Document JJKErx5zOg729w1nQw1eeV54B
RCRA Inspection Report
1) Inspector and Author of the Report
Daryl R. Himes Environmental Engineer RCRA Enforcement Section Chemical Safety and Land Enforcement Branch Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency, Region 4 61 Forsyth Street, SW Atlanta, Georgia 30303 (404) 562-8993
2) Facility Information
University of North Carolina at Chapel Hill (UNC) 1180 Estes Drive Extension UNC Buildings 488 and 531 Chapel Hill, North Carolina 27599-1650 EPA ID No.: NCD982093783
3) Responsible Official
Catherine Brennan, Executive Director, Environment, Health & Safety (EHS)
4) Inspection Participants
Catherine Brennan Sharon Myers Douglas Benjamin Daryl Himes Aram Kim
UNC Environmental Specialist, EHS, UNC - Main Campus Senior Hazardous Waste Specialist US EPA Region 4 NC Department of Environmental Quality
5) Date of Inspection
July 20 & 22, 2022, 9:00 a.m.
6) Applicable Regulations
North Carolina General Statutes (NCGS), 130A BOA-Article 9 (Solid Waste Management Act as amended Resource Conservation and Recovery Act (RCRA) Section 3005 and 3007 (42 U.S.C. 6925 and 6927) and the North Carolina Administrative Code (NCAC) Title 15 A Chapter 13A, [40 Code of Federal Regulation (C.F.R.) Parts 260-270, 273 and 279].
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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7) Purpose of Inspection
The purpose of this inspection was to conduct an unannounced RCRA compliance evaluation inspection (CEI) to determine the facility's compliance with the applicable regulations.
8) Facility Description
The University of North Carolina at Chapel Hill's Main Campus generates hazardous waste at various research and teaching labs. Hazardous wastes are also generated in pharmacies and clinics operated by the various clinics located in the UNC Health Care System.
The hazardous waste generated from The University of North Carolina at Chapel Hill's Main Campus and clinics is transported (via hazardous waste manifest) to the The University of North Carolina at Chapel Hill's Hazardous Waste Materials Facility (HWMF). The HWMF is a permitted storage facility at 1080 Estes Drive Extension, Chapel Hill, North Carolina. The HWMF includes Buildings 488 and 531. The current permit for the storage facility became effective on September 26, 2016 and expires on September 26, 2026.
Building 488 has a container unloading/loading dock, a consolidation room, and a liquid waste bulking and neutralization area. Building 531 has a container unloading/loading dock, flammable storage room eight hazardous waste storage bays, and several non-hazardous waste storage areas. According to the most recent generator notification submitted to the North Carolina Department of Environmental Quality (NCDEQ), the UNC-Main Campus (the largest contributor of hazardous wastes shipped to the HWMF) is registered as a large quantity generator of hazardous waste.
9) Findings
Upon arriving at the facility, the inspectors presented their credentials to Ms. Catherine Brennan, Executive Director, Environment, Health and Safety and explained the purpose of the inspection. Facility personnel explained the operations of Building 488 and Building 531 and then proceeded to take the inspection team through each of the buildings.
Building 488
Building 488 and 531 are both within a gated chain link fence. Building 488 is approximately 50 feet long by 36 feet wide and is constructed on a concrete slab. The floors in the hazardous waste storage area have been coated with an epoxy sealer that has been determined to be compatible with the stored hazardous waste. Hazardous wastes are initially received into Building 488. Once received, hazardous wastes are inventoried, packaged for storage, or bulked/blended for storage in Building 531. Incoming wastes which are hazardous solely for corrosiveness (D002) might be treated using elementary neutralization under a hood in Building 488.
Wastes coming into Building 488 are in containers up to 30-gallons in size for hazardous wastes and 55-gallons in size for nonhazardous wastes. Upon being received, they are characterized and segregated into waste types which include water reactive, flammable corrosives, alkaline
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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flammable/corrosive, alkaline corrosive, oxidizing acids, acidic corrosives, organic acids, and toxic liquids.
The segregated wastes up to one gallon are then placed into plastic secondary containment pans on storage shelves. These pans are capable of accommodating six to twelve 4-liter bottles, depending on the size of the pan. Individual containers are then placed into plastic lab pack drums located in front of the shelving units until full. Wastes in the lab packing area are consolidated in 2-gallon, 5-gallon, 15-gallon, 30-gallon or 55-gallon lab pack containers (Photo 1).
At the time of the inspection, 55 and 5-gallon containers were being used to manage hazardous wastes which had been characterized and subsequently lab packed into one of these containers. Each of the containers was closed, labeled with the words "Hazardous Waste" and marked with an accumulation start date of less than one year. The oldest date observed on a container in this area was October 5, 2021.
A room for universal wastes was also located in Building 488. The room measured approximately 15 feet by 18 feet. At the time of the inspection, each of the containers were closed, labeled with appropriate universal waste language and marked with accumulation start dates of less than one year.
Loading Dock
No hazardous wastes were observed on the loading dock area to Buildings 488 and 531 at the time of the inspection. A box truck is used to transport hazardous wastes to the facility from the various campuses.
Building 531
The storage area within Building 531 is segregated by three-foot concrete block walls (Photos 2, 3 & 4). Nine separate bays were identified and one bulking area. All containers in this area were labeled with the words "Hazardous Waste" and were closed and marked with an accumulation start date of less than one year unless noted otherwise. Below is a visual inventory of containers observed in this area at the time of the inspection.
Bay 1 had just been painted recently and was empty at the time of the inspection and no wastes were observed in the bay (Photo 2).
Bay 2 had just been painted recently and was empty at the time of the inspection and no wastes were observed in the bay (Photo 2).
At the time of the CEI, inspectors observed that Bay 3 contained nine 55-gallon and two 30gallon containers of hazardous waste flammables in this area. One of the 55-gallon containers in this bay was not marked with an accumulation start date at the time of the inspection.
Pursuant to Part VI (Land Disposal Restrictions) Section A (General Restrictions) of the State of North Carolina Division of Waste Management Hazardous Waste Management Permit Number NCD980093783, the Permittee is required to maintain compliance with the
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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requirements of 40 CFR 268 as adopted in 15A NCAC 13A .0112. [40 CFR 268.50(a)(2)(i)(D)] requires that owners and operators of treatment, storage and disposal facilities, mark each container with the date each period of accumulation begins.
Bay 4 contained four 55-gallon containers of toxic hazardous wastes and two 55-gallon containers of nonhazardous waste.
Bay 5 contained seven 55-gallon containers of hazardous waste corrosives.
Bay 6 contained two 55-gallon and one 30-gallon containers of universal waste batteries each was labeled with proper universal waste labeling and accumulation start dates of less than one year.
Bay 7 contained various radioactive mixed wastes awaiting a reduction in radiation which will allow for their shipment to an off-site treatment, storage, or disposal facility. Mixed wastes by definition are hazardous wastes, characteristic or listed, which contain one or more radionuclides. These generally licensed radiation sources (radionuclides) are authorized at the University under the auspices of the Division of Radiation Protection of NCDEQ. Long-lived mixed wastes are stored at the HWMF until they have decayed below regulated levels. Shortlived mixed waste radionuclides are allowed to decay, then the waste is handled as a hazardous waste. Following radioactive decay to below regulated levels, these wastes are shipped to an offsite hazardous waste disposal facility.
Bay 8 contained six 55-gallon, one 15-gallon and four 5-gallon containers of toxic organic hazardous wastes.
Bay 9 contained fifteen 55-gallon containers of hazardous waste corrosives and one 55-gallon container of used oil labeled as "Used Oil."
In an aisle outside of Bay 9, five universal waste batteries were observed on a low flatbed cart. Only one of the batteries was labeled with universal waste language at the time of the inspection.
Pursuant to 15A NCAC 13A .0119 [40 C.F.R. 273.14(a)], a SQHUW must label or mark each Universal Waste battery or container or tank in which the batteries are contained clearly with one of the following phrases: "Universal Waste - Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."
An intrinsically safe room was also used by the facility to store fifteen 55-gallon containers of ignitable hazardous wastes. One of the containers was not labeled with and accumulation start date at the time of the inspection (Photo 5). The container was subsequently labeled with a start date of 06/10/2022.
Pursuant to Part VI (Land Disposal Restrictions) Section A (General Restrictions) of the State of North Carolina Division of Waste Management Hazardous Waste Management Permit Number NCD980093783, the Permittee is required to maintain compliance with the requirements of 40 CFR 268 as adopted in 15A NCAC 13A .0112. [40 CFR 268.50(a)(2)(i)(D)] requires that owners and operators of treatment, storage and disposal facilities, mark each container with the date each period of accumulation begins.
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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No evidence of spills was observed in Building 531 and aisle space was maintained. The building was equipped with an eye wash station, spill kits and fire extinguishers. The flooring of the building appeared to be free of cracks or gaps during the inspection.
Records Review:
After the walk-through inspection of the facility, a review of the facility's records included a review of hazardous waste manifests for the past two years, the past years hazardous waste training records, weekly inspection logs for the past year and the facility's hazardous waste contingency plan.
During a review of the facility's hazardous waste manifests, it was determined that manifests for numerous shipments of incoming hazardous waste from The University of North Carolina at Chapel Hill (NCD980515308) Main Campus, an off-site large quantity generator, were not being signed upon receipt by the University of North Carolina at Chapel Hill's HWMF (NCD982093783) hazardous waste treatment and storage facility. Attachment B identifies manifests which were not signed upon receipt, the date the shipments left the main campus and the date they were signed as received by the hazardous waste treatment and storage facility. Note that numerous shipments for which the manifest was signed the business day following receipt are not included in this attachment.
Pursuant to Part I Section H.1 (Manifest System) of the State of North Carolina Division of Waste Management Hazardous Waste Management Permit Number NCD980093783, "the Permittee is required to comply with the manifest system when receiving hazardous waste from off-site in accordance with 40 CFR 264.71 as adopted in 15A NCAC 13A .0101 unless the Permittee submits and unmanifest waste report in accordance with 40 CFR 264.76 as adopted in 15 A NCAD 13A .0109."
Pursuant to 15A NCAC 13A .0109 [40 C.F.R. 264.71], if a facility receives hazardous waste accompanied by a manifest in accordance with paragraph (a)(1), the owner, operator or his/her agent must sign and date the manifest as indicated in accordance with paragraph (a)(2)(i) to certify that the hazardous waste covered by the manifest was received, that the hazardous waste was received except as noted in the discrepancy space of the manifest, or that the hazardous waste was rejected as noted in the manifest discrepancy space.
Closing Conference
The inspection team conducted an exit meeting at the end of the walk-through inspection and review of the facility's hazardous waste records with Catherine Brennan and Sharon Myers of UNC. During this meeting, the inspectors discussed their preliminary findings made during the inspection.
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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10) Signed
DARYL HIMES Digitally signed by DARYL HIMES Date: 2022.08.16 10:33:38 -04'00'
Daryl R. Himes Inspector
11) Concurrence
Digitally signed by ARACELI
ARACELI CHAVEZ CHAVEZ Date: 2022.08.16 17:18:38 -04'00'
Araceli B. Chavez Chief RCRA Enforcement Section
Date Date
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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ATTACHMENT A University of North Carolina at Chapel Hill
Chapel Hill, North Carolina COMPLIANCE EVALUATION INSPECTION
NCD982093783 July 20 & 22, 2022 Photos taken by Daryl R. Himes Photos taken with Canon Power Shot Elph 360 HS
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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i
Photo 1 - Building 488 Incoming Hazardous Waste Receiving Area
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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Photo 2 - Building 531 (Bays 1 & 2 on left)
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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Photo 3 - Building 531
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Photo 4 - Building 531
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Photo 5 - Building 531 - Container in Intrinsically Safe Room without accumulation start date
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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Attachment B
Manifest Number
Gen Date Signed TSD Date Signed # of Days before signed
100039506
9/2/2020
9/8/2020
6
100044170
10/15/2020
10/21/2020
6
100044672
11/3/2020
11/10/2020
7
100046010
11/4/2020
11/10/2020
6
100044675
11/4/2020
11/10/2020
6
100047175
11/30/2020
12/4/2020
4
100047287
12/1/2020
12/4/2020
3
100047349
12/3/2020
12/14/2020
11
100047728
12/9/2020
12/14/2020
5
100048389
12/21/2020
1/12/2021
22
100048703
1/6/2021
1/12/2021
6
100049346
1/7/2021
1/11/2021
4
100050093
1/14/2021
1/19/2021
5
100049848
1/19/2021
1/25/2021
6
100050872
1/20/2021
2/9/2021
20
100050892
1/20/2021
1/25/2021
5
100051056
1/25/2021
2/9/2021
15
100051676
2/4/2021
2/9/2021
5
100069937
2/11/2021
2/22/2021
11
100052152
2/11/2021
2/16/2021
5
100052117
2/11/2021
2/16/2021
5
100052373
2/16/2021
2/23/2021
7
100052354
2/18/2021
2/23/2021
5
100052792
2/24/2021
3/10/2021
14
100052793
2/24/2021
3/1/2021
7
100052872
2/25/2021
3/1/2021
6
100052559
2/25/2021
3/1/2021
6
100052695
3/1/2021
3/10/2021
9
100053312
3/3/2021
3/8/2021
5
100053393
3/4/2021
3/8/2021
7
100053534
3/10/2021
3/17/2021
7
100053772
3/11/2021
3/17/2021
6
100053773
3/11/2021
3/15/2021
4
100053973
3/17/2021
3/24/2021
7
100053674
3/18/2021
3/24/2021
6
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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Manifest Number 100054552 100054734 100054454 100054872 100054624 100054813 100055592 100056452 100056815 100056815 100057016 100057172 100057147 100057152 100057077 100057533 100057412 100057716 100057474 100057693 100057635 100058033 100058173 100058955 100059197 100059081 100059198 100059268 100059619 100059716 100059284 100059741 100059776 100059477 100059777 100059816 100059875 100059948 100059940 100059989 100059945
Gen Date Signed 3/25/2021 3/30/2021 3/31/2021 4/1/2021 4/1/2021 4/1/2021 4/8/2021 4/20/2021 4/21/2021 4/21/2021 4/27/2021 4/29/2021 4/29/2021 5/3/2021 5/3/2021 5/5/2021 5/6/2021 5/11/2021 5/11/2021 5/12/2021 5/12/2021 5/20/2021 5/26/2021 6/15/2021 6/18/2021 6/21/2021 6/21/2021 6/21/2021 6/28/2021 6/29/2021 6/29/2021 6/30/2021 6/30/2021 7/1/2021 7/1/2021 7/1/2021 7/2/2021 7/7/2021 7/7/2021 7/7/2021 7/7/2021
TSD Date Signed # of Days before signed
3/30/2021
5
4/6/2021
7
4/6/2021
6
4/6/2021
5
4/6/2021
5
4/7/2021
6
4/13/2021
5
5/3/2021
13
5/3/2021
12
5/3/2021
12
5/3/2021
6
5/3/2021
4
5/3/2021
4
5/13/2021
10
5/13/2021
10
5/10/2021
5
5/13/2021
7
5/20/2021
9
5/17/2021
6
5/20/2021
8
5/20/2021
8
5/27/2021
7
6/1/2021
6
6/25/2021
10
6/25/2021
7
6/25/2021
4
7/14/2021
23
7/14/2021
23
7/14/2021
16
7/14/2021
15
7/14/2021
15
7/14/2021
14
7/14/2021
14
7/14/2021
13
7/14/2021
13
7/14/2021
13
7/14/2021
12
7/14/2021
7
7/19/2021
12
7/19/2021
12
7/14/2021
7
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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Manifest Number 100059946 100059990 100060142 100060361 100060426 100060618 100061317 100061168 100061356 100061596 100061532 100061616 100061655 100061666 100061718 100061928 100062055 100063376 100063435 100063756 100063795 100063839 100064437 100064890 100065156 100065072 100065215 100065304 100065303 100065171 100065940 100066278 100066298 100066538 100066481 100066424 100066700 100066753 100066754 100066816 100067038
Gen Date Signed 7/8/2021 7/8/2021 7/9/2021 7/14/2021 7/15/2021 7/21/2021 8/4/2021 8/5/2021 8/5/2021 8/10/2021 8/10/2021 8/11/2021 8/11/2021 8/12/2021 8/13/2021 8/18/2021 8/19/2021 9/15/2021 9/16/2021 9/22/2021 9/23/2021 9/24/2021 10/6/2021
10/18/2021 10/19/2021 10/19/2021 10/20/2021 10/21/2021 10/21/2021 10/21/2021
11/3/2021 11/10/2021 11/11/2021 11/17/2021 11/17/2021 11/19/2021 11/22/2021 11/23/2021 11/23/2021 11/24/2021
12/2/2021
TSD Date Signed # of Days before signed
7/14/2021
6
7/14/2021
6
7/14/2021
5
7/19/2021
5
7/21/2021
6
7/28/2021
7
8/10/2021
6
8/10/2021
5
8/10/2021
5
8/18/2021
8
8/18/2021
8
8/18/2021
7
8/18/2021
7
8/18/2021
6
8/18/2021
5
8/27/2021
9
8/27/2021
8
9/22/2021
7
9/22/2021
6
9/27/2021
5
9/30/2021
7
9/30/2021
6
10/12/2021
6
10/27/2021
9
10/26/2021
7
10/26/2021
7
10/26/2021
6
11/3/2021
13
10/26/2021
5
10/26/2021
5
11/9/2021
6
11/17/2021
7
11/17/2021
6
11/29/2021
12
11/29/2021
12
11/29/2021
10
11/30/2021
8
11/30/2021
7
11/30/2021
7
11/30/2021
6
12/8/2021
6
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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Manifest Number 100067221 100067319 100067317 100067597 100067554 100067640 100067639 100067876 100067758 100067915
Gen Date Signed 12/7/2021 12/8/2021 12/9/2021
12/14/2021 12/15/2021 12/15/2021 12/15/2021 12/22/2021 12/22/2021 12/23/2021
TSD Date Signed # of Days before signed
12/14/2021
7
12/14/2021
6
12/14/2021
5
12/20/2021
6
12/22/2021
7
12/22/2021
7
12/20/2021
5
1/4/2022
13
1/5/2022
14
1/5/2022
13
100068278
1/5/2022
1/10/2022
5
100068335
1/6/2022
1/10/2022
4
100068239
1/6/2022
1/13/2022
7
100068580
1/10/2022
1/28/2022
18
100068698
1/12/2022
1/25/2022
13
100068740
1/13/2022
1/28/2022
15
100068710
1/14/2022
1/19/2022
5
100068956
1/19/2022
1/28/2022
9
100068977
1/20/2022
1/27/2022
7
100069256
1/28/2022
2/11/2022
14
100069338
1/31/2022
2/11/2022
11
100069383
2/2/2022
2/11/2022
9
100069419
2/2/2022
2/11/2022
9
100069425
2/3/2022
2/7/2022
4
100069680
2/8/2022
2/22/2022
14
100069736
2/9/2022
2/22/2022
13
100070617
3/1/2022
3/14/2022
13
100070697
3/3/2022
3/14/2022
11
100070278
3/4/2022
3/14/2022
10
100070735
3/4/2022
3/14/2022
10
100070839
3/8/2022
3/14/2022
6
100070807
3/9/2022
3/15/2022
6
100070915
3/9/2022
3/14/2022
5
100070927
3/10/2022
3/14/2022
4
100070984
3/10/2022
3/14/2022
4
100070976
3/10/2022
3/14/2022
3
100070987
3/11/2022
3/14/2022
3
100071015
3/11/2022
3/15/2022
4
100070978
3/11/2022
3/15/2022
4
100071157
3/15/2022
3/23/2022
8
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Manifest Number 100071198 100071237 100071171 100071409 100072000 100072938 100072998 100072960 100073146 100073215 100073309 100073447 100073556 100073713 100073877 100073025
Gen Date Signed 3/16/2022 3/17/2022 3/17/2022 3/25/2022 4/12/2022 5/16/2022 5/18/2022 5/17/2022 5/25/2022 6/1/2022 6/2/2022 6/6/2022 6/10/2022 6/16/2022 6/27/2022 7/1/2022
TSD Date Signed # of Days before signed
3/23/2022
7
3/23/2022
6
3/23/2022
6
3/31/2022
6
4/18/2022
6
5/19/2022
3
5/20/2022
2
5/19/2022
2
6/3/2022
9
6/3/2022
2
6/9/2022
7
6/9/2022
3
6/13/2022
3
6/20/2022
4
6/30/2022
4
7/5/2022
4
EPA-RCRA CEI Report The University of North Carolina at Chapel Hill NCD982093783 July 20 & 22, 2022
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