Document KQZ2OMY55reYQpYrKELXqNBX

Report Prepared by: Report Approved by: RCRA COMPLIANCE EVALUATION INSPECTION Wood Group Pratt & Whitney Industrial Turbine Services 38 Colorado Street Plattsburgh, New York NY2570006088 February 28, 2024 ROBERT Digitally signed by ROBERT MORRELL _M_O__R_R_E__L_L________D_at_e:_20_24_.0_3._26_0_8:_26_:3_1 -_04_'0_0' Robert Morrell, Geologist Monitoring Operations Section Date: ________________ Digitally signed by PHILIP PHILIP COCUZZA COCUZZA _________________D_at_e:_20_24_.0_3._26_08_:4_7:_52_-0_4'_00_' Philip Cocuzza, Supervisor Monitoring Operations Section Date: ________________ Wood Group Pratt & Whitney NY2570006088 Inspection Date: February 28, 2024 Page 2 of 5 Wood Group Pratt & Whitney NY2570006088 Inspection Date: February 28, 2024 Objective A RCRA Compliance Evaluation Inspection (CEI) was conducted at Wood Group Pratt & Whitney Industrial Turbine Services on February 28, 2024. The purpose of the inspection was to obtain information on the facility's hazardous waste management program. This information will be used to determine compliance with regulations pertaining to the Resource Conservation and Recovery Act (RCRA). Survey Participants Wood Group Pratt & Whitney Craig Ringer, Manager cringer@wgtest.com, 518-566-7142 U.S. Environmental Protection Agency Robert Morrell, Geologist morrell.robert@epa.gov, 732-906-6804 Facility Description Wood Group Pratt and Whitney Industrial Turbine Services is located at 38 Colorado Street in Plattsburgh, New York. The facility tests industrial turbine engines that are serviced, repaired, and assembled at the Pratt and Whitney plant in Bloomfield, Connecticut. The turbine engines are used in power generators for the aviation industry. The company has been operating at this location since 1981. There are four employees, and the testing facility operates 8 hours per day, 5 days per week. The industrial turbine engines are delivered to the facility and set up adjacent to the control room. Jet fuel and oil are added to the industrial turbine engines prior to testing. All turbine engines are operated and tested from the control room. Testing and evaluation may include turbine operation, power generation, and vibration analysis. The results of the testing are summarized and delivered in a final report. Water and Wastewater Water for the facility is provided by the City of Plattsburgh. Sanitary wastewater is discharged to the local POTW. There is no process wastewater generated on site. Page 3 of 5 Wood Group Pratt & Whitney NY2570006088 Solid and Hazardous Waste Management Inspection Date: February 28, 2024 After testing is completed, the jet fuel and oil are drained from the industrial turbine engine and placed in a 55-gallon drum in the hazardous waste storage area. If there are any jet fuel or oil leaks during testing, it is contained with absorbent material and placed in a 55-gallon drum in the hazardous waste storage area. Both drums have flammable labels and hazardous waste labels with RCRA hazardous waste codes D001 and D018. The drums are also stored in secondary containment overpacks. The waste flammable liquids (jet fuel, oil) are shipped to Safety Kleen Systems, a treatment, storage, and disposal facility (TSDF) in Smithfield, Kentucky. The waste solids containing flammable liquids are shipped to Clean Harbors, a TSDF in El Dorado, Arizona. On the day of the inspection, there were no hazardous waste containers being stored on site. There were two empty 55-gallon drums with hazardous waste labels in the hazardous waste storage area. The most recent shipment of hazardous waste was on February 7, 2024, when two 55-gallon drums were shipped to Clean Harbors and one 55-gallon drum was shipped to Safety Kleen Systems. Observations A review of the hazardous waste manifests indicates that Wood Group Pratt & Whitney Industrial Turbine Services is a small quantity generator of hazardous waste. In 2023, the facility generated two 55-gallon drums of waste flammable liquids (D001, D018) and four 55-gallon drums of waste solids containing flammable liquids (D001, D018). The facility maintains weekly inspection logs of the hazardous waste storage area. Hazardous materials safety training is provided once per year to employees that handle hazardous waste. The U.S. Department of Transportation (DOT) Hazardous Materials Shipping training is provided to the facility manager. Findings There were no violations or compliance issues found on the day of the inspection. Attachment Photograph (#1) Page 4 of 5 Wood Group Pratt & Whitney NY2570006088 Inspection Date: February 28, 2024 Photo #1: View of the hazardous waste storage area. Page 5 of 5