Document Ede683GEb1gvN0m0wy8kZyp0L

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At PROCTOR & GAMBLE DISTRIBUTING-WB DISTRIBUTION CENTER 160 Fawcett Drive West Branch, Iowa 52358 319-339-2076 EPA ID Number: IAR000502047 On January 25, 2023 By TOEROEK ASSOCIATES, INC. For U. S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division INTRODUCTION At the request of the Enforcement and Compliance Assurance Division/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U. S. Environmental Protection Agency (EPA) Region 7, Toeroek Associates, Inc., and its subcontractor CLAENE Group (Toeroek team) conducted a hazardous waste compliance evaluation inspection (CEI) at Proctor & Gamble Distributing (P&G) at 160 Fawcett Drive in West Branch, Iowa. The CEI was conducted under the authority of Section 3007 of the Resource Conservation and Recovery Act (RCRA), as amended. The CEI covered hazardous waste generator requirements, used oil management, and universal waste requirements, as applicable. This report and its attachments present the results of the CEI. PARTICIPANTS P&G: Andres F. Fajardo Roldan - Site Manager Michael Lindley - Agency Program (Entry & Exit briefing only via teleconference) Val Brachert - Site Environmental Schenker Logistics, Inc. (Schenker): Amanda Wilkins - Customer Service Manager Shannon Perteit - General Manager Chad Elder - Maintenance Manager Toeroek Team: Clifford Nelles, Inspector, 816-213-5192 INSPECTION PROCEDURES Prior to the CEI at P&G on January 25, 2023, I conducted a drive-by visual inspection. I did not observe any areas of concern during the drive-by. At approximately 0810 hours, I approached the security gate, contacted the main office by intercom, and explained the purpose of the CEI. Office personnel released the security gate so I could enter, and contacted Mr. Roldan to inform him of my arrival. Approximately 10 minutes later Mr. Roland and Mr. Elder met me in the main office lobby. I introduced myself and explained that I was there to conduct a hazardous waste CEI at the facility. We then went to a conference room where I conducted an entry briefing with facility representatives. The facility is owned by P&G and operated by Schenker. Mr. Roldan and Ms. Brachert participated in the entry briefing for P&G, and Mr. Lindley participated by teleconference. Mr. Perteit and Ms. Wilkins participated in the entry briefing for Schenker. During the entry briefing, I presented my business card and EPA credentials to Messrs. Roldan and Perteit and Mses. Brachert and Wilkins. I explained the scope and procedures for the CEI. I explained the facility's right to make confidentiality claims for any or all the information obtained and provided a Notice Regarding Proprietary/Confidential Business Information. I stated that at the conclusion of the CEI, Mr. Roldan would be presented with a Confidentiality Notice (Notice) with which he could make or not make a claim of confidentiality for the facility. I also provided Messrs. Roldan and Perteit and Mses. Brachert and Wilkins with a copy of U. S. Federal Codes 1001 and 1002, concerning communication of false statements and documents to federal inspectors, and RCRA Section 3007, explaining EPA's inspection authority, both of which they read. A copy of each of the following documents was left with Mr. Roldan during the inspection: x RCRA Facility Access Information Sheet x Mr. Trevor Urban's business card x RCRA Section 3007 x U.S. Federal Codes 1001 and 1002 x Instructions for Responding to a Notice of Preliminary Findings x Notice Regarding Proprietary/Confidential Business Information x E-Manifest Fact Sheet: Generators x Managing your Hazardous Waste: A Guide for Small Businesses x U.S. EPA Small Business Resources Information Sheet x Solvent-Contaminated Wipes Final Rule Summary Chart x IDNR Excluded Solvent-Contaminated Wipes Rule: Management Practices for Wipes, Rags, and Shop Towels x Recycling Electronics: A Guide for Businesses x Lead-Based Paint Activities: Handling and Disposal 2 x Battery Recycling/Disposal x Management of Fluorescent Lamps for Businesses x Incompatible Chemicals x Universal Wastes - Including Aerosol Cans x TCLP - Toxicity Characteristic Leaching Procedure x Part 279 Requirements: Used Oil Management Standards x EPA Region 7 Emergency Response Program x Chemical Facility Anti-Terrorism Standards x Iowa Environmental Guide for Businesses I reviewed the Hazardous Waste Site Info Verification Report (Verification Report) with Mr. Roldan (Attachment 1). Based on this review, I did not update the Verification Report. I conducted the visual inspection of the facility, accompanied by Mr. Roldan, Mr. Perteit, Ms. Wilkins, and Ms. Brachert. Following the visual inspection, I reviewed facility records including hazardous waste manifests with land disposal restriction (LDR) notifications, Safety Data Sheets (SDS), contingency plan, and training documentation. I prepared and completed a site-specific inspection checklist to document my observations. At the conclusion of the CEI, I conducted an exit briefing with Messrs. Roldan and Perteit and Mses. Brachert and Wilkins. Mr. Lindley participated in the exit briefing by teleconference. During the exit briefing, I provided a Receipt for Documents and Samples, which Mr. Roldan signed, acknowledging receipt (Attachment 2). I provided Mr. Roldan the Notice, which he signed indicating no confidential business information had been provided (Attachment 3). I also provided Mr. Roldan a Notice of Preliminary Findings (NOPF), which he signed to acknowledge receipt (Attachment 4). A map of the facility obtained during the CEI is included as Attachment 5, and a Google Earth aerial photograph of the facility is included as Attachment 6. The nine photographs taken during the CEI are included in Attachment 7. All of the 9 photographs are used in this report. FINDINGS AND OBSERVATIONS 1. Facility Description and General Information P&G operates as a warehouse and distribution center for consumer products manufactured under the P&G label (such as beauty, health and grooming, baby, fabric, and home care products). The facility receives packaged consumer products from two P&G manufacturing sites in Iowa City as well as contract manufacturers in the area. These products are warehoused, and then shipped to P&G Regional Distribution Centers as needed. P&G has been operating at its current location since 2003, and consists of a single warehouse building with approximately 780,000 square feet under roof. The facility operates 24 hours per day, 7 days per week. Approximately 209 employees (208 Schenker and 1 P&G employee) work one of two 12-hour shifts (6:00 a.m. to 6:00 p.m. and 6:00 p.m. to 6:00 a.m.). P&G's primary 3 North American Industry Classification System (NAICS) code is 493110 (General Warehousing and Storage). Most wastes generated by facility operations are waste consumer commodities. Ms. Wilkins explained that waste consumer commodities are damaged or unwanted products still within the original product packaging. Examples include expired products, products with damaged packaging, and unwanted promotional products. Waste consumer commodities can be hazardous or nonhazardous waste, with hazardous waste determinations based on product knowledge. Nonhazardous waste consumer commodities are primarily stored on warehouse racks and shipped off site for nonhazardous waste disposal. Hazardous waste consumer commodities are accumulated in the hazardous waste container accumulation area (HWCAA) and shipped off site for hazardous waste disposal. Single or small-volume damaged products that cannot be accumulated as waste in their original packaging are containerized upon generation and accumulated in the HWCAA. The wastes are separated into hazardous and nonhazardous wastes, with hazardous waste determinations based on product knowledge. Containerized wastes are shipped off site for hazardous or nonhazardous waste disposal as appropriate. Hazardous wastes generated during routine facility operations include waste aerosol cans and inadvertently broken fluorescent lamps. These wastes are considered hazardous based on product knowledge. Waste aerosol cans are accumulated in satellite accumulation area (SAA) containers in the Maintenance area, and full SAA containers are transferred to the HWCAA. Broken fluorescent lamps and cleanup materials are containerized upon generation and transferred to the HWCAA. These wastes are consolidated with hazardous waste generated as damaged product and are shipped off site as hazardous wastes. Nonhazardous wastes generated during routine facility operations include spent parts washer solvent, used oil, and used oil filters. The facility has one parts washer unit used for general degreasing in the Maintenance area. The parts washer solvent is an aqueous solution that is changed approximately every 3 months during routine servicing. Spent parts washer solvent is considered nonhazardous waste. It is containerized upon generation and immediately transported off site by the service contractor. Used oil generated during routine equipment maintenance is accumulated in a 275-gallon used oil storage container. Used oil filters are hot-drained, and then accumulated in a 55-gallon used oil storage container. Both used oil and used oil filters are managed as used oil according to Title 40 Code of Federal Regulations (40 CFR) Part 279. Used oil and used oil filters are shipped off site for recycling. Equipment and facility maintenance generates waste lamps, waste batteries, and general trash. Waste lamps are considered universal waste according to 40 CFR Part 273, and are accumulated in fiberboard universal waste accumulation containers. Waste lamps are shipped off site for recycling. Waste lead-acid batteries are generated from replacing batteries in fork trucks and emergency lighting. Waste lead-acid batteries are managed according to 40 CFR Part 266 Subpart G, and are shipped off site for reclamation. Waste batteries other than lead-acid batteries are primarily waste consumer commodities but may also include waste batteries generated at the facility. These batteries are considered universal waste according to 40 CFR Part 273, and are 4 shipped off site for recycling. General trash is considered nonhazardous and is accumulated in various containers and a compactor. General trash is collected for landfill disposal. The facility was last inspected on June 27 & 28, 2016 by an EPA contractor with no preliminary findings. 2. RCRA Status P&G is identified on the Notification Acknowledgement/Verification Report provided by EPA (Attachment 1) as a large quantity generator (LQG) of hazardous waste (generating more than 1,000 kg of hazardous waste per month). According to Ms. Wilkins, P&G is currently operating as a LQG of hazardous waste. Hazardous wastes shipped from P&G are generally manifested separately from nonhazardous wastes. During the CEI, I reviewed all hazardous waste manifests from calendar year 2020 through 2023 to date. A copy of a hazardous waste manifest tracking sheets for calendar years 2020 to date (tracking the manifest number, shipping date, designated facility, and manifest return date) is included as Attachment 8. For the purpose of this CEI, I determined P&G's hazardous waste generator status from the 2022 manifests and the 2021 Biennial Report (Attachment 9). The primary hazardous wastes generated at P&G are hazardous waste consumer commodities that are damaged, expired, or otherwise unwanted. Types and quantities of hazardous waste consumer commodities vary significantly from month to month. However, generation rates of all hazardous waste consumer commodities are solidly within LQG status. For example, the 2021 Biennial Report shows 64,996 pounds (29,482 kg) of Flammable Aerosols (Attachment 9, Page 4) and 24,366 pounds (11,052 kg) of expired aerosols (Attachment 9, Pages 6 and 7) were shipped off site in 2021. Therefore, I determined that P&G is operating as a LQG of hazardous waste and inspected the facility as such. I also determined during the CEI that P&G is operating as a SQH of universal waste and a used oil generator. P&G has one SAA for accumulation of hazardous waste aerosol cans. All other hazardous wastes are accumulated in the HWCAA. I inspected the SAA and HWCAA during the CEI. 3. Waste Streams This section of the CEI report describes the waste streams generated by the facility, including the facility's waste determination and waste codes, generation process and rate, management at the facility, and ultimate disposition. The following discussion of waste streams is based on conversations with facility representatives, the visual inspection, and my review of waste shipping documents. Messrs. Roldan and Perteit and Mses. Brachert and Wilkins accompanied me during the visual inspection. Mr. Elder joined the CEI during the visual inspection of the Maintenance area. All inspection participants were provided a copy of U.S. Federal Codes 1001 and 1002, which they read. Hazardous waste consumer commodities include damaged, expired, or otherwise unwanted consumer products within original packaging that are considered hazardous waste. Ms. Wilkins makes hazardous waste determinations for all waste consumer commodities based on product knowledge. Hazardous waste consumer commodities are typically D001, D003, and/or other 5 hazardous waste codes as applicable. The monthly generation rate varies significantly. The waste is collected by Heritage Environmental Services, (Heritage) and transported to Heritage in Indianapolis, Indiana, for incineration or bulking and transfer to another site. Hazardous waste consumer commodities were most recently collected on January 24, 2023. Hazardous waste consumer commodities are accumulated in the HWCAA upon generation. During the CEI, I observed no hazardous wastes accumulating in the HWCAA. Ms. Wilkins stated that hazardous waste consumer commodities had not been generated since the date of the last shipment (January 24, 2023). I asked Ms. Wilkins how the hazardous waste determinations are made. She explained that waste profiles have been established based on product knowledge (for example, information from the Safety Data Sheet [SDS] or discussions with Heritage personnel). Ms. Wilkins maintains waste profile information and other related information (such as example container labels for each waste stream) in a binder at the HWCAA. I reviewed the binder and noted no concerns with the profiled waste streams. Nonhazardous waste consumer commodities include damaged, expired, or otherwise unwanted consumer products within original packaging that are considered nonhazardous waste based on product knowledge. Nonhazardous waste consumer commodities are manifested separately from hazardous waste consumer commodities. A generation rate was not determined during the CEI, as quantities generated and shipped off site vary significantly from month to month. However, the rate is much higher than the hazardous waste consumer commodities generation rate. The waste is collected by Heritage and transported to Heritage in Indianapolis, Indiana. Nonhazardous waste consumer commodities were most recently collected on January 24, 2023. Nonhazardous waste consumer commodities are accumulated on warehouse shelving or in the HWCAA prior to shipment off site for disposal. I did not observe any nonhazardous waste consumer commodities on warehouse shelves during the CEI. Containerized hazardous wastes include single or small-volume hazardous waste products that are damaged or otherwise unwanted or that cannot be accumulated in original packaging. This category of waste also includes waste aerosol cans and inadvertently broken waste lamps (with cleanup materials) that are generated through routine facility operations. Ms. Wilkins makes hazardous waste determinations for all containerized hazardous wastes based on product knowledge. Containerized hazardous wastes are typically D001, D002, D003, D009, U205, and/or other hazardous waste codes as applicable. The monthly generation rate varies significantly. The waste is collected by Heritage and transported to Heritage Environmental, in Indianapolis, Indiana, for incineration or bulking and transfer to another site. Containerized hazardous waste was most recently collected on January 24, 2023. Containerized hazardous wastes are accumulated in the HWCAA upon generation, except for aerosol cans generated during facility operations. During the CEI, I observed no hazardous wastes accumulating in the HWCAA. 6 Waste aerosol cans are generated by facility maintenance activities such as painting. The facility considers waste aerosol cans hazardous (D001) based on product knowledge. Waste aerosol cans are accumulated in a SAA container in the Maintenance area upon generation. The monthly generation rate varies significantly. The waste is collected by Heritage and transported to Heritage Environmental, in Indianapolis, Indiana, for incineration or bulking and transfer to another site. I did not determine the date of last shipment. During the CEI, I observed a 55-gallon SAA container in the Maintenance area for accumulation of waste aerosol cans (Attachment 7, Photograph 3). The SAA container was near the point of generation, under control of the operator, closed, and held approximately 15 gallons of waste aerosol cans. The SAA container was labeled with the words "hazardous waste" and with an indication of the nature of the hazard. I physically inspected several cans within the SAA container and noted that they were empty. I observed a second 55-gallon SAA for empty aerosol cans in the Maintenance area (Attachment 7, Photograph 4). The SAA container was near the point of generation, under control of the operator, closed, and held approximately 15 gallons of waste aerosol cans. The SAA container was labeled with the words "hazardous waste" and with an indication of the nature of the hazard. I physically inspected several cans within the SAA container and noted that they were empty. I asked Ms. Wilkins why the facility maintained two 55-gallon SAA containers in the Maintenance area SAA. She stated that the hazardous waste vendor wants white lithium empty aerosol cans accumulated separately from other waste aerosol cans. Ms. Wilkins also stated that when the volume of waste accumulated in the two SAA containers exceeds a total of 55 gallons, one of the SAA containers would be transferred to the HWCAA within three days. I observed no deficiencies related to waste aerosol cans during the CEI. Containerized nonhazardous wastes include single or small volume nonhazardous products that are damaged or otherwise unwanted or that cannot be accumulated in original packaging. Ms. Wilkins makes hazardous waste determinations for all containerized nonhazardous wastes based on product knowledge. The monthly generation rate varies significantly, and a monthly generation rate was not determined during the CEI. The waste is collected by Heritage and transported to Heritage in Indianapolis, Indiana, for incineration or bulking and transfer to another site. Containerized nonhazardous wastes are accumulated in the HWCAA upon generation. During the CEI, I observed no wastes accumulating in the HWCAA. Spent parts washer solvent is generated from a single parts washer unit in the Maintenance area during routine servicing. The parts washer unit is used for general degreasing and contains Mirachem 500 Cleaner/Degreaser (an aqueous solvent). A copy of the SDS for Mirachem 500 Cleaner/Degreaser is included as Attachment 10. The facility considers spent parts washer solvent nonhazardous based on product knowledge. Approximately 14 gallons of spent parts washer solvent are generated every 3 months. Heritage-Crystal Clean (HCC) services the parts washer unit and transports the spent solvent to HCC in Davenport, Iowa, for recycling. During the CEI, I observed the parts washer unit in the Maintenance area and observed no deficiencies related to spent parts washer solvent (Attachment 7, Photograph 1). 7 Used oil is generated during routine maintenance of facility machinery and fork trucks. The facility manages used oil per requirements of 40 CFR Part 279. The facility accumulates used oil in a 275-gallon used oil storage container in the Maintenance area. Approximately 200 gallons of used oil are pumped from the used oil storage container every 6 months. Used oil is pumped by HCC and transported to HCC in Monee, Illinois, for recycling. During the CEI, I observed the 275-gallon used oil container in the Maintenance area (Attachment 7, Photograph 2). The used oil container held approximately 50 gallons of used oil, appeared to not be damaged or leaking, and was labeled with the words "used oil." Used oil filters are generated through routine maintenance of facility machinery and fork trucks. Used oil filters are hot-drained, but not punctured, crushed, or disassembled. The facility manages used oil filters as used oil per requirements of 40 CFR Part 279. Used oil filters are accumulated in a 55-gallon used oil storage container after hot-draining. Approximately 55 gallons of used oil filters are shipped offsite every 3 months. Used oil filters are collected by HCC and transported to HCC in Monee, Illinois, for recycling. During the CEI, I observed a 55-gallon used oil storage container in the Maintenance area (Attachment 7, Photograph 5). The used oil storage container held one used oil filter that was hot-drained, but not punctured, crushed, or disassembled. The used oil storage container was structurally sound with no apparent leaks or damage. However, the used oil storage container was not labeled with the words "used oil," as required by 40 CFR Part 279 (NOPF No. 1). I provided compliance assistance regarding management of used oil. During the CEI, employees of Schenker affixed labeling with the words "used oil" to the used oil storage container (Attachment 7, Photograph 9). Waste lamps are generated through facility maintenance, and are considered universal waste per 40 CFR Part 273. Waste lamps are accumulated in universal waste accumulation containers near the HWCAA. An estimated 200 to 300 waste lamps are generated every 6 months. Universal waste lamps (UWL) are collected by Heritage and transported to Heritage in Indianapolis, Indiana, for recycling. During the CEI, I observed nine UWL accumulation containers holding waste 4-foot and nonlinear lamps (Attachment 7, Photographs 6 through 8). All UWL accumulation containers were structurally sound, closed, labeled with the words "universal waste lamps," and marked with an accumulation start date of January 17, 2023 (Attachment 7, Photograph 8). I noted no deficiencies regarding management of waste lamps during the CEI. Waste batteries (non-lead-acid) are primarily waste consumer commodities and are unused. All non-lead-acid waste batteries are managed as universal waste per requirements of 40 CFR Part 273. Waste batteries are accumulated in universal waste accumulation containers near the HWCAA. The generation rate varies significantly and was not determined during the CEI. Universal waste batteries are collected by Heritage and transported to Heritage in Indianapolis, Indiana, for recycling. I did not observe any waste batteries (non-lead-acid) in accumulation during the CEI. 8 Waste lead-acid batteries are generated during fork truck and emergency lighting maintenance. Waste lead-acid batteries are managed as lead-acid batteries being reclaimed per requirements of 40 CFR Part 266 Subpart G. Waste lead-acid batteries are accumulated in a 1-cubic-yard container near the Maintenance area and are collected by the battery vendor (Interstate Battery of the Quad Cities in Rock Island, Illinois) on exchange for new batteries. Mr. Elder estimated that up to 20 waste lead-acid batteries are generated per month. I did not observe waste lead-acid batteries in accumulation during the CEI. General trash consists of office-type refuse, such as waste packaging materials and food containers. Waste consumer commodities are not considered general trash. The facility has determined that general trash is nonhazardous based on product knowledge. General trash is accumulated in several containers throughout the facility and transferred to a 4-cubic-yard rolloff container or compactor. General trash is collected by Republic Services and transported to Iowa City Landfill and Recycling in Iowa City, Iowa, for landfill disposal. 4. Required Response Equipment and Hazard Management Per 40 CFR 262.15(a)(8) and 262.17(a)(6), a LQG must operate to minimize the possibility of a fire, explosion, or spill, and must maintain emergency response equipment. During the visual inspection, I observed spill response equipment comprised of mats, absorbent materials, shovels, and brooms, as well as the presence and availability of fire extinguishers. I determined that the spill and fire response equipment was adequate for the hazardous wastes generated and accumulated at the facility. 5. Container Accumulation Areas P&G maintains one HWCAA in the Maintenance area. Heritage was at the facility on January 24, 2023, and removed all of the hazardous and nonhazardous waste in the HWCAA. Therefore, the HWCAA was empty at the time of the CEI. Copies of two hazardous waste manifests (dated December 21, 2022) are included in Attachment 11. I reviewed the manifest for the shipment on January 24, 2023, and noted that 173 pounds of waste aerosols (D001) and 2,450 pounds of waste corrosive liquids (D002) were shipped. According to Ms. Wilkins, the HWCAA is inspected weekly and a log is maintained. I reviewed three years of inspection logs and noted no missed inspections. A copy of the inspection log for the month of January 2023 is included as Attachment 11. I asked Mr. Roldan how a worker would summon emergency assistance. He stated that all of the workers who handled hazardous waste carry a two-way radio. 6. Manifests and Biennial Report P&G generated manifests for 42 hazardous waste shipments from January 25, 2020, to January 25, 2023. During the CEI, I reviewed manifests and LDR notifications for five shipments in 2020, five in 2021, five in 2022, and two in 2023. Copies of the manifests for hazardous wastes shipped on December 21, 2022, are included in Attachment 12 as examples. I noted no deficiencies during my review of manifests. 9 The Hazardous Waste Biennial Report for 2021 was submitted in February 22, 2022, and is included in Attachment 9. 7. Preparedness and Prevention Plan LQG facilities are required by 40 CFR 262.17(a) to meet the emergency preparedness, prevention, and procedures requirements including documented arrangements with response agencies. According to Mr. Roldan, P&G is the subject of a regular inspection by the West Branch Fire Department hazardous materials team. During those inspections, he said the fire department is shown the layout of the facility, the location of the hazardous waste HWCAA, and other facility features. During the CEI, I reviewed the facility's 45-page contingency plan. I noted that P&G last updated their contingency plan on May 6, 2021, and Mr. Loran Yoder was listed as the emergency coordinator (Attachment 13). I asked Ms. Wilkins about Mr. Yoder, and she explained that Mr. Yoder was the previous Site Compliance Manager who left the facility approximately six months ago. I determined the facility had not updated the emergency coordinator list in the contingency plan, as required by 40 CFR 262.17(a)(6) referencing 262.261(d) (NOPF No. 2). I provided compliance assistance regarding updates to the contingency plan. I reviewed the rest of the contingency plan against content requirements of 40 CFR 262.261. The contingency plan appeared to meet all other content requirements and included a Quick Reference Guide. Other than the emergency coordinator list in Attachment 13, I did not request a copy of the contingency plan because I noted no other deficiencies during my review. 8. Personnel Training Requirements Personnel training is required by LQG regulations specified in 40 CFR 262.17(a)(7) to ensure that employees are thoroughly familiar with proper waste handling procedures relevant to their responsibilities. During the CEI, I asked Mr. Roldan if hazardous waste training is provided to employees. He stated that hazardous waste management training is provided to all employees who handle hazardous waste within six weeks of hiring or being assigned to a job that handles hazardous waste. He also stated that annual refresher training is conducted. I asked Mr. Roldan who conducts the training. He stated that all training is online with Environmental Resources Management (ERM). Copies of 2021 and 2022 training records for Ms. Wilkins are included in Attachment 14 as examples of the training documentation maintained at the facility. A copy of the Job Description for a Manager Customer Service is included as Attachment 15. I reviewed the written job description for Ms. Wilkins who conducts the inspections and signs the manifest, and noted that the job description does not identify hazardous waste duties or training requirements as required by 40 CFR 262.17(a)(7)(iv)(B) and (C) (NOPF No. 3). NOPF No. 3 was not left with the facility but was added on March 14, 2023. Ms. Wilkins was notified on March 14, 2023 by email and telephone. 10 9. Air Emissions: 40 CFR Part 265 Subparts AA, BB, CC EPA regulations in 40 CFR Part 265, Subparts AA, BB, and CC apply to LQGs. If a LQG manages hazardous waste with an organic concentration greater than 10 parts per million by weight (ppmw), the standards specified in Subpart AA apply to hazardous waste air emissions from certain process vents. A process vent used in distillation, fractionation, solvent extraction, thin-film evaporation, air stripping, or steam stripping is regulated by Subpart AA. P&G is not subject to the Subpart AA regulations because the facility does not have any of the process vents listed above. If a LQG has equipment that contains or contacts hazardous waste composed of 10 percent or greater organics by weight, the facility is subject to Subpart BB standards for inspection and monitoring of the equipment. P&G is not subject to the Subpart BB regulations because it does not have equipment that contains or comes in contact with hazardous waste. The standards found in Subpart CC apply to LQGs that manage hazardous waste in containers with organic compounds (VOC) concentration that exceeds 500 ppmw. The Subpart CC standards are applicable because the facility accumulates hazardous waste that contains VOCs in 55-gallon hazardous waste accumulation containers. During the CEI, I determined that P&G meets the Subpart CC requirements for containers by using Container Level 1 controls (hazardous waste accumulation containers smaller than 122 gallons that are Department of Transportation [DOT]-approved). I noted no concerns with management of hazardous waste per the Subpart CC air emissions requirements. 10. Summary of Preliminary Findings In summary, as part of the CEI, I made the following preliminary findings: (1) Failure to store used oil filters in a container labeled as used oil, as required by 40 CFR 279.22(c)(1) (NOPF No. 1). (2) Failure to update a RCRA Contingency Plan emergency coordinator list when needed, as required by 40 CFR 262.17(a)(6) referencing 262.261(d) (NOPF No. 2). (3) Failure to identify hazardous waste duties or training requirements in written job descriptions as required by 40 CFR 262.17(a)(7)(iv)(B) and (C). Other than items specifically noted in the narrative, I observed no additional issues. However, further review by EPA may change or add to my findings. 11 Digitally signed by Clifford A. Clifford A. Nelles Nelles _____________________D_a_te_:_2_02_3_.0_3._17__12_:0_0_:2_7_-0_5_'0_0'_____ Date:___________________ Clifford A. Nelles, Inspector CLAENE Group Digitally signed by AMBER AMBER WHISNANT WHISNANT _____________________D_a_te_: _20_2_3._03_._27_2_3_:0_1:_0_9 _-0_5'_00_' _____ Date: ___________________ Amber Whisnant, Section Chief ECAD/CB/RCRA, EPA Region 7 Attachments: 1. Hazardous Waste Site Info Verification Report for Inspector (2 pages) 2. Receipt for Documents and Samples (1 page) 3. Confidentiality Notice (1 page) 4. Notice of Preliminary Findings (1 page) 5. Site Map (1 page) 6. Google Earth Photograph of Facility (1 page) 7. Photographic Documentation (Photolog and 9 Photographs) (7 pages) 8. Copy of Hazardous Waste Tracking (4 pages) 9. Copy of 2021 Biennial Report (7 pages) 10. Copy of SDS for Mirachem 500 Cleaner/Degreaser (4 pages) 11. Copy of January 2023 Inspection Log (4 pages) 12. Copies of manifests for shipments on December 21, 2022 (2 pages) 13. Copy of Emergency Coordinators List in RCRA Contingency Plan (1 page) 14. Copy of Training Records for Amanda Wilkins (2 pages) 15. Copy of Job Description for Amanda Wilkins (2 pages) 12