Document LommnMgqNyzXjyYgKkjVrMQvw
Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA REGION 7 Enforcement Division INSPECTION REPORT
03/05/2024 09:00 AM (CT)
Announced: No
03/06/2024 02:00 PM (CT)
Access: Granted
RCRA
Compliance Evaluation Inspection (CEI)
Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates
Polynt Composites USA Inc. MOD086787371 1412 Knox Street North Kansas City, MO 64116-3706 Clay County LQG 325211 Research and development of gel coating. 39.176102, -94.570908
Permit Number (If Applicable) Not Applicable
Lead Inspector:
Mike Martin
[Signature] Martin, Mike
Digitally signed by Martin, Mike Date: 2024.04.19 10:53:35 -05'00'
[Date]
EPA REGION 7
martin.mike@epa.gov
Additional EPA Staff Participating in Inspection:
Name
Title
Organization
Email
Amy Thompson
Inspector
EPA REGION 7
thompson.amy@epa.gov
Koba Butkovich
Inspector
EPA REGION 7
butkovich.koba@epa.gov
Supervisor Review: Amber Whisnant
[ESDignWatIuNreB] UCKNER
EPA REGION 7
Digitally signed by EDWIN BUCKNER Date: 2024.04.19 11:45:20 -05'00'
whisnant.amber@epa.gov
[Date]
SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI
At the request of the Enforcement and Compliance Assurance Division, I conducted a Resource Conservation and Recovery Act (RCRA) CEI at Polynt Composites USA Inc. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. During the CEI, I collected the information and data necessary to
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI.
Prior to beginning the inspection on the morning of March 5, 2024, I conducted a visual reconnaissance of Polynt searching for areas of concern observable from the adjacent roadway. I identified no environmental issues or concerns during this preliminary examination. Upon arriving unannounced at Polynt at 9:00 a.m., Ms. Thompson, Mr. Butkovich and I met with Mr. Kraynak. He escorted us to a conference room where we met Mses. Drake and Cortelli. I presented them with my EPA credentials and explained the purpose and procedures of the inspection.
The CEI consisted of a discussion of facility operations, waste generation, and waste management; a review of waste management records; and a visual inspection of waste generation and management areas (see attachment 1 for the Site Overview).
Ms. Thompson, Mr. Butkovich and I conducted at visual inspection of the following areas at Polynt:
Building 2 - HW Storage Area #1 Building 51 - R&D Labs; Annex Hallway (HW Storage Area #2); Dust Collector Room and Trash Compactor Building 52 - Pilot Plant R&D Lab (HW Storage Area #3)
Building 53 - Application Center Old Maintenance Shop
Old Processing Building - Old QC Lab
Document photocopies and photographs were collected as inspection documentation (Appendix 1). A total of 42 photographs were collected and a photolog was prepared (Appendix 1). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.1E), unless noted differently. Any authorized Federal regulatory citations noted in this report are adopted by reference in the authorized Missouri regulations.
Attendees Title/Organization RCRA Inspector/EPA
RCRA Inspector/EPA RCRA Inspector/EPA Loss Control Coordinator/Polynt
Group RD Director/Polynt HR Manager Americas/Polynt Regional EHS Manager/Polynt Group Leader-Vinyl/Polynt R&D Manager/Polynt Lab Support/Polynt
Name
Mike Martin (913) 55-7149 martin.mike@epa.gov
Amy Thompson
Opening Conf. Yes
Yes
Koba Butkovich
Yes
Keith Kraynak
Yes
(816) 391-6059
keith.kraynak@polynt.com
Carlotta Cortelli
Yes
Fallon Drake
Yes
David Maurin
Yes
Sandy Brantner
No
John Pajich
No
Ray Rice
No
Closing Conf. Yes
Yes Yes Yes
Yes Yes Yes No No No
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
Technical Assistance/Polynt
Kelley Potterf
No
No
Pilot Lab Chemist/Polynt
Bradley Strathman
No
No
Pilot Lab Chemist/Polynt
Jim Eisenhutt
No
No
Opening Conference
I presented Mr. Kraynak and Mses. Drake and Cortelli with my EPA credentials and explained the purpose and procedures of the inspection. I next presented them with a copy of RCRA Section 3007(a), which provides 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. They were made aware of their confidentiality rights and were informed that a Confidentiality Notice would be provided at the end of the inspection to make or not to make any confidentiality claims.
Polynt had been last inspected for RCRA compliance on September 4, 2019, by the MoDNR.
During the September 2019 MoDNR inspection, Polynt was cited for:
1. Failure to ensure containers are in good condition. 2. Failure to store satellite containers at or near any point of waste generation. 3. Failure to attempt to make arrangements with police, fire department and emergency response teams 4. Failure to make arrangements designate a primary emergency authority. 5. Failure to make arrangement with emergency response teams, contractors and equipment suppliers. 6. Failure to make arrangements with local hospitals. 7. Failure to document where state or local authorities decline to enter into such agreements. 8. Failure to submit the contingency plan to local emergency response agencies (repeat finding). 9. Contingency plan not up to date.
According to the Hazardous Waste Site Info Verification Report (Attachment 2), Polynt operates as a Large Quantity Generator (LQG) of D001, D002, D018, D035, F003, F005, U223 and U404 hazardous waste. Mr. Kraynak noted no changes to the Hazardous Waste Site Info Verification Report. Polynt generates greater than 2,200 pounds of known HW per month. Therefore, I inspected Polynt as a LQG. In addition, I determined Polynt to be a small quantity handler of universal waste and a used oil generator.
Facility/Site Information Number of employees Length of Facility at Location Operating Hours Size of Facility What type of generator facility verified as? Weather Conditions
45-50 1920's 7am to 4:30pm, Monday-Friday 4 buildings - 14 acre lot LQG Days 1 and 2 - Sunny
Process Description Polynt's gel coat production operation moved to other production sites and ceased in 2020. Polynt's current operation includes research and development of gel coating (resin, styrene, additives, and pigments), a pilot plant and a technical/demonstration application center. Gel coating is produced on site in small batches for research and development purposes.
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Polynt Composites USA Inc. Inspection Date(s):
Waste Description and Generation Waste
Process
Type
Pilot Plant Resin Waste (generated HW
from production of gel coating for
R&D - includes reactor drippings)
Pilot Plant Liquid Waste
HW
(generated from production of gel
coating for R&D)
Pilot Plant Solid Waste (cups, etc. HW generated from production of gel coating for R&D) R&D Resin Waste (generated from HW R&D)
R&D Composite Solids (generated HW from R&D)
R&D Lab Solids (generated from HW R&D- styrene)
Waste Styrene and Methanol
HW
R&D Solvent (generated from R&D HW - styrene and methanol)
Application Center Control Debris HW
Application Center Booth Rinse
HW
(waste acetone from cleaning
spray booth guns)
Generation Rate
165 pounds/month 482 pounds/month
307 pounds/month 814 pounds/month 352 pounds/month 173 pounds/month 402 pounds/month 173 pounds/month 50 pounds/month 183 pounds/month
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03/05/2024 - 03/06/2024
If HW, list all codes
D001 D035 F003 F005
Waste Determination
Method
Process Knowledge
Waste Amount
Oldest
Presently in Storage Accumulation
(less than 90-day Start Date
HW accumulation)
NA
NA
Waste Disposal Location
Tradebe (Millington, TN)
D001 D002 D035 F003
F005
D001 D035 F003 F005
Process Knowledge
Process Knowledge
Two 55-gallon less than 90-day HW
accumulation containers (HW storage containers) One 55-gallon HW storage container
02/28/2024 02/09/2024
Tradebe (Millington, TN)
Tradebe (Millington, TN)
D001 D035 F003 F005 D001 D035 F003 F005 D001 D035 F003 F005
D001
D001
D001 F003
D001 F003
Process Knowledge
Process Knowledge
Process Knowledge
Process Knowledge
Process Knowledge
Process Knowledge
Process Knowledge
One 55-gallon HW 02/20/2024 Tradebe
storage container
(Millington, TN)
One 55-gallon HW 02/20/2024 Tradebe
storage container
(Millington, TN)
One 55-gallon HW 02/20/2024 Tradebe
storage container
(Millington, TN)
NA
NA
Tradebe
(Millington, TN)
NA
NA
Tradebe
(Millington, TN)
NA
NA
Tradebe
(Millington, TN)
NA
NA
Tradebe
(Millington, TN)
Polynt Composites USA Inc.
Inspection Date(s):
Lab Pack (generation of old reagents/chemicals)
03/05/2024 - 03/06/2024
HW
675 pounds in 2023 D001 D035
Process
NA
F003 F005 Knowledge
NA
Tradebe
(Millington, TN)
Spent Aerosol Cans (general
HW Varies (one 55-gallon
D001
Process
NA
maintenance, spray paint, etc.)
container per year)
Knowledge
NA
Tradebe
(Millington, TN)
Cloth Wipes (facility wide;
EX
Varies
NA
Process
NA
reusable wipes contaminated with
(collected in 37 five to ten
Knowledge
acetone and sent off-site to be
gallon pails throughout
laundered)
the facility)
NA
Cintas
(Kansas City, MO)
*Prior to the CEI, the reusable solvent contaminated wipes were collected in 5-10-gallon pails labeled with the words "Recycle Program Rags." The Federal Solvent Wipes Rule was not being followed (labeling as "Excluded Solvent Contaminated Wipes" and written description to ensure the solvent contaminated wipes contain no free liquids)
Paint Booth Filters (change out of NH filters in the Application Center's two paint booths)
Varies
NA
Process
NA
Knowledge
NA
Republic
(Kansas City, KS)
Baghouse Dust (resin and
NH
fiberglass dust)
Varies
NA
Process
NA
Knowledge
NA
Republic
(Kansas City, KS)
Universal Waste Lamps (relamping acitivites)
UW
Two boxes per year
NA
Process
Three cardboard Less than one Safety-Kleen
Knowledge
boxes
year
(Norwell, MA)
Universal Waste Batteries (general UW maintenance)
Two pails per year
NA
Process Three 5-gallon pails Less than one Safety-Kleen
Knowledge
year
(Norwell, MA)
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Polynt Composites USA Inc. Inspection Date(s):
Used Oil
General Trash
UW Two 55-gallon containers per year
SW
NA
03/05/2024 - 03/06/2024
NA
Process
NA
Knowledge
NA
NA
NA
HW = Hazardous Waste SW = Solid Waste
EX = Exempt
AD = Analytical Data ND = Not Determined
UW = Universal Waste
UO = Used Oil
NA
Safety-Kleen
(Independence,
MO)
NA
Republic
(Kansas City, KS)
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
Building(s)
Building/Area/Sub-area Bldg. 53 - Application Center
Bldg. 2 - HW Storage Area #1
Building 52 - Pilot Plant R&D Lab (HW Storage Area #3) Old Maintenance Shop Old Processing Bldg - QC Lab
Facility Wide
Bldg. 51 - R&D Labs; Annex Hallway (HW Storage Area #2); Dust Collector Room, Compactor
Process Description
Area of Concern
Training/conference area, chemical storage, mixer
Yes
room, QC lab and two spray booths.
HW Storage Area #1. UW-lamps and batteries
Yes
storage.
HW Storage Area #3. Lab and two reactors for
Yes
small batch gel coat mfg.
Maintenance Shop (spent aerosol cans and lamps).
Yes
Former gel coat processing building. Gel coat
Yes
production operations shutdown in 2020.
Thirty-two 5 to 10-gallon pails of solvent
Yes
contaminated wipes.
HW Storage Area #2. R&D labs (resin waste,
No
composite solids, and lab solids).
SECTION II - OBSERVATIONS
Building: Bldg. 53 - Application Center
Observation #: MM1-OB-004
Date: 03/05/2024 Contains AOC: Yes Contains CBI: No
Person Interviewed: Kelley Potterf
Title: Technical Assistance
At the Bldg. 53 - Application Center, I observed one -full 5-gallon pail of unknown blue gel coat (IMG202403051301301302598124.jpg and IMG-202403051301351352829201.jpg). I asked Ms. Potterf if the container stored waste. Ms. Potterf stated that she did not know. I asked Ms. Bass if she had conducted a hazardous waste determination on the unknown blue gel coat. Ms. Potterf stated "No." Failure to conduct a hazardous waste determination - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1a).
At the Bldg. 53 - Application Center, I observed one 55-gallon HW satellite accumulation container each of control debris and booth rinse (IMG-2024030512555455542887733.jpg and IMG202403051312071272312137.jpg). The containers were closed, in good condition, labeled with the words "Hazardous Waste" and marked with the accumulation start date - 01/11/2024 and 03/05/2024 (the HW satellite accumulation containers were being managed under the Missouri Option for satellite accumulation).
At the Bldg. 53 - Application Center, I observed one 55-gallon less than 90-day HW accumulation container (HW storage container) of booth rinse (IMG-2024030512502750272103357.jpg). The container was closed, in good condition, labeled with the words "Hazardous Waste" and marked with the 03/05/2024 accumulation start date (the HW storage container was in route to HW Storage Area #1).
Photo(s) 1. IMG-2024030512502750272103357.jpg 2. IMG-2024030512555455542887733.jpg 3. IMG-202403051301301302598124.jpg 4. IMG-202403051301351352829201.jpg 5. IMG-202403051312071272312137.jpg
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
Building: Bldg. 2 - HW Storage Area #1
Observations #: MM1-OB-015 MM1-OB-023 MM1-OB-012 MM1-OB-014
Date: 03/05/2024
Contains AOC: Yes Contains CBI: No
Person Interviewed: Keith Kraynak
Title: Loss Control Coordinator
At Bldg. 2 - HW Storage Area #1, I observed one 55-gallon container storing eight to ten cloth wipes (IMG202403051409389381636107.jpg and IMG-202403051409459451711242.jpg). I asked Mr. Kraynak if the container stored hazardous waste. Mr. Kraynak stated that he did not know. I asked Mr. Kraynak if he had conducted a hazardous waste determination on the wipes. Mr. Kraynak stated "No." Failure to conduct a hazardous waste determination - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1d).
At Bldg. 2 - HW Storage Area #1, I observed one 55-gallon HW storage container of Pilot Plant Liquid Waste (IMG-2024030513492549252077078.jpg). The container was closed, in good condition, labeled with the words "Hazardous Waste" and marked with the 02/28/2024 accumulation start date.
At Bldg. 2 - HW Storage Area #1, I observed three boxes of UW-lamps and three 5-gallon pails of UWbatteries (IMG-202403051406576571634213.jpg). The UW was in closed containers, labeled with the words "Universal Waste-Lamps" or "Universal Waste-Batteries" and marked with the date of accumulation (less than one year).
Photo(s)
1. IMG-202403051409389381636107.jpg 2. IMG-202403051409459451711242.jpg
3. IMG-2024030513492549252077078.jpg 4. IMG-202403051406576571634213.jpg
Building: Pilot Plant R&D Lab
Observation #: MM1-OB-005 Date: 03/05/2024
Contains AOC: Yes
Contains CBI: No
Persons Interviewed: Bradley Strathman Jim Eisenhutt
Title: Pilot Lab Chemist Pilot Lab Chemist
At the Pilot Plant Lab, I observed the following HW satellite accumulation containers of reactor drippings (resin waste) not closed:
(1) four 5-gallon pails (IMG-2024030511054154176047.jpg ,IMG-2024030511054454460441.jpg, IMG202403051106056543519.jpg, IMG-2024030511061561553856.jpg, IMG-20240305110702721453147.jpg, IMG-202403051107587581324545.jpg, IMG-2024030511113211322068085.jpg, IMG2024030511122612261947268.jpg, IMG-2024030511123212322006534.jpg., IMG202403061033333333101419.jpg, and IMG-20240306103341334194304.jpg),
(2) four 5-gallon pail liners (IMG-202403051108138131219959.jpg, IMG-202403051108238231221454.jpg, and IMG-202403051108358351300384.jpg), and IMG-202403061033213321108742.jpg) and
(3) two 1-gallon pails (IMG-202403051106386381323519.jpg and IMG-20240306103509359113818.jpg).
Failure to close HW satellite accumulation containers - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(c)(1)(i) referencing 40 CFR 265.173(a) (NOPF 2).
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
The following HW satellite accumulation containers of reactor drippings (resin waste) were not labeled:
(1) two of four 5-gallon pails (two pails were labeled with the words "Hazardous Waste") (same photos as NOPF 2), (2) four 5-gallon pail liners (same photos as NOPF 2) and (3) two 1-gallon pails (same photos as NOPF 2).
Failure to label HW satellite accumulation containers with the words "Hazardous Waste or with other words identifying the contents" - 10 CSR 25-5.262(2)(C)(3) incorporating 40 CFR 262.34(c)(1)(ii) (NOPF 3).
Both Messrs. Strathman and Eisenhutt stated that the pails located under the reactors sampling ports are used to collected resin waste (IMG-202403061027462746105459.jpg, IMG-20240306102758275896800.jpg and IMG-202403061042284228123849.jpg) and are emptied into a 55-gallon container of Pilot Plant Liquid Waste or Pilot Plant Solid Waste. At the Pilot Plant Lab, I observed one 55-gallon HW storage container each of Pilot Plant Liquid Waste and Pilot Plant Solid Waste (IMG-20240305105113511381395.jpg and IMG20240305105114511479001.jpg). The containers were closed, in good condition, labeled with the words "Hazardous Waste" and marked with the accumulation start date (02/28/2024 and 02/09/2024).
At the Pilot Plant Lab, I also observed one 55-gallon container storing a three foot wood board and one clear 5gallon liner containing a white dust (IMG-2024030511232623261792662.jpg). I asked Mr. Kraynak if the container stored hazardous waste. Mr. Kraynak stated "No." I asked Mr. Kraynak if the liner stored hazardous waste. Mr. Kraynak stated "No." Mr. Kraynak stated that the liner contained a residual additive and it is nonhazardous based on review of the safety data sheet (SDS). I reviewed the additive's SDS and it appears that the residual additive dust would be non-hazardous. Photo(s)
1. IMG-20240305104459445951227.jpg 2. IMG-20240305105113511381395.jpg 3. IMG-20240305105114511479001.jpg 4. IMG-2024030511054154176047.jpg 5. IMG-2024030511054454460441.jpg 6. IMG-202403051106056543519.jpg 7. IMG-2024030511061561553856.jpg 8. IMG-202403051106386381323519.jpg 9. IMG-20240305110702721453147.jpg 10. IMG-202403051107587581324545.jpg 11. IMG-202403051108138131219959.jpg 12. IMG-202403051108238231221454.jpg 13. IMG-202403051108358351300384.jpg 14. IMG-2024030511113211322068085.jpg 15. IMG-2024030511122612261947268.jpg 16. IMG-2024030511123212322006534.jpg 17. IMG-2024030511232623261792662.jpg 18. IMG-202403061033213321108742.jpg 19. IMG-202403061033333333101419.jpg 20. IMG-20240306103341334194304.jpg
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Polynt Composites USA Inc.
Inspection Date(s):
21. IMG-20240306103509359113818.jpg 22. IMG-202403061042284228123849.jpg 23. IMG-202403061027462746105459.jpg 24. IMG-20240306102758275896800.jpg
03/05/2024 - 03/06/2024
Building: Old Maintenance Shop
Observation #: MM1-OB-011 Date: 03/05/2024
Contains AOC: Yes Contains CBI: No
Person Interviewed: Ray Rice
Title: Lab Support
At the Old Maintenance Shop, I observed four cardboard boxes of UW-lamps and one 5-gallon plastic tube of UW-lamps (IMG-2024030513323232322501563.jpg and IMG-2024030513325632562458350.jpg). I asked Mr. Rice if the containers stored spent lamps. Mr. Rice stated "Yes." I asked Mr. Rice if he knew the length of time of accumulation of the spent lamps. Mr. Rice stated "No." I asked Mr. Rice if the spent lamps were hazardous waste. Mr. Rice stated that he did not know. I asked Mr. Rice if he had conducted a hazardous waste determination on the spent lamps. Mr. Rice stated "No." Failure to conduct a hazardous waste determination - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1b).
At the Old Maintenance Shop, I observed one 55-gallon HW satellite accumulation container of spent aerosol cans (IMG-202403051323022322573674.jpg). The container was closed, in good condition, labeled with the words "Hazardous Waste" and marked with the accumulation start date - 11/07/2023 (the HW satellite accumulation container was being managed under the Missouri Option for satellite accumulation).
Photo(s) 1. IMG-202403051323022322573674.jpg 2. IMG-2024030513323232322501563.jpg 3. IMG-2024030513325632562458350.jpg
Building: Old Processing Bldg - QC Lab
Observation #: MM1-OB-013 Date: 03/05/2024 MM1-OB-022
Contains AOC: Yes Contains CBI: No
Person Interviewed: Keith Kraynak
Title: Loss Control Coordinator
At the Old Processing Bldg - QC Lab, I observed one 5-gallon pail storing ten cloth wipes (IMG20240305140008081985342.jpg and IMG-202403051400120121824142.jpg). I asked Mr. Kraynak if the pail stored hazardous waste. Mr. Kraynak stated that he did not know. Mr. Kraynak stated that this QC-Lab had been shutdown since 2020 and he was not aware of the length of time of accumulation of the wipes. I asked Mr. Kraynak if he had conducted a hazardous waste determination on the wipes. Mr. Kraynak stated "No." Failure to conduct a hazardous waste determination - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1c).
Photo(s) 1. IMG-20240305140008081985342.jpg 2. IMG-202403051400120121824142.jpg
10 of 37
Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
Building: Facility Wide
Observation #: MM1-OB-027 Date: 03/06/2024
Contains AOC: Yes Contains CBI: No
Person Interviewed: Keith Kraynak
Title: Loss Control Coordinator
Prior to the CEI, Polynt had been managing their reusable solvent contaminated wipes in 5-gallon to 10gallon pails labeled with the words "Recycle Program Rags." These wipes are sent off-site for laundering by Cintas and clean wipes are returned to Polynt. Mr. Kraynak stated that the solvent contaminated wipes are used to clean glassware and equipment. Throughout the visual inspection, I observed pails of solvent contaminated wipes not labeled with the words "Excluded Solvent Contaminated Wipes." At the Pilot Plant R&D Lab and Building 51-R&D Lab 222, I observed one 5-gallon pail each of solvent contaminated wipes labeled with the words "Recycle Program Rags" or "Recycle Program" (IMG-20240305104459445951227.jpg and IMG-2024030514412041201620279.jpg). Mr. Kraynak estimated a total of 37 pails of solvent contaminated wipes on-site (mostly in Building 51). Reusable solvent contaminated wipes are not stored in containers labeled with the words "Excluded Solvent Contaminated Wipes" - 40 CFR 261.4(a)(26)(iv) (NOPF 7). Prior to the completion of the CEI, facility personnel labeled one pail each of reusable solvent contaminated wipes located at the Bldg. 53 - Application Center and Building 51-R&D Lab 222 with the words "Excluded Solvent Contaminated Wipes" (IMG-20240306101254125456967.jpg and (IMG2024030610501969854.jpg). I asked Mr. Kraynak if Polynt had a written description to ensure the solvent contaminated wipes contain no free liquids. Mr. Kraynak stated "No." No written description to ensure the solvent contaminated wipes contain no free liquids - 40 CFR 261.4(a)(26)(v)(C) (NOPF 8).
Photo(s) 1. IMG-20240305104459445951227.jpg 2. IMG-2024030514412041201620279.jpg 3. IMG-20240306101254125456967.jpg 4. IMG-2024030610501969854.jpg
Building: Building 51 - Annex Hallway (HW Storage Area #2)
Observation #: MM1-OB-009 Date: 03/05/2024
Contains AOC: No
Contains CBI: No
Person Interviewed: Keith Kraynak
Title: Loss Control Coordinator
At the Building 51 - Annex Hallway (HW Storage Area #2), I observed one 55-gallon HW storage container each of resin waste, composite solids and lab solids (IMG-20240305102942294285244.jpg). The containers were closed, in good condition, labeled with the words "Hazardous Waste" and marked with the 02/20/2024 accumulation start date.
Photo(s) 1. IMG-20240305102942294285244.jpg
11 of 37
Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
SECTION III - RECORDS REVIEW
Record: Manifests
AOC: No
Ref #: MM1-RR-002 Reviewed By: Mike Martin
Reviewed Date: 03/06/2024
The past three years uniform hazardous waste manifests were on-file and appeared to be satisfactory.
Record: Personnel Training
AOC: Yes
Ref #: MM1-RR-004 Reviewed By: Mike Martin
Reviewed Date: 03/06/2024
From the review of HW job descriptions for the Facility Manager and Lab Support Generalist (Attachment 3), I did not observe the description of the type and amount of introductory and continuing training. I asked Mr. Kraynak if Polynt had a written description of the type and amount of introductory and continuing training required for HW staff. Mr. Kraynak stated "No." No written description of the type and amount of introductory and continuing training for required HW staff - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.16(d)(3) (NOPF 4).
Record: Inspections
AOC: No
Ref #: MM1-RR-005 Reviewed By: Mike Martin
Reviewed Date: 03/05/2024
Weekly HW inspections are conducted on HW satellite accumulation and storage containers. The weekly HW inspection logs for past three years were on-file and appeared to be satisfactory.
Record: Biennial Reports
AOC: No
Ref #: MM1-RR-006 Reviewed By: Mike Martin
Reviewed Date: 03/05/2024
The Biennial report was on-file (Attachment 4) and appeared to be satisfactory.
Record: Contingency Plan
AOC: Yes
Ref #: MM1-RR-007 Reviewed By: Mike Martin
Reviewed Date: 03/06/2024
Polynt's contingency plan consist of an Emergency Action Plan-EAP (revised 10/23/2023 to update Emergency Coordinators - Attachment 5), Integrated Contingency Plan-ICP (revised 11/2021 revised 10/23/2023 to update Emergency Coordinators - Attachment 6) and a quick reference guide (Attachment 7). Mr. Kraynak stated that the EAP refers to the ICP. I asked Mr. Kraynak if the contingency plans are upto-date and were submitted to local emergency agencies. Mr. Kraynak stated that the contingency plans are up-to-date and had not been submitted to local emergency agencies. Contingency Plan not submitted to local emergency agencies - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.53(b) (NOPF 5). From review of the EAP and ICP, the alternative evacuation routes are not listed. Contingency Plan does not list alternative evacuation routes - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.52(f) (NOPF 6).
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
SECTION IV - AREA OF CONCERN The presentation of Areas(s) of Concern does not constitute a formal compliance determination or violation. Building: Bldg. 53 - Application Center MM1-OB-004 Failure to conduct a hazardous waste determination on one -full 5-gallon pail of unknown blue gel coat - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1a). Building: Old Maintenance Shop MM1OB011 Failure to conduct a hazardous waste determination on four cardboard boxes of UW-lamps and one 5-gallon plastic tube of UW-lamps - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1b). Building: Old Maintenance Shop MM1OB013 Failure to conduct a hazardous waste determination on one 5-gallon pail storing ten cloth wipes - 10 CSR 255.262(1) incorporating 40 CFR 262.11(a) (NOPF 1c). Building: Bldg. 2 - HW Storage Area #1 MM1OB15 Failure to conduct a hazardous waste determination on one 55-gallon container storing eight to ten cloth wipes - 10 CSR 25-5.262(1) incorporating 40 CFR 262.11(a) (NOPF 1d). Building: Pilot Plant R&D Lab MM1OB005 Failure to close ten HW satellite accumulation containers - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(c)(1)(i) referencing 40 CFR 265.173(a) (NOPF 2). Building: Pilot Plant R&D Lab MM1OB005 Failure to label eight HW satellite accumulation containers with the words "Hazardous Waste or with other words identifying the contents" - 10 CSR 25-5.262(2)(C)(3) incorporating 40 CFR 262.34(c)(1)(ii) (NOPF 3). Records: Personnel Training MM1RR004 No written description of the type and amount of introductory and continuing training required for HW staff 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.16(d)(3) (NOPF 4). Records: Contingency Plan MM1RR007 Contingency Plan not submitted to local emergency agencies - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.53(b) (NOPF 5).
Contingency Plan does not list alternative evacuation routes - 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR 265.52(f) (NOPF 6).
Building: Facility Wide
MM1OB027
Reusable solvent contaminated wipes are not stored in containers labeled with the words Excluded Solvent Contaminated Wipes" - 40 CFR 261.4(a)(26)(iv) (NOPF 7).
No written description to ensure the solvent contaminated wipes contain no free liquids - 40 CFR 261.4(a)(26)(v)(C) (NOPF 8).
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Polynt Composites USA Inc. Inspection Date(s):
03/05/2024 - 03/06/2024
SECTION V - CLOSING CONFERENCE AND FOLLOW UP
Closing Conference
At the conclusion of the CEI, I summarized my findings and recommendations to Messrs. Kraynak and Maurin and Mses. Drake and Cortelli. I provided Mr. Kraynak with a Confidentiality Notice (Attachment 8), a Receipt for Documents and Samples (Attachment 9), and a Notice of Preliminary Findings (NOPF) (Attachment 10), which he signed as acknowledgement of receipt. No confidentiality claims were made by Polynt.
The following inspection documents and compliance assistance handouts were left with Polynt:
Notice Regarding Proprietary/Confidential Business Information (EPA Handout) Confidentiality Notice (Top page of the completed carbonless transfer set) Receipt for Documents and Samples (Top page of the completed carbonless transfer set) NOPF (Top page of the completed carbonless transfer set) Instructions for Responding to an NOPF (EPA Handout) Solvent Contaminated Wipes Final Rules Summary Chart (EPA Handout) Hazardous Waste Satellite Accumulation (MoDNR Technical Guidance Document)
Follow Up I observed no follow up at the time of the CEI.
Communication Log No additional information received by REGION 7 after exiting the Facility on 03/06/2024.
SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted.
SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Report Attachments
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