Document LpV7QevK0w7kn1wD33zjVXeaQ
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6 1445 ROSS AV ENUE, SUITE 1200
DALLAS, TEXAS 75202-2733
November 9, 2018
CERTIFIED MAIL: RETURN RECEIPT REQUESTED: 7015 1520 0003 3990 7152
Rhonda Grisham Environmental Consultant ALX Industries LLC 2204 Catalina Dr. Pasadena, Texas 77503
Re: EPA RCRA Compliance Evaluation Inspection- August 8, 2018; EPA ID# TXR000080711 - ALX Industries LLC- Pasadena, Texas
Dear Ms. Grisham,
On August 8, 2018, The United States Environmental Protection Agency (EPA) conducted an announced Compliance Evaluation Inspection (CEI) at the ALX Industries LLC Pasadena facility in Pasadena, Texas. I would like to thank you for the time and the courtesy you and your staff extended to our inspectors. Enclosed, please find a copy of the CEI Repmt which chronicles the inspection findings. A copy of this CEI Report will be transmitted separately to the Texas Commission on Environmental Quality (TCEQ).
Based on the information contained in the enclosed inspection report, there are areas of concern for which EPA may take enforcement action under the Resource Conservation and Recovery Act (RCRA). If you have not already done so, we encourage you to immediately address all compliance issues identified in the CEI Report.
If you have any questions regarding this matter, please contact Mr. Bill Mansfield of my staff at (214) 665-8321 or email to Mansfield.william@epa.gov.
Enclosure
Sincerely,
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Troy Stuckey Chief Waste Compliance III Section (6EN-H3) Waste Enforcement Branch
cc: James Gradney, MPA Manager, Waste Enforcement Section Enforcement Division (MC-128) Texas Commission on Environmental Quality P. 0. Box 13087 Austin, TX 78711
Peter B. Abel Waste Liaison Program Support Section (MC-174) Office of Compliance and Enforcement Texas Commission on Environmental Quality P. 0. Box 13087 Austin, TX 78711
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Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
Company Name: Facility Name: Facility Physical location: .
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Faci lity Contact:
08/14/2018 RCRA N/A
ALX Industries AlX Industries 2204 Catalina Dr. Pasadena,TX,77503 2204 Catalina Dr. Pasadena,TX,77503 Harris Rhonda Grisham rhonda@alxindustries.com
FRS Number: Identification/Permit Number: Media Number: NAICS: SIC:
110054869344 TXR000080711 N/A 331492 N/A
Personnel participating in inspection:
David Robertson
EPA/ 6EN-H1
Debra Pandak
EPA/ 6EN- H2
Bill Mansfield
EPA/ 6EN- H3
Brad Alexander
AlX Industries
Zach Petch
ALX Industries
Rhonda Grisham
ALX Industries
Candi Stansbury
AlX Industries
I Environmental Consultant
lead Inspector Inspector Inspector President Co-Founder Environmental Consultant Executive Assistant
214- 665-7363 214-665-7565 214-665-8321 832-767-2467 832-767-2467 832-767-2467 832-767-2467
EI?A lead Inspector Signature/Date
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David Robertson
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For David Robertson
11/08/18
Date
Supervisor Signature/Date
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Troy Stuckey
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Date
6ENFORM-019-R7 (2/15/2017)
1
Section I-INTRODUCTION
ALX Industries Inspection Date 08/14/2018
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors David Robertson, Debra Pandak, and Bill Mansfield arrived at ALX Industries at 8:25 AM on 08/14/18 for an announced inspection. We met with Brad Alexander (President), Zach Petch (Co-Founder), Rhonda Grisham (Environmental Consultant), and Candi Stansbury (Executive Assistant). David Robertson presented his credentials to Brad Alexander and informed him that this was an EPA inspection to determine the facilities compliance with the Resource Conservation and Recovery Act (RCRA). The scope of the inspection is a full compliance evaluation (FCE) and includes evaluation of the facility's compliance with RCRA.
FACILITY DESCRIPTION
ALX Industries operates in a metal warehouse building at 2204 Catalina Dr. in Pasadena Texas. ALX 'employs approximately 5 people and operates during normal business hours from 8amto 5pm. ALX reclaims silverfrom photo chemicals and photo film.
Section II- OBSERVATIONS
During the facility walk through, I observed the following processes:
1) Primary silver reclamation that uses an electrolytic plating machine that sits on top of approximately 275-gallon totes to extractsilverout of the fixer photochemical (Appendix 1, photos 1). Brad said that the fixercontains the majority of the silver and the developer usually contains little to no silver. Brad also said that human error is how the developer and fixer get mixed. This primary silver reclamation process is used only with the high concentration of silver found in the fixer. Test strips are used to determine the pH and silver concentration of the tote contents in turn to determine if primary reclamation is warranted. Zach demonstrated using the test strip as well as the copper pipe test in which a clean copper pipe is dipped into the contents of the tote, swirled around and them pulled out to see if silver is present on the pipe (Appendix 1, photos 8 -12).
2) The secondary silverreclamation process is called peristaltic and involves pumping the contents of the totes through a 5-gallon bucket of steel wool where the silver reacts and chemically bonds to the steel wool (Appendix 1, photo 2). Later the steel wool is burned to reclaim the silver.
3) Storage area in neighboring unit. (Appendix 1, photos 6 & 7)
2