Document O1nYjvDGrLLXZDpK9G3Q4Xz41

Inspection Entry Date/Time Inspection Exit Date/Time Weather Regulatory Program Type of Inspection EPA Region 10 Enforcement Division INSPECTION REPORT 08/23/2022 08:56 AM (PT) Announced: No 08/23/2022 03:07 PM (PT) Access: Granted Sunny, dry, 80s RCRA CEI - Compliance Evaluation Inspection Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Size of Facility Length of Facility at Location Geographic Coordinates Mailing Address/Secondary Address Qorvo Qorvo Us Inc ORQ000005322 2300 Ne Brookwood Pky Hillsboro, OR 97124 Washington LQG 334413 Semiconductor manufacturing Since 1997 45.539682, -122.936288 Same as above Permit Number (If Applicable) Not Applicable Additional Persons Participating in Inspection: Name Title Organization Zeb Bates Inspector Oregon DEQ Email Zebuliah.bates@deq.oregon.gov Phone Lead Inspector: Katie Bradshaw KATRINA BRADSHAW Date: 2022.09.21 11:57:11 -07'00' Digitally signed by KATRINA BRADSHAW EPA Region 10 bradshaw.katrina@epa.gov (206) 553-6318 Supervisor Review: Jen Sullivan Digitally signed by Jennifer A Jennifer A Sullivan Sullivan Date: 2022.09.21 13:36:37 -07'00' EPA Region 10 Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 8 Qorvo Us Inc Inspection Date: 08/23/2022 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI - Compliance Evaluation Inspection EPA Region 10 Lead Inspector, Katie Bradshaw, and Oregon DEQ Inspector, Zeb Bates, arrived at the Qorvo Us Inc Facility (the "Site" or "Facility"), located at 2300 Ne Brookwood Pky, Hillsboro, OR 97124, at 08:56 AM (PT) on 08/23/2022 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed James Cochran that this was an EPA Region 10 inspection to determine compliance with the Resource Conservation and Recovery Act (RCRA). This report is based on information supplied by Qorvo Us Inc Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its HQ including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Lead Inspector/EPA Region 10 Inspector Consultant Environmental Engineer Manager of Environment, Health & Safety Katie Bradshaw Zeb Bates Kristina LeVelle Kiley Ross James Cochran Phone Email 2065536318 bradshaw.katrina@epa.gov Opening Conf. Yes zebuliah.bates@deq.state.or.us No Yes (503) 615-9260 kiley.ross@qorvo.com Yes (503) 615-9199 james.cochran@qorvo.com Yes Closing Conf. Yes Yes Yes Yes Yes Opening Conference I, EPA Lead Inspector Katie Bradshaw arrived at the Qorvo Us Inc at 08:56 AM (PT) on 08/23/2022 for an inspection. I presented my credentials to and informed James Cochran that this was an EPA RCRA inspection. The table above presents all the inspection participants in opening and closing conferences. I also explained that I would be performing Leak Detection and Repair (LDAR) Monitoring on the Subpart BB and CC equipment, using a Toxics Volatile Analyzer (TVA2020). 2 of 8 Qorvo Us Inc Inspection Date: 08/23/2022 Facility/Site Information What type of generator facility verified as? Large Quantity Generator (LQG) What type of LQG generator facility notified? Operating Hours 24/7; 365 Weather Conditions Sunny, dry, 80s Number of employees 800 Process Description The facility manufacturers semiconductors in a series of etching and photoresist processes. There are a variety of waste streams produced, including metals, solvents, acids, and debris. The solvent system is gravity drained to a two-compartment 2,000-gallon tank, which has monthly checks (along with all the solvent piping and equipment) conducted by contractors using EPA Method 21. During the tour, we looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. We also observed the facility's universal waste and used oil management. Specifically, we inspected the following areas of the facility listed below. Only those areas in which we observed areas of concern or noted other pertinent issues are discussed in this inspection report. Building(s) Building/Area/Sub-area Fab Chem pass through Finish fab Photo Room Fab Tank Fab WW Machine shop Office bldg Link Outside Solvent tank room Bin 103 Bin 104 Outdoor CAA SECTION II - OBSERVATIONS Process Description Most of solvents SAA with two containers Universal waste area A little bit of manufacturing ER tank background 0.9 ppm CAA Corrosive; requested profile Pending analysis. Should say pending hazardous Area Of Concern No Yes Yes No No No Yes No No No No No No Yes 3 of 8 Qorvo Us Inc Inspection Date: 08/23/2022 QORVO US INC Observation #: KB1-OB-001 Person Interviewed: Date: 08/23/2022 Corrosive acid waste two containers. Both empty. Photo(s) 1. IMG-202208230941234123196533.jpg Contains AOC: Yes Title: Building: Outside/ solvent tank room Observation #: KB1-OB-003 Date: 08/23/2022 Person Interviewed: Contains AOC: No Title: Tank East compartment had 277 gallons; West had 70 gallons Funnel End caps/valves x34 Flanges x2 Ships every 5 days Valves x 3 No component detected more than 20 ppm. Contains CBI: No Contains CBI: No QORVO US INC Observation #: KB1-OB-006 Person Interviewed: Date: 08/23/2022 3 universal waste lamps on top of containers. Photo(s) 1. IMG-202208231128372837128416.jpg Contains AOC: Yes Title: Building: Fab/Finish fab Observation #: KB1-OB-004 Person Interviewed: Date: 08/23/2022 Finish fab vacuum open end. Photo(s) 1. IMG-20220823110154154169187.jpg Contains AOC: Yes Title: Building: Outside/Outdoor CAA/Bin 101 4 of 8 Contains CBI: No Contains CBI: No Qorvo Us Inc Inspection Date: 08/23/2022 Observation #: KB1-OB-002 Person Interviewed: Date: 08/23/2022 Contains AOC: Yes Title: Contains CBI: No Bin 101 label issue waste pending analysis didn't have "hazardous waste" or hazard indicator. SECTION III - RECORDS REVIEW In the interest of time, I requested records to be reviewed after the inspection (see Communication Log in Section V). SECTION IV - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: KB1-OB-001 Area: SAA Sub-area: Corrosive acid waste 2 containers; Citations: 40 CFR Both empty. Sections: 262.34(c)(1) Building: KB1-OB-006 Area: Universal Waste Sub-area: 3 UW lamps on top of containers Citations: 40 CFR Sections: 273.13(d)(1) Building: Fab KB1-OB-004 Area: Finish fab Sub-area: Finish fab vacuum open end Citations: 40 CFR Sections: 262.34(a)(1)(i) Building: Outside KB1-OB-002 Area: Outdoor CAA Sub-area: Bin 101 Bin 101 label issue waste pending analysis didn't have "hazardous waste" or hazard indicator Citations: 40 CFR Sections: 262.34(a)(3) 5 of 8 Qorvo Us Inc Inspection Date: 08/23/2022 SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference During the closing conference, I asked about BB equipment leaks recorded on 08/05/22, and if there was a timeframe for repair? Kylie Ross confirmed from the email traffic that it should be done within the next week. I reviewed the few areas of concern, and asked James Cochran to email the requested documents and photos of labels placed and containers closed as required. I explained that I was not making a compliance determination on site, and that any follow up would likely come from a compliance officer. I thanked them for their time and cooperation and departed the facility at 03:07 PM. Follow Up I observed some follow up at the time of the inspection. The extra container in the SAA was removed, the universal waste lamps were placed inside the closed containers, and labels placed to include the words hazardous waste and the hazard indicator. Communication Log Additional information was received by EPA Region 10 after exiting the Facility on 08/23/2022. James Cochran sent the following information on 08/25/2022: Contingency Plan Hazardous Waste Management SOP Inspection Photo Log and Corrections Manifest Tracking for 2021 Current Training Status Reports Solvent Tank Integrity PE Stamp Waste Management Profile for Corrosive Acid Contaminated Solids EPA DEQ Inspection Photo Log 8-23-22 SECTION VI - MONITORING ACTIVITIES Organic Air Emissions of some, but not all, Subpart BB and CC equipment. No emissions were detected above limits. SECTION VII - LIST OF APPENDICES 1. Photo Log 6 of 8 Qorvo Us Inc Inspection Date: 08/23/2022 APPENDIX 1: PHOTO LOG SAA 08/23/2022 09:42 AM Near fabrication area IMG-202208230941234123196533.jpg Photographer: Katie Bradshaw No CBI No PII Universal Waste Lamps on Containers 08/23/2022 11:28 AM Machine Shop IMG-202208231128372837128416.jpg Photographer: Katie Bradshaw No CBI No PII 7 of 8 Qorvo Us Inc Inspection Date: 08/23/2022 "Waste Pending Analysis" not labeled hazardous nor a hazard indicator 08/23/2022 01:25 PM Outdoor CAA Bin 101 IMG-202208230952155215211871.jpg Photographer: Katie Bradshaw No CBI No PII Hazardous waste vacuum with open end 08/23/2022 11:01 AM Fab/Finish fab IMG-20220823110154154169187.jpg Photographer: Katie Bradshaw No CBI No PII 8 of 8