Document VG8Xzv3DmKXJxeEJ1jX0OR32K

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: FRS Number: March 11-13, 2024 RCRA Large Quantity Generator Container Life Cycle Management, LLC /dba Drumco Arkadelphia Facility 142 Technology Drive Arkadelphia, Arkansas 71923 142 Technology Drive Arkadelphia, Arkansas 71923 Clark County (870) 230-8800 David Russell Plant Manager david.russell@greif.com 110057882260 Media Identifier Number: NAICS: ARR000005959 332439 - Other Metal Container Manufacturing Personnel participating in inspection: John Penland US EPA Region 6 (R6 ECD-SR) Jackson Renfroe ADEQ Ty Dobbins David Russell Kory Smith Edwin Olivares Michael Fourcand ADEQ Drumco Drumco Greif Greif Sr. Environmental Scientist Hazardous Waste Inspector - Supervisor Hazardous Waste Inspector Plant Manager Plant Superintendent Senior Environmental Manager Senior Environmental Engineer EPA Lead Inspector Signature/Date Supervisor Signature/Date JOHN PENLAND Digitally signed by JOHN PENLAND Date: 2024.04.30 09:47:21 -05'00' John Penland (Sr. Environmental Scientist - 6ECD-SR) Date Debra Pandak (RCRA Section Supervisor - 6ECD-SR) 04/30/2024 Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Drumco, Inc. Gum Springs Facility March 11-13, 2024 During the week of March 11, 2024, I, John Penland, conducted an unannounced inspection of the Drumco, Inc. facility located at 142 Technology Dr in Arkadelphia, AR, (Drumco) for compliance with the Resource Conservation and Recovery Act (RCRA). I was accompanied on this inspection by Arkansas Department of Environmental Quality (ADEQ) inspectors Jackson Renfroe and Ty Dobbins. The inspection will include walkthroughs of the facility's hazardous waste generation and management units, and a review of the facility records related to solid and hazardous waste management. The Drumco facility was targeted for inspection as part of the Region 6's evaluation of chemical container reconditioning operations in response to EPA's November 2022 Drum Reconditioner Damage Case Report. FACILITY DESCRIPTION The Drumco facility reconditions steel drums for the reusable packaging industry. The process takes used steel drums and burns away any paint and chemical residues in an incinerator. The drums are then bead blasted and painted. These reconditioned drums are then sold for reuse. The facility is registered as a Large Quantity Generator of Hazardous Waste and is assigned the EPA ID: ARR000005959. The primary waste streams include: incinerator ash (D007 - hazardous for chromium toxicity), spent bead blast media (non-hazardous), and plant trash/used personal protective equipment (non-hazardous). Section II - INSPECTION SUMMARY March 11, 2024 We arrived at the Drumco facility at approximately 09:55am Central Time and began the inspection with an opening conference. During this conference, we presented our credentials to Mr. Kory Smith and informed him that we were there to conduct an inspection of the facility under the authority of Section 3007 of RCRA. During this conference, we also discussed the purpose and scope of the inspection and notified them of the facility's right to assert a claim for Confidential Business Information for records collected during this inspection. Following the opening conference, we conducted our walkthrough of the facility's process and storage areas. This walkthrough was focused on inspector orientation of the site and container reconditioning process. We departed the facility at approximately 2:00pm Central Time. For our detailed observations, inspection notes, and records request, see the Daily Summary for March 11, 2024, in Appendix 2. March 12, 2024 We arrived at the facility at approximately 9:20am Central Time to begin our inspection day. We began the day with a more comprehensive walkthrough of the facility, focusing on each of the facility 2 Drumco, Inc. Gum Springs Facility March 11-13, 2024 process areas. During this walkthrough, we evaluated the facility's compliance with the hazardous waste container standards as well as the facility's general duty to prevent releases of hazardous waste or hazardous constituents to the environment. Following this walkthrough, we discussed the facility's operating procedures and records management. For our detailed observations, inspection notes, and records request, see the Daily Summary for March 12, 2024, in Appendix 2. March 13, 2024 We arrived at the facility at approximately 9:10am Central Time to conduct a closing conference. During this conference, we summarized the inspection and presented our preliminary findings as described in Section III of this report. Detailed notes of this discussion are provided in the Daily Summary for March 13, 2024, in Appendix 2. Section III - PRELIMINARY FINDINGS 1) Incineration of non-RCRA empty Containers [40 C.F.R. 270.1 & A.R. 23 270.1] 261.7(b)(1) A container or an inner liner removed from a container that has held any hazardous waste, except a waste that is a compressed gas or that is identified as an acute hazardous waste listed in 261.31 or 261.33(e) of this chapter is empty if: (i) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container (e.g., pouring, pumping, and aspirating), and (ii) No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner. During our inspection, we observed that operators did not make attempts to empty drums containing observable free flowing residues. Instead, operators were relying on the 1-inch requirement of 261.7(b)(1)(ii) and the shippers written certification that the drums were shipped empty. Unfortunately, this certification is not a regulatory requirement and does not relieve Drumco from their responsibility to ensure that containers are in fact RCRA empty prior to placing them in the drum furnace. Incineration of any residues remaining in non-RCRA empty drums would require a hazardous waste permit under 270. On April 1, 2024, Drumco provided a written response to this finding which can be found in Appendix 3. 2) Improper storage of Incinerator Ash [40 C.F.R. 262.17(a)(1) & A.R. 262.17(a)(1)] Incinerator ash at the facility has been determined to be a hazardous waste demonstrating the characteristic of chromium toxicity (D007). Analytical records reviewed indicated that the Ash contains leachable quantities of hexavalvent chromium with TCLP results between 12 and 199 mg/L. During this inspection, we found 130 containers of Ash which were improperly managed. The containers were found to be unlabeled, open, and in poor condition. On April 1, 2024, Drumco provided a written response to this finding which indicates that all of the containers identified in this finding have been removed from the site and disposed of as hazardous waste. See also, Appendix 1 Photos: 36 through 46; 48 through 52; and 69 through 74. 3 Drumco, Inc. Gum Springs Facility March 11-13, 2024 3) Operation of the facility which could cause a release of hazardous waste to the environment. [40 C.F.R. 262.251 & A.R. 23 262.251] Notwithstanding the storage concerns raised in finding 2, the facility's ash management infrastructure appears to be insufficient to contain the incinerator ash. During this inspection, we observed spills and releases of incinerator ash beneath and around the incinerator ash dump, the concrete pad adjacent to the incinerator where ash containers were being accumulated, the plant roadway adjacent to the incinerator where the ash roll-off container was stored, and beneath the conveyor system carrying drums out of the incinerator. During the inspection and in its April 1, 2024, written response to this finding, Drumco informed us that the facility was planning to reengineer its ash management equipment. According to Drumco, the project is planned to be completed by September 2024. See also, Appendix 1 photos: 18 through 20; 34 through 42; 45; 47; 49; 50; and 72 through 76. 4) Out of date Contingency Plan [40 C.F.R 262.261(d) & A.R. 23 262.261(d)] During our initial review of the facility contingency plan, we found that the list of emergency coordinators is out of date and lists Barry Wingard as an active employee that could serve as an emergency coordinator. The Contingency Plan also lacks a Quick Reference. Drumco has provided an updated Contingency Plan, including a Quick Reference, in its April 1, 2024, response to this finding. 5) Unpermitted receipt and storage of hazardous waste [40 C.F.R. 270.1 & A.R. 23 270.1] The facility improperly took custody of a container of hazardous waste from one of its suppliers. This container was clearly marked as hazardous waste and was shipped to the facility without a hazardous waste manifest. While this is likely to be a shipping error by the generator, the Drumco facility is not permitted to act as a designated facility for the receipt of hazardous waste. Instead of rejecting this shipment directly, Drumco took custody of the waste and placed it in its warehouse for storage prior to transport back to the generator at a later date. On April 1, 2024, Drumco provided a written response to this finding which can be found in Appendix 3. See also, Appendix 1 photos 2 through 4. 6) Waste Determination for out of service products [40 C.F.R. 262.11 & A.R. 23 262.11] The definition of solid waste includes in its definition of the word "abandoned", materials that are: 261.2(b)(3) "Accumulated, stored, or treated (but not recycled) before or in lieu of being abandoned by being disposed of, burned or incinerated;". During this inspection, we found 7 containers of products in the building labeled as chemical/paint storage (noted as the ancillary building in previous summaries). According to Kory Smith and David Russell, all or some of these materials are no longer used in the facility's manufacturing process and should be disposed. 262.11 requires generators to identify and make a hazardous waste determination for any solid waste they generate at the point of generation. If these chemicals are in fact not usable by the facility and are being stored in lieu of disposal, then Drumco is required to make a waste determination for these materials and manage them appropriately. Labels on the drums indicate that these materials may be flammable liquids and potentially meet the ignitable characteristic of hazardous waste (D001). 4 Drumco, Inc. Gum Springs Facility March 11-13, 2024 In its April 1, 2024, written response to this finding, Drumco indicated that it had made waste determinations for these containers and arranged for proper disposal. See also, Appendix 1 photos 6 through 15. Section IV - FOLLOW UP The following information was received by EPA on April 1, 2024, after exiting the Facility on March 13, 2024: 1) CLCM Arkadelphia's Response to EPA - This document includes a written response to each of the preliminary findings in Section III and a claim of Confidential Business Information for certain records collected during this inspection. Section V - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - Daily Inspection Summary emails Appendix 3 - CLCM Arkadelphia's Response to EPA 5 Drumco, Inc. Gum Springs Facility March 11-13, 2024 Attachment 1 Inspection Photo Log ID #: Drumco_2024_2 ID #: Drumco_2024_3 ID #: Drumco_2024_5 ID #: Drumco_2024_6 ID #: Drumco_2024_7 ID #: Drumco_2024_8 ID #: Drumco_2024_9 ID #: Drumco_2024_10 ID #: Drumco_2024_11 ID #: Drumco_2024_12 ID #: Drumco_2024_13 ID #: Drumco_2024_14 ID #: Drumco_2024_15 ID #: Drumco_2024_16 ID #: Drumco_2024_17 ID #: Drumco_2024_18 ID #: Drumco_2024_19 ID #: Drumco_2024_20 ID #: Drumco_2024_23 ID #: Drumco_2024_24 ID #: Drumco_2024_26 ID #: Drumco_2024_27 ID #: Drumco_2024_28 ID #: Drumco_2024_29 ID #: Drumco_2024_30 ID #: Drumco_2024_31 ID #: Drumco_2024_32 ID #: Drumco_2024_34 ID #: Drumco_2024_35 ID #: Drumco_2024_36 ID #: Drumco_2024_37 ID #: Drumco_2024_38 ID #: Drumco_2024_39 ID #: Drumco_2024_40 ID #: Drumco_2024_41 ID #: Drumco_2024_42 ID #: Drumco_2024_43 ID #: Drumco_2024_44 ID #: Drumco_2024_45 ID #: Drumco_2024_46 ID #: Drumco_2024_47 ID #: Drumco_2024_48 ID #: Drumco_2024_49 ID #: Drumco_2024_50 ID #: Drumco_2024_51 ID #: Drumco_2024_52 ID #: Drumco_2024_53 ID #: Drumco_2024_54 ID #: Drumco_2024_55 ID #: Drumco_2024_56 ID #: Drumco_2024_57 ID #: Drumco_2024_58 ID #: Drumco_2024_59 ID #: Drumco_2024_60 ID #: Drumco_2024_61 ID #: Drumco_2024_62 ID #: Drumco_2024_63 ID #: Drumco_2024_64 ID #: Drumco_2024_65 ID #: Drumco_2024_66 ID #: Drumco_2024_67 ID #: Drumco_2024_68 ID #: Drumco_2024_69 ID #: Drumco_2024_70 ID #: Drumco_2024_71 ID #: Drumco_2024_72 ID #: Drumco_2024_73 ID #: Drumco_2024_74 ID #: Drumco_2024_75 ID #: Drumco_2024_76 Drumco, Inc. Gum Springs Facility March 11-13, 2024 Attachment 2 Daily Inspection Summaries Warehouse - the majority of the facility's warehouse space is used to store a backlog of used containers which are not processable by the Drumco Arkadelphia facility. This includes galvanized steel drums, metal pails, steel pressure vessels, composite drums, and other specialty containers. Many of these containers bear markings from that indicate that the last held contents were hazardous waste. According to Mr. Smith, an additional 155 trailers full of containers were also stored at the facility of which 71 have been emptied. The facility has only identified 7 containers which were not empty so far while processing this backlog. Drum crushing and bailing area - In the drum crushing and baling area we observed viscous liquids draining from crushed steel drums that had previously been processed through the facility incinerator. These bales of crushed drums were being transported to a roll off container as scrap while continuing to drip a viscous liquid. Ancillary building (NE side of main building) - We inspected two bays of this building. In the easternmost bay, the facility has stored product paints and several containers of old paint not used in their process any longer and are intended to be disposed of. The paints designated as intended for disposal all bear flammable liquid markings but no waste labels. The western bay held drums of plant trash and hardened epoxy. These wastes are non-hazardous but have been stored in that building for more than a year. Incinerator area - one roll-off accumulating waste ash from the incinerator. One roll-off staged for future accumulation. Ash is pulled from the drop out area beneath the unit via a chain conveyor to an accumulation drum. This drum is dumped into the roll-off. Ash is present as drag-out in the area and piled on the floor near the drum. Container receiving area. - Operators were unloading drums directly from a box trailer on to the incinerator conveyor when we inspected this area. Drums were pulled from the truck and had lids and lockrings removed before being placed on the incinerator conveyor. Inspectors observed free liquids present in the containers being placed on the conveyor. Operators did not attempt to remove these residues by pouring or aspirating nor did they measure the depth of residues in the containers prior to placing them on the incinerator conveyor. In the northwest corner of the building we found several containers marked as hazardous waste which did not appear to be empty when tipped. Labels on the containers indicated that they held hazardous waste from with accumulation dates in 2019. Near the container receiving area we found a rack of freshly painted lock rings from a ring dip painting process. These rings were placed on the rack to dry and liquid paint had run onto the floor of the building impeding foot traffic. Reject Container area - The facility stages containers which were rejected for being non-RCRA empty in a designated area located near the offices in the warehouse. Two 55-gallon drums were present in the area today, both from . One of these containers was marked as containing 320 pounds of material and bore a hazardous waste label. <90-day waste paint area - The facility accumulates containers of paint waste in a designated area in the warehouse near the painting line. Three 55-gallon steel drums were present in the area today. All were closed, labeled as hazardous waste, and marked with an accumulation start date. Departed Facility at approximately 2:00pm Topics for inspection on March 12, 2024 Revisit of areas of interest identified during our initial walkthrough Further discussion of the facility backlog Review of the facility's container acceptance procedures Waste profile and determination review Identification of process management records Identification of personnel for training review 3 John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 4  In the warehouse near the incinerator ash dump we found a pallet of drums which were not empty. 1 was full of ammonia contaminated rags. 3 were marked as flammable solids. On the right side of the incinerator ash dump we found 2 containers (drums) of incinerator ash which were open, unlabeled, and in poor condition On the left side of the incinerator ash dump we found 4 containers (drums) of incinerator ash which were open, unlabeled, and in poor condition. When we first visited the roll-off being used for the accumulation of incinerator ash we found it to be open without an operator present. On the Northeast side of the main body of the drum incinerator we found 117 containers (drums) of incinerator ash which were open, unlabeled, and in poor condition Underneath the exit conveyor of the incinerator we found accumulations of incinerator ash on the ground for the full length of the conveyor. We also found 6 containers (5 drums and 1 hopper) of incinerator ash which were open, unlabeled, and in poor condition In the ancillary building located on the northeast side of the facility we found 1 container (drum) of incinerator ash which was open, unlabeled, and in poor condition. Additional container backlog was found in the warehouse on the northwest corner of the facility. More container backlog is stored in 80-100 box trailers located around the facility. On returning to the facility at approximately 1:30pm we observed a visible emissions event from the stack of the drum incinerator this event lasted for an undetermined period of time but we observed it for at least 5 minutes. Training Records request For the purpose of determining compliance with the training requirements of 262.16(a)(7), we are requesting the training records for: o Kory Smith o David Russell o Rodney Moore o Adrian Cooper o Steven Moore. Topics for inspecon on March 13, 2024 Review of records provided by the facility in response to our requests of March 12 and 13 Closing conference where we will provide our preliminary findings. John Penland Senior Environmental Scienst (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2 From: To: Cc: Subject: Date: Penland, John Jackson Renfroe; ty.dobbins@adeq.state.ar.us; kory.smith@greif.com; david.russell@greif.com; olivareshuertae@greif.com; fourcandm@greif.com Brad Toler; Pandak, Debra (she/her/hers) Daily Summary - March 13, 2024 - EPA RCRA Inspection of the Drumco facility in Arkadelphia, AR Thursday, March 14, 2024 1:04:00 AM All, Here is a summary of my notes from today's inspection. If there are any errors or omissions, please let me know. Name John Penland Jackson Renfroe Ty Dobbins Kory Smith David Russell Edwin Olivares Michael Fourcand Title Lead Hazardous Waste Inspector Hazardous Waste Inspector - Supervisor Hazardous Waste Inspector Plant Superintendent Plant Manager Senior Environmental Manager Corporate Senior Environmental Engineer Corporate Representing US EPA Region 6 ADEQ ADEQ Drumco Drumco Greif Greif Phone 214-6659717 501-9930761 501-4133640 870-4033163 501-3170159 323-2466280 Email Penland.john@epa.gov Jackson.Renfroe@adeq.state.ar.us Ty.Dobbins@adeq.state.ar.us Kory.Smith@greif.com David.russell@greif.com olivareshuertae@greif.com fourcandm@greif.com Daily Summary Entry to the facility - approximately 9:10am Daily Recap meeting - 9:15 am Closing Meeting Preliminary Findings. 1. Incineration of non-RCRA empty Containers [270.1] The RCRA Empty Definition 261.7(b) (1) A container or an inner liner removed from a container that has held any hazardous waste, except a waste that is a compressed gas or that is identified as an acute hazardous waste listed in 261.31 or 261.33(e) of this chapter is empty if: (i) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, and (ii) No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner This duty applies prior to placing the drums in the incinerator. During our inspection we observed that operators did not make attempts to empty drums with observable freeflowing residues. Instead, operators were relying on the 1-inch requirement of 261.7(b)(1)(ii) and the shippers written certification that the drums were shipped empty. Incineration of non-RCRA empty drums would require a hazardous waste permit under 270 as a hazardous waste incinerator. 2. Improper storage of Incinerator Ash [262.17(a)(1)] Incinerator ash at the facility has been determined to be a hazardous waste demonstrating the characteristic of chromium toxicity (D007). Analytical records reviewed indicated that the Ash contains leachable quantities of hexavalvent chromium with TCLP results between 12 and 199 mg/L. During this inspection we found 130 containers of Ash which were improperly managed. The containers were found to be unlabeled, open, and in poor condition. 3. Operation of the facility which could cause a release of hazardous waste to the environment [262.251] Notwithstanding the storage concerns raised in finding 2, the facility's ash management infrastructure appears to be insufficient to contain the incinerator ash. During this inspection we observed spills and releases of incinerator ash beneath and around the incinerator ash dump, the concrete pad adjacent to then incinerator where ash containers were being accumulated, the plant roadway adjacent to the incinerator where the ash roll-off container was stored, beneath the conveyor system carrying drums out of the incinerator. 4. Out of date Contingency Plan [262 Subpart M] During our initial review of the facility contingency plan we found that the list of emergency coordinators is out of date and lists Barry Wingard as an active employee that could serve as an emergency coordinator. The Contingency Plan also lacks a Quick Reference. 5. Unpermitted receipt of hazardous waste [270.1] The facility improperly took custody of a container of hazardous waste from . This container was clearly marked as hazardous waste and was shipped to the facility without a hazarodus waste manifest. While this is likely to be a shipping error, the Drumco facility is not permitted to act as a designated facility for the receipt of hazardous waste. 6. Waste Determination for out of service products [262.11] The definition of solid waste includes in its definition of the word "abandoned" materials that are : 261.2(b)(3) "Accumulated, stored, or treated (but not recycled) before or in lieu of being abandoned by being disposed of, burned or incinerated;" During this inspection we found 7 containers of products in the building labeled as chemical/paint storage (noted as the ancillary building in previous summaries). According to Kory Smith and David Russell, all or some of these materials are no longer used in the facility's manufacturing process and should be disposed. 262.11 requires generators to identify and make a hazardous waste determination for any solid waste they generate at the point of generation. If these chemicals are in fact not usable by the facility and are being stored in lieu of disposal then Drumco is required to make a waste determination for these materials and manage them appropriately. Labels on the drums indicate that these materials may be flammable liquids and potentially meet the ignitible characteristic of hazardous waste (D001) Followup Any additional records not uploaded during this inspection should be delivered by April 1. John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 Ty Dobbins Kory Smith David Russell Edwin Olivares Michael Fourcand Hazardous Waste Inspector Plant Superintendent Plant Manager Senior Environmental Manager Corporate Senior Environmental Engineer Corporate ADEQ Drumco Drumco Greif Greif 501-413-3640 870-403-3163 501-317-0159 Ty.Dobbins@adeq.state.ar.us Kory.Smith@greif.com David.russell@greif.com olivareshuertae@greif.com 323-246-6280 fourcandm@greif.com Daily Summary Entry to the facility - approximately 9:10am Daily Recap mee ng - 9:15 am Closing Mee ng Preliminary Findings. 1. Incineration of non-RCRA empty Containers [270.1] The RCRA Empty Defini on 261.7(b) (1) A container or an inner liner removed from a container that has held any hazardous waste, except a waste that is a compressed gas or that is iden fied as an acute hazardous waste listed in 261.31 or 261.33(e) of this chapter is empty if: (i) All wastes have been removed that can be removed using the prac ces commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspira ng, and (ii) No more than 2.5 cen meters (one inch) of residue remain on the bo om of the container or inner liner This duty applies prior to placing the drums in the incinerator. During our inspec on we observed that operators did not make a empts to empty drums with observable free-flowing residues. Instead, operators were relying on the 1-inch requirement of 261.7(b)(1)(ii) and the shippers wri en cer fica on that the drums were shipped empty. Incinera on of non-RCRA empty drums would require a hazardous waste permit under 270 as a hazardous waste incinerator. 2. Improper storage of Incinerator Ash [262.17(a)(1)] Incinerator ash at the facility has been determined to be a hazardous waste demonstrating the characteristic of chromium toxicity (D007). Analytical records reviewed indicated that the Ash contains leachable quantities of hexavalvent chromium with TCLP results between 12 and 199 mg/L. During this inspection we found 130 containers of Ash which were improperly managed. The containers were found to be unlabeled, open, and in poor condition. 3. Operation of the facility which could cause a release of hazardous waste to the environment [262.251] Notwithstanding the storage concerns raised in finding 2, the facility's ash management infrastructure appears to be insufficient to contain the incinerator ash. During this inspection we observed spills and releases of incinerator ash beneath and around the incinerator ash dump, the concrete pad adjacent to then incinerator where ash containers were being accumulated, the plant roadway adjacent to the incinerator where the ash roll-off container was stored, beneath the conveyor system carrying drums out of the incinerator. 4. Out of date Contingency Plan [262 Subpart M] 2 During our ini al review of the facility con ngency plan we found that the list of emergency coordinators is out of date and lists Barry Wingard as an ac ve employee that could serve as an emergency coordinator. The Con ngency Plan also lacks a Quick Reference. 5. Unpermitted receipt of hazardous waste [270.1] The facility improperly took custody of a container of hazardous waste from . This container was clearly marked as hazardous waste and was shipped to the facility without a hazarodus waste manifest. While this is likely to be a shipping error, the Drumco facility is not permi ed to act as a designated facility for the receipt of hazardous waste. 6. Waste Determination for out of service products [262.11] The defini on of solid waste includes in its defini on of the word "abandoned" materials that are : 261.2(b)(3) "Accumulated, stored, or treated (but not recycled) before or in lieu of being abandoned by being disposed of, burned or incinerated;" During this inspec on we found 7 containers of products in the building labeled as chemical/paint storage (noted as the ancillary building in previous summaries). According to Kory Smith and David Russell, all or some of these materials are no longer used in the facility's manufacturing process and should be disposed. 262.11 requires generators to iden fy and make a hazardous waste determina on for any solid waste they generate at the point of genera on. If these chemicals are in fact not usable by the facility and are being stored in lieu of disposal then Drumco is required to make a waste determina on for these materials and manage them appropriately. Labels on the drums indicate that these materials may be flammable liquids and poten ally meet the igni ble characteris c of hazardous waste (D001) Followup Any additional records not uploaded during this inspection should be delivered by April 1. John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 3 Drumco, Inc. Gum Springs Facility March 11-13, 2024 Attachment 3 CLCM Arkadelphia's Response to EPA Mr. John Penland Page 2 (i) All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, and (ii) No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner This duty applies prior to placing the drums in the incinerator. During our inspection we observed that operators did not make attempts to empty drums with observable free-flowing residues. Instead, operators were relying on the 1-inch requirement of 261.7(b)(1)(ii) and the shippers written certification that the drums were shipped empty. Incineration of non-RCRA empty drums would require a hazardous waste permit under 270 as a hazardous waste incinerator. CLCM Response: CLCM has reviewed the Agency's comment provided above and we disagree. As an initial matter, we note that in order to clean Resource Conservation and Recovery Act ("RCRA")-empty containers for reuse, reconditioners either burn or wash any residue out of the empty containers. The existing RCRA regulations explicitly state that containers that have been emptied of their contents under specific conditions, are treated as empty for regulatory purposes, and any residue "remaining in either: an empty container; or an inner liner removed from an empty container" is not subject to RCRA regulation. 40 C.F.R. 261.7(a). The Agency very deliberately applied this language to definitively state that "the burning of residue by a drum recycler would not be considered incineration of hazardous waste and would not require a permit." Letter to Dale D. Parker, Ph.D. from Alan S. Corson, Branch Chief, Studies and Methods Branch, dated Jan. 7, 1986 (EPA RO 12535). With respect to the "empty" determination, compliance with the RCRA-empty rule occurs at the supplier's facility. Under RCRA, if a supplier has emptied a container, and "[a]ll wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping and aspirating, and ... [n]o more than 2.5 centimeters (one inch) of residue remain on the bottom of the container," the container is empty for purposes of RCRA and any residual contents are not regulated under RCRA. 40 C.F.R. 261.7(b)(1) (emphasis in original). In promulgating the RCRA-empty rule, the Agency anticipated that some residual material might remain in the container. During the rulemaking, the Agency noted, One commenter asked for clarification of when a drum is "empty," noting that there is always a residue in drums, even when they are completely drained. The Agency recognizes this fact, and is using the words "empty" and "emptied" in the practical, rather than the absolute, sense. Larger containers, such as drums, are usually aspirated or pumped out. This leaves a small residue on the bottom. This should never be more than one inch and, in most cases, is substantially less. Mr. John Penland Page 3 U.S. Environmental Protection Agency, Document No. 24401-41 (Standards Applicable to Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities Under RCRA, Subtitle C, Section 3004: General Comments on Storage) (Dec. 30, 1980), at pp.39-40. At a supplier's facility, product is removed from containers in various ways - often by pumping the product as the Agency anticipated. This method leaves residue in the container that the supplier is not equipped to remove. Even if a supplier had the processes to invert and drain every container, small amounts of residual material will always remain. And that is expressly permitted under the rule that the Agency adopted. Also, the RCRA-empty standard does not require a supplier to employ any method that is not "commonly employed," even if it is possible to empty a container. "Pourable" residue may remain in a container "aspirated or pumped out." The container is nevertheless considered empty under the Agency's regulations if aspiration is the "commonly employed [method] to remove materials from that type of container ... and ... [n]o more than 2.5 centimeters (one inch) of residue remain on the bottom of the container. 40 C.F.R. 261.7(b)(1)(emphasis in original). If a supplier creates an empty container that meets the regulatory definition at their facility and upon acceptance by the reconditioner as empty, that designation must remain with the container as it is processed by the reconditioner. The fact that a drop of material might drip or "pour" from the container when a reconditioner inverts the container in the midst of the reconditioning process cannot suddenly make a RCRA-empty container, "nonempty." In addition, the container reclamation furnace at the site is not a "hazardous waste incinerator." Regulations applicable to "hazardous waste combustors" are not applicable to the container reclamation furnace. The Agency has already determined that container reclamation ovens are not subject to hazardous waste incineration standards. Pyrolizing containers in the container furnace is not "incineration" of hazardous waste. Under the Agency's own regulations, the container furnace is considered a "burn-off oven" not an "incinerator," and is not subject to regulation under 40 C.F.R. Part 63, Subpart EEE. Moreover, the container furnace is a processing furnace, not an incinerator. Regulations relating to "commercial and industrial solid waste incineration units" in 40 C.F.R. Part 60, Subpart CCCC very clearly and specifically state that container reclamation units are not incinerators. These regulations define a "burn-off oven" as "any rack reclamation unit, part reclamation unit, or drum reclamation unit. A burn-off oven is not an incinerator, waste-burning kiln, an energy recovery unit or a small, remote incinerator under this subpart." 40 C.F.R. 60.2265. The exclusion of burn-off ovens from the definition of "incinerator" was deliberate: Based on the comments, the lack of data, and our determination that we did not need to regulate burn-off ovens to comply with our CAA section 112(c)(6) obligation, we did not finalize standards for burnoff ovens. We revised the definition of burn-off oven in the final rule to distinguish such units from the units for which we established standards. We have not received data that would allow us to Mr. John Penland Page 4 establish standards for the various burn-off oven subcategories and, therefore, we are not proposing standards in this reconsideration notice. 76 Fed. Reg. 80,452, 80,460 (Dec. 23, 2011). This exclusion is consistent with the position taken by the Agency in the first set of Subpart CCCC standards issued under Section 129. See 65 Fed. Reg. 75,338, 75,375 (Dec. 1, 2000) [defining drum reclamation unit at 40 C.F.R. 60.2265 (for new units) and 60.2875 (for existing units) and excluding such units from the definition of incinerator.] A regulatory handbook published shortly after the Subpart EEE regulations were finalized and the same year that the initial Subpart CCCC was rule was issued explains why drum reconditioning units are furnaces, not incinerators: Drum reconditioning furnaces are properly classified as industrial process furnaces. Regulatory permit writers at the state and local level may sometimes incorrectly classify a drum reconditioning furnace as an incinerator and subsequently may apply regulations or other requirements specifically developed for incinerators. This is an improper regulatory classification. It is important to note that the purpose of a drum furnace is to pyrolize the used drum in preparation for shot blasting. The drum reconditioning facility is not a waste disposal operation. Air and Waste Management Association (AWMA), Air Pollution Engineering Manual, 2nd Ed., at 289. The Agency itself has consistently distinguished between container reclaimers and hazardous waste incinerators and the Agency's own regulations define container reclamation furnaces to be a type of burn-off oven, and not an incinerator. This definition is consistent with the purpose of these units, which is to pyrolize the containers in preparation for shot blasting, as noted in the AWMA Air Pollution Engineering Manual. It is also consistent with the absence of any discussion of container reclamation units in the docket for Subpart EEE, and with a distinction drawn between the two source categories in other Agency documents. For these reasons, the container reclamation furnace is not an "incinerator" and is not subject to permitting a "hazardous waste incinerator". 2. EPA Comment: Improper storage of Incinerator Ash [262.17(a)(1)] Incinerator ash at the facility has been determined to be a hazardous waste demonstrating the characteristic of chromium toxicity (D007). Analytical records reviewed indicated that the Ash contains leachable quantities of hexavalent chromium with TCLP results between 12 and 199 Mr. John Penland Page 5 mg/L. During this inspection we found 130 containers of Ash which were improperly managed. The containers were found to be unlabeled, open, and in poor condition. CLCM Response: Following the inspection, CLCM closed all open containers containing container furnace ash, properly labeled such containers, and properly disposed of each of the identified containers. Please see Attachment A (CLCM-ARKADELPHIA-0000001) for a photo demonstrating that all drums have been removed from the site. 3. EPA Comment: Operation of the facility which could cause a release of hazardous waste to the environment [262.251] Notwithstanding the storage concerns raised in finding 2, the facility's ash management infrastructure appears to be insufficient to contain the incinerator ash. During this inspection we observed spills and releases of incinerator ash beneath and around the incinerator ash dump, the concrete pad adjacent to the incinerator where ash containers were being accumulated, the plant roadway adjacent to the incinerator where the ash roll-off container was stored, beneath the conveyor system carrying drums out of the incinerator. CLCM Response: Contains CBI. Beginning in September 2023, CLCM engaged AECOM, a third-party environmental and engineering consulting firm, to evaluate, propose improvements and re-design the entire ash handling system at the site. Since the beginning of the engagement, AECOM has conducted several site visits, requested information from the site, and prepared design options for the ash handling system for site consideration. CLCM selected a final site design for the system on March 5, 2024. Please see Attachment B (CLCM-ARKADELPHIA-0000002 - CLCM-ARKADELPHIA-000006). CLCM has contracted with an industrial contractor that will be constructing the selected design for the system and construction is expected to be complete by September 2024. 4. EPA Comment: Out of date Contingency Plan [262 Subpart M] During our initial review of the facility contingency plan we found that the list of emergency coordinators is out of date and lists Barry Wingard as an active employee that could serve as an emergency coordinator. The Contingency Plan also lacks a Quick Reference. CLCM Response: Contains CBI. CLCM has updated its Contingency Plan to list current emergency coordinating employees, as well as a Quick Reference. Please see Attachment C (CLCM-ARKADELPHIA-0000007 - CLCM-ARKADELPHIA-000041). 5. EPA Comment: Unpermitted receipt of hazardous waste [270.1] The facility improperly took custody of a container of hazardous waste from . This container was clearly marked as hazardous waste and was shipped to the facility without a hazardous waste manifest. While this is likely to be a shipping error, the Drumco facility is not permitted to act as a designated facility for the receipt of hazardous waste. ATTACHMENT A CLCM-ARKADELPHIA-000001 ATTACHMENT B PUBLIC CLCM-ARKADELPHIA000004 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA000005 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA000006 ATTACHMENT C PUBLIC FIRE: (870) 246-4545 POLICE: (870) 246-4545 SHERIFF: (870) 246-2222 AMBULANCE: 911 In the event of an emergency always dial 911. CRITICAL OPERATIONS Colleagues of Drumco will not be required to remain in a facility to operate critical plant operations. All colleagues will be required to evacuate upon notification. ALARM SYSTEM REQUIREMENTS Alarm system requirements for notifying all colleagues in an emergency are the following: a. Provides warning for safe escape b. Can be perceived by all colleagues c. Alarm is distinctive and recognizable d. Colleagues are properly trained e. Emergency telephone numbers posted f. Emergency alarms have priority g. Alarm system is maintained properly by trained personnel SOUNDING THE ALARM The signal for immediate evacuation for the facility will be through radios. EVACUATION PLANS Emergency evacuation escape route plans (see appendix A) are posted in key areas throughout the buildings. All colleagues have been trained concerning these plans and should also be familiar with the evacuation plans for the other buildings within the company. AVAILABILITY Copies of the written emergency action plan shall be maintained at the workplace and available for review. When working off-site, colleagues of Drumco must be trained at each facility in reference to their sitespecific Emergency Action Plan and a copy of the EAP must be available for review. COLLEAGUE ACCOUNTABILITY PROCEDURES AFTER EVACUATION In the event of a fire emergency signaled by either the Emergency Plan Coordinator or the building alarm system, all occupants will promptly exit the building by the nearest exit. Once clear of the building, go to the designated point and immediately report to their supervisor. After evacuation, each supervisor (or designee) is responsible for accounting for each colleague assigned to that supervisor by rallying at the designated point and by conducting a head count. Each colleague will be accounted for by name. Each colleague is responsible for reporting to his or her supervisor so an accurate head count can be made. All supervisors are required to report their head count (by Name) to the Emergency Plan Coordinator. DESIGNATED RALLYING POINTS All colleagues will report to the front parking lot toward the far corner away from the building, nearest the street, or if exiting the rear of the building, colleagues will report to the rear parking lot by the exit gate. RESCUE OR MEDICAL DUTIES PROCEDURE In the event colleagues need medical treatment, the Emergency Medical facility or 911 will be notified for assistance. Site specific EAPs will be followed when necessary. CLCM-ARKADELPHIA-000026 RE-ENTRY Once the building is evacuated, no one is to re-enter the building for any reason. Rescue personnel (if designated and properly trained) are excluded from this rule. When the Fire Department or other responsible agency has notified us the building is safe for reentry, then, and only then, will personnel return to their workstations. 2. HAZARD WEATHER EMERGENCY PLAN When a hazardous weather alert is announced by the Plan Coordinator all colleagues should immediately go to the closest tornado refuge area. All colleagues should stay in the tornado refuge area until given the "all clear" sign from the Plan Coordinator. The designated tornado refuge area is in the bathrooms by the main offices and the bathrooms below the supervisor offices. TRAINING Colleague training is provided when: (a) the plan is initiated; (b) when colleague's required actions and responsibilities change; (c) there are any changes to the plan; (d) initially for new colleagues; (e) refresher training. Items Reviewed: a. Emergency Escape Procedures b. Escape Route Assignments c. Fire Extinguisher Locations and Training d. Procedures to Account for Colleagues e. Major Workplace Fire Hazards f. Colleague Training Programs g. Fire Prevention Practices h. Closing doors behind you i. Means of Reporting Fire and Other Emergencies j. Names and Titles of Emergency Plan and Fire Protection Coordinators k. Alarm Systems 1. Proper Housekeeping m. Emergency and Fire Prevention Plan Availability n. Hazard Weather Procedures The Safety Director will be made responsible to assist in the safe and orderly evacuation of all colleagues. He/she will check restrooms, stairwells, etc to ensure notification and assistance is given as needed, if safe to do so. All colleagues will be instructed as to safely assist others in the event of emergency. CLCM-ARKADELPHIA-000027 3. SPILL CONTAINMENT PLAN TABLE OF CONTENTS 1.0- INTRODUCTION 2.0 - PURPOSE AND SCOPE OF CONTINGENCY PLAN 3.0 - OVERVIEW OF FACILITY OPERATIONS 4.0 - EMERGENCY RESPONSE COORDINATOR 5.0 - COORDINATION OF EMERGENCY SERVICES 6.0 - EMERGENCY PROCEDURES AND RESPONSIBILITIES 7.0 - EVACUATION PLANS APPENDIX A - SITE MAP AND PLOT PLAN APPENDIX B - EVACUATION ROUTES AND STORAGE LOCATIONS FOR EMERGENCY SUPPLIES APPENDIX C - INCIDENT REPORTING FORM APPENDIX D - RECORD OF REVISIONS CLCM-ARKADELPHIA-000028 EMERGENCY RESPONSE AGENCIES, ORGANIZATIONS AND PERSONNEL National Response Center (NRC) (800) 424-8802 (24 hours) Chemtrec (800) 424-9300 (24 hours) Poison Hot Line (800) 392-9111 (24 hours) Drumco Primary Emergency Coordinator Russ Bryant Office: (870) 230-8800 Mobile: (501) 317-7152 Drumco Secondary Emergency Coordinator Kory Smith Office: (870) 230-8800 Mobile: (870) 403-3163 Drumco Tertiary Emergency Coordinator David Russell Office: (870) 230-8800 Mobile: (870) 317-0159 Arkadelphia Fire Department 911 (Emergency) (870) 246-9354 (Non-Emergency) Ambulance Arkadelphia Police Department 911 (Emergency) 911 (Emergency) (870) 246-4545 (Non-Emergency) Clark County Sheriff's Office 911 (Emergency) (870) 246-2222 (Non-Emergency) Arkansas State Police Baptist Health Medical Center (Emergency Department) (Primary Hospital) (501) 618-8000 (870) 295-2622 or (870) 230-1720 CHI St. Vincent - Hot Springs (Emergency Department) (Secondary Hospital) (501) 622-1000 Clark County Office of Emergency Management (870) 246-2222 Arkansas Department of Environmental Quality (501) 682-0744 Arkansas Department of Emergency Management (501) 730-9750 Waste Services, Inc. (24 Hours) (501) 888-4323 CLCM-ARKADELPHIA-000029 1.0 - INTRODUCTION Container Life Cycle Management LLC, doing business as Drumco of Arkansas (Drumco), owns and operates a steel drum reclamation facility located at 142 Technology Drive in Arkadelphia, Clark County, Arkansas. The company reconditions used metal drums and/or containers for resale. Drumco is a Large-Quantity Generator (LQG) of hazardous waste. As such, the company is subject to the applicable requirements of Arkansas Pollution Control and Ecology Commission Regulation No. 23, "Hazardous Waste Management", and the underlying federal Resource Conservation and Recovery Act (RCRA) requirements for hazardous wastes. The current version of Regulation No. 23 was promulgated on September 25, 2015. These rules are administered by the Arkansas Department of Environmental Quality (ADEQ). Per Subsection () 262.34(a)(4) of Regulation No. 23, an LQG must develop and implement an Emergency Response Contingency Plan for the hazardous waste activities conducted at their facility. (Unless otherwise noted, all regulatory citations provided in this Plan pertain to Regulation No. 23.) 2.0 - PURPOSE AND SCOPE OF CONTINGENCY PLAN Per Regulation No. 23, 260.51, this Emergency Response Contingency Plan (the "Plan") for the Drumco facility in Arkadelphia was prepared to comply with 265, Subpart D, "Contingency Plan and Emergency Provisions", of Regulation No. 23. It establishes a set of specific, organized, planned, and coordinated actions to be followed to minimize hazards to human health or the environment that may result from: Fires or explosions, and; Any unplanned sudden or non-sudden release of a hazardous waste or hazardous waste constituent to the air, soil, or surface water. Per Regulation No. 23, 260.10, a "waste constituent" is a chemical substance identified by name as a listed hazardous waste (261, Subpart D) or a substance that exhibits a toxicity characteristic for hazardous waste (261.24). The provisions of this Contingency Plan will be carried out immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents at the Arkadelphia facility which could threaten human health or the environment. Per Regulation No. 23, 265.52(a)-(f), the Contingency Plan for Drumco includes the following components: The procedures that facility personnel will follow in the event of an emergency; The arrangements made with local and state emergency response agencies; The names, addresses, and phone numbers of all persons qualified to act as an Emergency Coordinator; A list of all emergency response equipment at the facility; and, An evacuation plan for plant personnel. Per Regulation No. 23, 265.53, a copy of Drumco's Contingency Plan and all revisions to the document must be: (a). Maintained at the Arkadelphia facility; and CLCM-ARKADELPHIA-000030 (b). Submitted to all local police departments, fire departments, hospitals, and state and local emergency response teams that may be called upon to provide emergency services. Per Regulation No. 23, 265.54, this Contingency Plan must be reviewed, and immediately amended, if necessary, whenever: (a). Applicable regulations are revised. (b). The Contingency Plan fails in an emergency. (c). The facility changes in its design, construction, operation, maintenance, or other circumstances in such a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents; or, the facility changes in such a way that changes the response necessary in an emergency. (d). The list of emergency coordinators changes. (e). The list of emergency equipment changes. The Contingency Plan for Drumco will be updated and/or revised on an as-needed basis. A record of revisions is provided as Appendix D. Telephone numbers for pertinent local, state and federal emergency response agencies and organizations is provided at the beginning of the Contingency Plan for handy reference in case of an emergency. 3.0 - OVERVIEW OF FACILITY OPERATIONS Drumco reconditions used steel drums and/or containers at the Arkadelphia facility. Used drums are accepted for recycling only if they have been certified by the supplier as being free of hazardous waste (i.e., "RCRA empty"). The drum reconditioning process is performed as follows: After removing the lids, the drums and lids are placed on a conveyor and then transported through a large natural gas-fired furnace. The thermal treatment process removes any paint and/or residue. The metal items are then visually inspected. Those drums and lids deemed suitable for reclamation are "shotblasted" to remove any residual dust or scale. After the shotblaster, the drums are processed mechanically to reform any dents and/or deformities, reseal the bottom bead, and test the structural integrity of the drums. The drums and lids are then sent to separate paint booths. The painted items are subsequently conveyed through natural gas-fired drying ovens. A paint dipping operation is also performed as part of the drum reclamation process. Drum rings are stacked, dipped in paint, and then allowed to air dry. Finally, the reconditioned and painted steel drums are loaded onto truck trailers. The finished products are then shipped to customers. Drumco is an LQG of hazardous waste. The company generates over 2,200 pounds of non-acute waste per month. The following RCRA-regulated wastes are handled at the Arkadelphia facility: Waste ash and residue from the drum furnace. This material is a characteristic hazardous waste for chromium (Environmental Protection Agency (EPA) waste code D007). Waste paint-related material. This material is a characteristic hazardous waste for ignitability (code D001). The paints may also be listed wastes due to the presence of non-halogenated solvents (codes F003 and F005). CLCM-ARKADELPHIA-000031 The waste ash and paint-related material are collected at several satellite accumulation points located throughout the production areas of the Arkadelphia facility. The wastes are stored in 55-gallon drums. The containers are subsequently moved to a <90-day waste storage area pending shipment off-site. Waste ash is also stored in a large roll-off box prior to shipment. The hazardous wastes are periodically shipped off-site to permitted RCRA facilities for treatment and/or disposal. A site map and plot map of the Arkadelphia facility is enclosed as Appendix A. 4.0 - EMERGENCY RESPONSE COORDINATOR Per Regulation No. 23, 265.55, the Emergency Coordinator for Drumco is responsible for coordinating all emergency response measures at the Arkadelphia facility. To accomplish this objective, this person is thoroughly familiar with: All operations and activities at the facility. The layout of the facility. The locations and characteristics of the wastes handled on-site. All aspects of the facility's Contingency Plan. The location of all pertinent records maintained at the facility. In addition, the Emergency Coordinator has the management authority to commit the resources needed to carry out the Contingency Plan. At all times, there must be at least one Drumco employee either on the facility premises or on-call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures. The primary Emergency Coordinator for Drumco, his alternates, and their telephone numbers are listed below: Primary Emergency Coordinator Russ Bryant Office: (870) 230-8800 Mobile: (501) 317-7152 Secondary Emergency Coordinator Kory Smith Office: (870) 230-8800 Mobile: (870) 403-3163 Tertiary Emergency Coordinator David Russell Office: (870) 230-8800 Mobile: (501) 317-0159 The specific steps to be taken by the Emergency Coordinator in the event of an actual or imminent emergency are described in Section 6.0. These actions are described in Regulation No. 23, 265.56. CLCM-ARKADELPHIA-000032 5.0 - COORDINATION OF EMERGENCY SERVICES Per Regulation No. 23, 265.53, an LQG is required to submit a copy of the Contingency Plan to all local police departments, fire departments, hospitals, and state and local emergency response teams that may be called upon to provide emergency services. (There is no requirement for an LQG to submit a copy of the Plan to the EPA Regional Office or the authorized state agency, in this case ADEQ.) Drumco has submitted copies of its Contingency Plan to various local and state emergency response agencies. They are identified below: Arkadelphia Fire Department Arkadelphia Police Department Arkansas Department of Emergency Management Arkansas State Police Clark County Sheriff's Office Clark County Office of Emergency Services Baptist Health Medical Center CHI St. Vincent Mercy Health Center Waste Services, Inc. Records of these submittals are kept on-site for reference. 5.1 - OVERVIEW OF FACILITY OPERATIONS Drumco reconditions used steel drums and/or containers at the Arkadelphia facility. Used drums are accepted for recycling only if they have been certified by the supplier as being free of hazardous waste (i.e., "RCRA empty"). The drum reconditioning process is performed as follows: After removing the lids, the drums and lids are placed on a conveyor and then transported through a large natural gas-fired furnace. The thermal treatment process removes any paint and/or residue. The metal items are then visually inspected. Those drums and lids deemed suitable for reclamation are "shotblasted" to remove any residual dust or scale. After the shotblaster, the drums are processed mechanically to reform any dents and/or deformities, reseal the bottom bead, and test the structural integrity of the drums. The drums and lids are then sent to separate paint booths. The painted items are subsequently conveyed through natural gas-fired drying ovens. A paint dipping operation is also performed CLCM-ARKADELPHIA-000033 as part of the drum reclamation process. Drum rings are stacked, dipped in paint, and then allowed to air dry. Finally, the reconditioned and painted steel drums are loaded onto truck trailers. The finished products are then shipped to customers. Drumco is an LQG of hazardous waste. The company generates over 2,200 pounds of non-acute waste per month. The following RCRA-regulated wastes are handled at the Arkadelphia facility: Waste ash and residue from the drum furnace. This material is a characteristic hazardous waste for chromium (Environmental Protection Agency (EPA) waste code D007). Waste paint-related material. This material is a characteristic hazardous waste for ignitability (code D001). The paints may also be listed wastes due to the presence of non-halogenated solvents (codes F003 and F005). The waste ash and paint-related material are collected at several satellite accumulation points located throughout the production areas of the Arkadelphia facility. The wastes are stored in 55-gallon drums. The containers are subsequently moved to a <90-day waste storage area pending shipment off-site. Waste ash is also stored in a large roll-off box prior to shipment. The hazardous wastes are periodically shipped off-site to permitted RCRA facilities for treatment and/or disposal. A site map and plot map of the Arkadelphia facility is enclosed as Appendix A. 6.0 - Emergency Procedures and Responsibilities The RCRA requirements for the emergency procedures to be implemented in the event of a hazardous waste-related incident are established in 265.56 of Regulation No. 23. The sitespecific procedures to be used at the Arkadelphia facility are described in this section of the Contingency Plan. All plant personnel are trained to immediately notify the Emergency Coordinator if they identify an actual or potential emergency involving hazardous wastes (or other materials). The Emergency Coordinator will then assess the situation and take appropriate action. (If he determines that no immediate threat exists, then the Emergency Coordinator will be responsible for ensuring that prompt corrective action is taken.) In the event of a release, fire, or explosion, the Emergency Coordinator will immediately identify the character, exact source, amount, and areal extent of any released materials through his familiarity with the operations and activities of the plant, the location of the incident, and the characteristics of the waste handled. He may do this by observation or review of Safety Data Sheets (SDSs), facility records and/or manifests and, if necessary, by chemical analysis. Concurrently, the Emergency Coordinator will assess possible hazards to human health or the environment that may result from the release, fire, or explosion. This assessment will consider both direct and indirect effects of the release, fire, or explosion (e.g., the effects of any CLCM-ARKADELPHIA-000034 toxic, irritating, or asphyxiating gases that are generated, or the effects of any hazardous surface water run-off from water or chemical agents used to control fire and heat-induced explosions). Whenever there is an imminent or actual emergency at the site, the Emergency Coordinator (or his designee when the Emergency Coordinator is on-call) will immediately: (1). Activate internal facility alarms or communication systems, where applicable, to notify all facility personnel; and (2). Notify appropriate state or local agencies with designated response roles if their help is needed. If the Emergency Coordinator determines that the facility has had a release, fire, or explosion which could threaten human health or the environment outside the facility, then he will report his findings as follows: (1). If his assessment indicates that evacuation of local areas may be advisable, then the Emergency Coordinator will immediately notify appropriate local authorities. He must be available to help appropriate officials decide whether local areas should be evacuated; and (2). He will immediately notify either the government official designated as the on-scene coordinator for that geographical area, or the National Response Center (using their 24-hour toll free number 800-424-8802). The report must include: (a). Name and telephone number of reporter; (b). Name and address of facility; (c). Time and type of incident (e.g., release, fire); (d). Name and quantity of material(s) involved, to the extent known; (e). The extent of injuries, if any; and (f). The possible hazards to human health, or the environment, outside the facility. During an emergency, the Emergency Coordinator will take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other hazardous wastes at the facility. These measures will include, where applicable, stopping processes and operations; collecting and containing released waste; and, removing or isolating containers. Other measures may include the use of water sprays to prevent heat build-up; the construction of dikes to prevent the spread of spills; and, solidification and/or pumping of any free liquids. If the facility stops operations in response to a fire, explosion or release, then the Emergency Coordinator will monitor for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment, wherever this is appropriate. Immediately after an emergency, the Emergency Coordinator will provide for treating, storing, or disposing of any recovered waste, contaminated soil or surface water, or any other material that results from a release, fire, or explosion at the facility. (Unless Drumco can demonstrate otherwise, the recovered material will be managed as a hazardous waste in accordance with all applicable requirements of 262, 263, and 265 of Regulation No. 23.) The Emergency Coordinator will ensure that, in the affected area(s) of the facility: CLCM-ARKADELPHIA-000035 (1). No waste that may be incompatible with the released material is treated, stored, or disposed of until cleanup procedures are completed; and (2). All emergency equipment listed in the Contingency Plan is cleaned and fit for its intended use before operations are resumed. The Emergency Coordinator (or other appropriate Drumco official) will note in the operating record for the facility the time, date, and details of any incident that required implementation of the Contingency Plan. Within 15 days after the incident, he will submit a written report on the incident to the Director of ADEQ. The report must include: (1). Name, address, and telephone number of the owner or operator; (2). Name, address, and telephone number of the facility; (3). Date, time, and type of incident (e.g., fire, explosion); (4). Name and quantity of material(s) involved; (5). The extent of injuries, if any; (6). An assessment of actual or potential hazards to human health where this is applicable; and (7). Estimated quantity and disposition of recovered material that incident. or the environment, resulted from the An incident reporting form is provided as Appendix C. In case of a spill or release at the Drumco facility, all efforts will be taken to contain and remediate any spilled materials as described in this Contingency Plan. The following actions will be taken: (1). If a spill occurs in a work area that personnel in that area or maintenance personnel can clean up safely with absorbents or other materials, then clean up may be performed. The Emergency Coordinator will be notified of any such occurrence in a timely fashion. (2). If a spill occurs on-site or off-site that is beyond the capabilities of facility personnel to handle (i.e., training, equipment, etc.), then the Emergency Coordinator will make notify the appropriate response personnel such as outside contractor(s), fire department, etc. Spill containment kits with various emergency response supplies are stored throughout the Arkadelphia facility (see Appendix B). These items include loose vermiculite, absorbent pads and socks, spark-proof shovels and scoops, and other supplies. These supplies are to be used to clean up and prevent the spread of spilled material. An inventory of the emergency response equipment at the Arkadelphia facility is provided below: CLCM-ARKADELPHIA-000036 Equipment Portable Fire Extinguishers B) Spill Containment Kits B) Telephones (Intercom and Paging) Radios Alarm System (Siren) Eye Wash Station A) First Aid Station Personal Office Protective Equipment Miscellaneous Supplies Location See Site Map (Appendix See Site Map (Appendix Offices (All Phones) Department Managers Office See Site Map (Appendix Office (PPE) Maintenance Office and Warehous 7.0 - Evacuation Per Regulation No. 23, 265.52(f), the Contingency Plan must include an Evacuation Plan for facility personnel where there is a possibility that evacuation could be necessary. It must describe the signal(s) to be used to begin evacuation, the evacuation routes, and the alternate evacuation routes (in cases where the primary routes could be blocked by releases of hazardous waste or fires). The Evacuation Plan for the Arkadelphia facility is summarized below: In the event of an emergency where evacuation is necessary, "Evacuate the Facility" will be sounded over the intercom and paging system three times. All facility personnel and visitors will be directed to the designated emergency exit in their area. In the event of an emergency in the hazardous waste storage area, the discovery person or personnel responding will contact the Area Supervisor, who will sound the siren alarm and notify the Emergency Coordinator. In the event of an emergency involving a fire where control is beyond the plant capabilities, "Fire, Call 911" will be sounded over the intercom and paging system three times. The fire department will then be notified by the operator. If power is interrupted and the paging system is rendered inoperable, then communications will be made by voice, bullhorn, air horn or radio with every effort made to notify affected personnel. Evacuation routes and emergency exits to be utilized during an emergency are identified on Attachment B. CLCM-ARKADELPHIA-000037 CLCM-ARKADELPHIA-000038 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000039 EMERGENCY ACTION PLAN Quick Reference Guide KNOW YOUR SPACE Locate the AED, first aid cabinet, and fire extinguisher. Identify the safest space in your building in case of and active shooter or weather event. Know the emergency coordinator and the building address. Familiarize yourself with the locations of Stairwells, entry and exit points. COMMUNICATION All emergency coordination will be done via radio. MEDICAL EMERGENCIES Call 911. Know the address to the facility. ACTIVE SHOOTER Determine the best way to protect yourself: run, hide, fight. Find a room that is lockable if possible. Barricade the door once inside the room. Close the blinds and turn out the lights. Stay away from doors and windows. Call 911 Remain in place until the police give all clear. BOMB THREATS If a suspicions package is observed, do not touch it. Evacuate the building and call 911. If someone call with a bomb threat, write down the information and call 911 to report it. FIRE If the fire is small enough, locate a fire extinguisher and use the PASS method o Pull the pin o Aim a the base of the fire o Squeeze the trigger o Sweep the spray from side to side. The call for a fire evacuation will be done via radio. Ask one person to call 911. Exit the building through the closest door. Meet at the established rally points. Take roll. Do not re-enter the building until the fire department has determined that it is safe. WEATHER Tornado o When it is determined that a tornado is likely, the command to go to the weather shelter will be given by radio. CLCM-ARKADELPHIA-000040 CLCM-ARKADELPHIA-000041 ATTACHMENT D PUBLIC CLCM-ARKADELPHIA-000056 CLCM-ARKADELPHIA-000057 CLCM-ARKADELPHIA-000058 CLCM-ARKADELPHIA-000059 CLCM-ARKADELPHIA-000060 CLCM-ARKADELPHIA-000061 CLCM-ARKADELPHIA-000062 CLCM-ARKADELPHIA-000063 CLCM-ARKADELPHIA-000064 CLCM-ARKADELPHIA-000065 CLCM-ARKADELPHIA-000066 CLCM-ARKADELPHIA-000067 CLCM-ARKADELPHIA-000068 CLCM-ARKADELPHIA-000069 ATTACHMENT E PUBLIC CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000082 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000084 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000085 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000086 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000087 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000088 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000089 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000090 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000091 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000092 CONTAINS CONFIDENTIAL BUSINESS INFORMATION CLCM-ARKADELPHIA-000093 ATTACHMENT F CLCM-ARKADELPHIA-000094 CLCM-ARKADELPHIA-000095