Document NGzwOkkLmL8x8ZK9mar1mQoYp

RCRA Inspection Report 1) Inspector and Author of Report Alan Newman, Environmental Engineer RCRA Enforcement Section Chemical Safety and Land Enforcement Branch Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency, Region 4 61 Forsyth Street, S.W. Phone: (404) 562-8589 Atlanta, Georgia 30303 Email: newman.alan@epa.gov 2) Facility Information Techtrix, Inc. 525 Plainview Street Gadsden, Alabama 35901-2027 Etowah County EPA ID No.: ALD982167678 NAICS: 332813 Electroplating, plating, polishing, anodizing, and coloring 3) Responsible Officials Pamela Beavers, Plant Manager Office: (256) 543-2424 Cell: (256) 365-6458 Email: pamelabeavers@outlook.com 4) Inspection Participants Pam Beavers Tobie Bateman Kayla Acosta Paula Whiting Mike Neill Art Masters Kevin Simmons Alan Newman Corey Holmes Techtrix, Inc. Techtrix, Inc. EPA, Region 4 EPA, Region 4 EPA, Region 4 EPA, Region 4 EPA, Region 4 EPA, Region 4 ADEM 5) Date(s) of Inspection March 22, 2021 1:00 p.m. - 5:00 p.m. C.D.T. and March 23, 2021 7:30 a.m. - 4:30 p.m. C.D.T 6) Applicable Regulations Alabama Hazardous Waste Management and Minimization Act of 1978, Ala. Code 22-30-1 et seq [Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927)] and rules 335-14 of the Alabama Department of Environmental Management (ADEM) Administrative Code (ADEM Admin. Code) [40 Code of Federal Regulation (C.F.R.), Parts 260 - 270, 273, 278, & 279]. Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(a) [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 22-30-12(b) of the AHWMMA, Ala. Code 22-3012(b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with ADEM Admin. Code r. 335-14-3-.01(6) and (7) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in ADEM Admin. Code r. 335-14-3-.01(5)(a)7. and 8. [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in ADEM Admin. Code r. 335-14-3-.01(5)(a) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to ADEM Admin. Code r. 335-14-3-.01(7) [40 C.F.R. 262.17], a LQG may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 22-30-12(b) of the AHWMMA, Ala. Code 22-3012(b) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in ADEM Admin. Code r. 335-14-3-.01(7) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine Techtrix Inc.'s compliance with the applicable requirements of RCRA and the corresponding ADEM regulations. This was an EPA lead inspection. 8) Previous Inspection History Techtrix Inc. was inspected by ADEM on December 18, 2018. There were eleven violations documented in the ADEM trip report. The violations were resolved with formal enforcement on June 21, 2019. 9) Facility Description Techtrix, Inc. (Techtrix or Facility) was founded in 1987 and operates as an electroplating and metal finishing shop. The Facility occupies an 80,000 square foot building and employs approximately eleven employees. The facility operates twelve plating lines and a no discharge wastewater treatment system. Techtrix provides zinc, cadmium, copper, tin, nickel, gold, and silver electroplating services. The Facility also performs additional finishing services such as electroless nickel, alodine anodize, zinc phosphate, manganese phosphate, endurion, passivation, and selection brush plating. Techtrix is a large quantity generator of hazardous waste, a small quantity handler of universal waste, and generator of used oil. Techtrix's most recent notification of hazardous waste activity was submitted on March 27, 2020. The facility is accessed through a foyer and a locked door. EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 2 of 31 The following wastes are generated at the Facility:* Waste type Wastewater Treatment Sludge Basis for Listing Toxicity Spent Cyanide Plating Bath Solution Plating Bath Residues from Bottom of Plating Tanks Containing Cyanides Rinse Waters from Various Cleaning and Plating Baths Awaiting Treatment *From Techtrix's waste Toxicity, Reactivity Toxicity, Reactivity Toxicity, Reactivity, Corrosivity analysis plan. Rationale Listed Waste (F006) Characteristic Waste (D006, D007, D011) Listed Waste (F007) Characteristic Waste (D003) Listed Waste (F008) Characteristic Waste (D003) Characteristic Waste (D002, D003, D006, D007, and D011) 10) Opening Conference On March 22, 2021, EPA inspectors Alan Newman and Kayla Acosta, and EPA's sampling team lead, Paula Whiting, accompanied by ADEM inspector Corey Holmes, arrived at Techtrix at approximately 1:00 p.m. Pamela Beavers, Plant Manager, immediately received the inspectors. The inspectors introduced themselves, showed their credentials to Pamela Beavers, and explained the purpose of the visit. The inspectors described the anticipated use of equipment (digital camera, sampling equipment) during the inspection and provided a request for records. The inspectors discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to the EPA. The company did not assert a business confidentiality claim. The inspection participants also discussed health and safety protocols and required personal protective equipment before Pamela Beavers led the inspectors on a tour of the Facility operations. Pamela Beavers provided an overview of the facility's history and current operations during the opening conference. The facility was operating two designated central accumulation areas (CAAs), several satellite accumulation areas (SAAs), and a wastewater treatment plant (WWTP). The company does appear to meet the Small Business Regulatory Enforcement Fairness Act's classification of a "small business," which is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. The EPA inspector did not provide a copy of the agency's information sheet for small businesses, which can be found at https://www.epa.gov/sites/production/files/2017-06/documents/ smallbusinessinfo.pdf. 11) Findings Shipping and Receiving EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 3 of 31 Techtrix was storing multiple containers of paint on a pallet (Photo 1). Facility personnel stated that these containers were old and no longer used, and that these wastes were awaiting a waste determination. Techtrix had not made a hazardous waste determination on these solid wastes. Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Chemical Storage Techtrix was storing usable chemicals in two separate adjacent areas that were separated by a chain-link fence. In a third area, Techtrix was storing chemicals that were either unusable, expired, in poor condition, or usable (Photos 2-15). There were approximately sixty (60) 55gallon containers and seventy-five (75) smaller containers and bags of chemicals in this third area. A description of some of the waste and observations is included in Appendix 1. In summary, many of these containers were expired; many of the containers were in poor condition, leaking, or rusting; some containers were incompatible such that the containers failed to contain the waste. Several of these containers were open. Some of these containers were not labeled. There was no aisle space between containers. Although it appeared that most of these containers were discarded and had not been accessed for multiple years, Techtrix had not made a hazardous waste determination for all of these discarded materials. Techtrix was not conducting inspections of the hazardous waste observed in this area. The inspection team asked the facility for a detailed inventory of the containers in this area. Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(ii) [40 C.F.R. 262.17(a)(1)(ii)], which is a condition of the LQG Permit Exemption, if a container holding hazardous waste is not in good condition, or if it begins to leak, the generator must immediately transfer the hazardous waste from this container to a container that is in good condition, or immediately manage the waste in some other way that complies with the LQG Permit Exemption. Pursuant to[ADEM Admin. Code r. 335-14-3-.01 (7)(a)1.(iii) [40 C.F.R. 262.17(a)(1)(iii)], which is a condition of the LQG Permit Exemption, a generator is required to use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired. Pursuant to ADEM Admin. Code r. 335-14-3-.01 (7)(a)1.(iv) [40 C.F.R. 262.17(a)(1)(iv)], which is a condition of the LQG Permit Exemption, (A) a container holding hazardous EPA-RCRA CEI Report Page 4 of 31 Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 waste must always be closed during accumulation, except when it is necessary to add or remove waste; and (B) a container holding hazardous waste must not be opened, handled, or stored in a manner that may rupture the container or cause it to leak. Pursuant to ADEM Admin. Code r. 335-14-3-.01 (7)(a)1.(v) [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. Pursuant to ADEM Admin. Code r. 335-14-3-.01 (7)(a)5.(i) [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 the following: the words "Hazardous Waste"; an indication of the hazards of the contents; and the date upon which each period of accumulation begins clearly visible for inspection on each container. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 335-14-3-.14(6) [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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Tote Storage and Cyanide Storage Adjacent to the Chemical Storage area, Techtrix was storing waste and usable material in tanks and containers. There were three (3) blue, tall tote containers labeled as Class 8 Corrosive Sodium Hydroxide (Placard 1824) (Photos 16-17). Although the container labels stated that these totes were full of reusable material, facility personnel stated these totes had been here for several years, untouched. There were nine (9) 250-gallon totes in this area labeled as either reusable cadmium, reusable electroless nickel, or reusable alodine (Photos 17-20). These tote containers were each marked with a date of accumulation of June 27, 2019. Techtrix did not provide any records to document that this material had not been accumulated speculatively. ADEM Admin. Code r. 335-14-1-.02(1)(a)3. [40 C.F.R. 262.17(a)(1] defines "Accumulated speculatively" or "Speculative accumulation" as a material that is accumulated before being recycled. A material is not accumulated speculatively, however, if the person accumulating it can show that the material is potentially recyclable and has a feasible means of being recycled; and that - during the calendar year (commencing on January 1) - the amount of material that is recycled, or transferred to a different site for recycling, equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period. EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 5 of 31 Materials must be placed in a storage unit with a label indicating the first date that the material began to be accumulated. If placing a label on the storage unit is not practicable, the accumulation period must be documented through an inventory log or other appropriate method. In calculating the percentage of turnover, the 75 percent requirement is to be applied to each material of the same type (e.g., slags from a single smelting process) that is recycled in the same way (i.e., from which the same material is recovered or that is used in the same way). Materials accumulating in units that would be exempt from regulation under 335-14-2-.01(4)(c) are not to be included in making the calculation. Materials that are already defined as solid wastes also are not to be included in making the calculation. Materials are no longer in this category once they are removed from accumulation for recycling. Pursuant to ADEM Admin. Code r. 335-14-2-.01(2) [40 C.F.R. 261.2(a)(4)], spent materials, sludges and by-products are solid wastes when accumulated speculatively. Techtrix had not made a hazardous waste determination on three (3) blue, tall tote containers labeled as Class 8 Corrosive Sodium Hydroxide (Placard 1824) (Photo 16-17) and nine (9) 250-gallon totes labeled as either reusable cadmium, reusable electroless nickel, or reusable alodine (Photos 17-20), which were all located adjacent to the Chemical Storage area. Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. There were four 250-totes in this area that were labeled as hazardous waste and were marked with an accumulation start date of October 2020 (>90 days). Facility personnel stated that these containers had been recently pumped out and were reused to store more hazardous waste (Photos 17-18, 21-27). At least one of these totes was open (Photos 21-23). Facility representatives redated these containers with the accumulation start date of 3/16/2021. There was one partially full, open, 2' x 2' tank in this area that was labeled as Hypro-Tri Yellow Rinse and dated 2/4/2013 (Photos 28-29). Facility representatives stated that the date was incorrect and that the tank held rinse waters from one of the plating lines. They stated that this was a product and had been moved to this area within the last two weeks. The inspection team recommends that all containers be labeled accurately to reflect their contents. There was one blue former chicken incubator with two doors (Photos 17-18 and 30-31) used to store cyanide products. Techtrix was not managing several containers in this area as valuable product. The material appeared to be unusable waste because the containers were rusting and fully compromised (Photos 25-26). Although Techtrix had not made a hazardous waste determination on the contents of these containers at the time of the inspection, personnel indicated that the material would be hazardous waste. EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 6 of 31 Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(ii) [40 C.F.R. 262.17(a)(1)(ii)], which is a condition of the LQG Permit Exemption, if a container holding hazardous waste is not in good condition, or if it begins to leak, the generator must immediately transfer the hazardous waste from this container to a container that is in good condition, or immediately manage the waste in some other way that complies with the LQG Permit Exemption. Pursuant to ADEM Admin. Code r. 335-14-3-.01 (7)(a)1.(iv) [40 C.F.R. 262.17(a)(1)(iv)], which is a condition of the LQG Permit Exemption, (A) a container holding hazardous waste must always be closed during accumulation, except when it is necessary to add or remove waste; and (B) a container holding hazardous waste must not be opened, handled, or stored in a manner that may rupture the container or cause it to leak. CAA 1 Techtrix was storing hazardous waste tote containers in two designated CAAs. The first CAA was adjacent to the cyanide storage area and was storing liquid hazardous waste in twenty (20) tote containers ranging in size from 250-350 gallons. Each tote container was labeled with the words hazardous waste and marked with an accumulation start date, but none of the totes were marked with an indication of the hazards of its contents. Eleven totes were marked with an incorrect accumulation start date which was a future date (see table below); the other nine totes were marked with accumulation start dates prior to 12/22/2020, which indicated that the waste had been stored onsite for more than 90 days (Photos 32-39). The inspection team noted that the secondary containment of this storage area is not sufficiently impervious as required by the state regulations. An inventory of the tote containers stored in this area is below: EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Tote Date of Accumulation 1 11/23/2021* 2 11/23/2021* 3 11/24/2021* 4 12/14/2020 5 11/26/2021* 6 11/26/2021* 7 12/2/2020 8 11/17/2020 9 11/20/2020 Labeled as Hazardous Waste and with EPA Waste Number D002 D002 D002 F009 D002 D002 D002 F009 F009 Page 7 of 31 10 12/8/2021* F009 11 11/17/2020 F009 12 11/24/2021* D002 13 11/26/2021* D002 14 11/13/2021* D002 15 12/2/2020 D002 16 12/8/2021* D002 17 12/14/2020 F009 18 12/2/2020 F009 19 12/8/2021* D002 20 11/20/2020 F009 *dates incorrect (in the future) Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(viii) which incorporates ADEM Admin. Code r. 335-14-6-.09(6)(a), and is a condition of the LQG Permit Exemption, container storage areas must meet the following requirements: (a) Container storage areas must have a containment system that is designed and operated in accordance with 335-146-.09(6)(b), except as otherwise provided by 335-14-6-.09(6)(c). (b) A containment system must be designed and operated as follows: 1. A base must underlie the containers which is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed; 2. The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids; 3. The containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater. Containers that do not contain free liquids need not be considered in this determination; 4. Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity in addition to that required in 335-14-6-.09(6)(b)3. to contain any run-on which might enter the system; and 5. Spilled or leaked waste must be removed from the sump or collection area in a timely manner not to exceed 24 hours after detection. Accumulated precipitation must be removed in as timely a manner necessary to prevent overflow of the collection system. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)5.(i) [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 the following: an indication of the hazards of the contents and the date upon which each period of accumulation begins clearly visible for inspection on each container. EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 8 of 31 Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. F006 Supersack and Non-hazardous Waste Containers Techtrix was accumulating filter cake from the WWTP and floor debris (F006) in a supersack (Photos 40-43). Facility personnel stated that waste solids were being removed from underneath the plating lines in response to previous observations made by ADEM inspectors. This supersack was open, dated with an accumulation start date of 10/14/2020 (>90 days), and was not labeled with an indication of the hazard on the container. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(iv) [40 C.F.R. 262.17(a)(1)(iv)], 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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)5.(i) [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 the following: an indication of the hazards of the contents clearly visible for inspection on each container. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Techtrix was storing eighty-five (85) tote containers labeled as non-hazardous waste (Photos 40 and 44-48) adjacent to CAA 1. After the inspection, Techtrix determined that approximately half of these totes were storing hazardous waste due to the characteristic of corrosivity. Techtrix plans to ship the contents of all 85 containers off as hazardous waste corrosives (D002). At the time of the inspection, it appeared that some of these containers had leaked (Photos 46-47). At least one container was labeled as "on hold pending analysis" (Photos 49-50). Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. CAA 2 EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 9 of 31 The second CAA was adjacent to the eighty-five (85) tote containers labeled as non-hazardous waste described above and was storing approximately fifty-two (52) containers ranging in size from 250-350 gallons. Each container was labeled with the words hazardous waste and with an accumulation start date, but none of the containers were labeled with the indication of the hazards of its contents (Photos 51-60). The accumulations start dates for thirty-two (32) containers were dated prior to 12/22/2020 (>90 days). There was some waste accumulated on the floor of this CAA and at least one container had waste on the outside of the container (Photos 5859). The secondary containment of this storage area is not sufficiently impervious due to the coating on the floor peeling (Photo 60). The inspection team noted that the containers were stored without adequate aisle space. Techtrix personnel stated that the contents of twenty-two (22) containers had been consolidated in a tanker truck and shipped off site to a permitted deep well injection facility in Ohio on February 24, 2021. An inventory of the containers stored in this area is below: Row Number of Non-Hazardous Totes and Number of Hazardous Totes Comments 1 6 - Non-Hazardous 1 Hazardous Waste 2 9 (Hazardous Waste) 3 16 (Hazardous Waste) EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 One tote of hazardous waste had waste on outside of tote One tote of hazardous waste dated 12/7/2020 (>90 days) No Indication of the hazard Waste spilled on ground - Un-containerized No aisle space against wall One tote dated 10/14/2020 (>90 days) One tote dated 12/17/2020 (>90 days) One tote dated 12/10/2020 (>90 days) One tote dated 12/10/2020 (>90 days) One tote dated 12/10/2020 (>90 days) One tote dated 11/2/2020 (>90 days) One tote dated 11/2/2020 (>90 days) No indication of hazards on any totes One tote dated 11/9/2020 (>90 days) One tote dated 11/10/2020 (>90 days) One tote dated 11/4/2020 (>90 days) One tote dated 11/3/2020 (>90 days) One tote dated 12/7/2020 (>90 days) One tote dated 12/7/2020 (>90 days) One tote dated 11/13/2020 (>90 days) One tote dated 11/13/2020 (>90 days) One tote dated 11/30/2020 (>90 days) One tote dated 12/1/2020 (>90 days) One tote dated 12/1/2020 (>90 days) One tote dated 11/23/2020 (>90 days) No Indication of the hazards on any totes Page 10 of 31 4 20 (Hazardous Waste) One tote dated 12/2/2020 (>90 days) One tote dated 11/16/2020 (>90 days) One tote dated 11/16/2020 (>90 days) One tote dated 11/23/2020 (>90 days) One tote dated 11/16/2020 (>90 days) One tote dated 11/23/2020 (>90 days) One tote dated 12/14/2020 (>90 days) One tote dated 11/23/2020 (>90 days) One tote dated 11/13/2020 (>90 days) One tote dated 11/13/2020 (>90 days) One tote dated 12/17/2020 (>90 days) One tote dated 12/17/2020 (>90 days) No Indication of the hazards on any totes Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 335-14-3-.14(6) [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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(viii) which incorporates ADEM Admin. Code r. 335-14-6-.09(6)(a), and is a condition of the LQG Permit Exemption, container storage areas must meet the following requirements: (a) Container storage areas must have a containment system that is designed and operated in accordance with 335-146-.09(6)(b), except as otherwise provided by 335-14-6-.09(6)(c). (b) A containment system must be designed and operated as follows: 1. A base must underlie the containers which is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed; 2. The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids; 3. The containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater. Containers that do not contain free liquids need not be considered in this determination; 4. Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity in addition to that required in 335-14-6-.09(6)(b)3. to contain any run-on which might enter the system; and 5. Spilled or leaked waste must be removed from the sump or collection area in a timely manner not to exceed 24 hours after detection. Accumulated precipitation must be removed in as timely a manner necessary to EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 11 of 31 prevent overflow of the collection system. Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(i)b. [40 C.F.R. 262.17(a)(5)(i)b.], which is a condition of the LQG Permit Exemption, a generator must mark or label its containers with the following: an indication of the hazards of the contents clearly visible for inspection on each container. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 335-14-3-.14(2) [40 C.F.R. 262.251], and is a condition of the LQG Permit Exemption, a large quantity generator must maintain and operate its facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. Wastewater Treatment Plant (Hazardous Waste Tanks Area) There were three 250-gallon containers stored in the WWTP. One container was labeled as nonhazardous waste and two containers were labeled as hazardous waste. The liquid portions of the hazardous waste containers had been pumped into one of the tanks leaving a small amount of solids at the bottom. These containers were considered empty by the inspection team. The lid of one of these containers was in poor condition (Photos 61-67). The inspection team recommended that only containers in good condition be used to store hazardous waste. Techtrix was operating twelve (12) tanks for storage and treatment of liquid plating wastes. Techtrix was chemically treating the liquid waste to remove metals and adjust the pH. After chemical treatment in the tanks, liquids were further treated by filtering them in a filter press. The F006 filter cake produced from the filter press initially collected in a catch container and then placed in a supersack near the non-hazardous waste container storage area (Photos 40, 68-69). The filtered liquid wastes are stored either in a tank or in 250-350-gallon containers and then shipped off site as non-hazardous waste for disposal. At the time of the inspection, the catch container underneath the filter press was open, labeled as hazardous waste, F006, and dated 10/14/2020 (>90 days). This container was not labeled with an indication of the hazard. The inspection team also noted that a boiler in the tank area was leaking water that was pooling on the floor in this area. Techtrix had vacuumed up the boiler water and added it to the catch container underneath the filter press. The inspection team recommended that this practice be discontinued due to the generation of additional hazardous waste through this process. Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(i)b. [40 C.F.R. 262.17(a)(5)(i)b.], which is a condition of the LQG Permit Exemption, a generator must mark or label its containers with the following: an indication of the hazards of the contents clearly visible for EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 12 of 31 inspection on each container. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Tanks 1 and 2 were located side by side along the back wall of the facility. Tank 1 was labeled as hazardous waste and with the words "Brite Dip", the EPA waste code D002, and with an accumulation start date of 09/30/2020 (>90 days). This label was flopped over due to the adhesive failing on the back of the label. There was no indication of the hazard on this tank. There was waste material underneath this tank that appeared to have been there for some time (Photo 70). This open top tank was full on the day of the inspection (Photos 70-71). Tank 2 was labeled "NOT IN USE". There was no indication of the hazard on this tank. This open top, tank was full of semi-solid waste on the day of the inspection. There was waste material underneath this tank that appeared to have been there for some time (Photos 72-74). Tank 3 was a brown open-top, cone bottom tank that was labeled as hazardous waste and with the words "Sludge for Filter Press" and with an accumulation start date of 12/20/2020 (>90 days). There was evidence of a leak from one of the fittings on the side of the tank with spilled into the secondary containment. There was no indication of the hazard on this tank (Photos 7579). Tank 4 was a round, brown, cone-bottom tank with blue support legs. Tank 4 was labeled as hazardous waste and with the words "Bright Dip". This label also documented that the accumulation start date was 12/22/2020. There was no indication of the hazard on this tank. This open top tank was half-full on the day of the inspection (Photos 80-82). The Green Fiber tank, between Tanks 3 and 4, was labeled with the words "NOT IN USE". This open top, tank had approximately 5 feet of solids in the tank on the day of the inspection (Photos 75, 83). There was a brown circular tank next to Tank 3 that was full. This tank was not labeled (Photos 84-85). Tank 8 was a green, circular, open top, cone-top tank that was not labeled. This tank was full. There was some staining around the base of this tank (Photos 84-87). The tan poly tank (next to Tank 3) (Photo 84 (left side)), Tanks 9 and 10 (Photo 88), and the unlabeled rusting green tank (Photo 88 in background) were empty on the day of the inspection. There was one blue tank that was rectangular. This tank was labeled as non-hazardous steam-off water (Photos 89-91). Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 13 of 31 Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)5.(ii) [40 C.F.R. 262.17(a)], a large quantity generator accumulating hazardous waste in tanks must do the following do the following: a. Mark or label its tanks with the words "Hazardous Waste" and all appropriate EPA hazardous waste numbers associated with the waste as specified in 335-14-2-.03 and 335-14-2-.04; b. Mark or label its tanks with an indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704); c. Use inventory logs, monitoring equipment or other records to demonstrate that hazardous waste has been emptied within 90 days of first entering the tank if using a batch process, or in the case of a tank with a continuous flow process, demonstrate that estimated volumes of hazardous waste entering the tank daily exit the tank within 90 days of first entering; and d. Keep inventory logs or records with the above information on site and readily available for inspection. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10(7) [40 C.F.R. 265.196], which a condition of the LQG Permit Exemption, a tank system or secondary containment system from which there has been a leak or spill, or which is unfit for use, must be removed from service immediately, and the owner or operator must satisfy the following requirements: (a) Cessation of Use; prevent flow or addition of wastes. The owner or operator must immediately stop the flow of hazardous waste into the tank system or secondary containment system and inspect the system to determine the cause of the release. (b) Removal of waste from tank system or secondary containment system. 1. If the release was from the tank system, the owner/operator must, within 24 hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of hazardous waste to the environment and to allow inspection and repair of the tank system to be performed. 2. If the material released was to a secondary containment system, all released materials must be removed within 24 hours or in as timely a manner as is possible to prevent harm to human health and the environment. The facility considered the tank system to be an exempt wastewater treatment unit. However, these tanks are not subject to either Section 402 or 307(b) of the Clean Water Act and therefore EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 14 of 31 do not currently meet the exemption. These tanks are regulated as RCRA Subpart J Tanks. Zinc Plating Line On three sides of the zinc plating line there were supersacks used to accumulate hazardous waste solids from underneath the plating line (Photos 92-97). Each of the supersacks was open and not labeled with either the words hazardous waste, the indication of the hazard, or with the accumulation start dates. Two of these sacks had accumulated greater than 55 gallons on the day of the inspection. Techtrix personnel stated that these sacks had been collecting waste for greater than three days. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(iv) [40 C.F.R. 262.17(a)(1)(iv)], which is a condition of the LQG Permit Exemption, (A) a container holding hazardous waste must always be closed during accumulation, except when it is necessary to add or remove waste. Pursuant to ADEM Admin. Code r. 335-14-3-.01 (7)(a)5.(i) [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 the following: the words "Hazardous Waste"; an indication of the hazards of the contents; and the date upon which each period of accumulation begins clearly visible for inspection on each container. Pursuant to ADEM Admin. Code r. 335-14-3-.01 (7)(a)1.(v) [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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(a)4. [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 [ADEM Admin. Code r. 335-14-3-.01(5)(a)5.] [40 C.F.R. 262.15(a)(5)], 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. Alodine Plating Line Techtrix personnel stated that the Alodine plating line had not been operating for several months. The inspection team noted leaks from the alodine line (Photos 98-103). Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [40 C.F.R. EPA-RCRA CEI Report Page 15 of 31 Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021  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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Cadmium Plating Line Techtrix periodically operates a plating line to plate cadmium onto parts. On the day of the inspection, there were four tanks on this line with solids in the bottom of each tank (Photos 104107). There were no plating bath liquids present. Facility representatives stated that the waste inside these tanks would need to be cleaned out but that it would be a confined space entry. One solution Techtrix is considering is to cut the tanks apart to avoid the confined space entry requirements. Facility representatives stated that samples were taken and that a waste determination was pending. Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Outside of Production Building The inspection team toured the outside areas of the production building. The team noted green dust-like waste on upended poly tanks (Photos 108-110). The TCLP sampling result for this waste was 49 mg/L of Chrome, which is above the hazardous level. Facility representatives had not conducted a hazardous waste determination for this waste. The inspection team looked inside the solid waste dumpster at the side of the production building; there was remediated waste removed from underneath the plating lines in the dumpster similar to the waste inside the supersacks near the Zinc plating line (111-112). Facility personnel stated that this waste should have been added to the supersacks inside and not to the dumpster. There were three rusted containers grouped together near the solid waste dumpster (Photos 113-114). The EPA sampling team determined that these containers were storing solidified asphalt. Techtrix must make a hazardous waste determination on all solid wastes. Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 335-14-3-.14(2) [40 C.F.R. 262.251], and is a condition of the LQG Permit Exemption, a large quantity generator must maintain and operate its facility to minimize the possibility of a fire, explosion, or any unplanned sudden EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 16 of 31 or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. Owners Personal Building The owner of the facility has a small building beside the production building with a roll up door. The inspection team did not observe any waste in this building. Red Building The inspection team toured the red building which was used as a workshop. Facility personnel stated that this building was seldom used and there were few working lights in this building. In the first room the inspection team entered, there was one flammable cabinet which was storing paint and paint related materials (Photo 115). There was a leaking container of solvent inside this cabinet resulting in a puddle at the bottom of the cabinet. Pursuant to 40 C.F.R. 261.2(b)(3), materials are solid waste if they are abandoned by being accumulated, stored, or treated (but not recycled) before or in lieu of being abandoned by being disposed of, burned or incinerated. Many of the paints and related material inside the cabinet appeared to be abandoned old material that had been accumulated and stored in lieu of being disposed of. Techtrix had neither cleaned up the spilled material beneath the cabinet nor conducted a hazardous waste determination on the solid wastes inside the cabinet. In the second room in the Red Building, a few steps up, there was a stack of paint containers, a work bench with multiple containers, and a pallet of paint (Photos 116-118). Some of these containers looked to be in poor condition. It appears that many of these containers had been accumulated and stored in lieu of being disposed of. Techtrix should determine if these materials will be used and conduct a hazardous waste determination on material that is a solid waste. Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. Records Review The inspection team reviewed the following records: CAA weekly inspection records from January 2019 through March 2021, hazardous waste manifests February 2018 through March 2021, universal waste shipping documents, land disposal restriction forms, training records, the contingency plan, the waste minimization plan, biennial report, and notification for hazardous waste activity. The facility considered the tank system to be an exempt wastewater treatment unit. However, these tanks are not subject to either Section 402 or 307(b) of the Clean Water Act and therefore do not currently meet the exemption. These tanks are regulated as RCRA Subpart J Tanks. These tanks did not have tank integrity testing, daily tank inspections, or secondary containment among EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 17 of 31 other requirements. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10 [40 C.F.R. 265.192], and is a condition of the LQG Permit Exemption, a generator accumulating hazardous waste in tank systems must ensure that the foundation, structural support, seams, connections, and pressure controls (if applicable are adequately designed and that the tank system has sufficient structural strength, compatibility with the waste(s) to be stored or treated, and corrosion protection so that it will not collapse, rupture, or fail. The generator must obtain a written assessment reviewed and certified by a qualified Professional Engineer in accordance with 270.11(d) of this chapter attesting that the system has sufficient structural integrity and is acceptable for the storing and treating of hazardous waste. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10 [40 C.F.R. 265.193], and is a condition of the LQG Permit Exemption, a generator accumulating hazardous waste in tank systems must provide secondary containment in order to prevent the release of hazardous waste or hazardous constituents to the environment. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10 [40 C.F.R. 265.195], and is a condition of the LQG Permit Exemption, a generator accumulating hazardous waste in tank systems must inspect and document, where present, at least once each operating day, (a) data gathered from monitoring and leak detection equipment; (b) overfill/spill control equipment, above ground portions of the tank system, construction materials and the area immediately surrounding the externally accessible portion of the tank system; (e) ancillary equipment that is not provided with secondary containment; and (f) cathodic protection systems. Facility personnel stated that only four weekly inspections of the CAAs were conducted in 2019. They were discontinued after that time. The records do not designate which areas were inspected. The inspection team noted that Techtrix was storing hazardous waste without a permit or interim status in both of the two designed CAAs, the non-hazardous waste tote container area, the chemical storage area, the cyanide area, the catch container area near the tanks, the supersacks near the zinc plating line, and the supersack near the non-hazardous waste tote container storage area at the time of the inspection. Therefore, each of these areas was operating as a central accumulation area, which should have been inspected at least weekly. Pursuant to [ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(v)] [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. The actions that facility personnel should take in response to an emergency are described in the facility's Hazardous Waste Managment Plan, which was last updated in February 2019. A review of this plan was conducted by the inspection team. The plan describes actions facility personnel must take in response to fires, explosions, or any unplanned sudden or non-sudden EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 18 of 31 release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility. The plan describes arrangements agreed to with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals or the Local Emergency Planning Committee. The plan lists the names and emergency telephone numbers for persons identified as emergency coordinators. Pamela Beavers is listed as the primary emergency coordinator, and one other individual is listed. The plan includes a list of all emergency equipment at the facility. The list includes fire extinguishing systems, spill control equipment, communications and alarm systems, and decontamination equipment. The list is up to date. The plan includes the location and a physical description of each item on the list, and a brief outline of its capabilities. Some of the references in the plan are incorrect and point to the incorrect figures or tables. The plan includes an evacuation plan for personnel. This plan does describe signal to be used to begin evacuation, evacuation routes, and alternate evacuation routes. The inspection team noted multiple containers that were in poor condition throughout the facility. These containers held corrosives and cyanide waste. These wastes could pose a human health threat to the workers in this facility. Techtrix did not implement their contingency plan to address these containers. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates Pursuant to ADEM Admin. Code r. 334-14-3-.14(8) [40 C.F.R. 262.260(b)], and is a condition of the LQG Permit Exemption, a generator is required to carry out the provisions of the contingency plan immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or the environment. Although the contingency plan was last updated in February 2019, the facility did not create a quick reference guide when the plan was updated. As of the date of the inspection, no quick reference guide had been created or submitted to the all local emergency responders. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 334-14-3-.14(10) [40 C.F.R. 262.262(b)], and is a condition of the LQG Permit Exemption, a large quantity generator that is amending its contingency plan must at that time submit a quick reference guide of the contingency plan to the local emergency responders identified at paragraph (a) of this section or, as appropriate, the Local Emergency Planning Committee. The quick reference guide must include the following elements: 1. The types/names of hazardous wastes in layman's terms and the associated hazard associated with each hazardous waste present at any one time (e.g., toxic paint wastes, spent ignitable solvent, corrosive acid); 2. The estimated maximum amount of each hazardous waste that may be present at any one time; 3. The identification of any hazardous wastes where exposure would require unique or special treatment by medical or hospital staff; 4. A map of the facility showing where hazardous wastes are generated and accumulated, and routes for accessing these wastes; 5. A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and also evacuate citizens and workers; 6. The locations of EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 19 of 31 water supply (e.g., fire hydrant and its flow rate); 7. The identification of on-site notification systems (e.g., a fire alarm that rings off site, smoke alarms); and 8. The name of the emergency coordinator(s) and 7/24-hour emergency telephone number(s) or, in the case of a facility where an emergency coordinator is continuously on duty, the emergency telephone number for the emergency coordinator. Techtrix did not provide a written description of the type and amount of both introductory and continuing training to be given to each person filling the positions at the facility related to hazardous waste management. The inspectors were told that the most recent training had occurred 1/10/2020. No records were available to document the training or the participants in the training. Pamela Beavers was scheduled to receive outside RCRA training after the inspection. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)7 [40 C.F.R. 262.17(a)(7)], which is a condition of the LQG Permit Exemption, facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the regulations; (ii) Facility personnel must complete personnel training within six months of being hired or of being assigned to a new position at the Facility; (iii) Facility personnel must take part in an annual review of the initial training required by this section; and/or (iv) the generator must maintain training records that include, among others: the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; a written job description for each position; a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position; and records documenting that the required training has been given to and completed by Facility personnel. The inspection team reviewed available hazardous waste manifest records and land disposal restriction forms for shipments of hazardous waste sent since 2018. Hazardous waste manifest records show that F006 hazardous wastewater treatment sludge from electroplating operations waste are routinely shipped to EQ Metals Recovery LLC (Canton) (OHD986982155), D002/D007 hazardous waste sulfuric acid and chromium wastes are routinely shipped to Vickery Environmental (Ohio) (OHD020273819), and D003/D006/D008 hazardous waste cyanide plating bath wastes are routinely shipped to EQ Detroit (MID980991566). The most recent shipment was made on 2/23/2021. The shipments of waste were infrequent with one shipment of D002/D007 liquid waste in 2021 and two shipments in 2020; one of D002/D007 liquid waste and one of F006 filter cake. Because the operations observed during the inspection indicate that waste is generated at a consistent rate of generation, and not during discrete generation events, it appears that Techtrix stored hazardous waste for greater than 90 days prior to each shipment. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Techtrix did not file a Biennial Report for 2019 by March 1, 2020. Pursuant to ADEM Admin. Code r. 335-14-3-.04(2) [40 C.F.R. 262.41], a generator that is EPA-RCRA CEI Report Page 20 of 31 Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 a large quantity generator for at least one month of an odd-numbered year (reporting year) who ships any hazardous waste off-site to a treatment, storage, or disposal facility within the United States must prepare and submit a single copy of a Biennial Report to the Department by March 1 of each even numbered year. The Biennial Report must be submitted on the Hazardous Waste Generator Biennial Report form supplied by the Department and must cover generator activities during the previous calendar year and must include certain information. 12) Closing Conference The inspectors conducted the exit meeting at 3:00 pm with Pamela Beavers and Tobie Bateman. During this meeting, the inspectors stated their preliminary conclusions of the inspection. Techtrix agreed to provide inventory records for the chemical storage area. On April 30, 2021, Pam Beavers provided the inventory in an email to the inspection team. 13) Sampling Overview (If Applicable) During the Techtrix, Inc. sampling investigation, EPA's Laboratory Services and Applied Science Division (LSASD) personnel collected a total of sixteen samples. Seven samples were collected from 275- or 325-gallon totes, six samples were from various sized tanks, one soil sample from the drainage ditch, one sample from outdoor containers and one sample from a cadmium plating line dip tank. LSASD's Laboratory Services Branch chemists analyzed the samples for pH, total metals and TCLP metals. Laboratory analyses showed that fifteen of the sixteen samples collected from the totes, tanks, drainage ditch and plating line exhibited the toxicity characteristic (TC) for cadmium (D006), chromium (D007), lead (D008) and/or silver (D011). Cadmium toxicity characteristic leaching procedure (TCLP) results ranged from 18 mg/l to 4,300 mg/l for the seven samples which exceeded the cadmium TC regulatory level of 1.0 mg/l. For the twelve samples which exceeded the chromium TC regulatory level of 5.0 mg/l, chromium TCLP results ranged from 6.8 mg/l to 2,200 mg/l. Both lead and silver have a TC regulatory level of 5.0 mg/l and both had four samples exceed it. Lead TCLP results ranged from 7.4 mg/l to 13 mg/l while silver TCLP results ranged from 5.4 mg/l to 74 mg/l. Laboratory testing showed that three samples demonstrated the RCRA characteristic of corrosivity (D002) by having pH values of less than 2.0 Standard Units (SUs) or greater than 12.5 SUs. Sample T07 had a laboratory pH value of less than 1.0 SUs while samples T16 and TK02 had pH values of 12.71 and 12.95 SUs, respectively. (Table 3). A copy of the sampling results are included in Appendix 3. 14) Inspection Findings Based on the observations made during the inspection, Techtrix was apparently deficient with the following RCRA requirements: Pursuant to ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in ADEM Admin. Code r. 335-14-2-.01(2) [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 ADEM Admin. Code r. 335-14-3-.01(2) [40 C.F.R. 262.11]. EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 21 of 31 Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(a)4. [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 [ADEM Admin. Code r. 335-14-3-.01(5)(a)5.] [40 C.F.R. 262.15(a)(5)], 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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(ii) [40 C.F.R. 262.17(a)(1)(ii)], which is a condition of the LQG Permit Exemption, if a container holding hazardous waste is not in good condition, or if it begins to leak, the generator must immediately transfer the hazardous waste from this container to a container that is in good condition, or immediately manage the waste in some other way that complies with the LQG Permit Exemption. Pursuant to[ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(iii) [40 C.F.R. 262.17(a)(1)(iii)], which is a condition of the LQG Permit Exemption, a generator is required to use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(iv) [40 C.F.R. 262.17(a)(1)(iv)], which is a condition of the LQG Permit Exemption, (A) a container holding hazardous waste must always be closed during accumulation, except when it is necessary to add or remove waste; and (B) A container holding hazardous waste must not be opened, handled, or stored in a manner that may rupture the container or cause it to leak. Pursuant to [ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(v)] [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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)1.(viii) which incorporates ADEM Admin. Code r. 335-14-6-.09(6)(a), and is a condition of the LQG Permit Exemption, container storage areas must meet the following requirements: (a) Container storage areas must have a containment system that is designed and operated in accordance with 335-146-.09(6)(b), except as otherwise provided by 335-14-6-.09(6)(c). (b) A containment system must be designed and operated as follows: 1. A base must underlie the containers which is free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed; EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 22 of 31 2. The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids; 3. The containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater. Containers that do not contain free liquids need not be considered in this determination; 4. Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity in addition to that required in 335-14-6-.09(6)(b)3. to contain any run-on which might enter the system; and 5. Spilled or leaked waste must be removed from the sump or collection area in a timely manner not to exceed 24 hours after detection. Accumulated precipitation must be removed in as timely a manner necessary to prevent overflow of the collection system. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10 [40 C.F.R. 265.192], and is a condition of the LQG Permit Exemption, a generator accumulating hazardous waste in tank systems must ensure that the foundation, structural support, seams, connections, and pressure controls (if applicable are adequately designed and that the tank system has sufficient structural strength, compatibility with the waste(s) to be stored or treated, and corrosion protection so that it will not collapse, rupture, or fail. The generator must obtain a written assessment reviewed and certified by a qualified Professional Engineer in accordance with 270.11(d) of this chapter attesting that the system has sufficient structural integrity and is acceptable for the storing and treating of hazardous waste. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10 [40 C.F.R. 265.193], and is a condition of the LQG Permit Exemption, a generator accumulating hazardous waste in tank systems must provide secondary containment in order to prevent the release of hazardous waste or hazardous constituents to the environment. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10 [40 C.F.R. 265.195], and is a condition of the LQG Permit Exemption, a generator accumulating hazardous waste in tank systems must inspect and document, where present, at least once each operating day, (a) data gathered from monitoring and leak detection equipment; (b) overfill/spill control equipment, above ground portions of the tank system, construction materials and the area immediately surrounding the externally accessible portion of the tank system; (e) ancillary equipment that is not provided with secondary containment; and (f) cathodic protection systems. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)2. [40 C.F.R. 262.17(a)(2)], which incorporates ADEM Admin. Code r. 335-14-6-.10(7) [40 C.F.R. 265.196], which a EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 23 of 31 condition of the LQG Permit Exemption, a tank system or secondary containment system from which there has been a leak or spill, or which is unfit for use, must be removed from service immediately, and the owner or operator must satisfy the following requirements: (a) Cessation of Use; prevent flow or addition of wastes. The owner or operator must immediately stop the flow of hazardous waste into the tank system or secondary containment system and inspect the system to determine the cause of the release. (b) Removal of waste from tank system or secondary containment system. 1. If the release was from the tank system, the owner/operator must, within 24 hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of hazardous waste to the environment and to allow inspection and repair of the tank system to be performed. 2. If the material released was to a secondary containment system, all released materials must be removed within 24 hours or in as timely a manner as is possible to prevent harm to human health and the environment. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)5.(i) [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 the following: an indication of the hazards of the contents and the date upon which each period of accumulation begins clearly visible for inspection on each container. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)5.(ii) [40 C.F.R. 262.17(a)(5)(ii)], a large quantity generator accumulating hazardous waste in tanks must do the following do the following: a. Mark or label its tanks with the words "Hazardous Waste" and all appropriate EPA hazardous waste numbers associated with the waste as specified in 335-14-2-.03 and 335-14-2-.04; b. Mark or label its tanks with an indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704); c. Use inventory logs, monitoring equipment or other records to demonstrate that hazardous waste has been emptied within 90 days of first entering the tank if using a batch process, or in the case of a tank with a continuous flow process, demonstrate that estimated volumes of hazardous waste entering the tank daily exit the tank within 90 days of first entering; and d. Keep inventory logs or records with the above information on site and readily available for inspection. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 335-14-3-.14(2) [40 C.F.R. 262.251], and is a condition of the LQG Permit Exemption, a large quantity generator must maintain and EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 24 of 31 operate its facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 335-14-3-.14(6) [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. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates Pursuant to ADEM Admin. Code r. 334-14-3-.14(8) [40 C.F.R. 262.260], and is a condition of the LQG Permit Exemption, a generator is required to have a contingency plan for the facility. The contingency plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. (b) The provisions of the plan must be carried out immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or the environment. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)6 [40 C.F.R. 262.17(a)(6)], which incorporates ADEM Admin. Code r. 334-14-3-.14(10) [40 C.F.R. 262.262(b)], and is a condition of the LQG Permit Exemption, a large quantity generator must submit a quick reference guide of the contingency plan to the local emergency responders identified at paragraph (a) of this section or, as appropriate, the Local Emergency Planning Committee. The quick reference guide must include the following elements: 1. The types/names of hazardous wastes in layman's terms and the associated hazard associated with each hazardous waste present at any one time (e.g., toxic paint wastes, spent ignitable solvent, corrosive acid); 2. The estimated maximum amount of each hazardous waste that may be present at any one time; 3. The identification of any hazardous wastes where exposure would require unique or special treatment by medical or hospital staff; 4. A map of the facility showing where hazardous wastes are generated and accumulated, and routes for accessing these wastes; 5. A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and also evacuate citizens and workers; 6. The locations of water supply (e.g., fire hydrant and its flow rate); 7. The identification of on-site notification systems (e.g., a fire alarm that rings off site, smoke alarms); and 8. The name of the emergency coordinator(s) and 7/24-hour emergency telephone number(s) or, in the case of a facility where an emergency coordinator is continuously on duty, the emergency telephone number for the emergency coordinator. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(a)7 [40 C.F.R. 262.17(a)(7)], which is a condition of the LQG Permit Exemption, facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 25 of 31 duties in a way that ensures the facility's compliance with the regulations; (ii) Facility personnel must complete personnel training within six months of being hired or of being assigned to a new position at the Facility; (iii) Facility personnel must take part in an annual review of the initial training required by this section; and/or (iv) the generator must maintain training records that include, among others: the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; a written job description for each position; a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position; and records documenting that the training required has been given to and completed by Facility personnel. Pursuant to ADEM Admin. Code r. 335-14-3-.01(7)(b) [40 C.F.R. 262.17(b)], an LQG who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of ADEM Admin. Code r. 335-14-1 to 335-14-9 [40 C.F.R. Parts 124, 264 through 268 and Part 270]. Pursuant to ADEM Admin. Code r. 335-14-3-.04(2) [40 C.F.R. 262.41], a generator that is a large quantity generator for at least one month of an odd-numbered year (reporting year) who ships any hazardous waste off-site to a treatment, storage, or disposal facility within the United States must prepare and submit a single copy of a Biennial Report to the Department by March 1 of each even numbered year. The Biennial Report must be submitted on the Hazardous Waste Generator Biennial Report form supplied by the Department and must cover generator activities during the previous calendar year and must include certain information. 15) List of Appendices Appendix 1 - Inventory of containers in the Expired Chemical Storage area Appendix 2 - Photo Log: Photos taken by Kayla Acosta Photos taken with Olympus Tough Digital Camera EPA Property Tag: S75903 and Photos taken by Paula Whiting Photos taken with Olympus Tough Digital Camera EPA Property Tag: SC7374 Appendix 3 - EPA's LSLAD Sampling Investigation Report dated May 27, 2021. 16) Signed Digitally signed by ALAN ALAN NEWMAN NEWMAN Date: 2021.06.01 15:25:44 -04'00' Alan Newman Environmental Engineer EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Date Page 26 of 31 Concurrence Digitally signed by ARACELI ARACELI CHAVEZ CHAVEZ Date: 2021.06.01 15:22:27 -04'00' Araceli B. Chavez Chief RCRA Enforcement Section Date EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 27 of 31 Appendix 1: Inventory of containers in the Expired Chemical area Volume/Description Contents/Labels of Container 55-gallon - Blue Trichloroethylene Metal Labeled as Toxic 55-gallon - Black Metal 55-gallon - Black Metal 4 x 55-gallon - Black Poly 4 x 55-gallon - Blue Poly 3 x 55-gallon Black Poly 55-gallon - Blue Poly 55-gallon - Black Metal 55-gallon - Black poly 55-gallon - Black Poly 55-gallon - Black Poly 55-gallon - Blue Poly 55-gallon - Black Poly Alcohol Isopropyl Fed Grd Flammable Liquid Isopropyl (99%) Flammable Liquid Sodium Hypochlorite 12.5 % Corrosive Sodium Hypochlorite 12.5 % Corrosive Sodium Hypochlorite 12.5 % Corrosive Electroless Nickel Phos 685 K dry to touch oil IsoPrep 172 HW label D002 Isoprep 560L Corrosive Acetic Acid 56% Solution Corrosives Laser Brilliant Dip Marked as expired chemical pending waste determination Acetic Acid Marked as expired chemical pending waste determination Condition/Comments Rusting; no expiration date Still using this on Silver line Rusting through. expired 1/6/2014 Rusted through - container in poor condition Used to treat cyanide waste Expired 11/2004 Expired 6/28/2012 Expired 6/28/2012 May be reused Rusted Expired 12/2013 Dated 1/14/2019 Expired 1/2016 Manufactured 5/15/2008 Expired 7/8/2015 Manufactured 10/6/2009 Photo 119-120 119, 121 119, 122 123-124 125-127 128-130 131 132 133-134 135 136-137 138-139 138, 140 EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 28 of 31 55-gallon - Poly Blue 55-gallon - Black Poly 3 x 55-gallon Black Poly 3 x 55-gallon Black Poly 3 x 55-gallon - Blue 55-gallon fiber 6 x 5-gallon Blue (5) and Green (1) TechPhos 3000-NF Corrosive Marked as expired chemical pending waste determination Marked as expired chemical pending waste determination Isoprep 172 Corrosive ZB1010 Matte Tin Plate Blackener Sodium Hydroxide Caustic Soda Corrosive Metalive PreBlack Metex E 345 Corrosive - Sulfuric Acid - Merlin Starter - Isobrite 541 - 2 x ZC 1435 Hypro 200 sealer - ZC 1405 R HyproTech Expired 3/5/2017 Expired 1/2011 Expired 6/2014 Marked Usable Expired 3/4/2013 Dates: 8/8/2007 3/21/2008 One with no date Container damaged at bottom Expired 4/2020 (or 12/2022) - Expired 1/23/2013 - Expired 5/2016 - Expired 1/2015 - Expired 8/22/2015 5-gallon Cardboard Box 2 x 25-gallon 9 x 30-gallon Blue Poly 55-gallon Blue Poly 55-gallon Black Poly B-929 Nickel Strip powder Muriatic Potash Ferrous Sulphate TMT 15 Mercaptain Aqueous Trimercapto 5 triazine tri soldium salt Aqua ammonia Corrosive Matte Tin Plate Received 5/14/1997 Marked Usable Expired 3/4/2013 141-142 141, 143 144-145 147 148-150 151-152 153-159 160-161 162-164 165-166 167-168 169 EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 29 of 31 55-gallon Black Poly 55-gallon Black Poly 2 x 55-gallon Black Poly 55-gallon 2 x 55-gallon Black Poly 55-gallon white poly 55-gallon Fiber 40-gallon White 55-gallon Blue Poly 55-gallon Blue Poly 55-gallon Black Poly 2 x 5-gallon 2 x 10 gallon 55-gallon Fiber 55-gallon Rusted Metal 55-gallon Rusting 55-gallon Rusting 55-gallon Fiber 55-gallon Rusting Metal 55-gallon Black Poly 40-gallon Fiber 55-gallon Fiber 20-gallon Blue Poly 20-gallon Fiber 55-gallon EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Caustic Pot Ash Sodium Hydroxide Solution Corrosive Aluminum Sulphate Solution Meta Plate 2500-A Sealed Unknown - no labels Meta Plate 2500-B Unopened Oxalic Acid (good) Meta Kleen X-29 Parts Cleaner Fluid Phosphate SurTec 650 Chromit AL Manganese Phosphotex Crome vet 2 Corrosive Crome vet 1 Conductivity salt Corrosive Black Macro XL A Corrosive Potassium Metal Permanganate Stripper Rust Foe 2 metal Metex TS40-A Isoprep 188 Hyprocoate Black S Acid Salt Pending waste determination Zn Oxide Anti-foam HL36 Metex Acid 1 MM Tin Waste analysis pending Unknown 170 Manufactured 2/15/2007 171 172-174 175-176 177 Manufactured 12/9/2009 Expired 5/14/2015 178 179-180 181 182 Expired 7/2008 183 Expired 6/2002 184-185 Expired 6/2002 184, 186 Expired 11/1998 Expired 2/2002 184, 187 184, 188 Container was open Waste on floor Expired 2007 Expired 7/2012 Expired 5/2012 184, 189 190-191 190, 192 193 194 Expired 5/2007 195-196 Manufactured 8/24/2012 Expired 1/2005 195, 197 Page 30 of 31 55-gallon Fiber 55-gallon Red Metal 55-gallon Black Poly 75 smaller containers OPEX Preplate Corrosive Hydraulic Oil Silver Strike Expired 5/2002 198-216 EPA-RCRA CEI Report Techtrix, Inc. EPA ID# ALD982167678 March 22-23, 2021 Page 31 of 31