Document Nxo4LknN9ZbegZE6E9X5qbnb
REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION
At
UPS - IADES 2609 Dixon St Des Moines, IA 50316 (515)-214-4774
EPA ID Number: IAD048553481
On
June 23, 2022
By
Eastern Research Group, Inc.
For
U.S ENVIRONMENTAL PROTECTION AGENCY Region 7
Enforcement and Compliance Assurance Division
1.0 INTRODUCTION
At the request of the Enforcement and Compliance Assurance Division/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U.S. Environmental Protection Agency (EPA) Region 7, Eastern Research Group, Inc. (ERG) conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at UPS-IADES (UPS) in Des Moines, Iowa on June 23, 2022. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. Throughout the CEI, data and information were collected to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI.
2.0 PARTICIPANTS
UPS: Matthew Linebach, Base Supervisor Tom Blake, Facility Engineer
EPA Representative, ERG: Janosh Wolters, Energy Engineer, Lead Inspector Anshul Paripati, Chemical Engineer
3.0 INSPECTION PRECEDURES
After arriving unannounced at UPS at approximately 08:00, I performed a drive-by visual inspection of the facility and was unable to take a photograph of the main entrance due to heavy traffic. At the conclusion of the inspection, I took a photograph of the main entrance. During the drive-by, I did not note any areas of concern. I then entered the main entrance and was stopped by a security check point. I presented my inspector credentials to the security guard who ushered us to a parking spot. The security guard stated he would contact personnel from the facility's environmental department. Mr. Tom Blake arrived in approximately 10 minutes. I introduced myself to Mr. Blake, Engineer. I explained my reason for being on site is to conduct a RCRA CEI and asked to meet with the facility personnel who manages hazardous waste on site. While Mr. Blake was knowledgeable about the wastes generated on site, he stated Mr. Linebach, the Base Supervisor would have more knowledge on waste generation, management, transportation off site, and the location of hazard waste profiles. Mr. Blake guided us to the break room. I initiated the opening conference with Mr. Blake present as UPS's representative. I presented Mr. Blake with my inspector credentials and business card, as well as the business card of the EPA Task Order Contracting Officer Representative, Mr. Trevor Urban. Mr. Paripati explained he has not obtained a RCRA credential and was observing the inspection for training purposes. I then presented a copy of RCRA Section 3007(a), which contains EPA's inspection authority. I explained my need to collect accurate information and presented them with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I then presented Mr. Blake with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed UPS's confidentiality rights. I informed Mr. Blake that I would provide a Confidentiality Notice at the end of this inspection.
The inspection consisted of a discussion of facility operations, waste generation and waste management, a review of waste management records, and a visual inspection of the waste generation and management areas.
During the visual inspection of the facility, Mr. Blake guided us throughout the facility in order to conduct thorough evaluations of the facility's areas generating and accumulating hazardous waste. The facility also handles universal waste in a designated on-site area, which was also visually inspected. UPS has a parts washer; however, they are no longer used. I conducted an indepth visual inspection of the hazardous waste accumulation containers, used oil storage areas, and the universal waste storage area on site as labeled on the facility layout (see Attachment 1).
After the opening conference, we began the visual inspection and Mr. Linebach joined us for the remainder of the inspection. Mr. Linebach provided us with records of the hazardous waste manifests, universal waste manifests, off-site transfer of used oil, and the procedure for labeling hazardous waste drums.
Seven photographs were collected as inspection documentation and are shown in Attachments 2 and 3. Information collected during the inspection is documented on the EPA Inspection Checklist (see Attachment 4). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.01D), unless noted differently. At the conclusion of the inspection, I provided Mr. Linebach with a Confidentiality Notice and Receipt for Documents
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and Samples which he signed as acknowledgement of receipt (see Attachments 5 and 6 respectively). No confidentiality claims were made by UPS. No findings were observed at the time of the inspection. Therefore, a Notice of Preliminary Findings was not left with UPS. Based on the EPA RCRA Record, UPS has not been previously inspected.
The following inspection documents and compliance assistance handouts were left with UPS:
RCRA Section 3007(a) Title 18 U.S. Code, Sections 1001 and 1002 Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by
EPA in Connection with Inspections Confidentiality Notice (Facility copy) Receipt of Documents and Samples (Facility copy) Security Awareness Commercial Motor Vehicle Transportation Security Planning EPA E-Manifest Fact Sheet U.S. EPA Small Business Resources U.S. EPA Publication, Managing Your Hazardous Waste U.S. EPA Publication, Managing Used Oil-Advice for Small Businesses PowerPoint Presentation, 2013 Solvent Wipes Final Rule Pollution Engineering Article, 10 Common Questions for Waste Generators Iowa Department of Natural Resources (IDNR) Waste Exchange Folder and P2 Brochures IDNR Management of Fluorescent Lamps for Businesses Information Sheets IDNR Aerosol Can Disposal for Businesses Information Sheet University of Northern Iowa Waste Reduction Center Information Card Solvent-Contaminated Wipes Final Rule Summary Chart
4.0 FINDINGS AND OBSERVATIONS
Facility Information and Operations
UPS began operation in 1972 and currently employs approximately 750 people. The facility operates three, 8-hour shifts, seven days per week. UPS both owns and operates approximately 100,000 square feet of space across all buildings. Facility operations include the transportation of packages and there are no major raw materials used. The following waste streams are produced: ignitable waste, corrosive waste, U listed waste, used oil/used oil filters, aerosol cans, parts washer solvent, scrap metal, universal waste, and general trash.
RCRA Status
According to the Hazardous Waste Site Info Verification Report for Inspector (see Attachment 7), UPS notified as a federal Small Quantity Generator (SQG)(greater than 100 kilograms(kg)/ month but less than 1,000 kg/month) of the following hazardous wastes: D001, D002, D003, D007, D008, D016, D018, D019, D021, D028, D029, D035, D039, P075, U002, U057, U080, U122, U123, U134, U154, and U240. I asked Mr. Blake to review the Hazardous Waste Site Info
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Verification Report for Inspector, which I provided during the inspection. Mr. Blake indicated there were no updates needed. After reviewing the records and walking through the facility, I determined that the facility is operating as a federal SQG of D001, D002, D003, D007, D008, D016, D018, D019, D021, D028, D029, D035, D039, P075, U002, U057, U080, U122, U123, U134, U154, and U240 hazardous waste, a generator of used oil, and a small quantity handler of universal waste. I made the updates to the form as shown in Attachment 7.
4.3 Facility Waste Streams and Management A Waste Stream and Waste Handling Table for UPS is presented below. The table describes waste streams generated, generation process/rates, hazardous waste determinations, and onsite/off-site management. The rest of this page left blank intentionally.
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WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT
#
RATE
1
Ignitable
Leaking
D001 Hazardous (based 1,400 pounds per 55-gallon
Veolia ES Technical Solutions
Waste
packages
on process knowledge year
container
(Veolia) (NJD080631369) in
and knowledge of the
Flanders, NJ to Veolia ES
product)
Technical Solutions in Sauget,
IL (ILD098642424) for
incineration or fuel blending
2
Corrosive
Leaking
D002 Hazardous (based 90 pounds per 55-gallon
Veolia ES Technical Solutions
Waste
packages
on process knowledge year
container
(NJD080631369) in Flanders,
and knowledge of the
NJ to Veolia ES Technical
product)
Solutions in Sauget, IL
(ILD098642424) for
incineration or fuel blending
3
U Listed Waste Unused materials Hazardous (based on
170 pounds per 55-gallon
Veolia ES Technical Solutions
process knowledge and year
container
(NJD080631369) in Flanders,
knowledge of the
NJ to Veolia ES Technical
product)
Solutions in Sauget, IL
(ILD098642424) for
incineration or fuel blending
4
Used Oil
Facility
Excluded (managed as 1,160 gallons
1,160 gallon above Sent off site to Growmark in
maintenance of used oil per 40 CFR 279) every two
ground storage
Council Bluffs, IA
vehicles
months
tank
(IAD991286014) for recycling
(Invoice included in
Attachment 8)
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Used Oil
Filters
Hot punctured and drained used oil filters from vehicle maintenance
Excluded (based on management and process knowledge) recycled as scrap metal
One 55-gallon container every two months
55-gallon container
Sent of site to Growmark in Council Bluffs, IA (IAD991286014) for recycling.
5
WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT
#
RATE
6
Spent Aerosol Facility
Nonhazardous (based on Unknown, not 40-yard container Aspen Waste Systems in Des
Cans
maintenance
process knowledge and tracked at facility
Moines, IA to Metro Park East
(used until
knowledge of the
but estimated
Landfill in Mitchellville, IA
RCRA empty product)
less than 5
for landfills
and added to
aerosol cans per
general trash)
month
7
Parts Washer Cleaning oil and Nonhazardous (based on Less than 10-
In parts washer
Veolia ES Technical Solutions
Solution (SDS lubrication off process knowledge and gallons per year
(NJD080631369) in Flanders,
included in
small
knowledge of the
prior to no longer
NJ to Veolia ES Technical
Attachment 9) maintenance
product)
being used in
Solutions in Sauget, IL
tools
2022
(ILD098642424) for
incineration or fuel blending
8 Scrap Metal Facility
Excluded (based on
5-yard container 5-yard container Alter Metal Recycling in Des
maintenance on management and process picked up twice a
Moines, IA (IAD981501695)
vehicles
knowledge) recycled as week
for recycling
scrap metal
9
Wastewater
Facility washing Nonhazardous (based on 200,000 gallons Discharged via
Discharged via sanitary sewer
of delivery
process knowledge and per month
sanitary sewer to to Des Moines Metropolitan
trucks
knowledge of the
Des Moines
Wastewater Reclamation
product)
Metropolitan
Authority
Wastewater
Reclamation
Authority
10 General Trash Facility operations
Nonhazardous (based on process knowledge and knowledge of the product)
40-yard container picked up once every two weeks
40-yard container
Aspen Waste Systems in Des Moines, IA to Metro Park East Landfill in Mitchellville, IA for landfills
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Less-Than-180-Day Hazardous Waste Accumulation Area
UPS has one CAA located outside of the northern portion of the facility's warehouse shown on the facility layout (see Attachment 1). At the time of the inspection, there were a total of six 55gallon containers in the facility's CAA accumulating hazardous waste. The wastes observed were ignitable waste, ignitable reactive waste, formaldehyde buffer solution, waste nicotine, and methyl ethyl ketone. Section 4.5 of this report explains how wastes are generated on site. The facility manages the CAA in a separate shipping container outside. The containers were labeled and being managed as hazardous waste. Mr. Linebach stated Veolia picks up waste as needed and the facility does not accumulate more than 20 hazardous waste drums at once. In addition, Mr. Linebach stated the facility has shipped off approximately 1,600 pounds of hazardous waste in 2022 and a total of 6,951 pounds in 2021. Mr. Linebach stated Veolia then comes once a quarter and picks up between five and 20 barrels for disposal. During records review, Mr. Linebach showed me an excel spreadsheet that tracks all waste shipments off site. The excel spreadsheet shows weight, waste profile, ID number, and manifest number that is used to ship each respective waste off site. A screenshot of this tracking sheet is provided in Attachment 10.
UPS is responsible for correctly marking 55-gallon hazardous waste containers with all proper labeling requirements. At the time of the inspection, the 55-gallon containers observed were closed, in good condition, labeled as "Hazardous Waste", indication of the nature of the hazard, and had accumulation start dates on each container. The oldest accumulation start date observed was "3/29/2022" and was a 55-gallon container of ignitable waste. Photographs were taken of the CAA as an example of how waste is accumulated in the CAA (see Attachment 3, Photos 13).
During the visual inspection of the hazardous waste CAA, I observed posted emergency preparedness information, and emergency contact information posted inside the CAA container. In addition, the facility had signage stating instructions for proper management of the CAA. Mr. Linebach stated only adequately RCRA trained individuals have access to the CAA and carry radios with them at all times. I asked Mr. Linebach if the facility inspected the CAA. Mr. Linebach stated the CAA is inspected weekly and provided examples during the records review portion of the inspection. I reviewed the CAA logs and a copy of a CAA log is provided in Attachment 11 as an example. I reviewed all other 180-Day Hazardous Waste Accumulation Area management requirements, and no findings were noted.
4.5 Visual Inspection
Leaking Packages:
UPS only generates hazardous waste from managing shipments containing materials that would be considered hazardous waste when spilled or leaked from their original packaging. UPS does not conduct any manufacturing on site. The facility is strictly a sorting and shipment center for
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packages shipped with UPS. Throughout the sorting and transfer stages of the process, packages may break causing hazardous materials such as paint or cleaning chemicals to leak.
Mr. Linebach stated once a package is noticed to be leaking, only his team of RCRA trained associates are called to handle these packages. The package is opened, and the area is cleaned up immediately with absorbent. The package and all other cleaning supplies are collected in 55 gallon containers and managed as hazardous waste. Mr. Linebach explained that all cleaning supplies and wastes are solid when placed inside the 55-gallon container. Mr. Linebach explained the facility then contacts Veolia ES Technical Solutions to help with determining how the materials should be handled prior to pick up. For each individual package that leaks, a temporary profile is created. A "Damaged Material Form" is filled out by personnel. This form is provided in Attachment 12 as an example. Mr. Linebach stated the facility always assumes worst case and manages the waste as a hazardous waste if there is a slight possibility of being a hazardous waste. Veolia reviews the facility's determination and makes recommendations of how the waste should be handled and how containers should be labeled prior to pick up. Mr. Linebach reviews recommendations received from Veolia on a "Container Information Form". A Container Information Form is provided in Attachment 13 as an example. In addition, Veolia provides a "Damaged Material Form Confirmation" which indicates Veolia has also determined the waste to be a hazardous waste. Additionally, Veolia tracks the location and approximate level of each on site waste container. Veolia also provides UPS with technical direction on what types of materials can be co-mingled or added to a specific waste container. This ensures new containers are generated when new wastes are generated and that incompatible wastes are never comingled. Lastly, this management practice guarantees all hazardous waste on site is accumulated safely prior to being hauled off site. The confirmation form is provided in Attachment 14 as an example. I asked Mr. Linebach what happens if the waste determines differ between UPS and Veolia. Mr. Linebach stated although this is extremely rare, UPS could send a sample to be analyzed or Mr. Linebach would contact Veolia and speak to their personnel to ensure everyone is on the same page. From here, UPS would then use SDS, product knowledge, and potential analytical reports to ensure the wastes are managed properly. UPS manages each ID created for a leaked package separately and documents it within a folder to include SDS, analytical testing report (if applicable), Veolia review, damaged material notification, waste profile, and the original manifest of the material being shipped off site. I reviewed these folders for wastes being shipped off site for the previous three years. It appeared the facility was making every effort to make adequate waste determinations on all leaking packages observed on site.
Parts Washer:
UPS has one parts washer located in the maintenance shop that has been used in the past for occasional cleaning of small maintenance tools (see Attachment 3, Photo 4). However, Mr. Linebach stated the parts washer has not been used in over a year and the facility plans to haul off the spent parts washer solution that is contained in the parts washer. Historically, Veolia would provide parts washer solution and service the parts washer once per year. The parts washer solution is nonhazardous and was managed as a nonhazardous waste. The parts washer is
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used to clean off oils and lubricants off small maintenance tools. The SDS for the parts washer solution is provided in Attachment 9.
Used Oil:
Used oil is generated from vehicle maintenance on delivery trucks and other vehicles used on site. During maintenance activities, containers varying from one gallon to five gallons are used as transfer containers into the facility's used oil tank. Mr. Linebach explained used oil is only accumulated in smaller containers during maintenance activities and upon conclusion of the activities, the used oil is immediately placed into the used oil tank. Used oil is accumulated in a 1,160-gallon tank located in the maintenance shop (see Attachment 3, Photo 5). The container was closed, in good condition, and labeled "Used Oil". Used oil is picked up approximately once per month by Growmark in Omaha, NE for recycling. An invoice for the same company that manages used oil is provided in Attachment 8.
POTW:
The facility discharges wastewater generated from washing delivery trucks. During records review, I reviewed the facility initial request to discharge wastewater to the Des Moines Metropolitan Wastewater Reclamation Authority. Mr. Paul Ebert provided a letter indicating he reviewed the chemical agent used for cleaning and determined the facility could discharge wastewater from this process via sanitary sewer. In addition, I reviewed the facility's current discharge agreement which was renewed on 6/1/2022. Mr. Linebach explained the facility has not changed the chemical used for cleaning or added any additional chemical agents to this process. The initial letter and discharge agreement is provided in Attachment 15.
Scrap Metal:
UPS manages small amounts of scrap metal on site. The scrap is generated from serviced and maintenance of delivery trucks and other vehicles. Once the servicing is complete, the scrap metal is accumulated in two 5-yard containers which are picked up weekly.
Universal Waste:
UPS manages a small amount of universal waste on site. I observed one small carboard box located next to the environmental office accumulating used batteries. Additionally, I observed two 4-foot carboard boxes of universal waste lamps during my visual inspection (see Attachment 3, Photo 6). The containers were labeled as universal waste batteries or universal waste lamps, closed, and dated with the start accumulation date. The earliest accumulation start date observed on the universal waste containers was January 22, 2022, which was present on the 4-foot carboard box of universal waste lamps and is within one year of the inspection date. I did not note any issues or findings at the universal waste accumulation area.
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4.6 Other Regulatory Requirements
Preparedness, Prevention, and Emergency Requirements - Safety and emergency equipment were present and in satisfactory condition. Emergency preparedness information was posted in the CAA and in operations areas throughout the facility. The information was up-to-date and accurate.
I reviewed the preparedness, prevention, and emergency requirements and no findings were noted.
Manifest and Land Disposal Restriction (LDR) Requirements - UPS maintained records of manifests dating back three years on site. I reviewed the 12 manifests from the past three years. A manifest and LDR form is provided in Attachment 16 as an example. As explained in Section 4.5 of this report, manifests are tracked with each respective waste profile created. An example of how this is tracked is provided in Attachment 17.
I reviewed all other manifest and LDR requirements and no findings were noted.
5.0 SUMMARY OF FINDINGS
I observed no issues or findings during this inspection. However, further EPA review may add findings.
Digitally signed by Janosh
Janosh Wolters Date: 2022.08.16 11:11:10 Wolters
________________-0_4'0_0_' ___________ Janosh Wolters Energy Engineer Date: August 16, 2022
Digitally signed by CANDACE
CANDACE BEDNAR BEDNAR
________________D_ate_: 2_0_22_.08_.1_9 1_5_:22_:3_1 -_05_'0_0' Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 Date: _________________
Attachments: 1. Facility Layout (1 page) 2. UPS- IADES Photolog (1 page) 3. UPS- IADES Photos (7 Photos/8 pages) 4. EPA Inspection Checklist (22 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Hazardous Waste Site Information Verification Report (1 page) 8. Used Oil Invoice (1 page)
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9. Parts Washer Solution SDS (3 pages) 10. UPS Waste Tracking (1 page) 11. CAA Log (1 page) 12. Damaged Material Form (1 page) 13. Container Information Form (1 page) 14. Damaged Material Form Confirmation (1 page) 15. Wastewater Discharge Agreement (3 pages) 16. Manifest (3 pages) 17. Tracking Sheet for Manifest (1 page)
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