Document DvnjK8jgjJnRbvJY17wmQ4Qgd

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At SIOUX CITY FORD LINCOLN 3601 Singing Hills Blvd Sioux City, Iowa 51106 (712) 222-1813 EPA ID Number IAR000522466 On November 9, 2022 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division (ECAD), I conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Sioux City Ford Lincoln, located in Sioux City, Iowa, on November 9, 2022. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. During the inspection, I collected the information and data necessary to determine compliance with the applicable regulatory and statutory requirements. This report and attachments present the results of the CEI. 2.0 PARTICIPANTS Sioux City Ford Lincoln: Roxanne Flammang, Controller Walker Carrigan, Service Manager EPA: Mark Holcomb, Civil Investigator/Inspector (SEE) 3.0 INSPECTION PROCEDURES On November 9, 2022, I arrived unannounced at the business's main entrance at about 0930 hours. Initially I conducted a visual reconnaissance of the facility searching for areas of concern observable from the adjacent public roadways and parking lots. I identified no environmental issues or concerns during this preliminary examination. I introduced myself to the receptionist and asked to meet with the Office Manager or the Service Manager. I was introduced to the Service Manager, Mr. Walker Carrigan. Mr. Carrigan escorted me to their administrative offices and introduced me to Roxanne Flammang. Ms. Flammang stated that she was the dealership's Controller and had been with Sioux City Ford Lincoln for eight years and was listed as the site contact for hazardous waste on the EPA Notification Acknowledgement Verification Report. Mr. Carrigan told me he was the Service Manager and functioned as the technical point of contact for hazardous waste and that he had been with Sioux City Ford Lincoln in this role for four years. Mr. Carrigan told me there were currently no specific COVID-19 visitor requirements and no specific safety personal protective equipment requirements at this facility. At the opening conference, I presented my EPA ID and credentials. I next explained the purpose and procedures of the inspection. I presented Ms. Flammang and Mr. Carrigan with a copy of RCRA Section 3007(a), which provides inspection authority. I explained my need to collect accurate information and presented him with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I made them aware of their confidentiality rights and informed them that a Confidentiality Notice would be provided at the end of the inspection to make a confidentiality claim if they so desired. Mr. Carrigan acted as the facility representative during the course of the inspection including the visual part of the inspection. Ms. Flammang was present for the opening and exit briefing parts of the inspection. The inspection CEI consisted of a discussion of facility operations, waste generation, and waste management; a visual inspection of active waste generation and management areas; and a review of waste management records. I conducted a visual inspection of the following areas: x Outside Northeast Lot Dumpster Area x Northeast Side of Building Storage Area x Technician's Part Center x Furnace Room x Main Shop Bay x Waste Oil Tank Room x Quick Lane Pit x Outside North Lot Spent Tire Storage Area x Parts Receiving Area Spent Batteries Storage Area See Attachment #1 for the aerial and map views of the facility. Document photocopies and photographs were collected as inspection documentation (see Attachments #1-15 and Photos 1-13). The photo log is included in Attachment #2. Information collected during the inspection is documented on an Entry/Exit checklist, the hazardous waste compliance checklists, and in a notebook. I reviewed documents including the following: Safety Data Sheets (SDS); invoices; and manifests. I followed the inspection procedures detailed in the RCRA CEI Standard Operating Procedure 2321.01E, unless noted otherwise. At the conclusion of the inspection, I summarized my findings and recommendations with Ms. Flammang and Mr. Carrigan. I provided Ms. Flammang with a Receipt for Documents (see Attachment #3), a Confidentiality Notice (see Attachment #4), and a Notice of Preliminary Findings (NOPF) (see Attachment #5), which she signed as acknowledgement of receipt. No claim of confidential business information was made by Ms. Flammang. 2 I provided inspection and compliance assistance documents to Ms. Flammang and Mr. Carrigan during the inspection, some as paper versions and some in electronic PDF via email, that included the following: x RCRA Section 3007(a) (EPA Handout) x Title 18 U.S. Code, Sections 1001 and 1002 (EPA Handout) x Confidentiality Notice (Top page of the completed carbonless transfer set) x Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA In Connection with Inspections (EPA Handout) x Receipt for Documents and Samples (Top page of the completed carbonless transfer set) x Notice of Preliminary Findings (NOPF) with Instructions for Responding on back of form (top page of the completed carbonless transfer set) x Instructions for Responding to a NOPF (EPA Handout) x U.S. EPA Small Business Resource Information Sheet (EPA Handout) x Solvent-Contaminated Wipes Final Rule Chart (EPA Handout) x Recycling Electronics (Iowa Department of Natural Resources - IDNR Handout) x Lead-Based Paint Activities (IDNR Handout) x Excluded Solvent-Contaminated Wipe Rule (IDNR Handout) x Battery Recycling/Disposal (IDNR Handout) x Management of Fluorescent Lamps for Businesses (IDNR Handout) x Incompatible Chemicals (IDNR Handout) x Universal Wastes Including Aerosol Cans (IDNR Handout) x TCLP Waste Determination Testing (IDNR Handout) x Industry Sector Notebooks (EPA Handout) x Environmental Compliance Assistance Centers (EPA Handout) x eManifest Fact Sheet (EPA Handout) x RCRA Online A Quick Reference Guide (EPA Handout) x Requirements for Used Oil Management Standards (EPA Handout) x Emergency Response Program (EPA Handout) x Commercial Motor Vehicle Transportation System Security & Safety x Security Awareness (EPA Handout) x Chemical Facility Anti-Terrorism Standards (Homeland Security Handout) x Iowa Life/Changing Iowa Department of Economic Development - Iowa Environmental Guide for Business 4.0 FINDINGS AND OBSERVATIONS 4.1 Facility Information and Operations Sioux City Ford Lincoln is a Ford Lincoln automotive dealership with a service center. Sioux City Ford Lincoln is privately owned with HHB Properties LLC listed as the owner. Mr. Carrigan stated that the facility began operations at this new location in 2010. The facility is approximately 35,000 square feet and has about 100 employees, operating daytime hours, six days per week. See Attachment #1 for the facility aerial map views and facility diagrams. See Photo 6 for a Main Shop Bay overview. 3 4.2 RCRA Status Sioux City Ford Lincoln has not been inspected for RCRA compliance prior to this inspection. According to the RCRAInfo Notification Acknowledgement/Verification Report, Sioux City Ford Lincoln last notified as a Very Small Quantity Generator (VSQG) on May 30, 2017. I verified the Notification Acknowledgement/ Verification form with Ms. Flammang and Mr. Carrigan with only minor contact updates made (see Attachment #6). At the time of this inspection, I determined Sioux City Ford Lincoln to be a non-generator of hazardous waste (HW). In addition, Sioux City Ford Lincoln appears to be a small quantity handler of universal waste (SQHUW) batteries, and a generator of used oil. Post inspection, after a hazardous waste determination on an unknown drum was completed, it appears they may be a VSQG of hazardous waste with less than 100 kg or 220 lbs of non-acute hazardous waste generated per month, with waste codes: D001, D008, and D018. 4.3 Facility Waste Streams and Management Mr. Carrigan stated that the generation of the waste streams below are generally consistent from month to month. During the visual inspection I did not observe any spent fluorescent lamps, Mr. Carrigan stated that they had completely switched over to LED lights. The following waste streams are managed by Sioux City Ford Lincoln: Unknown Drum - During the visual inspection, I observed a black 55-gallon drum located outside near the northeast wall next to the used oil filters and scrap metal containers (see Photo 2). The drum had no visible labels. The drum appeared to be about 3/4 full, with no obvious damage or leaks. I asked Mr. Carrigan what was in the drum and how long it had been there. He stated that he did not know what was in the drum and was not sure how long it had been there or where it came from. I listed a finding to do a hazardous waste determination on the drum's contents. NOPF 4: Failure to make a hazardous waste determination on the unknown contents of the black 55-gallon drum on the northeast side of shop as required in 40 CFR 262.11(a) Post-inspection, on November 16, 2022, Mr. Carrigan sent me an email stating that they had completed the hazardous waste determination on the unknown liquid in the black 55-gallon drum and determined it to be "contaminated gasoline". He attached a copy of the Manifest from Safety Kleen used to transport the drums (see Attachment #15). It was not possible to determine the estimated generation rate since Mr. Carrigan did not have any additional information on when or how it was generated. A review of RCRAInfo showed no eManifests for Sioux City Ford Lincoln over the last three years. The new Manifest for this shipment (shipped on November 16, 2022) indicates they shipped two drums, with "100 gallons", approximately 600 pounds (estimated at 6 pounds per gallon) of "UN1263 Petroleum Distillate", with waste codes: D001, D008, and D018. The drums were transported by Safety Kleen to Safety Kleen, Inc. in Springfield, Kentucky, for H061 processing (fuel blending prior to energy recovery). As noted above, I only observed one unlabeled drum during the visual inspection, but Mr. Carrigan stated that they had found another drum, apparently with the same contents, in another location, and 4 shipped both out at the same time. The shipment of the estimated 600 pounds of hazardous waste in November 2022, with no additional information on the actual months of generation of this waste, could move them up to a small quantity generator (SQG) status for the month of November, or warrant notifying as an episodic event to maintain at least a very small quantity generator (VSQG) status. This may require additional EPA review. Used Oil - Sioux City Ford Lincoln estimates that they complete an average of 1000 vehicle oil changes per month and generate approximately 1500 gallons per month (estimated at six quarts per oil change) as part of their auto servicing process. See Photo 10 for a view under their "Quick Lane" oil changing service center. Onsite the used oil is collected and transferred into two large 10,000-gallon above-ground tanks located in the Used Oil Tank Room (see Photo 8). During the visual inspection, I observed two 10,000-gallon steel used oil tanks inside of a basement level concrete secondary containment room. Both tank gauges indicate about 85% full. Both tanks were labeled with "Used Oil". I noted a possible oil leak from right tank (see Photo 9). Photo 9 is a closeup view of right tank from previous Photo 8 that showed both tanks. I observed a 2-foot by 4-foot oil stain on the floor with oil absorbant scattered around it. There was no obvious current leak noted. The apparent oil stain appears mostly dry, but still shiny. Initially I issued a finding for the apparent oil leak: NOPF 3: Must maintain used oil tanks in good condition and free of leaks - possible small leak noted on 10,000-gallon tank - as required in 40 CFR 279.22(b)(2). After additional review, this NOPF was rescinded due to 1) the apparent leak was on concrete inside of a concrete containment room and did not make contact with the environment; and 2) Mr. Carrigan sent me an email on November 16, 2022, stating that he had cleaned up the oil stain area and rechecked it the following week and he did not observe any new oil leaking. Additionally, he attached a photograph showing no leaking or oil staining. The used oil in the 10,000-gallon tanks is then transferred to the 400-gallon used oil feeder tank in the Furnace Room (see Photo 5). During the visual inspection I observed a 400-gallon used oil tank, indicating about 1/2 full, located inside of a yellow steel secondary containment vessel. Mr. Carrigan stated that this 400-gallon tank was a feeder tank for the two space heaters in Photo 4. Both the tank and the fill pipe were labeled with "Used Oil" and appeared to be in good condition with no obvious leaks. The dual used oil-burning space heaters were two Clean Burn CB350 CTB units (see Photo 4), which the manufacture states are UL listed at 350,000 BTU each. Combined this would be 700,000 BTU, which appears to exceed the maximum allowable of 500,000 BTU per EPA regulation. Initially, I issued a finding for the 500,000 BYU exceedance: NOPF 1: The onsite used oil space heater may not exceed 500,000 BTU (the individual units are 350,000 BTU, each for a combined 700,000 BTU), as required in 40 CFR 279.23(b). After additional review, this NOPF was rescinded due to it appears that this regulation applies to the maximum BTU output per each unit, not the combined total of both units. See Attachment #8 for a September 30, 2022, invoice from Master Burn (Sioux Falls, South Dakota) for burner maintenance. Used Oil Filters - Sioux City Ford Lincoln generates an estimated 1000 used oil filters per month during their automotive servicing process. The used oil filters are hot drained and crushed in a hydraulic oil filter crusher (see Photo 11). The crushed oil filters are transferred to the outside blue container with the black lid seen in Photo 2. During the visual inspection this container was observed to be about full and in good condition. The spent oil filters are 5 processed monthly by Safety Kleen (Dallas, Texas) and sent to Oil Filter Recyclers in Astoria, Illinois for recycling. See Attachment #12 for the October 27, 2022, invoice. Used Anti-Freeze - Sioux City Ford Lincoln generates between 500 to 750 gallons per year of used anti-freeze during their automotive servicing process. The spent anti-freeze is transferred to an outside 250-gallon tote. During the visual inspection the tote was observed to be about full and in good condition (see Photo 2). The used anti-freeze is considered non-hazardous with no waste codes listed. It is transported by Safety Kleen (Dallas, Texas) to Safety Kleen Systems Inc. in East Chicago, Indiana for recycling. See Attachment #13 for a March 28, 2022, invoice. Spent Lead-Acid Batteries - Sioux City Ford Lincoln generates 15-20 spent lead-acid batteries per week from the automobile servicing process. Mr. Carrigan stated that the spent lead-acid batteries are core exchanged for a new battery from Johnson Auto Store and sent for recycling. The spent lead-acid batteries generated onsite are managed per 40 CFR Part 266, Subpart G. During the visual inspection, I observed six spent lead-acid batteries on plastic sheeting on a shelf in the Parts Receiving area pending pickup by the auto parts store (see Photo 13). The spent batteries appeared to be in good condition with no leakage noted. Reusable Solvent-Contaminated Cloth Rags - Sioux City Ford Lincoln generates reusable cloth shop rags during the vehicle maintenance process. Mr. Carrigan estimates that they generate 250 to 300 rags per week. They have determined these to be hazardous and process them according to the excluded solvent-contaminated wipes rule and send them to a commercial laundry for cleaning and return. Mr. Carrigan stated that the primary solvent that is used with the rags is Brake and Parts Cleaner. See Attachment #7 for an SDS for the Wurth Brake and Parts Cleaner. The SDS indicates the primary content solvent is >90% Heptane. I do not see Heptane listed on the F001-F005 solvent's list, but the flash point is listed at 16 degrees F, which meets the ignitable D001 characteristic and appears to qualify the rags for the excluded solventcontaminated wipe rule. Onsite they collect the rags in six 14-gallon red step cans with closed tops. Mr. Carrigan stated that they make sure they are not saturated with solvent. The rags are transferred to a larger container near the Technician's Parts Center (see Photo 3) and are then picked up by Max Walker Uniform and Apparel Rental weekly for laundering (see Attachment #10 for the November 1, 2022, invoice). During the visual inspection, I observed a 14-gallon red step can for soiled cloth rags in the Shop area (see Photo 7). The step can was closed and about 1/10 full. No free liquids were noted. There was also no "Excluded Solvent-Contaminated Wipes" label. The larger Shop cloth rag station in the Technician's Parts Center had clean rags on the top and used rags in the closed container on the lower section, which appeared to be about full. The rags also appeared to be dry. NOPF 2: Red step cans with solvent contaminated rags must be labeled "Excluded Solvent-Contaminated Wipes" as required in 40 CFR 261.4(a)(26) In a post-inspection email dated November 16, 2022, Mr. Carrigan informed me that they had labeled all their used rag step cans with "Excluded Solvent-Contaminated Wipes" labels and included photos. 6 Scrap Metal - Sioux City Ford Lincoln generates scrap metal as part of the auto repair process. Onsite the scrap metal is stored in a roll-off outside near the Northeast Side of building (see Photo 2). See Attachment #9 for a June 22, 2022, invoice that shows 4020 pounds of scrap metal being processed by Sioux City Compressed Steel (Sioux City, Iowa). During the visual inspection I observed a ten-foot-long metal skip container about full of scrap metal (see Photo 2). Mr. Carrigan stated Sioux City Compressed Steel periodically picks up the scrap metal and takes it to their local scrap yard for recycling. Waste Tires - Sioux City Ford Lincoln generates about 200 spent or damaged tires per month. Mr. Carrigan stated that the spent or damaged tires are stored onsite in the outside in the North lot. During the visual inspection I observe about 40-50 waste tires in a fenced storage area (see Photo 12). The tires are periodically sent to Liberty Tire Recycling for recycling. See Attachment #11 for the September 24, 2022, invoice. Cardboard - Sioux City Ford Lincoln generates recyclable cardboard from packaging. Mr. Carrigan estimated that the facility generates about eight cubic yards per week and stores it initially in the container shown in Photo 2 and then transfers it to an eight-cubic-yard dumpster of cardboard. During the visual inspection I observe the eight- cubic yard dumpster in Photo 1, which was about 3/4 full. The cardboard is collected weekly by Gill Hauling in Sioux City, Iowa, for recycling. General Trash - Sioux City Ford Lincoln generates general trash by routine business operations. Mr. Carrigan estimated that the facility generates about eight cubic yards per week and stores it an eight-cubic-yard dumpster in the northeast lot. During the visual inspection I observe the eight-cubic-yard dumpster in Photo 1 in the northeast lot, which was about full. The trash is collected weekly by Gill Hauling in Sioux City, Iowa, and transported to the local landfill. See Attachment #14 for the October 1, 2022, invoice. 4.4 Other Areas Reviewed Outside Facility Perimeter - I conducted a limited inspection of the outside perimeter of the facility and observed no hazardous waste storage tanks and containers except as noted above. See the aerial and map views in Attachment #1. Preparedness and Prevention - Sioux City Ford Lincoln has several fire extinguishers throughout the facility. The management of safety equipment appeared to be satisfactory. 5.0 SUMMARY OF FINDINGS 1. NOPF 1: RESCINDED 2. NOPF 2: Red step cans with solvent contaminated rags must be labeled "Excluded Solvent-Contaminated Wipes" as required in 40 CFR 261.4(a)(26) 3. NOPF 3: RESCINDED 7 4. NOPF 4: Failure to make a hazardous waste determination on the unknown contents of the black 55-gallon drum on the northeast side of shop as required in 40 CFR 262.11(a) Other than the items specifically noted in this narrative, I observed no additional issues or potential findings. However, further EPA review may change or add to my findings. MARK HOLCOMB HOLCOMB (Affiliate) Digitally signed by MARK (Affiliate) Date: 2022.12.15 13:20:59 ________________-_06_'0_0'_______________________ Mark Holcomb Civil Investigator, SEE Digitally signed by AMBER WHISNANT Date: 2022.12.29 AMBER WHISNANT _____________2_0:1_5_:49_-_06_'0_0'______________________ Amber Whisnant RCRA Section Chief, ECAD/Chemical Branch Attachments: 1) Facility Aerial & Map View (4 pages) 2) Photo Log (4 photos/2 pages) 3) Receipt for Documents (1 page) 4) Confidentiality Notice (l page) 5) NOPF (1 page) 6) EPA RCRA Notification Acknowledgement/Verification Report (1 page) 7) SDS Brake and Parts Cleaner (17 pages) 8) Invoice - Oil Burning Heaters Maintenance (2 pages) 9) Invoice - Scrap Metal (1 page) 10) Invoice - Shop Rags (1 page) 11) Invoice - Scrap Tires (1 page) 12) Invoice - Used Oil Filters (3 pages) 13) Invoice - Used Anti-Freeze (4 pages) 14) Invoice - General Trash (1 page) 15) Manifest - Contaminated Gasoline (2 pages) 8