Document DvkDZG7ErGbp8p75rDLQN3zMn

Inspection Date(s): Time: Program: Regulatory Program(s): REGION 10 Enforcement Division INSPECTION REPORT 08/31/2021 - 08/31/2021 Announced: No Entry: 09:25 AM (PT) Exit: 04:00 PM (PT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY; WASHINGTON STATE REGULATIONS Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) (City, state, zip code) County: CRANE CO ELDEC CORP MARTHA LAKE 16700 13TH AVE W LYNNWOOD, WA 98037 Aerospace Electronic Manufacturing 29 acres 212000 sq ft 1967 47.846748, -122.253655 Mr. Brian Anderson Manager Facilities Engineering & Environmental 16700 13th Ave W Lynnwood, WA 98037 brian.anderson@craneae.com cc: Ms. Barbara Anderson, Sr EHS Manager barbara.anderson@craneae.com Lynnwood, WA 98037 Snohomish Facility/Site Identifier: Media Number: NAICS: WAD009251042 N/A 334418 - Printed Circuit Assembly Manufacturing Lead Inspector: Katie Bradshaw Digitally signed by KATRINA KATRINA BRADSHAW BRADSHAW Date: 2021.11.03 16:36:10 -07'00' REGION 10 bradshaw.katrina@epa.gov (206) 553-6318 Additional Participants: Jon Jones REGION 10 Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan Date: 2021.11.04 14:25:55 -07'00' Digitally signed by Jennifer A Sullivan REGION 10 Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 7 ELDEC CORP MARTHA LAKE Inspection Date(s): 08/31/2021 - 08/31/2021 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: FCI - Focused Compliance Inspection. This was a Resource Conservation and Recovery Act (RCRA) inspection conducted pursuant to Washington's federally authorized RCRA program. The facility was inspected to evaluate compliance with the organic air emissions standards found in 40 CFR Part 265, Subparts AA, BB, and CC, as incorporated by reference into the Washington Administrative Code (WAC) at 173-303-400. The inspection was conducted as part of the EPA National Compliance Initiative for organic emissions from RCRA facilities. Attendees Title Name Lead Inspector Katie Bradshaw Inspector Jon Jones Sr EHS Manager Barbara Anderson Manager, Brian facilities, Anderson engineering & environmental Phone Email 2065536318 bradshaw.katrina@epa.gov Present in Opening Conf. Yes Present in Closing Conf. Yes (907) 2716329 Jones.Jon@epa.gov Yes Yes (425) 743- barbara.anderson@craneae.com Yes Yes 8693 (425) 308- brian.anderson@craneae.com Yes Yes 4841 Opening Conference EPA Lead Inspector Katie Bradshaw and EPA Inspector Jon Jones arrived at the Eldec Corp Martha Lake facility (Eldec or facility) at 09:25 AM (PT) on 08/31/2021 for an inspection. We presented our credentials to Brian Anderson and Barbara Anderson and informed them that this was an EPA RCRA Focused Compliance Inspection. The table above presents all the inspection participants. During the inspection we looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. Only those areas in which we observed areas of concern or noted other pertinent issues are discussed in this inspection report. We were accompanied for the entirety of the inspection by Brian Anderson and Barbara Anderson. 2 of 7 ELDEC CORP MARTHA LAKE Inspection Date(s): 08/31/2021 - 08/31/2021 Facility/Site Description The Legal Owner is listed in RCRAInfo as Crane Co, at 100 First Stamford Pl, Stamford, CT 06902. The Legal Operator is listed as Eldec Corp, at 16700 13th Ave W, Lynnwood, WA 98037. Additional information can be found on the facility's website at https://www.craneae.com/. Facility Info What type of generator facility verified as? What type of generator facility notified? Safety Training Provided to Inspector(s)? Operating Hours Weather Conditions Number of employees Large Quantity Generator (LQG) verified by Brian Anderson LQG Yes, oxygen deficiency monitors. 24/7, 1st and 2nd shift, skeleton 3rd shift. Cloudy, 50s 850 Process Description Aviation fuel is pumped through meters to test aerospace manufacturing equipment. There is a skid with a pump and heating system, which pressurizes the fuel. Some fuel that is tested undergoes a viscosity change, and then is pumped out to a 500-gallon tank. This fuel is sent a couple times a year to a TSD facility as usable product. The facility does not perform testing or emissions on the tank. The tank is ambient, and has a Nitrogen blanket. Organic hazardous waste includes liquid waste collected into 55-gallon DOT containers from aqueous cleaning units, saponifiers, and some solvent parts cleaning units. The facility also has a stencil wash system, which is not characterized as hazardous waste. There were also smaller lab pack drums containing organic hazardous waste in the Central Accumulation Area. Building(s) Building/Area/Sub-area Bldg 1 Magnetics Process Description Downstairs primarily sensor manufacturing and clean rooms, power and space, some warranty repair work Solvent cleaning Area of Concern No No 3 of 7 ELDEC CORP MARTHA LAKE Inspection Date(s): Bldg 2 PTP assembly Bldg 2A Bldg 3 AEP APP PCC Spray cleaning area Bldg 3 tank Bldg 4 Fuel flow transmitter testing Fuelflow systems 2 Chemical storage Tank Farm 08/31/2021 - 08/31/2021 Upstairs cafeteria, downstairs assembly area, vibe No system Vapor degreasing No Shipping/receiving No Engineering upstairs, R&D work, downstairs No manufacturing Vapor degreasing No Vapor degreasing No Vapor degreasing No No Varnish, coating gets dunked and baked off, once No a year Clean earth pumps it out. 25 gallons. Fuel flow transmitter test facility. Raise temp of Yes fuel, testing done about 175 degrees up to 250, closed loop system. Uncouple hose, some emissions of Jet A vapor, nitrogen. Flow leakage in a hazardous waste satellite Yes containers. Jet A gets emptied daily into a 55- gallon container, but the satellite container does not have a closure device and is an open container. This is a difficult to monitor tank that is visually Yes monitored for leaks weekly. There is also a sensor on the platform for liquid leak detection. CAA No No SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Bldg 4/Fuel flow transmitter testing Contains CBI: No Observation #: KB1-OB-003 Date: 08/31/2021 I observed six, approximately 5-gallon satellite receiver containers, labeled "Hazardous Waste," with funnels open to atmosphere. Each flow leakage container receives any overflow or leakage of jet A fuel from the testing hose when disconnected. The satellite receiver containers are emptied daily into a 55-gallon container. Photo(s) 1. Observation_Image-202108311115091591221993.jpg 4 of 7 ELDEC CORP MARTHA LAKE Inspection Date(s): 08/31/2021 - 08/31/2021 Building: Bldg 4/Fuel flow transmitter testing/Fuelflow systems 2 Contains CBI: No Observation #: KB1-OB-004 Date: 08/31/2021 Fuel condensation tank. Visual monitored for leaks weekly. Sensor to detect amount. If managed as hazardous waste, this tank requires leak detection and repair processes per Subpart CC requirements. On November 2, 2021 I sent an email to Brian Anderson asking if the fuel condensation tank contains hazardous waste. He replied the same day stating that the tank contains used Jet A fuel, which flows back to the tank farm area and is product, not hazardous waste. Photo(s) 1. Observation_Image-2021083111221622161412476.jpg SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Bldg 4 KB1-OB-003 Area: Fuel flow transmitter testing Sub-area: Six flow leakage satellite containers do not have closure devices (open containers). Citations: Sections: Closing Conference Du I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern that I observed during my walk-through inspection of the facility. I answered any questions they had and explained the follow-up process that would take place after the inspection. I requested the following documents to be sent via email: site drawing showing locations of tanks and hazardous waste central accumulation area waste profiles with 10% or more organic content air permits x 3 emissions report for degreasers and spray booths I received all documents on September 9, 2021, which are included in the Documents section attached to this report. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. 5 of 7 ELDEC CORP MARTHA LAKE Inspection Date(s): SECTION V - LIST OF APPENDICES Photo Log Observation_Image202108311115091591221993.jpg 08/31/2021 11:15 AM (PT) Katie Bradshaw Bldg 4/Fuel flow transmitter testing No CBI No PII View of flow leakage container satellite jet A gets emptied daily into 55gallon drum. Does not have closure (open container). Observation_Image2021083111221622161412476.jpg 08/31/2021 11:22 AM (PT) Katie Bradshaw Fuel flow transmitter testing/Fuelflow systems 2 No CBI No PII Fuel condensation tank. Visual monitored for leaks weekly. Sensor to detect amount. 08/31/2021 - 08/31/2021 6 of 7 ELDEC CORP MARTHA LAKE Inspection Date(s): 08/31/2021 - 08/31/2021 Document Log Document Type Document Name Contains Contains Uploaded Date Received CBI PII By Records Review ML-SITE-M Model (1).pdf No No Katie 09/09/2021 Bradshaw Records Review 093282.pdf No No Katie 09/09/2021 Bradshaw Records Review 534676.pdf No No Katie 09/09/2021 Bradshaw Records Review 824864.pdf No No Katie 09/09/2021 Bradshaw Records Review 937186.pdf No No Katie 09/09/2021 Bradshaw Other - SDS 556822-01.pdf NOVEC 72DA.pdf No No Katie 09/09/2021 Bradshaw Other Media ELDEC NOC 10953.pdf Program Permits No No Katie 09/09/2021 Bradshaw Other Media NOC 10837.pdf Program Permits No No Katie 09/09/2021 Bradshaw Other Media NOC 120040 Forward Cleaner, Program Permits signed copy from .pdf No No Katie 09/09/2021 Bradshaw Other - Air May 2021 Vapor Degreaser Emissions No No Katie 09/09/2021 Emissions Summary-Wit.pdf Bradshaw Summary Vapor Degreaser Communications ELDEC Corporation, Requested information 1.pdf No No Katie 09/09/2021 Bradshaw Inspection Reports Field_Notes_WAD009251042v1.0.pdf No No Katie 09/09/2021 Bradshaw 7 of 7