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f t E A ~ United States
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Environmental Protectior
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Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
03/06/2026 RCRA Generator
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Kiwo Inc. Kiwo 1929 Marvin Circle Seabrook, TX, 77586 Same Same Harris (281) 474-9777 Joe Nuding Email: joen@kiwo.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110063203297 TXR000084078 TCEQ SWR # 96625 323113, 325612, 325998 None
Personnel participating in inspection:
Bill Mansfield
US EPA Region 6
Joe Nuding
Kiwo, Inc.
I I Title: Plant Manager
Inspector Plant Manager
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
WILLIAM MANSFIELD
Bill Mansfield
Digitally signed by WILLIAM MANSFIELD Date: 2026.04.16 12:43:12 -05'00'
Date
DEB RA PAN DA K Digitally signed by DEBRA PANDAK
Date: 2026.04.16 13:00:27 -05'00'
-
Debra Pandak
Date
6ENFORM-019-R9 (02/27/2025)
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Kiwo Inc. 1929 Marvin Circle Inspection Date 03/06/2026
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION I, Bill Mansfield, EPA Region 6 inspector arrived at Kiwo at 8:56AM on 03/06/2026 for an announced inspection. I met with Joe Nuding the Plant Manager. I presented my credentials to Joe and informed him that this was an EPA inspection to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA). The scope of the inspection is a Compliance Evaluation Inspection (CEI) and includes evaluation of the facility's hazardous waste management activities.
FACILITY DESCRIPTION Kiwo's 1929 Marvin Circle location manufactures chemical products for screen making and specialty adhesives, offering a complete line of screen making products including photo-emulsions, CLEANLINE for environmentally safe screen cleaning, specialty screen printable adhesives, KIWOMAT high precision coating machines and Computer-To-Screen equipment. The facility has approximately 27 employees. The EPA ID TXR000084078 associated with the address of 1929 Marvin Circle was last registered in RCRAinfo in February of 2026 and indicates that Kiwo operates as a Very Small Quantity Generator (VSQG).
Section II - OBSERVATIONS During the opening conference the plant manager said the photo emulsion products process generates non-hazardous waste and ink cleaner products produced will sometimes generate hazardous waste. The plant manager also said a third party (Slick Response) handles waste characterization and chemists on-site also help to make waste determinations. Slick Response also handles pick up and disposal for the facility per the plant manager. Production and Storage Warehouse: Walking in the production and storage warehouse (Appendix 1, Photos 3 and 4) I observed a wash area that is used to wash photo emulsion residue out of equipment from the production line (Appendix 1, Photo 2). Per the plant manager the waste generated is non-hazardous and the sump is emptied and hauled off by Specialized Waste Services (now TAZ). I then observed a second wash area that is used for washing mixing equipment and per the plant manager the drain goes directly to the sewer (Appendix 1, Photos 5). Diazoe Room: Inside the warehouse is small room called the Diazoe Room. I observed a drum of expired product (Hardwater Diazoe) (Appendix 1, Photo 6). The plant manager said they cannot use it if it's expired and they would need to get it disposed of.
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Kiwo Inc. 1929 Marvin Circle Inspection Date 03/06/2026
The Deck:
This was an upstairs area in the warehouse. The Deck is used for storing products used in the production process and includes a small area on one side to store waste, and a separate room with new and spent lamp bulbs. The waste storage area is divided into two sections, the section on the left in Photo 9 of Appendix 1 is labeled as non-hazardous waste storage and the section on the right in Photo 9 of Appendix 1 is labeled as hazardous waste storage. I observed 3 drums labeled hazardous waste in the waste storage area and per the plant manager, the drums held off-spec product that may still be used in their process, and the labels were placed on the drums to keep employees from using them by mistake (Appendix 1, Photos 8, 9, and 11). Please note that Photo 11 of Appendix 1 is a side photo of the 2 drums on the right in Photo 9 of Appendix 1 and was taken to show the hazardous waste labels that could not be seen from the front. In the separate room on the Deck, I observed lamp bulbs and per the plant manager the bulbs on the shelf are new and the bulbs in the white box are spent. The white box of universal waste lamp bulbs was not labeled (Appendix 1, Photo 10).
Section III - AREAS OF CONCERN
I observed the following Areas of Concern (AOCs):
AOC 1 - Drums labeled hazardous waste on "The Deck". No regulatory requirement,
however a drum that is determined to be off-spec product and still able to be used in the production process, labeled as hazardous waste, is confusing when assessing compliance with hazardous waste management regulations.
AOC 2 - Box of universal waste lamp bulbs without label. Pursuant to 40 C.F.R. 273.14(e),
Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)".
AOC 3 - Drum of expired hardwater Diazoe in the Diazoe room. Pursuant to 40 C.F.R.
262.11, A person who generates a solid waste, as defined in 40 CFR 261.2, must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.
CLOSING CONFERENCE
The closing meeting was attended by me, Bill Mansfield (EPA Inspector), and Joe Nuding (Plant Manager). During the closing conference, I reviewed the 3 AOCs noted during the inspection, fielded questions from facility personnel, and provided information about the next steps in the inspection process.
Section IV - FOLLOW UP
EPA is awaiting the following requested information from the facility:
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1. SDSs for all chemicals (products). 2. POTW permit from City of Seabrook. 3. Hazardous waste determinations for all waste streams.
Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 11 photos taken 03/06/2026
Kiwo Inc. 1929 Marvin Circle Inspection Date 03/06/2026
4
Kiwo 1929 Marvin Circle Inspection Date(s) 03/06/2026
Appendix 1 Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 1
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0875.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: S Time: 10:20:44 NA
Description: Production and storage warehouse. Facility refers to the building as 1929.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 2
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0876.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: E Time: 10:23:31 NA
Description: Process vat wash area. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 3
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0877.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 10:38:09 NA
Description: Production floor. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 4
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0878.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 10:38:18 NA
Description: Raw material and finished goods. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 5
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0879.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 10:42:52 NA
Description: Wash area goes to sewer. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 6
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0880.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 10:57:30 NA
Description: Drum of expired Diazoe. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 7
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0881.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 11:07:11 NA
Description: Raw material container. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 8
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0882.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 11:08:47 NA
Description: Drum of material that could still be used labeled as hazardous waste.
Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 9
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0883.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 11:10:42 NA
Description: Waste storage area. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 10
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0884.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: Time: 11:30:34 NA
Description: Universal waste not labeled. Latitude: N/A
Longitude: N/A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Appendix 1
Facility/Location:
Photo No. 11
Kiwo 1929 Marvin Circle
City: Seabrook
County: Harris
Filename: TWC_0885.JPG
Photo Date:
Photographer: Bill Mansfield
State: TX 03/06/2026
Witness Name:
Direction: N Time: 11:32:20 NA
Description: Drums of off spec material that could still be used, labeled as hazardous waste.
Latitude: N/A
Longitude: N/A