Document K6rZ2ZxmBZrV6YJ78raeNMy2K
REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION
At
McMullen Ford Inc. 3401 S Expressway Council Bluffs, IA 51502
(712) 366-0531
EPA ID Number: IAD981701535
On
June 9, 2022
By
Eastern Research Group, Inc.
For
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/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U.S. Environmental Protection Agency (EPA) Region 7, Eastern Research Group, Inc. (ERG) conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at McMullen Ford Inc. (MFI) in Council Bluffs, Iowa on June 9, 2022. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. Throughout the CEI, data and information were collected to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI.
2.0 PARTICIPANTS
McMullen Ford Inc.: Scott McMullen, Partner Dan McMullen, Partner
EPA Representative, ERG: Joseph Watson, Senior Chemical Engineer
3.0 INSPECTION PRECEDURES
After arriving unannounced at MFI at approximately 09:30, I performed a drive-by visual inspection of the facility and took a photograph before beginning the inspection and did not note any areas of concern. I then entered the main lobby and I introduced myself to personnel in the lobby and met Mr. Scott McMullen. We were later joined by Mr. Dan McMullen. I then explained my reason for being on site is to conduct a RCRA CEI. Mr. Dan McMullen, Mr. Scott McMullen, and I were seated at a table in the lobby and began the inspection. I began the opening conference at approximately 09:50. I initiated the opening conference with Mr. Dan McMullen and Mr. Scott McMullen as MFI representatives. I presented them with my inspector credentials and business card, as well as the business card of the EPA Task Order Contracting Officer Representative, Mr. Trevor Urban. I then presented a copy of RCRA Section 3007(a), which contains EPA's inspection authority. I explained my need to collect accurate information and presented them with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I then presented them with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed MFI's confidentiality rights. I informed them that I would provide a Confidentiality Notice at the end of this inspection.
The inspection consisted of a discussion of facility operations, waste generation and waste management, a review of waste management records, and a visual inspection of the waste generation and management areas. Mr. Scott McMullen provided a facility layout (see Attachment 1) and explained facility operations and locations of hazardous waste generation and management.
During the visual inspection of the facility, Mr. Scott McMullen guided me throughout the facility in order to conduct thorough evaluations of the facility's operations. The facility also handles universal waste in one designated area on site as shown on the facility layout. The universal waste storage area was visually inspected. MFI uses three nonhazardous parts washers in the maintenance area. I conducted an in-depth visual inspection of the universal waste storage area, used oil storage area, and all manufacturing areas.
Seven photographs were collected as inspection documentation and are shown in Attachments 2 and 3. Information collected during the inspection is documented on the EPA Inspection Checklist (see Attachment 4). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.01D), unless noted differently. At the conclusion of the inspection, I provided Mr. Scott McMullen with a Confidentiality Notice, and Receipt for Documents and Samples which Mr. Scott McMullen signed as acknowledgement of receipt (see Attachments 5 and 6, respectively). No confidentiality claims were made by MFI.
The following inspection documents and compliance assistance handouts were left with MFI
RCRA Section 3007(a) Title 18 U.S. Code, Sections 1001 and 1002 Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by
EPA in Connection with Inspections
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Confidentiality Notice (Facility copy) Receipt of Documents and Samples (Facility copy) Security Awareness Commercial Motor Vehicle Transportation Security Planning EPA E-Manifest Fact Sheet U.S. EPA Small Business Resources U.S. EPA Publication, Managing Your Hazardous Waste U.S. EPA Publication, Managing Used Oil-Advice for Small Businesses PowerPoint Presentation, 2013 Solvent Wipes Final Rule Pollution Engineering Article, 10 Common Questions for Waste Generators Iowa Department of Natural Resources (IDNR) Waste Exchange Folder and P2 Brochures IDNR Management of Fluorescent Lamps for Businesses Information Sheets IDNR Aerosol Can Disposal for Businesses Information Sheet University of Northern Iowa Waste Reduction Center Information Card Solvent-Contaminated Wipes Final Rule Summary Chart
4.0 FINDINGS AND OBSERVATIONS
Facility Information and Operations
MFI began operating in 1975 and currently employs approximately 50 people. The facility operates on a six day, 8-hour shift flex schedule. The facility has a footprint of approximately 40,000 square feet on 3.99 acres. MFI's operations consist of automobile maintenance and sales. The primary raw materials used are replacement parts, sandpaper, lead and chromium free paints, oil, batteries, tires, coolant, lacquer/thinner. The following waste streams are produced: oily rags/personal protective equipment (PPE), aerosol cans, paint waste, paint booth filters, parts washer solutions, tires, scrap metal, used oil, used oil filters, universal waste batteries, and general trash.
4.2 RCRA Status
According to the Notification Acknowledgement/Verification Form (see Attachment 7), MFI notified as a federal Small Quantity Generator (SQG) of hazardous waste but no waste codes were identified. I asked Mr. Scott McMullen to review the Notification Acknowledgement/Verification Form, which I provided prior to records review and visual inspection of the waste generation areas. Mr. Scott McMullen stated the information on the form was accurate to the best of his knowledge. After reviewing the records and walking through the facility, it appears that the facility is operating as a federal Very Small Quantity Generator (VSQG) of D001, F003, and F005 hazardous wastes, a generator of used oil, and a small quantity handler (SQH) of universal waste. MFI generates approximately 120 pounds of hazardous waste monthly. based on a review of facility records, a visual inspection of process and waste management areas, and interviewing personnel. MFI was never previously inspected by the EPA.
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4.3 Facility Waste Streams and Management A Waste Stream and Waste Handling Table for MFI is presented below. The table describes waste streams generated, generation process/rates, hazardous waste determinations, and onsite/off-site management. The rest of this page left blank intentionally.
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WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT MANAGEMENT
#
RATE
1 Waste Paints Painting
D001, F003, and F005 Three 55-gallon 55-gallon
Heritage Crystal Clean,
operations
(based on process
containers every containers
LLC (ILR000130062) to
knowledge and
year
Giant Resource Recovery
knowledge of the
Sumter, Inc.
product)
(SCD036275626) in
Sumter, SC and Heritage
Environmental Services,
LLC (IND093219012) in
Indianapolis, IN for
energy recovery (Invoice
included in Attachment 8)
2 Paint Gun
Paint gun
D001, F003, and F005 One 5-gallon 5-gallon container Heritage Crystal Clean,
Cleaner
cleaning unit
(based on process
container every
LLC (ILR000130062) to
Solvent (SDS
knowledge and
quarter
Giant Resource Recovery
included in
knowledge of the
Sumter, Inc.
Attachment 9)
product)
(SCD036275626) in
Sumter, SC and Heritage
Environmental Services,
LLC (IND093219012) in
Indianapolis, IN for
recycling (Invoice
included in Attachment 8)
3 Oily Rags/
Miscellaneous Nonhazardous (based on Unknown - not Added to general Waste Connections in
PPE/Other
solids, PPE,
process knowledge and tracked
trash 8-yard
Ceresco, NE to Loess
Debris
absorbent pads, used containers
knowledge of the product)
containers
Hills Regional Sanitary Landfill in Mitchell
Malvern, IA
(IAD000678185) for
landfill
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WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT MANAGEMENT
#
RATE
4 Paint Booth Replacement of Nonhazardous (based on Floor filters
None -
Filter Shop in Omaha, NE
Filters
air filters in the process knowledge and changed monthly Immediately
(ILR000130062) for
paint booth
knowledge of the
and the ceiling removed from site recycling (Invoice
product)
filters changed upon replacement included in Attachment
annually
10)
5 Aerosol Cans Facility operations
Nonhazardous (use product until RCRA empty and dispose of in metal recycling container)
Unknown - not tracked
1-yard scrap metal Jim Steere picks up scrap
container
metal for recycling
6 Used Coolant Engine coolant Nonhazardous (based on Engine coolant 275-gallon
system repair
process knowledge and is typically
container
knowledge of the
reused
product)
Not typically managed off site. Would be shipped off site and managed by Heritage-Crystal Clean
7 Nonhazardous Cleaning oil and Nonhazardous (based on 20-gallon and 20-gallon and 30- Heritage-Crystal Clean,
Parts Washer greases off small process knowledge and 30-gallon parts gallon parts
LLC in Omaha, NE for
Solvent (SDS maintenance
knowledge of the
washers serviced washers
recycling (Invoice
included in
tools and parts product)
quarterly
included in Attachment 8)
Attachment
11)
8 Used Oil
Maintenance on Nonhazardous/Excluded 500 gallons per 400-gallon tank
Jebro Inc. of Sioux City,
vehicles,
(managed as used oil per month
IA (IAD020201604) for
including brake 40 CFR 279)
recycling (Invoice
and transmission
included in Attachment
fluid
12)
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WASTE STREAM # 9 Used Oil Filters
GENERATION PROCESS
Vehicle oil changes
HAZARDOUS WASTE DETERMINATION
Nonhazardous (based on process knowledge and knowledge of the product)
ESTIMATED GENERATION RATE 350 oil filters er month
ON-SITE MANAGEMENT
55-gallon containers
OFF-SITE MANAGEMENT
Jebro Inc. of Sioux City, IA (IAD020201604) for recycling (Invoice included in Attachment 12)
10 Scrap Metal Facility operations
Nonhazardous (based on process knowledge and knowledge of the product)
1-yard per month
1-yard container
Jim Steere picks up scrap metal for recycling
11 Used Tires
12 Sump and Oil/Water Separator Cleanout
13 Universal Waste Batteries
Tire replacement
Nonhazardous (based on process knowledge and knowledge of the product)
Carwash and vehicle maintenance operations
Nonhazardous (based on process knowledge and knowledge of the product)
Facility maintenance
Nonhazardous/Excluded (managed as universal waste)
500 tires per year
Sumps are cleaned out on an annual basis
1-gallon container per year and approximately 20 battery cores per month
Stacked in service area
Oil/Water separator and service area sumps
1-gallon container and on pallet
Liberty Tire Recycling, LLC Pittsburgh, PA for recycling (Invoice included in Attachment 13) Council Bluffs Septic Service, Inc. of Council Bluffs, IA (Invoice included in Attachment 14) transferred to a local POTW. Factory Motor Parts Co. of Omaha, NE delivers to Factory Motor Parts Co. Minneapolis, MN for recycling (Invoice included in Attachment 15)
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WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT MANAGEMENT
#
RATE
14 General Trash Facility
Nonhazardous (based on 8-yard container 8-yard containers Waste Connections in
operations
process knowledge and emptied three
Ceresco, NE to Loess
knowledge of the
times per week
Hills Regional Sanitary
product)
Landfill in Mitchell
Malvern, IA
(IAD000678185) for
landfill
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Visual Inspection
Painting Operations:
During the visual inspection, I observed the painting operation. Mr. Scott McMullen explained the facility paints vehicles in the paint booth. FMI also mixes paints and cleans the paint gun in the paint room next to the paint booth. Mr. Scott McMullen stated that Filter Shop in Omaha replaces the floor filters monthly and replaces the ceiling filters annually. A service invoice is included in Attachment 10. The filters do not contain free liquids and are dry at the time of servicing. Spent paint filters are managed as nonhazardous waste. I asked Mr. Scott McMullen if there is any chrome or lead pigments in the paint. Mr. Scott McMullen stated that the facility had switched to chrome and lead-free paints several years ago. I looked at all of the labels of all of the paints in the paint room and none of the paints contained lead or chrome compounds. FMI uses solvents to thin paints and coatings, as necessary. In the paint room I observed a Heritage Clean Gun Cleaner Model 6A-000-AI (see Photo 4, Attachment 3). The unit has a 5-gallon container of Paint Gun Cleaner Super 16. According to service invoices in Attachment 9, Heritage-Crystal Clean services the unit quarterly. I contacted Mr. Portillo, the Branch Sales Manager of the Heritage-Crystal Clean, LLC in Omaha, NE. He stated that when a technician arrives, if the paint gun solvent is dirty they will replace the 5-gallon container or top off the container with solvent if it is still usable. He stated that Heritage-Crystal Clean recycles the spent solvent. Heritage-Crystal Clean also transports full 55-gallon drums of paint waste during service visits. The service receipt states that the paint waste shipments are manifested but Mr. Portillo did not provide hazardous waste manifest of the shipments. I did observe the hazardous waste shipments in RCRAInfo with D001, D007, D008, F003, and F005 waste codes. I noticed that the manifested wastes had D007 and D008 waste codes. I told Mr. Scott McMullen that since his paints no longer contained chrome or lead, that the D007 and D008 waste codes appear to no longer be required on the waste paint manifest. I observed one 55-gallon container of waste paint that was closed and labeled with an indication of the nature of the hazard. I did not note any issues or findings related to waste management from painting operations.
Parts Washers:
During the visual inspection, I observed two parts washers. Mr. Scott McMullen explained small tools and pieces of equipment could be cleaned in the parts washers. A typical parts washer is shown in Photo 2, Attachment 3. The parts washer solvent is nonhazardous and the SDS is provided in Attachment 9. Mr. Netherton stated the parts washer is serviced by Heritage-Crystal Clean on a quarterly basis. The most recent invoice is provided in Attachment 9. Mr. Netherton stated the facility ensures parts and tools cleaned with other aerosol cleaners are not comingled in the parts washer in order to avoid cross contamination of the materials. I did not note any issues or findings related to parts washer management.
Used Oil and Filters:
During the visual inspection, I observed oil changes being conducted in the service area. I asked Mr. Scott McMullen how the facility manages used oil and oil filters. Mr. Scott McMullen stated
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that oil filters are punctured and hot drained and placed in 55-galllon drums. He also showed me that the used oil collection units are pumped into a 400-gallon used oil tank on the east side of the building (see Photo 3, Attachment 3). I observed the used oil tank which was closed, in good condition, and labeled "Used Oil." Mr. Scott McMullen stated that transmission oil and brake fluid are also added to the used oil tank and recycled and stated that the facility generates approximately 500 gallons per month of used oil. Mr. Scott McMullen also stated that the facility collects engine coolant during radiator repairs but typically puts the antifreeze back into the vehicle and has not had to dispose of used antifreeze in over a year. MFI uses a 275-gallon tote for managing used engine coolant. I did not note any issues or findings related to antifreeze, used oil, or oil filter management.
Used Tires:
Mr. Scott McMullen stated that MFI replaces around 500 tires per year that are recycled and that Liberty Tire recycling, LLC of Pittsburgh, PA recycles the used tires generated by MFI. I did not note any issues or findings related to used tire management.
Scrap Metal:
MFI generates scrap metal from replacement parts, other vehicle components, RCRA empty aerosol cans, and metal packaging. I asked Mr. Scott McMullen how MFI would manage an aerosol can if it was damaged and could not be emptied. Mr. Scott McMullen stated that Heritage-Crystal Clean would manage the aerosol can as a hazardous waste if necessary. Two 1yard containers located on the southeast corner of the building accumulate the scrap steel (see Photo 6, Attachment 3). Mr. Scott McMullen stated that Jim Steere picks up scrap metal for recycling. I did not note any issues or findings related to scrap metal management.
Sump and Oil/Water Separator Cleanout:
In addition to the service area, MFI also operates a car wash. MFI also has an oil/water separator to prevent oil and other materials from discharging to the sewer. I observed these activities during the walkthrough. Mr. Scott McMullen stated that Council Bluffs Septic Service, Inc. pumps out the sumps, the car wash, and the oil/water separator on an annual basis. Mr. Scott McMullen stated that hazardous materials do not enter the sumps and the materials pumped out are nonhazardous.
Universal Waste:
MFI managed universal waste in the southern corner on the warehouse as labeled on the facility layout (see Attachment 1). Mr. Scott McMullen explained batteries are generated from replacing batteries for vehicles and key fobs. During the visual inspection I observed a one-gallon container of universal waste batteries (see Attachment 3, Photo 7). The one-gallon container was closed, in good condition, and labeled as "Universal Waste Used Batteries." The container was
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labeled with an accumulation start date of "4/1/2022." MFI does not generate or manage universal waste lamps.
I observed no issues or findings during this inspection. However, further EPA review may add findings.
Joseph
Digitally signed by Joseph Watson
Watson
Date: 2022.08.08 12:44:51 -04'00'
______________________________
Joseph Watson
Senior Chemical Engineer
Date: August 8, 2022
AMBER
Digitally signed by AMBER WHISNANT
_W___H___IS__N___A__N___T_______-0_5_'_0_0_' _ Date: 2022.08.08 19:06:10
Amber Whisnant
Section Chief
ECAD/CB/RCRA, EPA Region 7
Date: _________________
Attachments: 1. Facility Layout (6 pages) 2. McMullen Ford Photolog (1 page) 3. McMullen Ford Photos (7 photos/8 pages) 4. EPA Inspection Checklist (18 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Notification Acknowledgement/Verification Form (1 page) 8. Heritage-Crystal Clean Service Invoices (7 pages) 9. Super 16 Paint Gun Cleaner SDS (14 pages) 10. Paint Booth Filter Recycling Invoice (2 pages) 11. Parts Washer SDS (7 pages) 12. Used Oil and Oil Filter Recycling Invoice (2 pages) 13. Tire Recycling Invoice (2 pages) 14. Sump Pump Out Invoice (1 page) 15. Battery Recycling Invoice (1 page)
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