Document JJkBZMVzZbM3j6Zx7gwrYQKGe

RCRA Inspection Report 1) Inspector and Author of Report Tarin Tischler Life Scientist Phone: 404-562-9702 tischler.tarin@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 The Boeing Company 100 Boeing Way Titusville, Fl 32780-8046 EPA ID#: FLD984217026 NAICS #: 336414 - GUIDED MISSILE AND SPACE VEHICLE MANUFACTURING 336419 - OTHER GUIDED MISSILE AND SPACE VEHICLE PARTS AND AUXILIARY EQUIPMENT MANUFACTURING 3) Responsible Officials Michele Czajka Senior Environmental Health and Safety Specialist michele.a.czajka@boeing.com 4) Inspection Participants Fritz Nunley, The Boeing Company Michele Czajka, The Boeing Company Abigail Gaston, The Boeing Company Lance Long, Allied Security Michael Eckoff, FDEP Carly Cogburn, FDEP Tarin Tischler, USEPA Bill Kappler, USEPA 5) Date of Inspection March 14, 2024, 9:29 AM 6) Applicable Regulations1 Resource Conservation and Recovery Act (RCRA) Sections 3002, 3005 and 3007 (42 U.S.C. 6922, 6925 and 6927), and the regulations promulgated pursuant thereto at 40 Code of Federal Regulations (C.F.R.) Parts 260-270, 273 and 279. 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. EPA-RCRA CEI Report Page 1 of The Boeing Company EPA ID# FLD984217026 3/14/2024 Florida Statutes (F.S.) Chapter 403.702 et seq., and the regulations promulgated pursuant thereto and set forth at the Florida Administrative Code (Fla. Admin. Code Ann. r.), Chapters 62710, 62-730 and 62-750. 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 Fla. Admin. Code Ann. r. 62-730.160(1) [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 403.722 of the Florida Statutes, Fla. Stat. 403.722 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [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 status, as required by Section 403.722 of the Florida Statutes, Fla. Stat. 403.722 [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in Fla. Admin. Code Ann. r. 62730.160(1) [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine The Boeing Company's compliance with the applicable requirements of RCRA and the corresponding Florida regulations. This was an EPA lead inspection. 8) Facility Description The Boeing Company (hereinafter "Boeing" or the "facility") is one of the top aerospace companies in the world. Boeing develops, manufactures and services commercial airplanes, defense missiles, and rockets in more than 150 countries. The Boeing Company is the fourth largest defense contractor in the world. The company was founded in Washington on July 15, 1916. The Boeing Company is headquartered in Arlington, Virginia. The Boeing facility located at 100 Boeing Way, Titusville, Florida 32780 serves primarily as office space and conference rooms for Boeing employees and contractors. All manufacturing, research, and other activities that generate hazardous waste are performed at the Boeing Kennedy Space Center location, which operates under EPA ID number FLR000206755. The facility does not generate hazardous waste at the Titusville location. Boeing originally notified as Not a Generator in January of 2008, and subsequently notified as a Very Small Quantity Generator (VSQG) in May 2015 and January 2018. The facility most recently notified as a Large Quantity Generator (LQG) on February 28, 2020. 9) Previous Inspection History The facility has never been inspected by the State or EPA. 10) Opening Conference On March 14, 2024, EPA inspector Tarin Tischler, accompanied by EPA inspector William Kappler and Florida Inspectors Michael Eckoff and Carly Cogburn, arrived at The Boeing Company at approximately 9:29 AM. Lance Long, Security Site Supervisor, immediately received the inspectors. Michele Czajka, Senior Occupational Health and Safety Specialist, and the inspectors were joined by Fritz Nunley, Senior Occupational Health and Safety Specialist, and Abigail Gaston, Environmental Health and Safety Manager for the opening conference. The inspectors introduced themselves, showed their credentials to the facility representatives and explained the purpose of the visit. The inspectors described the anticipated use of equipment (iPad) during the inspection and provided a request for records. The EPA inspector explained that the Small Business Regulatory Enforcement Fairness Act's classification of a "small business" is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. A copy of the EPA's information sheet for small businesses can be found at https://www.epa.gov/sites/production/files/2017-06/documents/smallbusinessinfo.pdf. The EPA inspector also discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. The company did not assert a business confidentiality claim. Michele Czajka provided an overview of the facility's history and current operations during the opening conference. The inspection participants also discussed health and safety protocols and required personal protective equipment before Facility representative led the inspectors on a tour of the Facility operations. 11) Inspection Observations The opening conference and subsequent records review was conducted in a conference room on the first floor of the facility. Fritz Nunley informed inspectors that the Titusville location is the mailing address for the Boeing facility located in Building K6-0696 on Kennedy Space Center Property. The Kennedy Space center location operates under EPA ID number FLR000206755 with an address registered as Buildings K6-0894 and K6-0696 on Kennedy Space Center Orlando, Florida 32899. The space center location cannot accept mail, so a notification as a Large Quantity Generator was incorrectly made for this address when updating facility records across multiple locations at DEP's request. Pursuant to Fla. Admin. Code Ann. r. 62-730.150(2)(b), All generators, transporters, or persons who own or operate a facility which treats, stores, or disposes of hazardous waste, and everyone required to notify under Rule 62 730.181, F.A.C., shall notify the Department of all changes in status and shall use the "8700-12FL - Florida Notification of Regulated Waste Activity," Form 62-730.900(1)(b), [adopted by reference in paragraph 62-730.150(2)(a), F.A.C.], to do so. Facility representatives informed inspectors that hazardous waste is generated on one continuous property in multiple buildings at the Kennedy Space Center Location. No public roads separate the buildings under this EPA ID number. Points of generation at this location include a PCC laboratory which generates lab waste and the Commercial Crew (CCTS) area which generates nonhalogenated solvent debris, corrosive contaminated debris, expired chemical products, and other chemical contaminated debris. The facility is a Large Quantity Generator due to acutely hazardous waste NASA also generates waste in a building at Kennedy Space Center under a NASA operated EPA ID number. 12) Records Review Facility representatives brought some records for the Boeing facility under EPA ID FLR000206755 to the opening conference, while other records were available online for review. The Kennedy Space Center facility requires 48-hour notice for entry and was not able to be inspected. Other records inspectors reviewed the following records at the time of the inspection: - Uniform hazardous waste manifests from 2017 to 2022 - Land disposal restrictions - Weekly inspection records for the CCTS CAA Inspectors requested uniform hazardous waste manifests from 2023 and 2024, training records for personnel at both sites, written job descriptions for Fritz Nunley and Michele Czajka, and Contingency Plan and Quick Reference Guide. 13) Closing Conference The inspectors conducted the exit meeting with Michele Czajka, Fritz Nunley, and Abigail Gaston. During this meeting, the inspectors stated their preliminary conclusions of the inspection. The Boeing Company agreed to provide requested records for both facilities by 3/28/2024. 14) Signed TARIN TISCHLER Digitally signed by TARIN TISCHLER Date: 2024.04.30 16:28:03 -04'00' Tarin Tischler Life Scientist 15) Concurrence ALAN NEWMAN Alan R. Newman, Acting Chief RCRA Enforcement Section Digitally signed by ALAN NEWMAN Date: 2024.05.01 09:56:04 -04'00'