Document MJB5G8mexoJL7KG2BqGzzwxxk

Report Prepared by: Report Approved by: RCRA COMPLIANCE EVALUATION INSPECTION O-I Glass 7134 County House Road Auburn, New York NYD088662754 August 29-30, 2024 ROBERT Digitally signed by ROBERT MORRELL MORRELL Date: 2024.10.28 15:41:51 __________________-_0_4'_00_'__________ Robert Morrell, Geologist Monitoring Operations Section Date: ________________ Digitally signed by PHILIP PHILIP COCUZZA COCUZZA ___________________D_a_te_: _20_2_4._10_.2_9_0_7:_55_:26 -04'00' Philip Cocuzza, Supervisor Monitoring Operations Section Date: ________________ O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Page 2 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Objective A RCRA Compliance Evaluation Inspection (CEI) was conducted at O-I Glass on August 29-30, 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 O-I Glass Patrick Salvador, Environmental Manager Patrick.salvador@o-i.com, 315-317-6365 Jeffrey Armour, Unit Plant Manager Jeffrey.armour@o-i.com, 315-246-7926 John Bianchi, Quality Manager John.bianchi@o-i.com Michael Carter, Safety Manager Michael.carter@o-i.com Glenn Hunter and Associates James Corbett, Environmental Coordinator jcorbett@ghacorp.net, 419-270-8805 U.S. Environmental Protection Agency Robert Morrell, Geologist morrell.robert@epa.gov, 732-906-6804 Facility Description O-I Glass, formerly known as Owens-Brockway Glass Container Incorporated, is located at 7134 County House Road in Auburn, New York. The facility is a manufacturer of glass containers for the food and beverage industry. The 450,000 square foot manufacturing facility is located on a 119acre site. There are 230 employees, and the plant operates two 12-hour shifts, 24 hours per day, 7 days per week. Glass pellets, silica sand, and soda ash are delivered to the facility by rail car. For each batch, the ingredients are blended and then heated to approximately 2400oF in one of two furnaces. The molten glass is conveyed to the Mold Shop, where there are five automated mold lines. Only three of the five mold lines were operating during the inspection. The molten glass is poured into the molds and air is blown in to create openings for the glass containers. After several automated steps, the glass containers are removed from the molds. The containers are air-cooled and Page 3 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 conveyed to the Selecting Area, where the glass is inspected for defects using cameras and lights. The glass containers are palletized and conveyed to the warehouse, where the final product is weighed and wrapped for shipping. Rejected products are conveyed to a bin for reuse as stock in the manufacturing process. Water and Wastewater Water for the facility is provided by the City of Auburn. Sanitary wastewater is discharged to the City of Auburn Wastewater Treatment Plant (WWTP). Process water is used to convey the recycled glass to the beginning of the manufacturing process. The process wastewater flows to an oil water separator. The recovered oil is placed in a carboy container and stored in the Waste Accumulation Room (Oil Room) as non-hazardous used oil. The wastewater from the oil water separator is discharged to the City of Auburn WWTP. The process wastewater discharge is sampled quarterly for compliance with the industrial user permit issued by the City of Auburn WWTP and 40 CFR Part 426 Subpart H - Glass Container Manufacturing Subcategory. Solid and Hazardous Waste Management Used oil from machinery and the oil water separator is collected and stored in carboys and drums in the Oil Room as non-hazardous used oil. The used oil is picked up once per week by Safety Kleen Systems. Universal waste, consisting of spent batteries and fluorescent bulbs, is stored in the universal waste cabinet in the Storage Room. Used aerosol cans are placed in a 55-gallon satellite container with a hazardous waste label in the Storage Room. Approximately 30 gallons of parts cleaner solvent are generated each year when the solvent is replaced in the parts cleaners (there are two parts cleaners). The solvent is shipped as a D039 hazardous waste (tetrachloroethylene) to Clean Harbors of Baltimore, Maryland. Approximately every few years, waste sodium hydroxide is generated when the glass container forming equipment is cleaned or the caustic dip tank is cleaned. The waste corrosive liquid is shipped as a D002 hazardous waste to Spring Grove Resource Recovery in Cincinnati, Ohio. One of the furnaces (A1) was recently decommissioned and replaced with a new furnace (A2). The furnace brick and dust was analyzed by Envirosafe Services of Ohio as part of a waste profile. The waste brick and dust contained elevated levels of cadmium, chromium, and lead. Approximately 100 tons of hazardous waste (D006, D007, D008) was generated during the replacement of the furnace. The hazardous waste solid was shipped by rail car to Envirosafe Services in Oregon, Ohio. Page 4 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Observations A review of the hazardous waste manifests indicates that O-I Glass is a small quantity generator most months but is a large quantity generator during certain months when periodic maintenance of furnaces and equipment cleaning occur. In the last 12 months, the facility generated 30 gallons of D039 hazardous waste from the parts washers, 4800 pounds of D002 hazardous waste from the caustic cleaning operations, and 100 tons of hazardous waste solids (D006, D007, D008) during the furnace replacement. The most recent shipment of hazardous waste was on May 3, 2024. On the day of the inspection, there was a 55-gallon satellite container in the Storage Room. The container was half full of used aerosol cans. There was a hazardous waste label marked with the contents of the drum. There were no containers of hazardous waste being stored in the Waste Accumulation Room (Oil Room) on the day of the inspection. Hazardous materials safety training is provided annually to employees that handle hazardous waste. Department of Transportation (DOT) shipping certification is provided for employees that sign hazardous waste manifests. The facility maintains a weekly inspection log of the Waste Accumulation Room. The facility provided a hazardous waste contingency plan that summarized its hazardous waste operations and emergency contact information. Findings There were no violations or compliance issues found on the days of the inspection. The satellite container was in a room where product containers were being stored. It was recommended to facility representatives to relocate the satellite container to the adjacent Waste Accumulation Room. The container has since been relocated. Attachments Photographs (#1 - #4) Page 5 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Photo #1: View of the Waste Accumulation Room (Oil Room). Page 6 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Photo #2: View of the universal waste cabinet. Page 7 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Photo #3: View of the satellite container in the Storage Room. Page 8 of 9 O-I Glass NYD088662754 Inspection Date: August 29-30, 2024 Photo #4: View of the relocated satellite container in the Waste Accumulation Room. Page 9 of 9