Document Ex1Bg0mG4dKBvJRdry74xr1ER
RCRA Inspection Report
1) Inspector and Author of Report
Alan Newman Environmental Engineer Phone: 404-562-8589 Newman.alan@epa.gov
U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch RCRA Enforcement Section 61 Forsyth Street, S.W. Atlanta, Georgia 30303
2) Facility Information
Techtrix, Inc. 525 Plainview Street Gadsden, Alabama 35901-2027 Etowah County
EPA ID #: ALD982167678 NAICS #: 332813 Electroplating, plating, polishing, anodizing, and coloring
3) Responsible Officials
Joshua B. Sullivan, Esq. Office: (256) 547-7200 Email: josh@kkslawgroup.com
4) Inspection Participants
Pam Beavers Alan Newman
Techtrix, Inc. EPA, Region 4
5) Date of Inspection
January 18, 2024; 1:00 pm - 3:00 pm. C.D.T.
6) Applicable Regulations1
Alabama Hazardous Waste Management and Minimization Act of 1978, Ala. Code 22-30-1 et seq., and rules 335-14-1 to 335-14-17 (2016 and 2018) of the Alabama Department of Environmental Management (ADEM) Administrative Code (ADEM Admin. Code).
As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions alleged herein will be to the authorized State program; however, for ease of reference, the federal citations will follow in brackets.
Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near the point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or without having interim
1 As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions will be to the authorized State program. However, for ease of reference, the federal citations will follow in brackets.
status, as required by Section 22-30-12(b) of the AHWMMA, Ala. Code 22-30-12(b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with ADEM Admin. Code r. 335-14-3.01(6) and (7) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in ADEM Admin. Code r. 335-14-3-.01(5)(a)7. and 8. [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in ADEM Admin. Code r. 335-143-.01(5)(a) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption").
Pursuant to ADEM Admin. Code r. 335-14-3-.01(7) [40 C.F.R. 262.17], a LQG may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 22-30-12(b) of the AHWMMA, Ala. Code 22-30-12(b) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in ADEM Admin. Code r. 335-14-3-.01(7) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption").
Pursuant to ADEM Admin. Code r. 335-14-11-.02(1)(a)244. [40 C.F.R. 273.9], a small quantity handler of universal waste (SQHUW) is a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time.
Techtrix and EPA entered into a RCRA 7003 Administrative Order on Consent (AOC) on September 14, 2021, to address an imminent and substantial endangerment at the facility.
7) Purpose of Inspection
The purpose of this inspection was to conduct an announced focused inspection to determine Techtrix's progress with the current RCRA 7003 CAFO compliance schedule. This was an EPA lead inspection.
8) Facility Description
Techtrix, Inc. (Techtrix or Facility) was founded in 1987 and operates as an electroplating and metal finishing shop. The Facility occupies an 80,000 square foot building and employs approximately eight employees. The facility operates twelve plating lines and a no discharge wastewater treatment system. Techtrix provides zinc, cadmium, copper, tin, nickel, gold, and silver electroplating services. The Facility also performs additional finishing services such as electroless nickel, alodine anodize, zinc phosphate, manganese phosphate, endurion, passivation, and selection brush plating.
Techtrix is a large quantity generator of hazardous waste, a small quantity handler of universal waste, and generator of used oil.
EPA-RCRA CEI Report January 18, 2024
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Techtrix, Inc.
EPA ID# ALD982167678
The following wastes are generated at the Facility:
Number
Waste Stream Description
Reason for Hazardous Waste Determinations
EPA Waste Codes
1 Spent Bright Dip (alkaline) Reactivity, Toxicity, D002, D006, D007, D008,
and Corrosivity
D011, F007, F009
*D003 - as appropriate
2 Spent Bright Dip (acid) Reactivity, Toxicity, D002, D006, D007, D008,
and Corrosivity
D011, F007, F009
*D003 - as appropriate
3 Plating Bath Residues from Plating Tanks Containing Cyanides
Toxicity and Corrosivity
F007, F008, orF009) Characteristic Waste D002
*D003 - as appropriate
4 Debris (including plant Toxicity cleanup: plastic, cardboard, paper, and or rags) from plant without cyanides
D002, D007, D008, D011 *D002 - as appropriate
5 Cadmium Salt Solids bottom of Vats
Electroplating parts Cyanide/Alkaline (D002) salts
D006, D007, D008, D011, F008
6 Spent Bright Dip (acid) Toxicity and
(Chrome Baths)
Corrosivity
D002 and D007
7 Filter Cakes from the
Corrosivity
F006
treatment of
electroplating bathes
8 Filter Cakes from the treatment of Waste Streams #1 and 2
Corrosivity
F006 and F008
9) Previous Inspection History
EPA and ADEM have conducted three RCRA CEIs at the subject facility between 2021 and 2024 and found twenty-nine violations during those inspections. Subsequent to the 2021 CEI, Techtrix and EPA entered into a RCRA 7003 CAFO to ensure compliance.
10) Opening Conference
On January 18, 2024, EPA inspector Alan Newman arrived at Techtrix at approximately 1:00 pm. Pam Beaver, Plant Manager, immediately received the inspector. The inspector introduced themselves, showed their credentials to Pam Beaver, and explained the purpose of the visit.
EPA-RCRA CEI Report January 18, 2024
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Techtrix, Inc.
EPA ID# ALD982167678
The inspector described the anticipated use of a digital camera during the inspection. Pam Beaver provided an update of facility's current operations during the opening conference. The inspection participants also discussed health and safety protocols and required personal protective equipment before Pam Beaver led the inspector on a tour of the Facility operations.
11) Inspection Observations
The inspector toured the areas where waste was being stored and where waste was being treated.
Chemical Storage Area and Former Expired Chemical Storage Area
Techtrix was storing usable chemicals in multiple adjacent areas separated by chain-link fences. The supplies were separated into alkaline cleaners, brighteners and additives, and acids. This area was more organized than the previous visits. The supplies were in orderly rows with labels visible from the adequate aisle ways.
Central Accumulation Areas (CAAs)
The primary purpose of the focused compliance inspection was to view all the CAAs at the facility (Photographs 1-7). There were multiple storage areas inspected including:
Central Accumulation Area
Number of Containers of Hazardous Waste
Waste Stream
CAA 1 Bay Door CAA Solid Hazardous
Waste CAA
Former NonHazardous Waste CAA
31 - 250-gallon totes 29 - 250-gallon totes 9 - 250-gallon totes 2 - 55-gallon containers
1 - Supersack 3 - 250-gallon totes & 3 - 250-gallon totes newly discovered behind equipment
(Unknowns)
CAA 2
Compressor Room CAA
Filter Press
4 - Supersacks of F006 10 - 250-gallon totes 4 - 250-gallon totes 18 - 55-gallon containers of
Solids 8 - 250-gallon totes
WS #3 WS #1 WS #7
Treated Filter Press Supernate
and unknowns
WS #7
Empty Containers
Process Supernate
Oldest Accumulation
Start Date 3/20/2020 3/20/2020 3/20/2020
3/20/2020
9/25/2023 N/A
N/A
Each CAA was being managed with sufficient aisle space, the containers were in good condition, labeled, and closed. There were three 250-gallon totes in the Former non-hazardous waste CAA that were tucked behind some antiquated equipment at the rear of this area and discovered once the forward totes were removed for treatment. The facility was not operating the CAAs
EPA-RCRA CEI Report January 18, 2024
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Techtrix, Inc.
EPA ID# ALD982167678
storing hazardous waste with adequate secondary containment. This is a repeat violation from previous inspections. The facility was storing waste for more than 90 days. This is repeat violation and the subject of the 2021 RCRA 7003 CAFO. Techtrix continues to treat and to discharge treated wastewaters at the site on schedule with the approved compliance milestones submittal.
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Tenn. Comp. R. & Regs. 0400-12-01-.02(1)(b) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11].
Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270].
Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(viii) which incorporates ADEM Admin. Code r. 335-14-6-.09(6)(a), and is a condition of the LQG Permit Exemption, container storage areas must meet the following requirements: (a) Container storage areas must have a containment system that is designed and operated in accordance with 335-14-6-.09(6)(b), except as otherwise provided by 335-14-6-.09(6)(c). (b) A containment system must be designed and operated as follows:
1. A base must underlie the containers which is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed; 2. The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids; 3. The containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater. Containers that do not contain free liquids need not be considered in this determination; 4. Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity in addition to that required in 335-14-6-.09(6)(b)3. to contain any run-on which might enter the system; and 5. Spilled or leaked waste must be removed from the sump or collection area in a timely manner not to exceed 24 hours after detection. Accumulated precipitation must be removed in as timely a manner necessary to prevent overflow of the collection system. Wastewater Treatment Tanks
There are just two tanks remaining onsite that are storing historic waste out of the original eleven: Tanks 7 and 11. As the staff have extra time, the tanks are being cleaned out. The removed waste is stored in the solids CAA area.
EPA-RCRA CEI Report January 18, 2024
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Techtrix, Inc.
EPA ID# ALD982167678
12) Records Review
There were no records reviewed during this site visit.
13) Closing Conference
The inspectors conducted the exit meeting at 3:00 pm with Pam Beaver. During this meeting, the inspectors stated their preliminary conclusions of the inspection.
14) Summary of Observations
During the inspection, observations were made concerning the following RCRA requirements: There were three containers of unknown materials in CAA 2.
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Tenn. Comp. R. & Regs. 0400-12-01-.02(1)(b) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11].
There were multiple containers that had been stored for longer than 90 days.
Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270].
Hazardous waste was being stored in areas that did not have adequate secondary containment.
Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(viii) which incorporates ADEM Admin. Code r. 335-14-6-.09(6)(a), and is a condition of the LQG Permit Exemption, container storage areas must meet the following requirements: (a) Container storage areas must have a containment system that is designed and operated in accordance with 335-14-6-.09(6)(b), except as otherwise provided by 335-14-6-.09(6)(c). (b) A containment system must be designed and operated as follows:
1. A base must underlie the containers which is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed; 2. The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids;
EPA-RCRA CEI Report January 18, 2024
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Techtrix, Inc.
EPA ID# ALD982167678
3. The containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater. Containers that do not contain free liquids need not be considered in this determination; 4. Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity in addition to that required in 335-14-6-.09(6)(b)3. to contain any run-on which might enter the system; and 5. Spilled or leaked waste must be removed from the sump or collection area in a timely manner not to exceed 24 hours after detection. Accumulated precipitation must be removed in as timely a manner necessary to prevent overflow of the collection system.
15) List of Attachments Attachment 1 - Photo Log: 14 Photos taken on: January 18, 2024 Photos taken by: Alan Newman Photographs taken with Lumix Digital EPA Property Tag: S75870
16) Signed
ALAN NEWMAN Date: 2024.05.02 13:34:47 -04'00' Digitally signed by ALAN NEWMAN
Alan R. Newman Environmental Engineer
17) Concurrence
ALAN NEWMAN Date: 2024.05.02 13:35:11 -04'00' Digitally signed by ALAN NEWMAN
Alan R. Newman Acting Chief RCRA Enforcement Section
EPA-RCRA CEI Report January 18, 2024
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Techtrix, Inc.
EPA ID# ALD982167678
Appendix 1
Photograph Log:
Photos taken January 18, 2024 Photos taken by Alan Newman
RCRA CEI Report - Appendix 1- Photograph Log Page 1 of 4 EPA ID No.: ALD January 18, 2024
Photograph 1: CAA 1.
Photograph 4: Former Non-Hazardous Waste CAA.
Photograph 2: Bay Door CAA.
Photograph 5: CAA 2.
Photograph 3: CAA for Solids.
RCRA CEI Report - Appendix 1- Photograph Log Page 2 of 4 EPA ID No.: ALD January 18, 2024
Photograph 6: Compressor Room CAA.
Photograph 7: Filter Press Storage Area.
Photograph 10: Tank 11.
Photograph 8: Filter Press Storage Area.
Photograph 11: Wastewater Treatment Tanks.
Photograph 9: Wastewater Treatment Tanks.
Photograph 12: Wastewater Treatment Tanks.
RCRA CEI Report - Appendix 1- Photograph Log Page 3 of 4 EPA ID No.: ALD January 18, 2024
Photograph 13: Wastewater Treatment Tanks.
Photograph 14: Wastewater Treatment Tanks.
RCRA CEI Report - Appendix 1- Photograph Log Page 4 of 4 EPA ID No.: ALD January 18, 2024