Document DveNpvxoaB6wdjdbN1xyqw5NO

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 September 6, 2024 Jon Reid, Environmental, Health, and Safety Manager Americas Styrenics, LLC 1761 Route 12 Gales Ferry, CT, 06335 Re: U.S. EPA-Region 1 Inspection Report of Americas Styrenics, July 9-10, 2024 Dear Mr. Reid: In accordance with current policy, I am providing you with a copy of the final inspection report summarizing observations made during the July 9-10, 2024, Compliance Evaluation Inspection (CEI) of your facility. This inspection was conducted under the authority of RCRA. Please contact me at 617-918-1309 or maisano.ryan@epa.gov if you have any questions. Sincerely, RYAN Digitally signed by RYAN MAISANO MAISANO Date: 2024.09.06 15:34:03 -04'00' Ryan Maisano, Physical Scientist EPA Inspector, Waste and Chemical Compliance Section cc: Joesph Schiavone, CT DEEP Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 RCRA Compliance Inspection of: Americas Styrenics 1761 Rte 12 Gales Ferry, CT 06335 July 9-10, 2024 Date of Inspection September 6, 2024________ Date Inspection Report Approved September 6, 2024________ Date Inspection Report Finalized September 6, 2024_______ Date Inspection Report Transmitted to Facility RYAN Digitally signed by RYAN MAISANO _M__A_I_S_A_N__O____D1_5a:t3_e4:_:2302_2-_40.40_'90_.00'6_____ Ryan Maisano, Physical Scientist Waste and Chemical Compliance Section _________________________ O'Donnell, Mary Jane Digitally signed by O'Donnell, Mary Jane Date: 2024.09.06 12:02:28 -04'00' Mary Jane O'Donnell, Manager Waste and Chemical Compliance Section Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Date: From: Thru: To: Subject: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 RCRA HAZARDOUS WASTE INSPECTION REPORT September 6, 2024 Waste and Chemical Compliance Section Lisa Papetti, Senior Enforcement Coordinator Waste and Chemical Compliance Section RCRA Enforcement File Environmental Protection Agency ("EPA") Resource Conservation and Recovery Act ("RCRA") Inspection of Americas Styrenics. I. GENERAL INFORMATION Facility Name: Americas Styrenics Facility EPA Identification Number: Type of Inspection (CEI, FCI, CSI, etc.): Name(s) of inspector(s): Date(s) of inspection: CTD001159730 Compliance Evaluation Inspection Ryan Maisano Drew Meyer July 9-10, 2024 II. SITE INFORMATION Site Name: Complete Street Address: Complete Mailing Address: Americas Styrenics, LLC 1761 Route 12 Gales Ferry, CT 06335 1761 Route 12 Gales Ferry, CT 06335 Contact(s) (Name, Title, Phone Number, Email) Date of latest Notification of Hazardous Waste Activities (per RCRAInfo): Date of first Notification of Hazardous Waste Activities (per RCRAInfo): Date established at present location: NAICS Code: Jon A. Reid EH&S Engineer 840-440-7862 jreid@amsty.com 02/29/2024 01/01/1980 Americas Styrenics around 2008. Facility was owned by Dow Chemical from 1950s. 325211 Plastics Material and Resin Manufacturing Current Property Owner: Cashman Dredging & Marine Contracting Co., LLC Current Operator: Americas Styrenics, LLC Waste codes generated (per most recent Biennial Report): D-Codes: D001 D003 D004 D022 F-Codes: F001 F002 F003 NOTIFICATION IN RCRAInfo: TSDF LQG SQG VSQG Universal Waste Handler (circle one): SMALL/LARGE Burner/Blender Transporter Receiving waste from off-site (if so, describe): Generator of State Waste Non-Notifier Other: Facility Operating Status if different from above: N/A Page 4 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 III. IN-BRIEF Credentials Presented: Yes No Attendees (names/titles): EPA: Ryan Maisano, Physical Scientist Drew Meyer, Environmental Scientist Americas Styrenics: Jon Reid, EH&S Engineer Steven Lake, Plant Manager During the inspection in-brief the EPA inspection team provided an overview of the inspection locations and requested paperwork to be reviewed. The EPA inspection team provided the Small Business Resources Information Sheet to the facility personnel. The inspection team briefly discussed handling Confidential Business Information (CBI). The inspection team requested to be advised if or when any CBI was provided. Representatives from Americas Styrenics stated most of the areas hazardous waste was located did not have areas of CBI. Jon Reid, EH&S Engineer and Steven Lake, Plant Manager provided an overview of the facility's history, process, waste generation, training of personnel, and personal protective equipment (PPE) required while in the facility. Number of Employees: 31 employees Size of Facility: Length of Facility at Location: Total Property 158 Acres Americas Styrenics Leases 31 Acres Americas Styrenics began operating at this site around 2008 Operating Hours: 24 hours a day Number of Shifts: 2-twelve-hour shifts. 4 groups of employees rotate shifts. Primary Emergency Coordinator: Alternate Emergency Coordinator: Type of Operation: Steven Lake-Plant Manager Jon Reid-EH&S Engineer Polystyrene manufacturer Page 5 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Facility Description: America's Styrenics is a manufacturer of polystyrene and styrene monomers. The company was originally founded as a joint venture between The Dow Chemical Company and Chevron Philips. America's Styrenics was transferred the EPA ID number when it leased land from Dow Chemical in 2008. In 2010, Dow Chemical sold the site to Styron, LLC. In 2022, the site was purchased by Cashman Dredging and America's Styrenics has leased the land since 2008. Cashman Dredging operates their offices on the property. America's Styrenics manufactures plastic polystyrene pellets to sell to various companies that produce plastic spoons, water bottles, lab products, takeaway containers, CD/DVD jewel cases, etc. The facility operates one, HWAA (hazardous waste accumulation area) and 5 SAAs (satellite accumulation area). The HWAA is located outside and under cover. Universal waste is stored in the Warehouse and includes batteries, e-waste, and bulbs. The facility holds a RCRA permit issued by Connecticut Department of Energy and Environmental Protection because the site includes a hazardous waste tank and a boiler and industrial furnace (BIF). The current permit is in effect until September 25, 2027. In October 2020, a spill of styrene was reported to CT DEEP. The spill was from loose packing on a valve on E-Train. Veolia Environmental Services is used by the facility to transport and pick up hazardous and nonhazardous waste. Process Description: America's Styrenics has two manufacturing plants("trains") labeled by the facility as the E-Train and GTrain. Both trains produce polystyrene plastic pellets for the plastics industry. This is mainly done by compounding and heating. The biggest difference between the two trains is the E-Train can accept recycled plastic. E-Train: The E-Train process starts with styrene storage tanks delivered either by train, truck, or boat. The ETrain can also accept used polystyrene that has been shredded as raw material in the process. This is accepted at the facility in the form of used clothes hangers. The facility includes a dock which can receive chemicals. The product then goes through PCR filters to a feed tank. The feed tank is used to feed the three reactors that heat the product to 120 C in the first reactor, 140 C in the second reactor, and 160 C in the third. These three reactors are in sequence. Once the product flows through the three reactors it travels to two de-volatilizers that are in sequence. The first de-volatilizer is held at a temp of 150 C to 170 C and the second de-volatilizers is held to 280 C. From the de-volatilizers, the material is then cooled in a water bath. After the material is cooled it is then cut and screened. The material is then stored in silos waiting for pickup by truck or train. G-Train: Page 6 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 The G-Train has a similar process to the E-Train and produced the same plastic pellets. It was not engineered to receive the recycled shredded clothes hangers. The G-Train starts with the same product storage tanks as the E-Train. The first step is the boiling reactor that reaches a temperature of 40 C. From there the product goes to a de-volatilizer which is at 170 C and then another de-volatilizer at 280 C. Dyes are then added, if required. The product is then cooled by water bath, cut, and screened. Finally, the pellets are stored in silos for pickup by truck or train. Tank V-1910 and BIF: The Tank V-1910 is the hazardous waste storage tank that is used to store spent Ethylbenzene/styrene mix called tar. This tank stores the tar that does not go back into the process. Tar, along with heat, is used to start the reaction to create the polystyrene pellets. Tank V-1910 is 2,700 gallons and directly feeds one of the two BIFs. The other BIF is fueled by natural gas. The heat from the BIFs is used in the process of the plastic pellet manufacturing. CT DEEP RCRA Part B Permit Number DEEP/HWM-072-001 Waste Management Units Covered by Permit Hazardous Waste Storage Tank V-1910 BIF-Boiler Unit A Comments: Observations The hazardous waste storage tank has an operating capacity of 2,700 gallons. It has a design capacity of 3,000 gallons. Struthers Wells Boiler is permitted to burn 53.6 gallons per hour. The BIF is used to burn the excess process styrene waste. The BIF has the capacity to burn natural gas and uses it as a startup fuel and to maintain temperatures needed for the styrene reactions, if not waste feed. The BIF and hazardous waste storage tank appears to meet the operating conditions of the CT DEEP Part B Permit. The permitted waste codes managed by the tank and BIF are D001 and D018. QC Lab: The QC Lab is located in the G-Train building and conducts various analyses of raw material and finished plastic pellets. Waste generated in the lab includes used PPE, cleaning rags, and contaminated glassware. SAAs in the QC Lab includes drums for PPE and small containers in the fume hood for liquid waste. Types of Waste Handled: Ignitable (D001) Corrosive (D002) Reactive (D003) TCLP (D004 - D043) Universal Wastes (Types: batteries) Other (specify): F or K listed wastes Used Oil P or U listed wastes State Regulated Wastes Precious Metals Unknown Wastes Hazardous Scrap Metals Spent mercury-containing lamps, used electronics, and various types of Page 7 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Comments (descriptions and constituents if known): Handling/Management Methods: Containers Tanks - aboveground Wastewater Treatment ("WWTU") Tanks - underground Drip pads Containment building Hazardous Waste Storage Areas(s) (HWSA(s)) Satellite Accumulation Areas (s) (SAA(s)) Other-hazardous waste fuel is burned in a BIF unit. Comments: IV. PHYSICAL INSPECTION The walkthrough started on July 9, 2024, the EPA inspection team was led around the facility by Jon Reid and Steven Lake from the facility. The inspection team donned safety glasses, hard hats, and fireresistant bib overalls. WASTES OBSERVED: Waste Stream Waste Flammable Liquid, UN1993, Styrene, 3, II, RQ 6/13/2024 Waste Flammable Liquid, UN1993, Styrene, 3, II, RQ 6/25/2024 Non-Regulated Non-DOT Used Oil 6/27/2024 EPA/State Waste Code D001 D001 Container 55-gallon white drum 55-gallon white drum 55-gallon white drum Location HWAA HWAA HWAA Universal WasteE-Waste 6/3/2024 Universal Wastebatteries Spent mercurycontaining lamps 1 CY cardboard box 6-white buckets 2-cardboard boxes Warehouse Warehouse Warehouse TarStyrene/Ethylbenz ene Hazardous Waste D001, D018 F001, F002 V-1910 White 2,700-gallon tank 30-gallon Outside Lab Comments Container is marked with words "used "oil. Dates 4/3/20244/13/2024 Page 8 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Solid, NA3077 Lab contaminated PPE (methylene chloride, methanol), 9, II Hazardous Waste Empty Aerosols, Flammable, UN1950 Hazardous Waste Flammable Liquid, Toxic, UN1992, Styrene, methanol, chrome, 6.1, II Hazardous Waste, Waste Flammable liquid, Tetrahydrofuran, mineral oil, 3, II Hazardous Waste, Waste Organic Peroxide Type F Solid, Tertbutylperoxy cyclohexane, 5.2 Hazardous Waste, Waste Flammable liquid, UN1993, Styrene, Ethyl Benzene, 3, II Hazardous Waste, Waste Solids containing flammable liquid, UN3175, Styrene, Ethyl Benzene, 4.1, II Hazardous Waste Solid, NA3077 methylene chloride, methanol, 9, II Waste Flammable Liquid, UN1993, Styrene, 3, II D001 D001, F002 D001, F002 D003, D001 D001, D018 D001 F001, F002 D001 black drum 20-gallon blue drum 5-gallon clear container 5-gallon clear container 25-gallon blue drum 55-gallon white drum 30-gallon black drum 25-gallon blue drum 55-gallon white drum Lab Lab Lab Initiator Building 38 Tank Farm Tank Farm Tank Farm Tank Farm In Lab Hood In Lab Hood Page 9 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 HAZARDOUS WASTE DETERMINATIONS Requirements Determination conducted for all waste streams, by what method Determination updated, as needed (documentation on-site) Comments: Observations (Yes/NO/NA-Explain if needed) Yes Yes, most recent determination was done for all hazardous waste was 4/15/2024. EPA inspectors were provided a Waste Determination log that includes the name of the waste stream, tracking number, process, results, date of most recent determination, and person making the determination. IGNITABLES/REACTIVES/INCOMPATIBLES Requirements Ignitable & reactive wastes separated from sources of ignition or reaction No smoking signs (for ignitable & reactive wastes) Separation of all incompatibles (either incompatible wastes or wastes with incompatible containers) Storage > 50 feet from property line Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes, "No Smoking" signs are posted in the hazardous waste accumulation area. Yes Yes PREPAREDNESS & PREVENTION Requirements: Observations (Yes/No/NA-Explain if Needed) Wastes handled in a manner to minimize the potential for a fire, explosion or a release Arrangements with local authorities Immediate accessible to internal communications/alarm systems Telephone/hand-held two-way radio Emergency equipment (fire extinguishers, spill control decontamination equipment) Equipment maintenance Access to emergency equipment Adequate aisle space (each area) Adequate source of water in the event of a fire (federal regulations) Comments: Yes Yes Yes Yes Yes Yes Yes Yes Yes Financial assurance and closure costs were reviewed during the records review. The last Page 10 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 financial was completed on February 29, 2024, by Deloitte. Closure costs are estimated to be around $226,409. Financial assurance for closure was also performed by Deloitte and the mechanism was a financial test. PRE-TRANSPORT REQUIREMENTS Requirements: Packaging Labeling (if applicable, DOT hazard class) Marking (words "Hazardous Waste", generator information if being shipped) Contents described Proper DOT shipping name Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes SATELLITE ACCUMULATION Requirements: Approximate number of satellite accumulation areas Amount of waste per waste stream per satellite accumulation area (describe each area) Appropriate amount of waste storage in SAA Containers labeled and marked with contents described SAA at or near point of generation Containers closed when not actively adding or removing waste Condition of containers Impermeable base Secondary Containment Spill Control material Comments: Observations (Yes/No/NA-Explain if Needed) Five See wastes observed list. Yes Waste from instruments in lab was not labeled as hazardous waste (See Photo #26). Yes All containers observed were closed All containers observed appeared to be in good condition Yes Yes, secondary containment in Tank Farm appears to not be sealed Yes CONTAINER STORAGE - HWSA Requirements: Number of container storage areas Location(s) Observations (Yes/No/NA-Explain if Needed) One Outside Page 11 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Containers marked and contents described Containers marked with accumulation start date Approximate number & sizes of containers: Description: Floor drains/sumps Containers closed when not actively adding or removing waste Condition of containers (leaks, ruptures, dents, corrosion, heat, pressure) Impermeable base Secondary Containment Incompatibles separated by e.g., dike/wall Storage less than 90 days or 180 days for SQG (hazardous waste) Spill Control material Comments: Yes Yes Two-55-gallon,Hazardous waste drums-Waste Styrene D001, One non-hazardous waste drumWaste Oil None observed Yes Containers appeared to be in good condition Yes Yes Yes Yes, all dates observed were within 90 days. Yes, spill control equipment was observed. WASTE TANKS Requirements: Tank inventory/description (note type above/underground, location, age, construction (materials), ancillary equipment, capacity & waste type(s) Adequate secondary containment for tanks and ancillary equipment. Adequate leak detection system (including ancillary equipment). Describe corrosion protection system Special requirements for ignitable and reactive waste Labeling - Hazardous waste tanks, words "Hazardous Waste" and description of contents Tanks marked with accumulation start date, Storage less than 90 days Overflow/High Level alarms Flow cut-off equipment Certification of major repairs to tank Evidence of releases/leaks, describe Release reported, date (if known) Any out of service tanks, describe Existing Tank Systems (installed before July 14, 1986) - written tank integrity assessment on-site (P.E. certified) Observations (Yes/No/NA-Explain if Needed) Yes, V1910(spent tar/styrene) tank is managed as hazardous waste Yes N/A Yes, flammable and no smoking signs were observed. See Photos 15 and 17. Yes, see Photo 15 Storage is less than 90 days. Tank feeds BIF Yes Yes Yes. Tank was replaced in 2000. PE certification was reviewed. No None per facility No Old and new tank integrity assessment was reviewed by the inspection team. Page 12 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Does assessment address all the required items New Tank Systems (installed after July 14, 1986) written tank design, construction/installation assessment on-site (P.E. certified) Does assessment address all required items Documented installation & tightness test on-site Comments: Yes P.E. certification for new tank was reviewed by the inspection team Yes Yes Stainless steel tank (V1910) and associated piping is inspected daily. HAZARDOUS WASTE MANAGEMENT IN OTHER TYPE(S) OF UNITS Requirements Describe any other type of unit not described above, which is used for the storage or treatment of hazardous waste(s). Provide details of the unit construction and operation, wastes managed, amounts, frequency, and relevant procedures Does the operation of the unit listed above comply with all relevant RCRA standards Comments: Observations (Yes/NO/NA-Explain if Needed) The facility uses a BIF to treat the tar (spent styrene waste). The heat from the BIF is used back into the process. Two heaters were observed during the inspection. One was fueled by tar and the other was fueled by natural gas (See Photo 14). Yes USED OIL Requirements: Does the facility generate used oil Is the generator's used oil mixed with other waste(s) What type of waste(s) is used oil mixed with Listed Characteristic Non-hazardous waste If mixture is with characteristic hazardous waste, is the combined waste tested for characteristics Testing for rebuttable presumption Total halogen content determination Total halogen content determined by testing or generator knowledge Are the total halogens less than 1,000 ppm or greater than 1,000 ppm F-listed halogen constituents above 100 ppm Used oil managed according to applicable standards Is used oil accumulated on-site in: Container(s) Aboveground tank(s) Underground tank(s) Observations (Yes/No/NA-Explain if Needed) Yes No, used oil is managed as non-hazardous waste and labeled with the words "used oil." N/A N/A Yes Yes No Yes Used oil in managed in 55-gallon drums and stored near the HWAA at the time of the inspection (See Photo 5). Page 13 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Describe type, method, and condition Comments: Used oil was observed in white, 55-gallon drums. The condition of the drum was closed, and it appeared in good condition. INSPECTION SCHEDULE AND LOG Requirements: Does the facility claim inspections are conducted (tank and/or container inspections) Written inspection schedule Inspection log (adequacy of contents: date, time, items inspected, corrective actions, identity of inspector, signatures, etc.) Documentation Appropriate tank inspections, including containment, level detection, ancillary equipment Appropriate treatment equipment inspections All loading/unloading areas subject to spills (when in use) All hazardous waste storage areas (satellite and < 90 day where applicable), at all required frequencies All Safety and emergency equipment (monthly) where necessary Tanks cathodic protection (within six months, then yearly) where necessary Comments: Observations (Yes/No/NA-Explain if Needed) Yes, daily inspections. Yes Yes Yes, documentation is stored in a data base called Skybridge. Yes Yes Yes Yes Yes N/A CONTINGENCY PLAN Requirements: Plan on-site Date of plan Emergency Coordinator(s) name, address, home, and office phone numbers Number to call to report emergency (internal) Plan to local authorities with proof of distribution (police, fire, hospital, emergency response teams) Emergency procedures (fire, explosions, releases/spills) Emergency coordinator(s) on-site or within a short driving distance of the company at all times Observations (Yes/No/NA-Explain if Needed) Yes January 2023 Contingency Plan lists "shift leaders" as emergency coordinators. Yes Yes, recent plan update was submitted to local authorities. Yes Yes Page 14 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Emergency equipment list location, description, capabilities Evacuation plan (signal, primary and alternate routes) Has the contingency plan been amended All remaining applicable requirements addressed Comments: Yes Yes Yes Yes Contingency plan does not list the hazardous waste tank as an area where hazardous waste is stored. PERSONNEL TRAINING RECORDS Requirements: All facility personnel that require training identified All facility personnel that require training have been properly trained New employees trained within 6 months and documentation of OST Annual refresher training for all employees requiring training Last annual training date for each employee Written description of training course Adequate training for all employees Job title, job description, name of employee, and description of required training Job duties related to hazardous waste Records maintained on-site until closure or three years for former employees Comments: Observations (Yes/No/NA-Explain if Needed) Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes AIR EMISSIONS - SUBPART BB Requirements: Does the generator have equipment (valves, pumps, compressors, flanges, pressure relief devices, sampling connection system, or openended valves or lines) that contacts hazardous waste with greater than 10% organic concentration (describe) The facility maintains a Subpart BB plan Does the generator claim that any of this equipment is exempt from Subpart BB If an exemption is claimed, does the generator Observations (Yes/No/NA-Explain if Needed) Yes, the hazardous waste tank, associated piping, and BIF all contact hazardous waste. All of this piping and tanks are tagged and monitored. See photos 19-21. Yes No N/A Page 15 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 have documentation to support this claim, in accordance with 265.1064(k) Does the facility have a list of each piece of equipment that is subject to Subpart BB with a listing of the type of service for each piece of equipment All required equipment marked in such a manner that it can be distinguished readily from other pieces of equipment Did the facility mark/label all compliance monitoring points Pumps in light liquid service checked by visual inspection each calendar week for indications of liquids dripping from the pump seal Air monitoring conducted in accordance with Reference Method # 21 Does the facility designate any pump, compressor or valve to be operating at no detectable emissions (i.e., less than 500 ppm above background) Pumps, compressors, or valves operating in compliance with the requirements of 265.1052(e), 265.1053(i) and/or 265.1057(f) Pumps or valves in light liquid service NOT designated as operating at no detectable emissions monitored monthly to detect leaks? Records of monthly air monitoring inspections of each pump or valve in light liquid service present Are leaks (<10,000 ppm) from each pump or valve repaired on the 5-day/15-day requirement Describe any pumps that are exempt from 265.1052 Does the facility have a record of each leak detected under the requirements of 265.1052, 265.1053, 265.1057 and 265.1058 Describe any equipment in heavy liquid service Compliance status of any equipment in heavy liquid service All associated records for the Subpart BB program maintained. Comments: Yes Yes Yes Yes Yes Yes Yes N/A N/A Yes N/A Yes Hazardous waste tank(V1910), associated piping, and BIF all contact liquid hazardous waste Equipment is in compliance. Yes Page 16 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 AIR EMISSIONS - SUBPART CC Tanks: Requirements Generator manages hazardous waste with volatile organic concentration > 500 ppm/wt in tanks Claims of any exemptions from the requirements of this subpart Comments: Observations (Yes/NO/NA-Explain if Needed) Yes No If the facility manages hazardous waste with volatile organic concentrations equal or greater than 500 ppm/wt in tanks, complete the following table for the tanks managing the waste. TANK ID V1910 TANK CAPACITY (gallons) 2,700 WASTE TYPE Sytrene, Ethylbenzene DESIGN (fixed or LEVEL OF floating roof) CONTROL (1,2 or 3) Fixed 1 Tanks continued: Requirements: Facility maintains a Subpart CC Plan Facility has conducted appropriate waste determinations as required by 265.1084 For a fixed-roof tank using Level 1 Controls, did the facility determine the maximum vapor pressure of the waste Facility records of the results of the maximum vapor pressure determination Did the facility inspect the fixed roof and its closure devices immediately upon putting the tank into service and at least once per year In the event of a defect involving a tank system, did the facility make first repairs no later than 5 calendar days after detection and complete repairs no later than 45 calendar days after detection If a floating roof tank is used, has the facility notified the Regional Administrator 30 days prior to a planned inspection and as soon as possible in the case of an unplanned inspection Compliance with operating standards of 265.1085 Observations (Yes/No/NA-Explain if Needed) Yes Yes, waste determinations are updated annually. Last waste determinations were completed 4/15/2024 Yes Yes Yes Yes N/A Yes Page 17 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 Compliance with monitoring standards of Subpart Yes CC Compliance with record keeping standards of Yes 265.1090 Comments: Containers: Requirements: Does the generator manage in containers (>26 gallons in size, non-satellite) hazardous waste with volatile organic concentrations equal or greater than 550 ppm/wt Do the containers meet Department of Transportation("DOT") requirements Are the containers closed Observations (Yes/No/NA-Explain if Needed) All hazardous waste is managed in SAAs, V1910/BIF, or HWAA. Yes Yes MANIFESTS Requirements: Dates/months of shipping records reviewed Manifests maintained for three years Correct EPA ID numbers used All required parts completed Correct shipping names, numbers used Copies distributed correctly Exception reports filed, and available for review Manifests used for all hazardous waste shipments Appropriate copy(ies) on-site: Comments: Observations (Yes/No/NA-Explain if Needed) July 2022-July 2024 Yes Yes, CTD001159730 used. Yes, all appropriate copies were provided. Yes Yes Not observed Yes Yes LAND DISPOSAL RESTRICTIONS Requirements: Generator has determined whether the waste meets treatment standard(s) If the waste or contaminated soil does not meet the treatment standard(s), the generator has sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility or the generator has sent individual notification(s) for each shipment of waste If the waste or contaminated soil meets the Observations (Yes/No/NA-Explain if Needed) Yes Not observed Yes Page 18 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 treatment standard(s) at the original point of generation, the generator has sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility The generator has identified all appropriate Yes waste codes and/or underlying hazardous constituents (UHCs) on each shipment The generator retained on-site a copy of each Yes LDR documentation for 3 years Comments: ANNUAL/BIENNIAL REPORT Requirements: The company has completed an annual or biennial report, when/if it is required Comments: Observations (Yes/No/NA-Explain if Needed) Yes UNIVERSAL WASTE Requirements: Does the company/facility handle universal wastes What universal wastes are handled/generated by the facility Does the company/facility qualify as an LQH or SQH of universal waste Does the current handling of universal waste prevent breakage, leakage, spillage or damage that could cause leakage Are the containers of universal waste structurally sound and compatible with the contents Do the universal waste containers carry appropriate markings/labeling Does universal waste meet the requirements for accumulation start date Does the generator comply with the less than one year accumulation time limit Is the universal waste item or container dated from the earliest receipt of the item or when first placed in the container Does the company/facility keep appropriate manifests or shipping documents of universal wastes either received at or shipped from the Observations (Yes/No/NA-Explain if Needed) Yes Universal waste includes batteries, e-waste, and mercury containing spent bulbs. Yes Yes Yes Yes, all dates observed were less than one year. Yes Yes Yes Page 19 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015 facility to a destination facility Are records kept for at least three years from date of receipt to or transfer from the facility Comments: Yes Universal waste is located in the Warehouse. OUT-BRIEF List Attendees (names/titles): EPA: Ryan Maisano, Physical Scientist Drew Meyer, Environmental Scientist Americas Styrenics: Jon Reid, EH&S Engineer John Brownhill, Operations Manager Summary of out-brief: (include a list of areas of concern that were discussed) The EPA inspection team provided information on RCRA inspection program process, inspection report timelines, and summary of enforcement options available to the EPA. The out-brief was conducted on July 10, 2024, on-site before the inspection team left the facility. The inspection team provided an overview of the observations made including: Lab waste bottles/containers were not labeled as hazardous waste. Secondary containment in Tank Farm appears to not be sealed. Contingency plan lists emergency contacts as the "shift leaders." Contingency plan does not list the hazardous waste tank as an area where hazardous waste is stored. See ATTACHMENT 1: Digital Images taken by EPA Region 1 during the inspection Page 20 of 20 EPA RCRA Inspection Checklist Version 1a - November 17, 2015