Document NN2Y44KZaOdYLe1J48YeRnq8

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1445 ROSS AVENUE, SUITE 1200 DALLAS, TEXAS 752022733 November 13, 2018 CERTIFIED MAIL: RETURN RECEIPT REQUESTED Mr. Al Pliodzinskas Environmental Manager Hempel USA 600 Conroe Park North Dr. Conroe, Texas 77303 Re: EPA RCRA Compliance Evaluation Inspection - July 17-20, 2018 EPA ID# TXR000032490 -Hempel USA - Conroe, TX Manufacturing Fa~ility Dear Mr. Pliodzinskas, On July 17-20,2018, the United States Environmental Protection Agency (EPA) conducted an unannounced Compliance Evaluation Inspection (CEI) at the Hempel USA facility located in Conroe, Texas. I would like to thank you for the time and the courtesy you and your staff extended to our inspector. Enclosed, please find a copy of the CEI Report which chronicles the inspection findings. A copy of this CEI Report will be transmitted separately to the Texas Commission on Environmental Quality (TCEQ). Based on the information contained in the enclosed inspection report, there are areas of concern for which EPA may take enforcement action under the Resource Conservation and Recovery Act (RCRA). If you have not already done so, we encourage you to immediately address all compliance issues identified in the CEI Report. If you have any questions regarding this matter, please contact Mr. Fred Deppe of my staff at (214) 665-7591 or email to deppe.fred@epa.gov. Enclosure Sincerely, Wr~ ~(J~Mark Potts Chief Waste Enforcement Branch cc: James Gradney, MPA Manager, Waste Enforcement Section Enforcement Division (MC-128) Texas Commission on Envirorunental Quality P. 0. Box 1677 Austin, TX 73101-1677 Peter B. Abel Waste Liaison Program Support Section (MC-174) Office ofCompliance and Enforcement Texas Commission on Envirorunental Quality P. 0. Box 13087 Austin, TX 78711 ft~ UnitodS'"'"' OC7"\=.._.l...._. Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) July 17-20, 2018 RCRA Company Name: Facility Name: Facility Physical Location : (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Hempel USA Conroe Manufacturing Facility 600 Con roe Park North Dr. Conroe, TX 77303 600 Conroe Park North Dr. Conroe, TX 77303 Montgomery County AI Pliodzinskas i ALPL@ Hempel.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110005185566 RCRAID:TXR000032490 32551 - Paint and Coating Manufact uring Personnel participating in inspection: John Penland EPA Region 6 (6EN-H2) Justin Phillips Hempel USA Eric Massey Hempel USA Boyd Kelly Hempel USA Sylvain Fillion Hempel USA Sr. Env. Scientist Regional QHSE Mgr Regional Supply Chain Mgr Safety and Process Mgr Regiona l Operations Mgr 214-665 -97 1 7 936-523-6024 936- 523-6033 936- 523-6000 636-523-6085 EPA Lead Inspector Signature/Date Supervisor Signature/Date afvLl_ Jol{(~ Penland (6EN-H2) v...t ~)) l)\AAM'K M a r l (if< ~(6Er(-\i) - ll/is 1 '~ Date u!tJ /t8 Date ' 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION Hempel USA - Conroe, TX Facility July 17-20, 2018 PURPOSE OF THE INSPECTION During the week of July 17,2018, I, John Penland, conducted an unannounced inspection of t h e Hempel USA paint manufacturing facility located in Conroe, Texas for compliance with the Resource Conservation and Recovery Act (RCRA). Beginning on July 17, 2018, I met with the representatives of Hempel USA listed in the following table and conducted an opening inspection briefing. Justin Phillips Eric Massey Boyd Kelly Sylvain Fillion Hempel USA Hempel USA Hempel USA Hempel USA -- Regional QHSE Mgr Regional Supply Chain Mgr Safety and Process Mgr Regional Operations Mgr - During this briefing, I presented my credentials to the representatives and explained that the inspection was being conducted under the authority of Section 3007 of RCRA. The inspection included walkthroughs o f the f acility' s manufacturing process areas, warehouses, waste storage and accumulation units, and a review of facility records related to waste determination and management. I concluded the inspection on July 20, 2018, with a closing conference where I presented my provisional areas of concern to the facility representatives. This report serves as documentation of all onsite activities and observations. Photographs taken during the inspection to document onsite observations are included as Appendix 1. A summary of all areas of concern identified during the inspection is provided in Section Ill. FACILITY DESCRIPTION Hempel USA operates a paint and coat ing manufacturing facility located at 600 Conroe Park North Drive in Conroe, Texas. The facility is registered as a Conditionally Exempt Small Quantity Generator with the RCRA ID of TXR000032490. According to Sylvain Fillion, the facility ships approximately 75 to 85 containers of waste per month to a Trade be facility in Tennessee for fuel blending and ultimately burning for energy recovery. According to facility records this waste was declared to be a universal waste under the State of Texas' Universal Paint Waste rule. The Hempel manufacturing facility consists of 3 warehouse areas, a large batch blending area, a small batch blending area, a maintenance shop, 2 laboratories, associated product and raw material storage tanks, and a central waste storage area . For a general facility layout, refer to the facility map included as Appendix 2. The pri mary products manufactured at this facility consists of epoxy resin-based coatings. These coatings are produced and sold in two parts, a resin base and a curing agent, that when mixed, produce a closely adherent surface coating which can be used in various commercial and industrial applications. 2