 19 AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 1: One of three SAAs in the Mix Room for accumulating Stream G hazardous waste solids. This SAA is located next to the CMX-200 Tank Washer. The 55-gallon drum in this SAA is labeled hazardous waste solid filters and it is marked with a flammable solids DOT hazard placard. It is not marked to indicate the contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 1 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 2: One of three SAAs in the Mix Room for accumulating Stream G hazardous waste solids. This SAA is located in the far corner of the room. The 55-gallon drum in this SAA is labeled hazardous waste solid chips and it is marked with a flammable solids DOT hazard placard. It is not marked to indicate the contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 2 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 3: One of three SAAs in the Mix Room for accumulating Stream G hazardous waste solids. This SAA is located in the middle of the room. The 55-gallon drum in this SAA is labeled hazardous waste solids and it is marked with a flammable solids DOT hazard placard. It is not marked to indicate the contents are toxic. The container lid does not make complete contact with the top of the container. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 3 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 4: An elevated blue rinse tank used with the CMX-200 Tank Washer and one 55-gallon drum in the CMX-200 Tank Washer SAA in the Mix Room. The drum was closed and labeled hazardous waste Stream A MEK, and it was marked with flammable liquid DOT hazard placard. It is not marked to indicate the contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 4 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 5: Ten 55-gallon drums of hazardous waste observed on portable secondary containment pallets in the Mix Room near the Distillation Unit. None of the containers were marked to indicate the contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 5 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 6: Closer view of two of the ten 55-gallon drums of hazardous waste observed on portable secondary containment pallets in the Mix Room near the Distillation Unit shown in Photo 5. It is not marked to indicate the contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 6 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 7: Three of six 55-gallon drums of hazardous waste observed on portable secondary containment pallets in the Mix Room near the center of the room. The drum on the left was not labeled as hazardous waste or marked with an indication of the hazards of its contents. The drum in the center was labeled as hazardous waste and marked with a flammable liquid DOT hazard placard. The drum on the right was not labeled as hazardous waste, but it was marked with a flammable liquid DOT hazard placard. None of the hazardous waste containers were marked to indicate their contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 7 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 8: Two of six 55-gallon drums of hazardous waste observed on portable secondary containment pallets in the Mix Room near the center of the room. The drums were not labeled as hazardous waste, marked with an indication of the hazards of its contents, or marked with an accumulation start date. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 8 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 9: One of six 55-gallon drums of hazardous waste observed on portable secondary containment pallets in the Mix Room near the center of the room. The drum was not labeled as hazardous waste. The ink on the label had run, causing the values marked on the NFPA fire diamond to be illegible. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 9 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 10: Hazardous waste liquid observed in the portable secondary containment unit beneath six 55-gallond drums of hazardous waste in the middle of the Mix Room. This secondary containment pallet appeared to be a container holding hazardous waste at the time of the inspection, and that container was neither closed nor labeled. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 10 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 11: SAA for accumulating hazardous waste Stream A High Water in Liquid Laboratory. The basin is labeled as hazardous waste, but it is not marked with an indication of the hazards of its contents. One 5-gallon bucket of hazardous waste was observed inside the basin, which is connected to the air handling system. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 11 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 12: One of six 14-gallon step-to-open flammable cans in the Liquid Laboratory SAA for accumulating Stream G hazardous waste solids. The container is labeled "Stream G hazardous waste solids," but it is not marked with an indication of the hazards of its contents. In addition, the original "oily rags" and "empty every night" labels are still visible on the container. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 12 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 13: One of red 2-gallon container in the Film Laboratory SAA for accumulating Stream A hazardous waste liquids. The container is labeled hazardous waste, and it is marked with an NFPA fire diamond. However, the numbers marked on the fire diamond had smudged off and were no longer legible. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 13 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 14: One of four 14-gallon step-to-open flammable cans in the Film Laboratory SAA for accumulating Stream G hazardous waste solids. The container was not labeled "hazardous waste" or marked with an indication of the hazards of its contents. In addition, the original "oily rags" and "empty every night" labels are still visible on the container. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 14 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 15: One 5-gallon container in the Color Laboratory SAA for accumulating Stream A High Water hazardous waste liquids. The container is labeled hazardous waste, and the hazards of the contents of the container are indicated using an NFPA fire diamond. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 15 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 16: One of two 14-gallon step-to-open flammable cans in the Color Laboratory SAA for accumulating Stream G hazardous waste solids. The container is not labeled hazardous waste, and it is not marked with an indication of the hazards of its contents. In addition, the original "oily rags" and "empty every night" labels are still visible on the container. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 16 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 17: One 30-gallon step-to-open can in the Mix Room Laboratory SAA for accumulating Stream G hazardous waste solids. The container is labeled hazardous waste, and it is marked with a flammable solids DOT hazard placard. It is not marked to indicate the contents are toxic. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 17 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 18: One 14-gallon step-to-open flammable can in the In-Process Laboratory SAA for accumulating Stream G hazardous waste solids. The container is labeled hazardous waste, but it is not marked with an indication of the hazards of its contents. In addition, the original "oily rags" and "empty every night" labels are still visible on the container. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 18 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 19: CAA located in Drum Storage Area 2. The floor has been painted to define individual rows for storing pallets of hazardous waste containers. The inspectors observed approximately onehundred 55-gallon drums of hazardous waste arranged in three rows of wooden pallets. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 19 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533) AkzoNobel Specialty Plastic RCRA CEI Photographs Laurie Benton DiGaetano, USEPA Photo 20: One box of 2-foot universal waste lamps, one box of 4-foot universal waste lamps, one box of 6-foot universal waste lamps and one box of 8-foot universal waste lamps in the Warehouse. All of the boxes were open. The boxes of 6-foot and 8-foot lamps were labeled as universal waste lamps, but no labels were affixed to the boxes of 2-foot and 4-foot lamps. Instead, these labels were located on a clipboard that had been placed on top of each container. The oldest universal waste label was dated 11/04/2021. EPA-RCRA CEI Report AkzoNobel Specialty Plastics EPA ID# SCD000608331 January 13, 2022 Page 20 of 20 Laurie Benton DiGaetano (Panasonic DMC TS-5 #S09533)