Document M4YMq9d9EwYg32Ym776k1vBpj

RCRA Compliance Evaluation Inspection Report 1) Inspector and Author of Report David A. Champagne Physical Scientist Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch RCRA Enforcement Section U.S. Environmental Protection Agency - Region 4 Sam Nunn Atlanta Federal Center 61 Forsyth Street, S.W. Atlanta, Georgia 30303 Phone: (404) 562-9028 Fax: (404) 562-8566 E-mail: champagne.david@epa.gov 2) Facility Information Inteplast Engineered Films Corp. 7549 Brokerage Drive Orlando, Florida 32809-5625 County: Orange Latitude: 28.453796 Longitude: -84.418123 EPA ID Number: FLD984201251 Primary NAIC: 323111 - Commercial Gravure Printing Other NAICS: 326111 - Plastics Bag and Pouch Manufacturing 3) Responsible Official Mr. James Sciaino, Plant Manager Phone: (407) 630-1706 Email: jsciaino@inteplastef.com 4) Inspection Participants Mr. James Sciaino, Plant Manager Inteplast Engineered Films Corp. Mr. Michael Eckoff, Inspector, Florida Department of Environmental Protection (FDEP) Ms. Kristen Johannessen, Inspector, FDEP Mr. David A. Champagne, Inspector, U.S. EPA 5) Date of Inspection April 8, 2021 09:00 a.m. Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 1 of 21 6) Applicable Regulations 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. 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 62-710, 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. 62-730.185(1) [40 C.F.R. 273.9], a "Small Quantity Handler of Universal Waste" (SQHUW) is a universal waste handler who does not accumulate 5,000 kilograms or more total of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. 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. 62-730.160(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"). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17], a large quantity generator (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"). 7) Purpose of Compliance Evaluation Inspection On April 8, 2021, Mr. Michael Eckoff, Florida Department of Environmental Protection (FDEP), and David Champagne, U.S. EPA, conducted a routine compliance evaluation inspection of Inteplast Engineered Films Corp. (Inteplast or facility) to determine the facility's compliance with state and federal hazardous waste regulations. This was an EPA lead inspection. Inteplast was represented by Mr. James Sciaino, Plant Manager. Upon entering the facility, the inspectors introduced themselves, showed their credentials and explained the purpose of the visit. The facility representatives provided a description of the facility and a process-based inspection was conducted. Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 2 of 21 8) Compliance History Inteplast was last inspected May 24, 2017 as a large quantity generator of hazardous waste. The following violations were identified: 62-730.150(2)(b) [State statutory or Regulatory requirement that is broader-in-scope than federal RCRA requirements]; 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 Regulations Waste Activity Form 40 C.F.R. 262.11; Make a hazardous waste determination 40 C.F.R. 262.34(a); Date a hazardous waste container 40 C.F.R. 262.41(a); Submit a biennial report 40 C.F.R. 265.52(d); List names and addresses for emergency coordinator(s) 40 C.F.R. 265.52(e); List of emergency equipment 40 C.F.R. 265.54(d); Contingency plan update with new Emergency Coordinator 40 C.F.R. 265.173(a); Keep a container closed during storage 40 C.F.R. 265.174; Conduct weekly inspections 9) Facility Description Inteplast Engineered Films Corp. formulates high quality plastic films for printers, converters, and end users with simple mandate. Inteplast is located at 7549 Brokerage Drive in Orlando, Florida. The most recent Hazardous Waste Generator Notification (EPA Form 8700-12) dated February 28, 2020, characterized the facility as a large quantity generator (LQG) of hazardous waste. The facility operates its extrusion department 24 hours a day, 7 days a week, and the printing department operates 24 hours a day 5 days a week. Inteplast began operations in the 65,000 sq. ft. building in 2011 and currently has approximately 70 employees. 10) Inspection Findings Plate Mounting Room Plates are used to make designs on film. After a plate has been used, the facility uses isopropyl alcohol (IPA) to wipe down the machine and plates. At the time of the inspection, there was not a hazardous waste container in this satellite accumulation area (SAA). A facility representative stated that he disposes of the solvent contaminated rag, immediately after use, in a hazardous waste container located in the hazardous waste central accumulation area (CAA). At the time of the inspection, the inspection team made note and notified the facility of a strong solvent odor radiating from this room. Plate Mounting, Film Production Floor - Hazardous Waste Central Accumulation Area At the time of the inspection, there were sixteen (16) 55-gallon hazardous waste containers in the CAA. The containers were double stacked in two rows of 4 containers. This area lacked aisle space and was difficult for the inspection team to conduct the CEI of the Plate Mounting Room and Film Production Floor's CAA (Photographs 1 and 2 of 21). Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 3 of 21 Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(6)], which incorporates Fla. Admin. Code Ann. R. 62-730.160(1) [40 C.F.R. 262.255], and is a condition of the LQG Permit Exemption, a generator is required to maintain aisle space to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes. Hazardous waste labels, containing the accumulation dates and significant information containing the contents of the container, were not clearly visible at the time of the inspection (Photographs 1, 3, and 4 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R 262.17(a)(5)(i)(C)], which is a condition of the LQG Permit Exemption, the date upon which each period of accumulation begins, must be clearly visible for inspection on each container. At the time of the inspection, the facility was storing hazardous waste in a CAA and did not take precautions to prevent an accidental ignition of ignitable waste by posting "No Smoking" signs (Photograph 3 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R 262.17(a)(1)(vi)(B)], which is a condition of the LQG Permit Exemption, special conditions for accumulation of ignitable/reactive waste require LQGs to take precautions to prevent accidental ignition or reaction of ignitable or reactive waste and "No Smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. At the time of the inspection, the sixteen (16) hazardous waste containers stored in the CAA were not labeled with the indication of the hazards of the contents (Photograph 4 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(5)(i)], which is a condition of the LQG Permit Exemption, a generator must mark or label its containers with an indication of the hazards of the contents. At the time of the inspection, within the immediate location of the CAA, there was no decontamination eye-wash station present (Photograph 3 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(6)], which incorporates Fla. Admin. Code Ann. R. 62-730.160(1) [40 C.F.R. 262.252(c)] and is a condition of the LQG Permit Exemption, all areas deemed applicable by Fla. Admin. Code Ann. R. 62-730.160(1) [40 C.F.R. 262.250] must be equipped with decontamination equipment. Printing Department and Central Accumulation Area Located in this department are two (2) 8-color printers and two (2) 10-color printing press machines. Also located in this department are two (2) Regenerative Thermal Oxidizers (RTO 1 and RTO 2) that oxidize and decompose volatile organic compounds (VOCs). The RTO has various towers which contain specialized thermal ceramic material and consists of a four-step process of heating, incineration, recovery, and purging. The RTO has an industrial-grade air pollution control device that uses high temperatures to combust and decompose VOCs into carbon dioxide (CO2) and water vapor. These Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 4 of 21 machines appeared to be operational, and visually free of leaks at the time of the inspection. Waste generated in the Ink Dispensing Room and the Printing Department, are collected, and stored in a CAA within this designated area. At the time of the inspection there were three (3) 55-gallon hazardous waste containers in this CAA. All containers were labeled and dated. One container was not closed during accumulation at the time of the inspection (Photograph 5 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) 262.17(a)(1)(iv)(A), which is a condition of the LQG Permit Exemption, a container holding hazardous waste must always be closed during accumulation, except when it is necessary to add or remove waste. At the time of the inspection, the facility was storing hazardous waste in a CAA and did not take precautions to prevent an accidental ignition of ignitable waste by posting "No Smoking" signs (Photograph 6 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R 262.17(a)(1)(vi)(B)], which is a condition of the LQG Permit Exemption, special conditions for accumulation of ignitable/reactive waste require LQGs to take precautions to prevent accidental ignition or reaction of ignitable or reactive waste and "No Smoking" signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste. Located in the Worker Station of the Printing Department, the facility was managing six (6) 55-gallon containers, two (2) 10-gallon containers, and a 5-gallon container of spent solvent-contaminated rags. The inspection team asked the facility to make a hazardous waste determination on the spent solventcontaminated rags prior to disposal (Photographs 7-9 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Fla. Admin. Code Ann. r. 62-730.030(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11]. Ink Dispensing Room Paint is formulated and mixed in this area. At the time of the inspection, there was D001 paint-related hazardous waste in a 55-gallon container in a SAA that was not closed, not labeled with the words "Hazardous Waste" nor an indication of the hazard of the contents (Photographs 10 and 11 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.15(a)(4)], which is a condition of the SAA Permit Exemption, a generator is required to keep containers of hazardous waste closed at all times during accumulation, except when adding, removing, or consolidating waste; or when temporary venting of a container is necessary for the proper operation of equipment, or to prevent dangerous situations, such as build-up of extreme pressure. Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.15(a)(5)(i) and (ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers (i) with the words "Hazardous Waste" and (ii) with an indication of the hazards of the contents. Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 5 of 21 During the mixture process of various paint-related products, paint containing hazardous materials is subsequently splattered on the walls and floor of the room. This room must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste. Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(6)], which incorporates Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.251] and is a condition of the LQG Permit Exemption, facilities must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste. Maintenance Department Aerosol cans are used for various touch-ups and general maintenance on parts or machines and are thrown in the regular trash. The inspection team requested a hazardous waste determination for the municipal disposal of unpunctured aerosol cans (Photograph 12 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Fla. Admin. Code Ann. r. 62-730.030(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11]. The maintenance department generates spent rags. At the time of the inspection, it was unclear how the facility was managing two (2) 10-gallon containers storing spent rags. A hazardous waste determination was requested (Photographs 13 and 14 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Fla. Admin. Code Ann. r. 62-730.030(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11]. The maintenance department has a two milling machines. At the time of the inspection, a waste determination was requested for the scrap metal and documentation indicating where the metal is shipped for disposal or recycling (Photographs 15 and 16 of 21). Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Fla. Admin. Code Ann. r. 62-730.030(1) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.11]. Maintenance Parts Room Located in the Maintenance Parts Room was storage for universal waste. At the time of the inspection, there was a 4-foot container of universal waste lamps that was not labeled, dated, or closed. There were two (2) additional 4-foot containers of universal waste lamps that were labeled, but not dated, or closed. There were also four (4) 8-foot universal waste lamps that were not in containers, labeled or dated Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 6 of 21 (Photographs 17-21 of 21). Pursuant Fla. Admin. Code Ann. r. 62-730.185(1) and Fla. Admin. Code Ann. r. 62-737.400(5) [40 C.F.R. 273.13(d)], a SQHUW must manage universal waste lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment. Pursuant to Fla. Admin. Code Ann. r. 62-730.185(1)[40 C.F.R. 273.14(e)], a SQHUW must label or mark each lamp or container of lamps clearly with one of the following phrases: "Universal Waste-Lamp(s),"or "Waste Lamp(s)," or "Used Lamps." Pursuant to Fla. Admin. Code Ann. r. 62-730.185(1) and Fla. Admin. Code Ann. r. 62-737.400(7) [40 C.F.R. 273.15(a) and (c)], a SQHUW may accumulate universal waste no longer than one year and must to be able to demonstrate the length of time that the universal waste has accumulated from the date that it became a waste or was received. Records On Monday April 19, 2021, Mr. Sciaino emailed the EPA and FDEP copies of weekly inspections from 2018, 2019 and 2020. The inspection team conducted a record review of the facility's weekly inspections for the hazardous waste central accumulation area storage location. The weekly inspection log did not identify the two CAAs so it is unclear whether both locations are inspected. The following weekly inspections were noted to span beyond seven days. January 22, 2018 through January 31, 2018 (9 days) March 7, 2018 through March 21, 2018 (14 days) June 11, 2019 through June 19, 2019 (8 days) November 12, 2019 through December 18, 2019 (36 days) December 18, 2019 through December 26, 2019 (8 days) April 8, 2020 through April 17, 2020 (9 days) June 30, 2020 through July 8, 2020 (8 days) September 21, 2020 through September 29, 2020 (8 days) Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(1)(v)], which is a condition of the LQG Permit Exemption, a generator is required to, at least weekly, inspect central accumulation areas looking for leaking containers and for deterioration of containers caused by corrosion or other factors. On Monday April 19, 2021, Mr. Sciaino emailed the EPA and FDEP a copy of the facility's Contingency Plan and Quick Reference Guide. The most recent contingency plan was dated April 20, 2020, and Quick Reference Guide document, version 1.0.0, was dated April 14, 2021. At the time of the inspection, a quick reference guide of the contingency plan had not been created or submitted to local emergency responders. Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(6)], which incorporates Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.262(b)] and is a condition of the Large Quantity Generator Exemption, a large quantity generator that is amending its contingency plan must at the time submit a quick reference guide of the contingency plan to the local emergency Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 7 of 21 responders identified in paragraph (a) of this section. On Monday April 19, 2021, Mr. Sciaino emailed the EPA and FDEP copies of 2018, 2019, and 2020 manifests. Certificate of Disposals from the designated facility were attached. Inteplast utilizes the following transporters to transfer hazardous waste: Univar Solutions USA Inc. EPA ID: TXR000084869 (2020) Freehold Cartage Inc. EPA ID: NJD054126164 (2020) The facility utilizes Giant Resource Recovery EPA ID: SCD036275626 for the disposal of hazardous waste generated on site. On Monday April 19, 2021, Mr. Sciaino emailed the EPA and FDEP training record documentation. Mr. Rafael Nieto and Mr. Jeremy Steffan completed a RCRA Hazardous Waste Management Webinar on December 16, 2020. The training was conducted by Lion Technology Inc. The most recent training document for Mr. James Sciaino was for a two-day RCRA Hazardous Waste Management Workshop dated October 22, 2019. Training was not provided for eight of the ten members on the Emergency Response Team listed in the contingency plan. Facility personnel must take part in an annual review of the initial training. Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(7)(iii)], which is a condition of the LQG Permit Exemption, facility personnel must take part in an annual review of the initial training required in paragraph 40 C.F.R. 262.17(a)(7)(i) of this section. At the time of the inspection, no written job descriptions were provided for positions at the facility related to hazardous waste management. On Monday April 19, 2021, Mr. Sciaino emailed the EPA and FDEP a document describing the job descriptions for hazardous waste management related positions within the facility. This document was not dated and presumed to have been created after the inspection. Pursuant to Fla. Admin. Code Ann. r. 62-730.160(1) [40 C.F.R. 262.17(a)(7)(iv)(A)], large quantity generators must maintain the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job. 11) Summary The inspectors conducted the exit meeting with facility team presenting the preliminary results of the inspection. Inteplast Engineered Films Corp was inspected as a large quantity generator of hazardous waste. At the time of the inspection, the facility did not appear to be in compliance with some requirements of RCRA. The inspection concluded at approximately 12:00 hours. 12)Signed ___________________________ David Champagne Inspector and Author of Report Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 _________________________ Date Page 8 of 21 13) Concurrence and Approval ARACELI Digitally signed by ARACELI CHAVEZ _C_H__A_V_E_Z_______-0_4'_00_' __________ Date: 2021.05.20 10:53:52 Araceli B. Chavez Chief RCRA Enforcement Section _________________________ Date Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 9 of 21 RCRA CEI Photographs for Inteplast Engineered Films Corp. 7549 Brokerage Drive Orlando, Florida 32809-5625 Taken by: David Champagne, U.S. EPA April 8, 2021 Camera Model: Google Pixel XL Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 10 of 21 Photograph 1 of 21: Plate Mounting, Film Production Floor - Hazardous Waste CAA Photograph 2 of 21: Plate Mounting, Film Production Floor - Hazardous Waste CAA Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 11 of 21 Photograph 3 of 21: Plate Mounting, Film Production Floor - Hazardous Waste CAA Photograph 4 of 21: Plate Mounting, Film Production Floor - Hazardous Waste CAA Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 12 of 21 Photograph 5 of 21: Printing Department - Hazardous Waste CAA Photograph 6 of 21: Printing Department - Hazardous Waste CAA Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 13 of 21 Photograph 7 of 21: Spent Rag Collection Area Photograph 8 of 21: Spent Rag Collection Area Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 14 of 21 Photograph 9 of 21: Spent Rag Collection Area Photograph 10 of 21: Ink Dispensing Room - Hazardous Waste SAA Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 15 of 21 Photograph 11 of 21: Ink Dispensing Room - Hazardous Waste SAA Photograph 12 of 21: Maintenance Department - Aerosol Can Disposal Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 16 of 21 Photograph 13 of 21: Maintenance Department - Spent Rag Collection Container Photograph 14 of 21: Maintenance Department - Spent Rag Collection Container Inteplast Engineered Films Corp. FLD984201251 Page 17 of 21 April 8, 2021 Photograph 15 of 21: Maintenance Department - Scrap Metal Generation Area Photograph 16 of 21: Maintenance Department - Scrap Metal Generation Area Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 18 of 21 Photograph 17 of 21: Maintenance Parts Room - Universal Waste Storage Area Photograph 18 of 21: Maintenance Parts Room - Universal Waste Storage Area Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 19 of 21 Photograph 19 of 21: Maintenance Parts Room - Universal Waste Storage Area Photograph 20 of 21: Maintenance Parts Room - Universal Waste Storage Area Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 20 of 21 Photograph 21 of 21: Maintenance Parts Room - Universal Waste Storage Area Inteplast Engineered Films Corp. FLD984201251 April 8, 2021 Page 21 of 21