Document QgZ7O2dJgVx10nnNDXnBozbpo
RCRA Inspection Report
1) Inspector and Author of Report
Alan Newman
RCRA Enforcement Section
Chemical Safety and Land Enforcement Branch
Enforcement and Compliance Assurance Division
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
(404) 562-8589
Atlanta, Georgia 30303
newman.alan@epa.gov
2) Facility Information
Arconic Tennessee LLC, South Plant 300 North Hall Road Alcoa, Tennessee 37701 ID No. TND003383551
3) Responsible Officials
Mr. Shane Strickland, EH&S Superintendent Arconic Tennessee LLC, South Plant 2300 North Wright Road Alcoa, Tennessee 37701 (865) 977-2561 shane.strickland@arconic.com
4) Inspection Participants
Devin Belleau Shane Strickland John Montgomery Danny Byrd David Dubose Bob Grabowski Gerald Webster Alan Newman
Arconic Arconic Arconic Arconic Waste Management Waste Management TDEC EPA
5) Date of Inspection
June 10, 2021 8:30 am - 4:00 pm
6) Applicable Regulations
Resource Conservation and Recovery Act (RCRA) Sections 3002, 3005, and 3007 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927), Tennessee Hazardous Waste Management Act,
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Tennessee Code Annotated (T.C.A.) 68-212 part 1 & 3 and the Used Oil Collection Act of 1993, T.C.A. 68-211, Part 10; and the Tennessee Hazardous Waste Management Regulations, Tennessee Rule Chapter 0400-12-01, and 40 Code of Federal Regulation (C.F.R.), Parts 260 270, 273, 278, & 279.
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(h) [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 68-212-108 of the THWMA, Tenn. Code Ann. 68-212108 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(h) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption").
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1. [40 C.F.R. 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 Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1.] [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(g)2. or 0400-12-01.03(1)(h)1. [40 C.F.R. 262.16(b) or 262.17(a)], except as required in Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1.(vii and viii)] [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in Ten Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1. [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption").
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.12(1)(i) [40 C.F.R. 273.9], a "Small Quantity Handler of Universal Waste" (SQHUW) is a Universal Waste handler who does not accumulate 5,000 kilograms or more of Universal Waste (batteries, pesticides, mercurycontaining equipment, or lamps, calculated collectively) at any time.
7) Purpose of Inspection
The purpose of this inspection was to conduct an announced compliance evaluation inspection to determine Arconic's compliance with the applicable requirements of RCRA and the corresponding TDEC regulations. This was an EPA lead inspection.
8) Previous Inspection History
The most recent inspection was conducted by TDEC on October 30, 2019. There were two violations noted during this inspection that were addressed with informal enforcement.
9) Facility Description
Arconic Tennessee LLC, South Plant (Arconic) recycles scrap aluminum from various sources (no longer including aluminum cans, which are processed elsewhere) into large aluminum ingots weighing as much as 25-30,000 pounds. The primary processes area remelting, alloying, and casting utilizing two secondary smelters.
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The waste streams generated by the facility include:
Waste Number/Name
Waste Codes
Waste Gas & Diesel
D018, D001
Waste liquid paint & solvent
D001, D008, D035, F003, F005
Waste Compressed Flammable Gases
Non-halogenated waste paint materials
Waste acids with debris
Waste propane cylinders
D001, D035, D039 D001, D008, D035, F003, F005
D002 D001
Waste dust & debris
D006, D008
Lbs. in 2020 432 200 1094
2146
932 10 4594
The facility began operations in the early 1940s d.b.a. Alcoa. The company changed ownership in 2016. Arconic employs approximately 1000 workers and occupies approximately 100 acres.
Arconic submitted a notification of hazardous waste activity on March 2, 2021, which identified them as a large quantity generator of hazardous waste, a small quantity handler of universal waste and a used oil generator. The primary NAICS code is 331315 - Aluminum Sheet, Plater, and Foil Manufacturing.
10) Opening Conference
On June 9, 2021, EPA inspector Alan Newman and TDEC inspector Gerald Webster telephoned Devin Belleau at Arconic, Inc. to conduct an opening conference to explain the purpose of the impending inspection visit the following day and determine details of COVID-19 related protocols for the facility. The inspectors described the anticipated use of digital cameras during the inspection and provided a request for records. On the following day, June 10, 2021, EPA inspector Alan Newman, accompanied by TDEC inspector Gerald Webster, arrived at Arconic, Inc. at approximately 8:30 a.m. Devin Belleau, the Environmental Manager, immediately received the inspectors. The inspectors introduced themselves, showed their credentials to Devin Belleau, and watched the required safety video and answered medical screening questions. The inspectors discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. The company did not assert a business confidentiality claim. The inspection participants also discussed health and safety protocols and required personal protective equipment before Devin Belleau led the inspectors on a tour of the Facility operations.
Devin Belleau provided an overview of the facility's history and current operations during the opening conference. The company does not appear to meet the Small Business Regulatory Enforcement Fairness Act's classification of a "small business," which is generally set by the Small Business Administration using the business' NAICS code and annual receipts or number of employees. Therefore, the EPA inspector did not provide a copy of the agency's information
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sheet for small businesses, which can be found at https://www.epa.gov/sites/production/files/2017-06/documents/smallbusinessinfo.pdf.
11) Findings
Building 278 Central Accumulation Area
The inspection team toured Building 278 which serves as a central accumulation area (CAA) for containerized hazardous waste, used oil, and assorted other stored items including of two the emergency response trailers for site-wide use (Photos 1-6).
There were three fiber cylinders of universal waste lamps labeled as universal waste with accumulation start dates (ASD) of 5/18/2021, 6/1/2021, and 4/26/2021 respectively, and one 30gallon container of universal waste lamps with an ASD of 5/3/2021.
There were three 5-gallon buckets of universal waste batteries: one for lithium batteries with an ASD of 4/27/2021, one for alkaline batteries, and one for lead acid batteries with an ASD of 6/8/2021. There was one lead acid battery that was not labeled as universal waste. Facility personnel stated that this battery had recently arrived, and they were able to place this battery into the dedicated 5-gallon container which was labeled.
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.12(2)(e)1. [40 C.F.R. 273.14(a)], a SQHUW must label or mark each Universal Waste battery or container or tank in which the batteries are contained clearly with one of the following phrases: "Universal Waste Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."
There were four 55-gallon metal containers of hazardous waste being stored in this CAA. Three containers were storing waste aerosol cans and the other container was storing waste paint. The containers were labeled with the words "Hazardous Waste," the indication of the hazard and the oldest ASD was 3/31/2021. Two of these containers did not have the year included on the ASD. Facility personnel corrected this at the time of the inspection. This is an area of concern. Additionally, there were nineteen (19) 55-gallon metal containers of non-regulated material, seven 55-gallon containers of used oil, and two used oil tanks. These containers and tanks were labeled, in good condition, closed.
Baghouses 1 and 2 CAA
The tour continued to the baghouses 1 and 2 area CAA. There was one roll off container underneath each baghouse (Photo 7). These containers were labeled with the words "Hazardous Waste," the indication of the hazard, and the oldest ASD was 4/6/2021. Facility personnel stated that instead of sending off the roll offs for disposal they have emptied the roll off containers into 55-gallon metal containers for shipment due to the low amount of waste being generated in this area. The most recent roll off shipment was in December 2020.
Accumulation areas
In Building 88 (storage area #10; the Can Rec), Arconic was accumulating one 55-gallon container of aerosol cans in a satellite accumulation area (SAA) which was labeled with the
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words "Hazardous Waste," and with an indication of the hazard. The container was in good condition and closed. The lid was affixed with an inward spring-loaded flip top (Photos 8-9).
In Building 90 (storage area #9; the I/CR Office), Arconic was accumulating one 5-gallon container of universal waste batteries which was labeled with the words "Universal Waste" and a ASD of 9/28/2020. The container was in good condition and closed.
In Building 134 (storage area #11; the Old Potroom), Arconic was accumulating one 55-gallon container of aerosol cans in a SAA which was labeled with the words "Hazardous Waste," and with an indication of the hazard. The container was in good condition. The lid was affixed with an inward spring-loaded flip top and the lid was ajar (Photo 10). Arconic was also accumulating one 5-gallon container of universal waste batteries which was labeled with the words "Universal Waste" and a ASD of 3/18/2021. The container was in good condition and closed.
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1.(iv) [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.
In Building 135 (storage area #12; the Old Potroom), Arconic was accumulating one 55-gallon container of waste paint in a SAA which was labeled with the words "Hazardous Waste," and with an indication of the hazard (Photos 11-13). The container was in good condition and closed. This container was affixed with a latched funnel. This container was being stored on a plastic containment pallet. This pallet was partially full of waste paint. Facility personnel were unsure if the waste paint in the secondary containment would have been hazardous during the inspection. There was a dumpster nearby that had waste paint, waste paint residues, and waste paint rollers and debris (Photos 14-15). Arconic should make a hazardous waste determination on these solid wastes. If these solid wastes are hazardous, they should be properly managed (not in the dumpster).
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Tenn. Comp. R. & Regs. 0400-12-01-.02(1)(b) [40 C.F.R. 261.2], must determine if the at waste is a hazardous waste following methods articulated in Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11].
In Building 180 (storage area #14 CR Maintenance), Arconic was accumulating universal waste batteries in a flip top 55-gallon metal container dated 1/11/2021 and aerosol cans in a 55-gallon metal SAA container which was labeled with the words "Hazardous Waste," and with an indication of the hazard. These containers were in good condition, labeled, and closed. In another location in this building, Arconic accumulates oily waste in a container. This container was empty on the day of the inspection. Arconic also accumulates e-waste in this area. Arconic operates a parts washer and a sand blast cabinet in this building. Once waste is generated from the sand blast cabinet, Arconic should ensure that the waste is properly characterized and managed. There were no deficiencies noted in these areas.
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In Building 81 (storage area #7 Melting/Casting), Arconic was accumulating used oil absorbents in a container and operating a Safety-Kleen parts washer. Also, in Building 81 (storage area #8 Melting/Casting), Arconic was accumulating aerosol cans in a 55-gallon metal flip-top metal container in a SAA which was labeled with the words "Hazardous Waste," and with an indication of the hazard and universal waste batteries in a 5-gallon bucket dated 10/27/2020. There were no deficiencies noted in these areas.
In Building 45 (storage area #5 Truck Shop), Arconic was accumulating one 55-gallon metal container of used fuel (gas and diesel) and two 55-gallon metal containers for waste aerosols which were both labeled with the words "Hazardous Waste," and with an indication of the hazard. Arconic was also accumulating universal waste batteries in a 5-galllon plastic bucket that was dated 9/20/2020. Arconic was storing used oil in two tanks in Building 45 (Photo 16). These tanks were labeled with the words "Used Oil".
In the Central Building and Grounds (CB&G) area, Building 150, Arconic is storing items from recently demolished buildings (Buildings 49 and 53). Several of these items appear to be wastelike (Photos 17-20). Arconic should review all items in this building and determine if any of them are solid waste and manage them appropriately.
Record Review
The inspection team reviewed the contingency plan, the inspection records, the manifests/LDR documents, training records, and waste minimization plan. The inspection team recommends that Arconic ensure that full names and full dates be entered into the documentation for the CAA inspections. Arconic's inspection forms also have a place to enter the time. Several records did not record the time. There were no deficiencies noted with these records.
12) Closing Conference
The inspectors conducted a closing conference at 4:00 pm with Devin Belleau. During this meeting, the inspectors stated their preliminary conclusions of the inspection.
13) Inspection Findings
Based on the observations made during the inspection, Arconic was apparently deficient with the following RCRA requirements:
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Tenn. Comp. R. & Regs. 0400-12-01-.02(1)(b) [40 C.F.R. 261.2], must determine if the at waste is a hazardous waste following methods articulated in Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(b) [40 C.F.R. 262.11].
Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1.(iv) [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.
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Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.12(2)(e)1. [40 C.F.R. 273.14(a)], a SQHUW must label or mark each Universal Waste battery or container or tank in which the batteries are contained clearly with one of the following phrases: "Universal Waste Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."
14) List of Appendices
Appendix 1 - Photo Log: 20 Photos taken on: June 10, 2021 Photos taken by: Alan Newman Photos taken with: Panasonic DMC TS-5 Digital Camera EPA Property Tag: S09533
15) Signed
Digitally signed by ALAN
ALAN NEWMAN NEWMAN Date: 2021.08.26 14:14:06 -04'00'
Alan Newman Environmental Engineer
Date
Concurrence
ARACELI CHAVEZ
Digitally signed by ARACELI CHAVEZ Date: 2021.08.26 16:19:28 -04'00'
Araceli B. Chavez Chief RCRA Enforcement Section
Date
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Photographs
Photos taken by Alan Newman, EPA Photos taken on June 10, 2021 Photos taken with: Panasonic DMC TS-5
Digital Camera EPA Property Tag: S09533
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Photo 1: Emergency Response Trailer.
Photo 4: Building 278 Universal Waste Lamps.
Photo 2: Building 278 CAA.
Photo 5: Building 278 Universal Waste Batteries.
Photo 3: Building 278 CAA.
Photo 6: Building 278 Used Oil containers and tanks.
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Photo 7: Baghouse CAA.
Photo 10: Building 134 SAA and Universal waste accumulation.
Photo 8: Building 88 Aerosol Can SAA.
Photo 9: Building 88 Aerosol Can SAA.
Photo 11: Building 134 Waste Paint SAA container.
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Photo 12: Building 134 Waste Paint SAA container spill pallet.
Photo 15: Building 134 dumpster.
Photo 13: Building 134 Waste Paint SAA container.
Photo 16: Building 45 used oil tanks.
Photo 14: Building 134 dumpster.
Photo 17: Building 150 materials.
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Photo 18: Building 150 materials.
Photo 20: Building 150 materials.
Photo 19: Building 150 materials.
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