Document OzQ0VZVe6KBmkNr9Kn2GKJgqw

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At FRES-CO SYSTEM USA INC. 2026 Fernwood Avenue Red Oak, Iowa 51566 712-623-8100 ext.6684 EPA ID Number: IAR000007013 On February 28, 2023 By TOEROEK ASSOCIATES, INC. For U. S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 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, Toeroek Associates, Inc., and its subcontractor CLAENE Group (Toeroek team) conducted a hazardous waste compliance evaluation inspection (CEI) at Fres-Co System USA Inc. (Fres-Co) at 2026 Fernwood Avenue in Red Oak, Iowa. The CEI was conducted under the authority of Section 3007 of Resource Conservation and Recovery Act (RCRA), as amended. The CEI covered hazardous waste generator requirements, used oil management, and universal waste requirements, as applicable. This report and its attachments present the results of the CEI. PARTICIPANTS Fres-Co: Anthony Evans-EHS Coordinator Greg Armstrong-Plant Manager (Entry and Exit Briefing only) Michael Higgins-Facility Manager Jack L. Keat Jr.-Ink Room Supervisor Toeroek Team: Clifford Nelles, Inspector, 816-213-5192 INSPECTION PROCEDURES Prior to the CEI at Fres-Co on February 28, 2023, I conducted a drive-by visual inspection. I did not observe any areas of concern during the drive-by. At approximately 7:15 a.m., I entered the lobby at Fres-Co. I observed a sign with instructions to sign the visitor's log and call the number posted on the telephone. I dialed the number, identified myself to the employee, and explained the purpose of the CEI. The employee asked me to wait in the lobby and stated that someone would be with me shortly. I read the safety policies posted by the telephone. A short time later, Mr. Evans met me in the lobby. After brief introductions, I explained the purpose and scope of the CEI to him. Mr. Evans and I adjourned to a conference room where we were met by Messrs. Armstrong and Higgins. I proceeded to conduct an entry briefing with Messrs. Evans, Armstrong, and Higgins. During the entry briefing, I presented my business card and EPA credentials to Messrs. Evans, Armstrong, and Higgins. I explained the scope and procedures for the CEI. I explained the facility's right to make confidentiality claims for any or all the information obtained and provided a Notice Regarding Proprietary/Confidential Business Information. I stated that at the conclusion of the CEI, Mr. Evans would be presented with a Confidentiality Notice (Notice) with which he could make or not make a claim of confidentiality for the facility. I also provided Messrs. Evans, Armstrong, and Higgins a copy of U. S. Federal Codes 1001 and 1002, concerning communication of false statements and documents to federal inspectors, and RCRA Section 3007, explaining EPA's inspection authority, both of which they read. A copy of each of the following documents was left with Mr. Evans during the inspection: x RCRA Facility Access Information Sheet x Mr. Trevor Urban's business card x RCRA Section 3007 x U.S. Federal Codes 1001 and 1002 x Instructions for Responding to a Notice of Preliminary Findings x Notice Regarding Proprietary/Confidential Business Information x E-Manifest Fact Sheet: Generators x Managing your Hazardous Waste: A Guide for Small Businesses x U.S. EPA Small Business Resources Information Sheet x Solvent-Contaminated Wipes Final Rule Summary Chart x IDNR Excluded Solvent-Contaminated Wipes Rule: Management Practices for Wipes, Rags, and Shop Towels x Recycling Electronics: A Guide for Businesses x Lead-Based Paint Activities: Handling and Disposal x Battery Recycling/Disposal x Management of Fluorescent Lamps for Businesses x Incompatible Chemicals x Universal Wastes - Including Aerosol Cans x TCLP - Toxicity Characteristic Leaching Procedure x Part 279 Requirements: Used Oil Management Standards 2 x EPA Region 7 Emergency Response Program x Chemical Facility Anti-Terrorism Standards x Iowa Environmental Guide for Businesses I reviewed the Notification Acknowledgement/Verification Report (Verification Report) with Mr. Evans (Attachment 1). Based on this review, I made no updates or changes to the Verification Report. I conducted the visual inspection of the facility, accompanied by Messrs. Evans and Higgins. Following the visual inspection, I reviewed facility records including hazardous waste manifests with land disposal restriction (LDR) notifications, Safety Data Sheets (SDS), contingency plan, and training documentation. I prepared and completed a site-specific inspection checklist to document my observations. At the conclusion of the CEI, I conducted an exit briefing with Messrs. Evans, Armstrong, and Higgins. During the exit briefing, I provided a Receipt for Documents and Samples, which Mr. Evans signed, acknowledging receipt (Attachment 2). I provided Mr. Evans the Notice, which he signed indicating no confidential business information had been provided (Attachment 3). I also provided Mr. Evans a Notice of Preliminary Findings (NOPF), which he signed to acknowledge receipt (Attachment 4). A map of the facility obtained during the CEI is included as Attachment 5, and a Google Earth aerial photograph of the facility is included as Attachment 6. The 15 photographs taken during the CEI are included in Attachment 7. FINDINGS AND OBSERVATIONS 1. Facility Description and General Information Fres-Co manufactures flexible packaging for the food industry. The facility's manufacturing operations use various types of polyester sheeting on large rolls. Fres-Co binds polyester sheeting using adhesive and then prints logos and designs on the polyester to make package impressions. Raw materials used to manufacture the flexible packaging include polyester, aluminum foil, polyethylene, nylon, adhesive, ink, and coatings. Fres-Co utilizes a Rotogravure printing system. The printing presses use solvent based inks and the image is engraved onto a cylinder that imprints on the polyester as it passes over a rotating drum. The facility prints and laminates packaging on two lines--one that prints and laminates sequentially and one that conducts printing and laminating separately. Equipment is cleaned by use of ethyl acetate or a mixture of ethyl acetate and alcohol. The solvent is either applied directly to the equipment or wiped on with a rag. Spent solvent is reclaimed in one of two distillation units (stills) in a closed-loop system. Spent solvent is hard piped to a 200-gallon feed tank serving the distillation unit. After distillation, reclaimed solvent is hard piped to a 1,000-gallon clean solvent tank, which is hard piped back into the cleaning process. The facility generates approximately 1,000 gallons of spent solvent every 50 hours. The distillation units are operated 24 hours per day, 5 days per week, and have an approximately 81% recovery rate. 3 Still bottoms are generated during solvent reclamation. The facility considers still bottoms to be hazardous (D001, F003) based on product and process knowledge. Still bottoms are shipped offsite to WRR Environmental Services in Eau Claire, Wisconsin, for fuel blending. Solvent mixed with ink or waste solvent that is deemed too dirty for distillation, called "requal" by the facility, is considered D001 characteristic, F003 listed hazardous waste and is sent off site for fuel blending. The printing process also generates used ink and solvent filters (waste flammable solids). Waste flammable solids are considered D001 characteristic hazardous waste and are sent off site for disposal. Cleaning and maintenance of equipment by use of solvent also generates ink-saturated rags and mop heads that are considered D001 characteristic hazardous waste and consolidated with the used filters in the waste flammable solids waste stream. Waste flammable solids are shipped offsite to WRR Environmental Services in Eau Claire, Wisconsin, for fuel blending or bulking/transfer to another facility. Waste disposal wipes used for wipe cleaning equipment are managed as excluded solvent-contaminated wipes according to Title 40 Code of Federal Regulations (40 CFR) 261.4(b)(18) and are shipped to WRR Environmental Services in Eau Claire, Wisconsin, for fuel blending. Fres-Co also uses a parts washer to clean printing equipment. Facility and equipment maintenance also generates used oil, used lamps, used batteries, and general trash. The facility manages used oil according to provisions of 40 CFR Part 279. Used lamps and used batteries are managed as universal waste per 40 CFR Part 273. General trash is considered to be nonhazardous waste and is transported to the to the Montgomery County Landfill in Red Oak, Iowa, for landfill disposal. Fres-Co began operations at this location in 2001. According to Mr. Evans, Fres-Co currently employs approximately 127 full-time staff who work one of three 8-hour shifts per day (7:00 a.m. to 3:00 p.m., 3:00 p.m. to 11:00 p.m., and 11:00 p.m. to 7:00 a.m.), Monday through Friday. The facility consists of a single 100,000-square foot building, on approximately 10 acres. FresCo's North American Industrial Classification System (NAICS) code is 323lll Commercial Gravure Printing. Fres-Co was last inspected by an EPA contractor on April 18-19, 2017. The contractor left the following findings: x Failure to identify the name and telephone number for the Emergency Coordinator in the RCRA Contingency Plan x Failure to amend the RCRA Contingency Plan x Failure to include a written description of the education or qualification associated with each job title x Failure to prepare a written description of the type and amount of introductory and continuing training provided x Failure to label a hazardous waste satellite accumulation container with the words "hazardous waste" x Failure to label a hazardous waste satellite accumulation container with an indication of the nature of the hazard x Failure to close a hazardous waste satellite accumulation container 4 x Failure to label a hazardous waste accumulation container with an indication of the nature of the hazard x Failure to demonstrate the length of time of accumulation for universal waste lamps x Failure to make an adequate hazardous waste determination None of these findings were repeated during this CEI. 2. RCRA Status Fres-Co is identified on the Verification Report provided by EPA (Attachment 1) as a large quantity generator (LQG) of hazardous waste (generating more than 1,000 kilograms [kg] of hazardous waste per month. Through a review of current operations, interview with Mr. Evans, and review of waste disposal records (manifests and tracking records), I determined that the facility is operating as a LQG of hazardous waste. Fres-Co generates three primary hazardous waste streams: waste flammable liquids-requal, still bottoms, and waste flammable solids. According to the facility's 2021 Hazardous Waste Biennial Report (Attachment 8), Fres-Co generated a total of 490,557 pounds (222,513 kg) of requal, still bottoms, and waste flammable solids in 2021. This rate (approximately 40,878 pounds [18,542 kg] per calendar month) easily exceeds the LQG threshold of 1,000 kg per month. Therefore, I inspected the facility as a LQG of hazardous waste. I also inspected the facility as a used oil generator and a small quantity handler (SQH) of universal waste (accumulating less than 5,000 kg of universal waste at any time). 3. Waste Streams This section of the CEI report describes the waste streams generated by the facility, including the facility's waste determination and waste codes, generation process and rate, management at the facility, and ultimate disposition. The following discussion of waste streams is based on conversations with facility representatives, the visual inspection, and my review of waste shipping documents. Messrs. Evans and Higgins accompanied me during the visual inspection. Mr. Keat joined the CEI during the visual inspection of the Ink Room. All inspection participants were provided a copy of U.S. Federal Codes 1001 and 1002, which they read. Waste flammable liquids-requal consists of spent solvent mixed with ink or spent solvent that is deemed too dirty for distillation. The waste is generated during cleaning of printing and laminating equipment. Copies of the SDSs for the primary ink (Belloe Color HS Black), cleaning solvents (ethyl acetate and isopropyl alcohol), and laminating adhesives (Liofol UR3649 and Liofol LA 2790-2) are included as Attachment 9 through 13, respectively. The facility considers waste flammable liquids-requal to be hazardous (D001, F003) based on product and product knowledge. Based on the 2021 Biennial Report (Attachment 8), the facility generates approximately 25,638 pounds of waste flammable liquids-requal per month. The waste is accumulated in 5 and 55-gallon satellite accumulation containers (SAC) and full containers are transferred to the hazardous waste container accumulation area (HWCAA) in the Ink Room. The 55-gallon hazardous waste accumulation containers (HWAC) are collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for fuel blending. 5 During the CEI, I observed three 55-gallon SAC of waste flammable liquids-requal and eight 5gallon SAC. Representative photographs of the 55-gallon SAC at 206 Station 11 and the 5-gallon SAC at 206 Station 9 Adhesive are included in (Attachment 7, Photographs 1 and 2). Each SAC was at or near the point of generation, under the control of the operator, and labeled with the words "hazardous waste" and an indication of the nature of the hazard. All SACs were closed except where waste was actively been added to the container (Attachment 7, Photograph 2). I observed no deficiencies with satellite accumulation of waste flammable liquids-requal during the CEI. I observed 26 HWACs in the Ink Room HWCAA, including 18 HWACs of waste flammable liquids. HWACs labeled as waste flammable liquids could be requal or still bottoms. The HWACs were staged on a 3-level rack system against the wall (Attachment 7, Photographs 6 through 8). Because of the HWAC staging, it appeared that the facility did not maintain adequate aisle space for waste management and emergency equipment as required by 40 CFR 262.17(a)(6), referencing 40 CFR 262.255 (NOPF No 2). Also because of the HWAC staging, I could not observe accumulation start dates on each HWAC. I determined that the facility failed to mark HWACs with accumulation start dates that were clearly visible for inspection, as required by 40 CFR 262.17(a)(5)(i)(C) (NOPF No 3). After the facility removed the HWACs from the stock racks, I observed that all were structurally sound, full, closed, labeled with the words "hazardous waste" and an indication of the nature of the hazard, and marked with accumulation start dates. The oldest accumulation start date was February 19, 2023. I provided compliance assistance regarding management of HWACs during the CEI. Still bottoms consists of solids and ink/solvent liquids remaining after solvent reclamation in the distillation unit. The facility considers still bottoms to be hazardous (D001, F003) based on product and process knowledge. Based on the 2021 Biennial Report (Attachment 8), the facility generates approximately 10,000 pounds of still bottoms per month. The waste is accumulated in 55-gallon SACs beneath the distillation units, and full SACs are transferred to the Ink Room HWCAA. Still bottoms are collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for fuel blending. During the CEI, I observed the active distillation unit and the SAC for still bottoms beneath the unit (Attachment 7, Photographs 9 and 10). The SAC was at the point of generation, under the control of the operator, labeled with the words "hazardous waste" and an indication of the nature of the hazard, and closed. The SAC was empty at the time of the CEI. I observed still bottoms HWACs in the Ink Room HWCAA, and noted deficiencies for inadequate aisle space and accumulation start dates not clearly visible for inspection. These deficiencies are described in the waste flammable liquids-requal section above. Waste flammable solids consists of ink-saturated rags, mops, filters used for cleaning equipment and filtering ink or solvent (D001, F003) that are used for cleaning equipment and filtering ink. The facility considers waste flammable solids to be hazardous (D001, F003) based 6 on product and process knowledge. Based on the 2021 Biennial Report (Attachment 8), the facility generates approximately 4,942 pounds of waste flammable solids per month. The waste is accumulated in 5-gallon SACs at the point of generation and transferred to the Make Ready Room where it is compacted into a 55-gallon HWAC. The waste is collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for fuel blending or bulking/transfer to another facility. During the CEI, I observed a 55-gallon HWAC in the Make Ready Room for compaction of waste flammable solids. The HWAC was structurally sound, closed, labeled with the words "hazardous waste" and an indication of the nature of the hazard, dated February 28, 2023, and held approximately 10 gallons of compacted waste flammable solids. Thickened rollout is a high viscosity solvent blend used for cleaning vertical surfaces. The facility considers waste thickened rollout to be nonhazardous based on product and process knowledge. I did not determine the waste generation rate during the CEI. The waste is collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for fuel blending. During the CEI, I observed a 55-gallon container of waste thickened rollout and adhesive plumbing parts at Press 208 (Attachment 7, Photographs 4 and 5). The container was labeled with the words "hazardous waste" and an indication of the nature of the hazard (flammable solids). However, the container was open as the lid ring was not secured. I asked Mr. Evans what was in the container and he stated the contents were thickened rollout and adhesive plumbing parts. Mr. Evans explained that thickened rollout was nonhazardous and provided an SDS for the material (Attachment 14). Based on the SDS, thickened rollout has a flash point of 195 and does not appear to be hazardous when spent. I asked Mr. Evans if the container was being managed as a hazardous waste. He stated that the container is not being managed as hazardous waste and that it had been labeled incorrectly. Excluded solvent-contaminated wipes consist of spent disposable wipes generated by wipe cleaning of presses. The facility manages spent disposable wipes as excluded solventcontaminated wipes according to provisions of 40 CFR 261.4(b)(18). Excluded solventcontaminated wipes are accumulated in 5-gallon containers. The facility generates approximately 295 pounds of excluded solvent-contaminated wipes per month. Excluded solvent-contaminated wipes are collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for fuel blending. During the CEI, I observed four 5-gallon excluded solvent-contaminated wipes containers. A photograph of the container at 206 Station 11 is in Attachment 7, Photograph 3. Excluded solvent-contaminated wipes containers were structurally sound, closed, and labeled with the words "excluded solvent-contaminated wipes." I did not observe free liquids in the containers, and noted no concerns with management of excluded solvent-contaminated wipes. Printing equipment parts washer solvent is generated during changeout of the parts washer solvent used for cleaning printing equipment. The facility uses FRP Ultra Resin Remover in the printing equipment parts washer. Fres-Co considers waste printing equipment parts washer solvent to be nonhazardous based on product and process knowledge. A copy of the SDS for FRP Ultra Resin Remover is included as Attachment 15. Spent parts washer solvent is piped 7 directly from the parts washer into the nonhazardous distillation unit in a closed loop system. This distillation unit is dedicated to nonhazardous parts washer solvent. Solids (bottoms) from this parts washer are considered to be nonhazardous based on product and process knowledge. I did not observe accumulation of printing equipment parts washer solvent or bottoms during the CEI. Used Oil is generated during the maintenance of facility equipment and is accumulated in 55gallon used oil storage containers in the maintenance shop. The facility manages used oil according to provisions of 40 CFR Part 279. The facility generates approximately 10 gallons of used oil per month. Used oil is collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for fuel blending. During the CEI, I observed a 55-gallon used oil storage container in the maintenance shop (Attachment 7, Photographs 13 and 14). The 55-gallon used oil storage container appeared to be structurally sound with no evidence of leaking or damage, held approximately 15 gallons of used oil, and was labeled with the words "used oil." I noted no deficiencies with management of used oil during the CEI. Universal waste lamps are generated by maintenance personnel replacing spent lamps. The facility manages spent lamps as universal waste lamps according to provisions of 40 CFR Part 273. Fres-Co generates approximately 16 universal waste lamps per month. The universal waste lamps are accumulated in fiberboard universal waste accumulation containers in the mezzanine of the maintenance shop. Universal waste lamps are collected by Brenntag Great Lakes and transported to WRR Environmental in Eau Claire, Wisconsin, for recycling. During the CEI, I observed a universal waste accumulation container in the maintenance shop mezzanine that held approximately 15 spent lamps (Attachment 7, Photographs 11 and 12). The universal waste accumulation container was structurally sound, closed, labeled with the words "universal waste" and "spent lamps," and marked with an accumulation start date of February 9, 2023. I noted no deficiencies with management of universal waste lamps during the CEI. Universal waste batteries are generated by replacement of spent batteries in equipment. The facility manages spent batteries as universal waste batteries according to provisions of 40 CFR Part 273. Fres-Co generates approximately 8 pounds of universal waste batteries per month. Universal waste batteries are accumulated in a 2-gallon universal waste accumulation container in the vestibule leading to the production areas. Universal waste batteries are shipped to Battery Solutions in Howell, Michigan, for recycling. During the CEI, I observed the 2-gallon universal waste accumulation container in the vestibule. (Attachment 7, Photograph 15). The universal waste accumulation container was labeled with the words "used batteries," marked with an accumulation start date of January 2, 2023, and held approximately 10 universal waste batteries. I noted no deficiencies with management of universal waste batteries during the CEI. General trash consists of office-type refuse, such as waste packaging materials and food containers. The facility has determined that general trash is nonhazardous based on product and 8 process knowledge. General trash is accumulated in several containers throughout the facility and transferred to a 4-cubic-yard roll-off container or compactor. General trash is collected by Republic Services and transported to the Montgomery County Iowa landfill for disposal. I observed accumulation of general trash during the CEI and noted no deficiencies with management of general trash. 4. Required Response Equipment and Hazard Management Per 40 CFR 262.15(a)(8) and 262.17(a)(6), a LQG must operate to minimize the possibility of a fire, explosion, or spill, and must maintain emergency response equipment. During the visual inspection, I observed spill response equipment comprised of mats, absorbent materials, shovels, and brooms, as well as the presence and availability of fire extinguishers. I determined that the spill and fire response equipment was adequate for the hazardous wastes generated and accumulated at the facility. 5. Container Accumulation Areas Fres-Co maintains two HWCAAs, one in the Ink Room and another in the Make Ready Room. In the Make Ready Room, I observed one 55-gallon HWAC where waste flammable solids are compacted. The HWAC was structurally sound, closed, labeled with the words "hazardous waste" and an indication of the nature of the hazard, dated February 28, 2023, and held approximately 10 gallons of compacted waste flammable solids. In the Ink Room, I observed 26 HWACs of waste flammable liquids and waste flammable solids. The HWACs were staged on a 3-level rack system against the wall (Attachment 7, Photographs 6 through 8). As described in Section 3 of this report, it appeared that the facility did not maintain adequate aisle space for waste management and emergency equipment as required by 40 CFR 262.17(a)(6), referencing 40 CFR 262.255 (NOPF No 2), or mark HWACs with accumulation start dates that were clearly visible for inspection, as required by 40 CFR 262.17(a)(5)(i)(C) (NOPF No 3). After the facility removed the HWACs from the stock racks, I observed that all were structurally sound, full, closed, labeled with the words "hazardous waste" and an indication of the nature of the hazard, and marked with accumulation start dates. The oldest accumulation start date was February 19, 2023. I provided compliance assistance regarding management of HWACs during the CEI. I asked Mr. Keat if the HWCAAs are inspected. He stated that he conducts inspections of both HWCAAs on a weekly basis. I asked Mr. Keat if he maintained an inspection log and he stated that an inspection log is kept. I reviewed the inspection log for the last three years and noted no missed inspections. A copy of the inspection record from February 27, 2023, is included as Attachment 16. I asked Mr. Keat how an operator would summon emergency assistance and he stated that all workers who manage hazardous waste carry two-way radios. 6. Manifests and Biennial Report Fres-Co generated manifests for 203 hazardous waste shipments from February 28, 2020, to February 28, 2023. During the CEI, I reviewed each of the manifests and LDR notifications (59 shipments in 2020, 66 shipments in 2021, 70 shipments in 2022, and eight shipments in 2023 to 9 date). During the review, I noted eight manifests from 2020 to 2021 that did not include the EPA hazardous waste code for waste flammable solids (D001, F003) as required by 40 CFR 262.20(a) (NOPF No. 1). Copies of two of the eight manifests without the hazardous waste code, dated July 15, 2020, and April 14, 2021, are included in Attachment 17. A copy of the February 22, 2023, manifest is included as Attachment 18. The Hazardous Waste Biennial Report for 2021 was submitted in February 2022 (Attachment 8). 7. Preparedness and Prevention Plan LQG facilities are required by 40 CFR 262.17(a) to meet the emergency preparedness, prevention, and procedures requirements including documented arrangements with response agencies. According to Mr. Evans, Fres-Co is the subject of a regular inspection by the Red Oak Fire Department hazardous materials team. During those inspections, he said the fire department is shown the layout of the facility, the location of the hazardous waste HWCAAs, and other facility features. During the CEI, I reviewed the facility's Contingency Plan. The contingency plan appeared to meet all the content requirements, including a Quick Reference Guide. Since Fres-Co has four operating shifts, each shift has an Emergency Coordinator and at least two alternates. A copy of the list of Emergency Coordinators from the Contingency Plan is included as Attachment 19. I noted no deficiencies during my review of emergency preparedness, prevention, and procedures requirements or the facility's Contingency Plan. 8. Personnel Training Requirements Personnel training is required by LQG regulations specified in 40 CFR 262.17(a)(7) to ensure that employees are thoroughly familiar with proper waste handling procedures relevant to their responsibilities. During the CEI, I asked Mr. Evans if hazardous waste training is provided to employees. He stated that hazardous waste management training is provided to all employees who handle hazardous waste within six months of hiring or assignment to a job that handles hazardous waste. He also stated that annual refresher training is conducted. I asked Mr. Evans who conducts the training. He stated that all training is conducted by Compliance Management International. I reviewed the training records for the last three years for Messrs. Woodward, Keat, and Evans. Copies of training records for Messrs. Keat and Woodward are included in Attachment 20 as examples of the training documentation maintained at the facility. I reviewed the written job description for Messrs. Keat and Woodward and noted that the job description and titles were adequate. A copy of the Job Description for an Ink Technician is included as Attachment 21. I noted no deficiencies with personnel training requirements during the CEI. 9. Air Emissions: 40 CFR Part 265 Subparts AA, BB, CC EPA regulations in 40 CFR Part 265, Subparts AA, BB, and CC apply to LQGs. If a LQG manages hazardous waste with an organic concentration greater than 10 parts per million by weight (ppmw), the standards specified in Subpart AA apply to hazardous waste air emissions from certain process vents. A process vent used in distillation, fractionation, solvent extraction, thin-film evaporation, air stripping, or steam stripping is regulated by Subpart AA. Fres-Co is not 10 subject to the Subpart AA regulations because the facility does not have any of the process vents listed above. If a LQG has equipment that contains or contacts hazardous waste composed of 10 percent or greater organics by weight, the facility is subject to Subpart BB standards for inspection and monitoring of the equipment. Fres-Co is not subject to the Subpart BB regulations because its distillation unit is a closed-loop hard-piped system. Solvent is hard-piped to the 200-gallon feed tank, which is considered to be part of the distillation unit, with no prior accumulation. The standards found in Subpart CC apply to LQGs that manage hazardous waste in containers with organic compounds (VOC) concentration that exceeds 500 ppmw. The Subpart CC standards are applicable because the facility accumulates hazardous waste that contains VOCs in 55-gallon hazardous waste accumulation containers. During the CEI, I determined that Fres-Co meets the Subpart CC requirements for containers by using Container Level 1 controls (hazardous waste accumulation containers smaller than 122 gallons that are Department of Transportation [DOT]-approved). I noted no concerns with management of hazardous waste per the Subpart CC air emissions requirements. 10. Summary of Preliminary Findings In summary, as part of the CEI, I made the following preliminary findings: (1) Failure to have waste codes on hazardous waste manifests as required by 40 CFR 262.20(a) (NOPF No. 1). (2) Failure to provide adequate aisle space for waste management and emergency equipment as required by 40 CFR 262.17(a)(6)--262.255 (NOPF No. 2). (3) Failure to have an accumulation start date visible as required by 40 CFR 262.17(a)(5)(i)(C) (NOPF No. 3) Other than items specifically noted in the narrative, I observed no additional issues. However, further review by EPA may change or add to my findings. 11 Clifford A. Digitally signed by Clifford A. Nelles Date: 2023.04.21 _N__e_ll_e_s________15_:2_6:_15_-0_5'_00_' ________________________ Date:___________________ Clifford A. Nelles, Inspector CLAENE Group Digitally signed by AMBER WHISNANT Date: 2023.04.28 AMBER WHISNANT ______________19_:3_2:_02_-0_5_'00_' ________________________ Date: ___________________ Amber Whisnant, Section Chief ECAD/CB/RCRA, EPA Region 7 Attachments: 1. Hazardous Waste Site Info Verification Report for Inspector (2 pages) 2. Receipt for Documents and Samples (1 page) 3. Confidentiality Notice (1 page) 4. Notice of Preliminary Findings (1 page) 5. Site Map (1 page) 6. Google Earth Photograph of Facility (1 page) 7. Photographic Documentation (Photolog and 15 Photographs) (12 pages) 8. Copy of 2021 Biennial Report (5 pages) 9. Copy of SDS for Belle Color HS Black (17 pages) 10. Copy of SDS for Ethyl Acetate (11 pages) 11. Copy of SDS for Isopropanol Alcohol (19 pages) 12. Copy of SDS for Liofol UR3649 (6 pages) 13. Copy of SDS for Loctite Liofol 2790-22 (6 pages) 14. Copy of SDS for Thickened Rollout (7 pages) 15. Copy of SDS for FRP Ultra Resin Remover (12 pages) 16. Copy of Inspection Log dated February 27, 2023 (1 page) 17. Copies of Manifests dated July 15, 2020 and April 14, 2021 (2 pages) 18. Copy of Manifest dated February 22, 2023 (1 page) 19. Copy of Emergency Coordinators from RCRA Contingency Plan (1 page) 20. Copies of Training Records for Douglas Woodward and Jack Keat (3 pages) 21. Copy of Job Description for Ink Technician (3 pages) 12