Document OnqVav7qZ3MXNbRKKYkG0Q9L

RCRA Inspection Report 1) Inspector and Author of the Report David Champagne Physical Scientist (404) 562-9028 champagne.david@epa.gov U.S. EPA Region 4 Resource Conservation and Recovery Act Enforcement Section Chemical Safety and Land Enforcement Branch Enforcement and Compliance Assurance Division 61 Forsyth St., S.W. 10th Floor Atlanta, Georgia 30303-8960 2) Facility Information Stella-Jones Corporation 13539 Highway 45 Scooba, Mississippi 39358 EPA ID# MSD985980846 NAICS: 321114 - Wood Preservation 3) Responsible Official Mr. Merlin Grassiree, Production Supervisor Stella-Jones Corporation mgrassiree@stella-jones.com (662) 476-8000 Ext. 6653 (662) 883-1091 4) Inspection Participants Mr. J.L. Bowman, Plant Manager Mr. Merlin Grassiree, Production Supervisor Ms. Jessica Walker, EHS Technician Ms. Jessica Tierny, EHS Manager Mr. David Champagne, U.S. EPA Region 4, Inspector Mr. Brad Justice, MDEQ Inspector 5) Date of Inspection March 9, 2021, 10:15 hours Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 1 of 10 6) Applicable Regulations Mississippi Hazardous Waste Management Regulations (MHWMR), 11 Miss. Admin. Code Pt. 3, R. 1.1-1.24 Section 17-17-1 et seq. of the Mississippi Code of 1972, Miss. Code Ann. 17-17-1 et seq. Section 17-17-27 of the Mississippi Code of 1972, Miss. Code Ann. 17-17-27 Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40. C.F.R. 262.10], a Large Quantity Generator (LQG) is a generator who generates greater than or equal to 1,000 kilograms (2200 lbs) of non-acute hazardous waste in a calendar month. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [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 12-8-66 of the GHWMA, Ga. Code Ann. 12-8-66 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [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 17-17-27(4) of the Mississippi Code of 1972, Miss. Code Ann. 17-17-27(4), and without complying with 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). 7) Purpose of Inspection The purpose of the inspection was to conduct an announced hazardous waste compliance evaluation inspection (CEI) to determine the facility's compliance with applicable RCRA regulations. 8) Facility Description Stella-Jones Corporation (facility) is located at 13539 Highway 45 in Scooba, Mississippi (Lat 32.77074, Long -88.46498) and is part of the Lumber & Plywood Product Manufacturing Industry. The most recent Hazardous Waste Generator Notification (EPA Form 8700-12) dated March 1, 2021, characterized the facility as a large quantity generator (LQG) of hazardous waste. The facility was built in the mid-1980s and sits on about 40 acres. The facility has 35 employees and operates 10-hour shifts starting as early as 06:00 hours and concluding as late as 17:00 hours Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 2 of 10 CST. Southern Yellow Pine trees are brought to the facility for evaluation and determining whether the tree will meet utility pole specifications. The facility has a Water Pollution Control Permit to discharge wastewater (Permit No. MS0044733 Expires 1/31/2022). The facility is a True Minor. The State of Mississippi Department of Environmental Quality Permit Regulations states that True Minor sources are not required to obtain a permit to operate air emission equipment. 9) Previous Inspection/Compliance History Stella-Jones Corporation was last inspected by MDEQ and the EPA on March 30, 2016 and had no violations. MDEQ also conducted compliance evaluation inspections (CEI) on May 2, 2011 and March 26, 2007 with no violations. 10) Findings Opening Conference On Thursday March 4, 2021, MDEQ hosted a conference call with the facility to discuss the EPA's and MDEQ's plans to conduct a RCRA Hazardous Waste CEI and to ensure everyone could adhere to the CDC's Covid-19 guidance. On Tuesday March 9, 2021, the EPA and MDEQ inspectors arrived at the facility around 10:15 hours CST and met with Mr. J.L. Bowman, Plant Manager, Mr. Merlin Grassiree, Production Supervisor, Ms. Jessica Walker, EHS Technician and Ms. Jessica Tierney, EHS Manager (teleconference). The inspectors presented their credentials to the team and explained that the purpose of the visit was to conduct a RCRA Hazardous Waste CEI. The facility provided a brief overview of the process and both parties proceeded with a process-based walk through of the facility. Peeler The Peeler staging area is where Southern Yellow Pine trees are brought in and peeled or shaved of the bark. The trees then move through an assembly line where each tree's specifications are measured and cut to customer specifications. Trees are marked with aerosol spray paint cans with the tree size classification that determines utility end use. At the time of the inspection, there was one 55-gallon satellite accumulation area (SAA) container used to store D001 hazardous waste that was empty. Non-hazardous wood shavings are burned in the on-site boiler. Framing Shop The facility has two 10 ft3 kilns, a 400-horsepower boiler and 100-horsepowered diesel boiler to aid or act as a backup for the drying process of the poles. The drying process takes about 8 hours from start to finish. This area has a 55-gallon SAA container used to collect hazardous waste from punctured aerosol cans. This container was not labeled "Hazardous Waste" (Photograph 1 of 3). Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 3 of 10 Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [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". Treating Area Located in this area are trees that have been cut to utility-pole specifications and have been soaked in a pentachlorophenol/diesel mixture. The poles are rolled on a metal drip pad to the door pit of the retort cylinder and placed inside. A 55-gallon SAA hazardous waste container was used to collect any spills onto the metal drip pad. At the time of the inspection, this container was labeled and closed. Concentrated pentachlorophenol is diluted with diesel and administered, as needed, to the retort cylinder. When the door to the retort cylinder is opened, residual pentachlorophenol spills out and is collected in the door pit area. This area is drained through the wastewater treatment process and any potential sludge left is collected in 55-gallon containers and labeled as F032 hazardous waste (NA3077). Located adjacent to the filter where pentachlorophenol-diesel mixture passes through, one 55gallon SAA container storing F032 hazardous waste was being used to collect any incidental spills. This container was closed, labeled "Hazardous Waste" and labeled with the characteristic of the hazardous contents. One approximate 2.5-gallon transfer container used to catch incidental spills from filter change outs contained F032 hazardous waste. This 2.5-gallon SAA container was not labeled "Hazardous Waste" or labeled with the hazardous contents of the container, and the container was not closed (Photograph 2 of 3). Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [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 11 Miss. Admin. Code Pt. 3, R. 1.3 [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. Two yellow tanks approximately 5,000 gallon in size, are used as settling tanks for the spent pentachlorophenol-diesel mixture collected from the door pit of the retort cylinder and starts the separation process for the wastewater treatment. The facility representatives stated that very minimal sludge waste is generated, but that, when needed, the tank is cleaned out and the sludge is disposed as F032 hazardous waste. Samples are taken to determine exact separation specifications before continuing to another separation tank and treatment tank. Filters used at each treatment location are disposed of as F032 Hazardous Waste. Outside this building are two Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 4 of 10 wastewater treatment containment basins. The facility operates a zero-discharge wastewater treatment process. Also located in the treatment area is a 250-gallon tote for the collection of used oil. At the time of the inspection, this container was labeled. A yellow secondary container was being used to collect used oil from oil filter canisters. This container was not labeled "Used Oil" (Photograph 3 of 3). Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.22 [40 C.F.R. 279.22(c)(1)], containers and aboveground tanks used to store used oil at generator facilities must be labeled or marked clearly with the words "Used Oil." 90-Day Central Accumulation Area (CAA) Located adjacent to the retort cylinder were thirteen (13) 55-gallon CAA containers storing hazardous waste. Twelve (12) of the CAA containers were storing F032 hazardous waste (pentachlorophenol diesel sludge and debris) and one (1) 55-gallon CAA container storing D001 hazardous waste (aerosols). The oldest dated container storing hazardous waste was January 18, 2021. All containers were labeled "Hazardous Waste", labeled with the characteristic of the hazardous contents, dated, and closed. Laboratory Lab technicians drill small holes in the poles and sample the wood to determine absorption penetration has met specifications. This material has been approved for disposal at the Kemper County Landfill and is considered non-hazardous waste. Records On March 4, 2021, the inspection team requested record-keeping documentation be emailed to adhere to CDC Guidelines for social distancing during the Covid-19 pandemic. On March 10, 2021, Ms. Tierney emailed the EPA and MDEQ a summary of all the emails containing recordkeeping documentation for the facility. Hazardous Waste Training Records for facility personnel document the attendees' names and job titles. The Quick Reference Guide and Contingency Plan is kept on file as required by the regulations. The plan was created in May 2014 and last updated in June 2020. Hazardous Waste Inspection Records of the storage areas are conducted either by treatment process personnel or Mr. Grassiree. All inspection records and manifests dating back 3 years were provided along with the Annual Hazardous Waste Report and Drip Pad Certification. The existing drip pad was upgraded in 2011 to meet the requirements of Hazardous Waste Regulations found in 40 CFR 265 Subpart W. The pad was certified in 2011 by Mr. Pete Sheck, PE (#11594) from Phoenix Environmental Engineering of Nashville, Tennessee when the upgrade was completed. The facility maintains a copy of the drip pad upgrade certification on site and was last modified in 2019. 11. Summary Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 5 of 10 The inspectors conducted the exit meeting with facility team presenting the preliminary results of the inspection. Stella-Jones Corporation was inspected as a large quantity generator of hazardous waste. At the time of the inspection, the facility did not appear to be in compliance with some requirements of RCRA. The inspection concluded at approximately 14:00 hours. 12) Signed _________________________ David Champagne Physical Scientist 13) Concurrence ARACELI ARACELI CHAVEZ Digitally signed by _C__H__A_V__E_Z___1_2_:4_0:_08_-_04_'0_0' Date: 2021.04.20 Araceli Chavez Chief RCRA Enforcement Section _4_/1_9_/_2_0_2_1___ Date ____________ Date Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 6 of 10 Photographs of Stella-Jones Corporation 13539 Hwy 45 Scooba, MS 39358 EPA ID# MSD985980846 Camera Model: Google Pixel XL By: David Champagne Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 7 of 10 Photograph 1 of 3: SAA Container for hazardous waste from punctured aerosols Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 8 of 10 Photograph 2 of 3: SAA container used to collect incidental spills from filtration of hazardous material Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 9 of 10 Photograph 3 of 3: Yellow secondary containment for used oil Stella-Jones Corporation EPA ID# MSD985980846 March 9, 2021 Page 10 of 10