Document YrrQEYjmqp1kn2DEjzeM4xMnN

US Environmental Protection Agency - Region 2 Caribbean Environmental Protection Division Response and Remediation Branch Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection Facility Name: EPA ID Number: Date of Inspection: Generator Status in Record: Generator Status at the time of inspection: RCRA Permitted: Basis for Inspection: Corrective Action: Project ID University of Puerto Rico Mayagez Campus PRD000691063 March 8 - 10, 2023 Non-Generator (Federal & State) SQG No Core Program No CEPD-RCRA-23-0440 Facility Physical Location: (Municipality, PR, zip code) Geographical Coordinates: Facility Owner: Facility Operator: 259 Norte Boulevard Alfonso Valds Cobin, Mayagez, Puerto Rico 1812'32.95"N, 67 8'29.36"W Ms. Maria Isabel Fernndez, Health, (787) 832-4040 ext. 3022, 3506, 3886 Occupational and Environmental Safety (787) 349-4791 (mobile) Office Director maria.fernandez11@upr.edu Mailing address: P.O. Box 9000 Mayagez, P.R. 00681-9000 Ms. Damaris Santiago, Health, Occupational (787) 832-4040 ext. 3221, 3506 and Environmental Safety Specialist Damaris.santiago1@upr.edu Mailing address: P.O. Box 9000 Mayagez, P.R. 00681-9000 NAICS: 611310 - Colleges, Universities, and Professional Schools SIC: 8221 Colleges, Universities, and Professional Schools Area: 315 acres of land property Number Employees: 13,316 Students, 1,181 Regular Staff Members and 625 Members of the Educational Staff Personnel participating in inspection: Eduardo R. Gonzalez EPA Region 2-CEPD Enforcement Officer (787) 977-5839 gonzalez.eduardo@epa.gov Khrystian Vazquez EPA Region 2-CEPD Enforcement Officer (787) 977-5860 vazquez.khrystian@epa.gov Status: Final Record Schedule: 1044(c) Multi-media Checklist: ATTACHMENT # N/A Referral: No EPA Lead Inspector Signature/Date X May 20, 2023 1 Supervisor Signature/Date Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 X Da vid N . Cueva s M ira nd a , Ph.D. May 20, 2024 1 INTRODUCTION On March 8 thru 10, 2023, a Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection (the "Inspection") was conducted at University of Puerto Rico-Mayagez Campus (the "Facility" or "UPR Mayagez Campus"), pursuant to Section 3007 of RCRA. The Facility is located on 259 Norte Boulevard Alfonso Valds Cobin, Mayagez, Puerto Rico. As part of the Inspection, an opening meeting, walkthrough, documents review and closing meeting were conducted to evaluate Facility's compliance with the requirements that govern hazardous waste generators, universal waste handlers and used oil generators as per RCRA. UPR Mayagez Campus is designated in the RCRAInfo1 database as a "Non-Generator of Hazardous Waste" as notified to EPA on January 1, 2008. However, UPR Mayagez Campus has never formally notified EPA that the Facility manages laboratory wastes as an eligible college or university under 40 Code of Federal Regulations (CFR) Subpart K - "Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities." Furthermore, according to EManifest data, UPR Mayagez Campus had been generating hazardous waste as a Large Quantity Generator (LQG) at the time of this inspection. According to EPA's RCRA Info and ECHO records, one full Clean Air Act inspection (one-Federal) was conducted on March 9, 2005, as an Operating Minor Source Emission (PR0000007209710000) and no violation were identified at the Facility. One RCRA Inspection (one-Federal) was conducted at the Facility on March 9 thru 18, 2005, in the areas of general generator requirements of hazardous wastes, and violations were found in areas of 40 CFR 262.11- "Hazardous Waste Determination and Recordkeeping," 40 CFR Part 270.1(c) - "Storage of Hazardous Waste Without a Permit, "40 CFR 265.173(a), 40 CFR 265.171- "Failure to Keep Hazardous Waste Containers Closed and Failure to Store Hazardous Waste Containers in Good Condition," 40 CFR 265.31-"Failure to Minimize Risks," 40 CFR 265.16 - "Failure to Provide Personnel with Hazardous Waste Training," 40 CFR Part 265 Subparts C and D- "Failure to Have a Contingency Plan/Failure to Make Arrangements with Local Authorities," 40 CFR 279.22(c)(1) - "Failure to Label or Mark Clearly Containers with the Words "Used Oil Containers," 40 CFR 262.40(a) - "Failure to Keep a Signed Generator Copy for Manifests," 40 CFR 262.42(a)(1) - "Failure to Contact Transporter or Owner or Operator of the Designated Facility for each Manifests," and, 40 CFR 262.42(a)(2) - "Failure to File an Exception Report for each Manifest." On September 30, 2005, EPA issued a Complaint, Compliance Order, and Notice of Opportunity for Hearing (Docket No. RCRA-02-2005-7115) against UPR Mayagez Campus. The Complaint alleged that UPR had violated requirements of RCRA and regulations concerning the handling and management of hazardous waste at 1 RCRA Info and ECHO, EPA's Enforcement Compliance and History Online System Status: Final 2 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 its Mayagez Campus, Puerto Rico. Based on the multiple violations and pursuant to the authority of Section 3008(a)(3) of RCRA, 42 U.S.C. 6928(a)(3), and the RCRA Civil Penalty Policy, EPA proposed a civil penalty in the total amount of $908,469 for the RCRA violations On August 16, 2006, EPA and UPR Mayagez Campus entered into a Consent Agreement and Final Order (CA/FO) to settle the RCRA violations identified EPA's Complaint. As stated in the Complaint, EPA found that Mayagez Campus failed to operate its Facility in a manner that would minimize the risk of releasing hazardous wastes into the environment. It was storing containers of hazardous waste in several buildings and open areas on campus that were leaking, open or mislabeled. The containers held wastes ranging from used oil, various acids and spent solvents to formaldehyde. Mayagez Campus was also storing hundreds of containers of old and expired chemicals, such as picric acid, in an unsafe manner. The investigation determined that the university also had failed to properly determine which of the wastes they generate are hazardous wastes. The Facility never put plans into place with local emergency response managers to respond to a chemical spill or incident on campus. In addition, UPR Mayagez Campus didn't comply with the conditions and regulations necessary to qualify for permit exemptions. EPA ordered UPR Mayagez Campus to fix leaking containers, place wastes in closed containers, properly label and store wastes and put into place a plan with local emergency response managers within 30 days. EPA has given the university one month to set up a system to determine which wastes it generates campus wide are hazardous and to ship this off campus for proper disposal in a timely manner. Also, under the CA/FO, UPR Mayagez Campus had three months to obtain permits to accumulate and store hazardous waste, or alternatively, to meet the conditions for an exemption from permit requirements. As part of the EPA Complaint, UPR Mayagez Campus proposed a Supplemental Environmental Project (SEP) as part of the settlement negotiation process related to the findings of the EPA Inspection. The proposed SEP was an Environmental Management System (EMS) with the main goal of reducing the impact of the chemical substances and materials used at campus to fulfill its academic mission, and to promote source reduction, pollution prevention and compliance promotion awareness, and activities. The focus of the EMS was hazardous chemicals and wastes, although universal wastes and electronic equipment were also be managed. According to the record, the EMS program was implemented until May 2018, when UPR Mayagez Campus decided to implement a Laboratory Management Plan (LMP) to standardize the management of hazardous waste materials regulated under RCRA in accordance with the regulation provided by 40 CFR 262 Subpart K with respect to its laboratories, as an alternative to complying with the requirements of 262.11 - "Hazardous Waste Determination and Recordkeeping," and 262.15 - "Satellite Accumulation Area Regulations for Small and Large Quantity Generators." Additionally, before EPA Inspection, UPR Mayagez Campus submitted self-disclosures under EPA's Audit Policy whereby the university self-disclosed possible violations of federal hazardous waste, clean water, and clean air laws. EPA normally would grant relief from financial penalties for self-disclosed violations, but it was determined that UPR Mayagez Campus was not eligible for full relief because it was not correcting all its violations. As a result, EPA conducted its own comprehensive inspection of the campus, and found numerous violations proposing a $908,469 fine for these violations. Status: Final 3 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 2 OPENING MEETING (DAY 1- MARCH 8, 2023) On March 8, 2023, an opening meeting was held between Ms. Maria Isabel Fernndez, Health, Occupational and Environmental Safety Office Director, and Ms. Damaris Santiago, Health, Occupational and Environmental Safety Specialist both from UPR Mayagez Campus, Khrystian Vazquez, EPA RCRA Inspector, and me. We identified ourselves as EPA RCRA Enforcement Officers and told the Facility representatives that the purpose of my visit was to conduct a RCRA Inspection at the Facility to evaluate its hazardous waste management practices and compliance. I discussed the objectives of my inspection, and the requirements under RCRA for a Small or Large Quantity Generator (SQG or LQG). We asked Ms. Fernndez to provide us for review UPR Mayagez Campus' manifests (last three years), and land disposal records regarding the handling, transportation, and final disposal of hazardous waste generated, and stored at the campus. We also asked for review the waste analysis plan, weekly inspection records, personnel training requirements, biennial report, waste minimization plan, closure plan, contingency and emergency and preparedness plan, Used Oil manifests, and RCRA air emission requirements under 40 CFR 265 Subparts AA, BB & CC certification reports. Ms. Fernndez stated that UPR Mayagez Campus does not have to comply with Subparts AA, BB & CC of RCRA requirements, since the only area that might apply is in the hazardous waste containers storage area. However, the Facility is classified as a Small Quantity Generator. She added that containers holding volatile organic wastes were provided by Capitol Environmental Services Inc. and they were contained cover and manufactured tested seals in accordance with the Department of Transportation (DOT) (49 CFR 178 - Specifications for Packagings) requirements, and the United Nations (UN) Performance Oriented Packaging Standards. In addition, UPR Mayagez Campus' container management practices (transferring, storing, and stacking) are provided to prevent of volatile air emissions in a well vented and controlled storage areas. Based on a review of electronic manifests, it was estimated that approximately over 2,200 pounds of hazardous waste are generated at the Facility monthly and disposed of with Capitol Environmental Services, Inc. every six months. I was told by Ms. Fernndez that there are one Central Accumulation Area (CAA) for collection of all hazardous waste containers in the campus and various hazardous waste satellite accumulation areas (SAA) for the management of hazardous wastes in the academic laboratories. Ms. Fernndez stated that the UPR Mayagez Campus has chosen an alternative generator regulation for managing hazardous waste in academic laboratories in accordance with the regulation provided by 40 CFR 262 Subpart K - "Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities," with respect to its laboratories, as an alternative to complying with the requirements of 262.11 and 262.16. She also explained that the UPR Mayagez Campus as an eligible academic entity has developed the 20182020 Laboratory Management Plan (LMP) in accordance with 262.214 that describes how the laboratories at the campus will comply with the requirements of Subpart K. During the inspection, Ms. Fernndez informed EPA Inspectors about a pipe break that supplies raw water to the Bo. Filter Plant located in Miradero, Mayagez. This plant supplies water to most of the Status: Final 4 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Mayagez City, as well as neighboring towns such as Hormigueros, Aasco, Cabo Rojo and Rincn. According to the Puerto Rico Aqueducts and Sewers Authority (AAA) the estimated repair time would be 48 hours. The UPR Mayagez Campus did not have drinking water service since the morning of March 8, 2023, which is the reason why the University Administration determined that classes on the afternoon of March 8, 2023, would be offered on-line via remote technology as well as in the March 9 and 10, 2023. Campus Administration also determined that staff should not report to work on March 9, 2023. This information was shared with EPA Inspectors who decided to continue with the Inspection. 2.1 LABORATORY MANAGEMENT PLAN (LMP) Ms. Fernndez stated that the 2018-2020 Laboratory Management Plan (LMP) was developed to standardize the management of "hazardous" materials discarded at the laboratories at UPR Mayagez Campus that are regulated under RCRA in accordance with the regulation in 40 CFR 262 Subpart K as an alternate process for academic institutions to manage their hazardous wastes. It must be noted that this process differs from the one originally established by RCRA for the industrial generators of hazardous waste. Referring to 2018-2020 Laboratory Management Plan, Ms. Fernndez explained the protocols in place for the management of hazardous waste generated at the academic laboratories. She also stated which laboratories were covered by LMP which included chemical stockrooms that do not support laboratories, vehicle maintenance areas, machine shops, print shops, academic photo processing. As discussed in the opening meeting, EPA Inspectors would adhere to the procedures contained in the LMP to conduct the RCRA Inspection as described below in the academic program. 2.1.1 Container Labeling Referring to the 2018-2020 Laboratory Management Plan (LMP), UPR Mayagez Campus has decided to use the definition of "Unwanted Materials" to all chemical substances that are expired, used, or generated due to experiments unless determined otherwise by the laboratory worker, or until a formal determination is performed by the UPR Mayagez Campus Environmental, Health and Safety Office (OSSOA). It is also established in the LMP that all containers used to store "Unwanted Materials" must be labeled with the following information: The words "Unwanted Material" Contents of the container (chemical materials in the container and quantity) Accumulation start date Status: Final 5 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 It will be the responsibility of the laboratory worker within the laboratory to prepare the label and verify that labels are placed on all containers of unwanted material stored in the laboratory. Containers will not be removed from a laboratory unless the "CHEMATIX"2 label the is attached to the container. 2.1.2 Method of Removal of Unwanted Material Referring to the 2018-2020 Laboratory Management Plan (LMP), unwanted materials shall be removed from the laboratory using a rolling 6-month approach, that is, each container will be removed within 6 months from the container's accumulation start date. OSSOA personnel will remove unwanted materials from a laboratory after the laboratory places a request for removal through the Chematix system. Chematix may be used to monitor whether removal of unwanted materials from a laboratory may be necessary. Furthermore, a laboratory will not accumulate more than 55-gallons of unwanted materials. It is the laboratory's responsibility to comply with all OSSOA requirements, including appropriate labeling, use of correct containers, and notification time. If a laboratory accumulates a total volume of unwanted material more than 55-gallons, all containers of unwanted material in the laboratory: Will be removed from the laboratory within 10 calendar days of the date that 55-gallons were exceeded. If a laboratory accumulates more than 1-quart of any of the 6 P-listed reactive acutely hazardous unwanted materials, all containers of reactive acutely hazardous unwanted material: Must be removed from the laboratory within 10 calendar days of the date that 1-quart was exceeded. To ensure compliance with this requirement, the 6 P-listed reactive acutely hazardous unwanted materials are: P006 - Aluminum phosphide P009 - Ammonium picrate P065 - Mercury fulminate P081 - Nitroglycerine P112 - Tetranitromethane P122 - Zinc phosphide (> 10%) Laboratories that generate more than 55-gallons of unwanted materials or 1-quart of reactive acutely unwanted materials will need to request removal of the waste from the laboratory at the moment that the 55-gallons or 1-quart volume of unwanted material is reached. The laboratory worker assigned to each generation point will be responsible to comply with all requirements established by OSSOA. 2 CHEMATIX is a chemical management software, capable of tracking chemicals from point of entry as inventory to point of exit as waste, as well as every point in between, providing a robust environment in which to track substances and maintain compliance with all governmental regulations. Status: Final 6 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Once the unwanted materials are removed from the laboratory by a trained professional, the hazardous waste determination will be made on the Central Accumulation Area (CAA) within four days of the unwanted materials arriving at this location. All RCRA applicable requirements for small quantity generators including those on 40 CFR 262.34(d), 262.34(f) and 40 CFR 265 Subpart I will be observed in the CAA. The removal of unwanted materials from a laboratory is different from a laboratory clean-out procedure. The clean-out process can only be implemented once a year per laboratory or generation area. 2.1.3 Making Hazardous Waste Determination Referring to the 2018-2020 Laboratory Management Plan (LMP), unwanted materials will be moved only by OSSOA authorized personnel to the Central Accumulation Area (CAA). Once the unwanted material is moved to the CAA, the hazardous waste determination will be made within four days of the material arriving at the CAA. Within this four-day time frame, OSSOA personnel would determine if the material is eligible for re-use, recycling or will be handled as a nonhazardous waste. After the hazardous waste determination is made, all applicable requirements in the CAA will continue to apply and be observed as usual. Unwanted materials removed from the laboratories to the CAA must be identified with its removal date. 2.1.4 Laboratory Clean Out Procedures Referring to the 2018-2020 Laboratory Management Plan (LMP), performing a Laboratory Clean Out procedure is not mandatory and will be directly influenced by the availability of funding to carry out a clean out. OSSOA will evaluate the laboratory inventory of chemicals and other materials which are no longer needed or that have expired, in order to determine the subsequent removal of those chemicals or other unwanted materials. Conducting a clean out will be considered for one of the following reasons, it may be on a routine basis (e.g., at the end of a semester or academic year) or as a result of a renovation, relocation, or change in laboratory supervisor/occupant. The clean out process allows for the redistribution of the chemicals. If a laboratory worker makes a determination that a chemical can be used in another laboratory, it would be considered a product and thus not regulated under RCRA. However, if such determination is made after it is removed from the laboratory, the clean-out chemical would be regulated as an unwanted material until it is redistributed from the CAA to another laboratory for further use. Clean outs will only be performed once every twelve (12) months per laboratory. At the conclusion of the laboratory clean-out, all unwanted materials must be removed from the laboratory. 2.1.5 Emergency Prevention Referring to the 2018-2020 Laboratory Management Plan (LMP), to ensure a quick response in case of an emergency occurring in a UPRM laboratory, emergency contact information will be posted in every laboratory near the laboratory phone. This list will include contact information for both emergency responders on campus and off campus. Evacuation routes will also be posted in every laboratory. Status: Final 7 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Ms. Fernndez provided us with a list of active laboratories at the UPR Mayagez Campus that have been chosen to manage hazardous waste in academic laboratories in accordance with the regulation provided by 40 CFR 262 Subpart K as depicted in Table No. 1 below. Table No. 1 - LMP Active Laboratories Under 40 CFR 262 Subpart K Building # / Building Name Alfredo Ramrez de Arellano y Rosell Alfredo Ramrez de Arellano y Rosell Alfredo Ramrez de Arellano y Rosell Room # CTA-220 CTA-219 CTA-223 Lab Name Food Chemistry Research Lab CTA-220 Food Microbiology CTA-219 Storage Room CTA-223 473 /Mechanical Engineering 473 /Mechanical Engineering 473 /Mechanical Engineering 473 /Mechanical Engineering 473 /Mechanical Engineering L-004 L-123 L-123 L-126 L-240 Research Lab L-004 Research Lab L-123 A Research Lab L-123 B Research Lab L-126 Research-Teaching Lab L-240 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 /Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero Status: Final 8 AD-PLA AP-003 AP-100 AP-102 AP-103 FALZ-001 FALZ-012 FALZ-02 FALZ-07 I-LAB I-PLA JD-LAE JD-PLA L-PLA P-002 P-010B P-014A P-014A P-018 P-108 P-112 P-114 P-119 P-121 Adjuntas - Almacen Research Lab AP-003 Entomology Lab Fito-pathology Lab Nematology Lab Doctoral Lab - 001 Quarantine Lab - Francisco Sein Research Lab FALZ-02 Lab BNF Isabela - Laboratory Isabela - Plaguicidas Juana Diaz - Lab Entomologiy Juana Diaz - Plaguicidas y Abonos Lajas - Almacen de Plaguicidas Research Lab P-002 Research Lab P-010B Animal Biotechnology (*) Research Lab P-014A Explosives Storage Room P-018 Teaching Laboratory Research Lab P-112B Research Lab P-114 Research Lab P-119C Research Lab P-121 interior CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero 479 / Agricultural Sciences Faculty - Jesus T. Pinero P-209 RP-FDS RP-IBIOL RP-LCA RP-LCAS RP-LQA RP-V, BM Research Lab P-209 Soil Physics Lab Research Lab - Biology Laboratorio Central Analitico RP-Lab Calidad de Agua y Suelos RP-Lab Quimica-Agroambiental Lab Virologia y Biologia Molecular 490 / Luis Stefani / Engineering 490 / Luis Stefani / Engineering 490 / Luis Stefani / Engineering 490 / Luis Stefani / Engineering 490 / Luis Stefani / Engineering 490 / Luis Stefani / Engineering S-101 S-106 S-110 S-214 S-311 S-314 Research Lab S-101 Research Lab S-106 Research Lab S-110 Biomedical Instrumentation Research Lab Teaching Lab S-311 Research Lab S-314 733 / Civil Engineering 733 / Civil Engineering CI-018 CI-018 Environmental Engineering Research Lab CI-008 Dr. Carlos Ramirez 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 734 / Chemical Engineering 101-A 101-A 101-A 101-A 101-B 101-B 101-H 101-I 101-J,K 101-J,K 101-K 101-M 101-M 101-N 101-O 102-A,B 102-A,B 102-A, B 102-E, D 103-A 103-A-1 104-A Research Lab 101-A Research Lab 101-A M. Domenech Research Lab 101-A M. Latorre Research Lab 101-A M. Torres Research Lab 101-B Research Lab 101-B (D. Suleiman) Research Lab 101-H, I Inactive Research Lab 101-J Storage - Dr. Nelson Cardona Research Lab 101-K Research Lab 101-M Research Lab 101-M (Acevedo) Research Lab 101-N Research Lab 101-O Research Lab 102-A, B Research Lab 102-A, B (L. Saliceti) Research Lab 102-A, B (P. Ortiz) Research Lab INQU-102-E, D Chemical Analysis Lab 103-A Research Lab 103-A Research Lab 104-A 816 / Chemistry 816 / Chemistry Status: Final Q-007 Q-008 9 Storage Room Flammables Q-008 CEPD-RCRA-23-0440 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry Status: Final Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Q-009 Q-011 Q-023 Q-027 Q-030 Q-031 Q-042 Q-046 Q-048 Q-050 Q-051 Q-058 Q-058 Q-059 Q-106 Q-108 Q-110 Q-112 Q-116 Q-155 Q-157 Q-159 Q-161 Q-161 Q-163 Q-165 Q-205 Q-205 Q-207 Q-207 Q-209 Q-211 Q-213 Q-215 Q-228 Q-230 Q-238 Q-240 Q-256 Q-258 Q-266 Q-268 Q-277 10 Preparations Laboratory Science on Wheels Educational Center Research Lab Q-023 Natural Products Lab Q-027 Lab Q-030 Environmental Analytical Group Molecular Spectroscopy II Lab Q-042 Physical Chemistry Lab Q-046 Molecular Spectroscopy Lab Q-048 Physical-Chemistry Q-050 Teaching Lab Q-051 Acids Q-058 Solids Q-058 Explosives Research Lab Q-106 Teaching Lab Q-108 Inorganic Chemistry Lab Q-110 Bio-inorganic Lab Q-112 Bio-inorganic Lab Q-116 Surface and Materials Research Lab Q-155 Surface and Materials Research Lab Q-157 Research Lab Q-159 Research Lab Q-161 Research Lab Q-161 - Jose Cortes Research Lab Q-163 Research Lab Q-165 Agronomy and Soils Lab Q-205 Agronomy ans Soils II Q-205 Agronomy and Soils II Q-207 Agronomy and Soils Q-207 Research Lab Q-209 Research Lab Q-211 Organic Research Lab Q-213 Research Lab Q-215 General Chemistry Q-228 General Chemistry Q-230 General Chemistry Conc. General Chemistry Conc. Q-240 General Chemistry Q-256 General Chemistry Q-258 General Chemistry Q-266 General Chemistry Q-268 Research Lab Q-277 CEPD-RCRA-23-0440 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 816 / Chemistry 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology Status: Final Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Q-279 Q-282 Q-284 Q-286 Q-305 Q-307 Q-309 Q-311 Q-313 Q-315 Q-328 Q-330 Q-338 Q-340 Q-354 Q-356 Q-356 Q-364 Q-366 Q-375 Q-377 Q-379 Q-381 Q-383 Q-385 Natural Products Lab Q-279 Natural Products Lab Q-282 Natural Products Lab Q-284 Natural Products Lab Q-286 Research Lab Q-305 Research Lab Q-307 Biochemistry Teaching Lab Q-309 Medicinal Chemistry Lab Q-311 Research Lab Q-313 Organic Chemistry Lab Q-315 3462,64 Organic Chemistry Q-328 3462, 64 Organic Chemistry Q-330 Analytical Chem for Eng Te Q-338 Anal Chem for Eng Q-340 Anal Chem Q-354 Analytical Chem Lab Q-356 Inorganic Chem Teaching Lab Q-356 Teaching Lab Q-364 Organic Chemistry Teaching Lab Q-366 Research Lab Q-375 Biochemistry Lab Q-377 Research / Teaching Lab Q-379 Research Lab Q-381 Electrochemistry Lab Q-383 Research Lab Q-385 B-020 B-026 B-073 B-087 B-089 B-120 B-123 B-133 B-137 B-148 B-148 B-218A B-218B B-220 B-230 B-241 B-257 11 Teaching Lab B-020 Microscopy Research Lab B-026 Biotechnology B-073 Specimen Room B-087 Storage Room B-089 Teaching Lab B-120 General Biology Lab B-123 Teaching Lac B-133 Parasitology Lab B-137 Research Lab B-148 a Research Lab B-148 b Mycology Lab B-218A Research Lab B-218B Genetics Lab B-220 Research Lab B-230 Microbiology Lab B-241 Research Lab B-257 CEPD-RCRA-23-0440 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 819 / Biology 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics 700 / Physics Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 B-258 B-266 B-282B B-322 B-329A B-331 B-337 B-348 B-351 B-360 Mycology Lab B-258 Microbiology Lab B-266 Research Lab B-282B Research Lab B-322 Immunology Teaching Lab B-329A Research Lab B-331 Microbial Ecology Lab B-337 Virology / Molecular Genetics Lab B-348 Virology Lab B-351 Mycology Lab B-360 F-103 F-105 F-107 F-117C F-125E F-129 F-225 F-305 F-316 F-431 F-458 Research Lab F-103 Research Lab F-105 Research Lab F-107 Research Lab F-117C Research Lab F-125E Research Lab F-129 Lab F-225 Research Lab F-305 Lab F-316 Research Lab F-431 Lab F-458 2.2 FACILITY PHYSICAL DESCRIPTION AND OPERATION The University of Puerto Rico was created by an act of the Legislative Assembly on March 12, 1903, emerging as an outgrowth of the Normal School, which had been established three years earlier to train teachers for the Puerto Rican school system. In 1908, the benefits of the Morill-Nelson declared applicable to the island, forested the rapid growth of the University. Evidence of that growth was the establishment of the College of Liberal Arts at Rio Piedras in 1910 and the College of Agriculture at Mayagez in 1911. The University of Puerto Rico is a well-established and mature institution, with a total enrollment of over 69,000 students. The University consists of the Mayagez Campus, the Medical Sciences Campus, and the Rio Piedras Campus, which are dedicated to both undergraduate and graduate education; and the Colleges at Aguadilla, Arecibo, Bayamon, Carolina, Cayey, Humacao, Ponce, and Utuado which provide undergraduate education. In 1966, the Legislative Assembly reorganized the University of Puerto Rico as a system of autonomous campuses, each under direction of a chancellor. Therefore, each autonomous institutional unit has a Chancellor as chief administrator and academic officer. The College of Agriculture and Mechanic Arts (CAAM) became the University of Puerto Rico Mayagez Campus. Status: Final 12 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Within the philosophical framework established by the University of Puerto Rico Act, the Mayagez Campus directs its efforts towards the development of educated, cultured citizens, capable of critical thinking, and professionally qualified in the fields of agricultural, social, and natural sciences, engineering, humanities, and business administration. They should be able to contribute in an efficient manner to the cultural, social, and economic development of the Puerto Rican and international communities. This process is aimed at endowing our alumni with a strong technical and professional background and instill a strong commitment to Puerto Rico and our hemisphere. Today, the Mayagez Campus of the University of Puerto Rico is a co-educational research center, bilingual, and non-sectarian school comprising the Colleges of Agricultural Sciences, Arts and Sciences, Business Administration, Engineering, and the Division of Continuing Education and Professional Studies. The College of Agricultural Sciences includes the Agricultural Experiment Station (i.e., Alzamora Farm), and the Agricultural Extension Service. According to the 2022-2023 Fiscal Year Annual Report, the University of Puerto Rico - Mayagez Campus managed a budget from the general account funds (i.e., Commonwealth Central Government Funds) during last fiscal year of $116,602,725.00 in Campus, and with an enrollment over 13,316 undergraduate and graduate students, and with 1,181 regular staff members and 625 members of the educational staff. 2.3 PHYSICAL SETTING The site is located at approximately 105 feet above mean sea level. Figure 1 presents the site location on a portion of the US Geological Service (USGS) Topographical Map. Figure 2 presents an aerial photograph of the site. The closest superficial water body is the Atlantic Ocean located approximately 0.88 miles to the west of the site (see ATTACHMENT I). 2.4 SOLID AND HAZARDOUS WASTE GENERATION The UPR Mayagez Campus was founded in 1911, and is located on 259 Norte Boulevard Alfonso Valds Cobin, Mayagez, Puerto Rico. Approximately thirteen thousand (13,000) students attend numerous colleges operated at this campus. The UPR-Mayagez Campus also housed over two thousand five hundred (1,806) full time faculty, and staff personnel. The university covers an area approximately of 315 acres and houses over eighty-nine (89) buildings including Administrative Offices and a Campus Hotel. Along with the traditional academic curricula, UPR Mayagez Campus is involved in extensive research activities in a variety of areas including agricultural farming. Additionally, large physical maintenance department supports all Campus' activities. UPR Mayagez Campus also generates small quantities of medical regulated waste from its local Medical Services Unit, and Nursing College where medical analyses are conducted as part of the medical diagnosis examinations. Accordingly, there is a medical waste program in place to collect wastes in red plastic cannisters properly labeled and stored for final disposition. From a RCRA perspective, hazardous waste is generated from numerous sources throughout the Campus, including the areas listed below and depicted in Figure No. 1 of the UPR Mayagez Campus Map. Status: Final 13 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 General Engineering Department Chemical Engineering Department Civil Engineering Department Mechanical Engineering Department Electrical & Computer Department Marine Science Department Geology Department Art Education Department Theater/Performing Art Biology Department Chemistry Department Physics Department Investigation & Research Development Centers Nursing School Medical Services Unit Research & Development Laboratories Printing Department Physical Education Department (Swimming Pool Chemical Storage Area) Physical and Maintenance Shops Agricultural Science Department Agronomy and Soils Department Agricultural Experimental Stations (i.e., farms) Administrative Offices and Campus Hotel Typically, the primary waste generated and stored at UPR Mayagez Campus include corrosives, oxidizers, flammable, poisons, acute hazardous wastes, reactive, waste solvents, compressed gas cylinders, paint waste, and other laboratory chemicals and agricultural (i.e., pesticides) wastes. Hazardous wastes generated from the building maintenance department and vehicles and equipment shop include paint wastes, used oil, spent degreaser, spent fluorescent lamps, and used batteries. Paint jobs are conducted throughout the campus where is needed by painting shop staff. As part of the painting operations, thinner is used to clean up paint brushes, and other related equipment. Once the thinner is spent and mixed with paint wastes, it is collected and disposed of as special wastes. There are various Agricultural Science Laboratories located at the Alzamora Farm. The laboratories could potentially generated laboratory wastes and discarded pesticides, in which pesticide spills could contaminate soils and water run-off could heavily impact septic wells, sewage systems and stormwater drainages. It was also noted that the university staff does not have much control or inventory of extremely hazardous substances, and continuously exercise the practice to accumulate hazardous chemicals for long periods of time (years), which have resulted in accumulation of large amounts of dangerous chemical wastes at different campus locations. Therefore, UPR-Mayagez Campus must maintain and operate the facility to minimize the possibility of fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which have threaten human health and the environment. Status: Final 14 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Additionally, the art department, and under theater performing activities generate waste paints and spent thinners as well as printing wastes which could be considered as hazardous wastes, and on some occasions are dumped down the sinks or disposed of as domestic garbage. It must be noted that the university does not have any discharge permits under the Puerto Rico Aqueduct and Sewer Authority (PRASA) sanitary sewage system nor has a local wastewater treatment plant on-site. Based upon a review of UPR Mayagez Campus' manifest records, it appeared that UPR Mayagez Campus is a Small Quantity Generator since it generates over 2,200 pounds of hazardous waste every month, and disposed of with Capitol Environmental Services, Inc. every six months. It must be noted that at the time of the inspection many of the manifest records were not available for review. In addition, it appears that hazardous waste generated at the Campus may not be properly characterized nor manifested as required by RCRA regulations. It has been determined by EPA Inspectors the university need to make appropriate hazardous waste determinations on hazardous wastestreams generate throughout the Facility. Oher solid wastes generated at the Facility were Universal Waste (UW) associated with the management of spent fluorescent lamps, Ni-Cd batteries, and disposal of unused sanitation product with Capitol Environmental Services, Inc. Recyclable materials such as alumnium, cardboard, papel are disposed of with WR Recycling. Other disposal of sanitation, maintenance and housekeeping products are disposed of with Campos & Carreras Services at the Mayagez Municipal Solid Waste Landfill. Status: Final 15 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Figure No. 1- University of Puerto Rico Mayagez Campus Map (https://www.uprm.edu/portales/mapa) Status: Final 16 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 3 FACILITY WALKTHROUGH (DAY 2 - MARCH 9, 2023) Ms. Maria Fernndez, Health, Occupational and Environmental Safety Office (OPASO) Director accompanied me during the Facility walkthrough. At the Facility various university engineering and science departments, medical services unit, research centers, printing department, physical education department (swimming pool chemical storage area), physical and maintenance shops, agricultural science farms among other administrative offices and supporting units were inspected as described below. The observations for each area are described below. Refer to Appendix 1 for pictures taken during the inspection. 3.1 CHEMICAL ENGINEERING DEPARTMENT This building houses over twenty-two (22) chemical/biochemical research laboratories, teaching classrooms with cabinets used for the storage of chemical substances, chemical storage areas, and the storage room for the accumulation of chemical hazardous and toxic materials. This building also houses numerous hazardous waste satellite areas managed under Laboratory Management Plan RCRA 262 Subpart K. Ms. Fernndez and Ms. Jessamine Hernandez, EH&S Officer, both from OPASO served as the UPR Mayagez Campus' representatives and escorts. 3.1.1 Chemical Engineering Research Laboratory (Cellular & Molecular) IQ-101 K EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. One (1) 1-liter Erlenmeyer Flask with a "Biohazard Waste," unlabeled and without hazardous waste determination. If it is managed as a laboratory waste," the content and the container must be labeled as "Unwanted Material" and dated with its accumulation start date (N/UM/, N/D) (see Picture No. 1). ii. One (1) 2-liter container with a yellow-colored spent solvent (PBS) labeled as "Hazardous Waste," and with an accumulation start date of July 13, 2022, not managed as "Unwanted Material" (N/UM/, N/D) (see Picture No. 2). iii. One (1) 4-liter amber container with "ACS Reagent 37%" waste labeled as "Unwanted Material" but not dated with its accumulation start date (UM, N/D) (see Picture No. 3). iv. One (1) 2.5-liter plastic container with "DMF/DCM" waste labeled as "Hazardous Waste" but not dated with its accumulation start date nor managed as "Unwanted Material" (N/UM/, N/D) (see Picture No. 4). v. Storage of chemical reagents at laboratory cabinets was conducted without following any safety protocols or compatibility characteristics of the reagents failing to minimize the possibility of a fire, explosion, or any chemical violent reaction. 3.1.2 Chemical Engineering Research Laboratory (Catalyst) IQ-101 J EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: Status: Final 17 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 i. Eight (8) 4-liter ambar containers stored inside a cabinet area all labeled as "Unwanted Materials" and without their accumulation start dates. It was noted that three of them were empty and one contained discarded vials at the time of the inspection. However, no compatibility characteristics protocols were followed in the storage area (i.e., sulfuric acid) (UM, N/D) (see Picture No. 5). ii. Four (4) 4-liter ambar containers stored in trays containing THF (Tetrahydrofuran) and 1,4Dioxane dated as July 16, 2019, and March 3, 2020, not in use and abandoned and not managed as "Unwanted Material," without a hazardous waste determination of the content of the containers. I mentioned that THF is common peroxide-forming after degradation if not used within 12 months (see Picture No. 6). iii. One (1) 4-liter glass container with a spent mobile phase connected to a high-performance liquid chromatography (HPLC) not in use since November 2022. The container was unlabeled and without hazardous waste determination, or no indication if the contents was being managed as an "Unwanted Material" or not (see Picture No. 7). vi. Storage of chemical reagents at laboratory cabinets was conducted without following any safety protocols or compatibility characteristics of the reagents using alphabetical order and failing to minimize the possibility of a fire, explosion, or any chemical violent reaction. 3.1.3 Chemical Engineering Research Laboratory (Porous Absorbent/Sorbents Synthesis) IQ-101 HI EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. Six (6) 4-liter ambar containers stored inside a cabinet area, only two were labeled as "Unwanted Materials" and one with its accumulation start date of March 3, 26, 2019 which exceeded over six months of the LMP. The other containers were not dated with their accumulation start dates. (N/UM, N/D) (see Picture No. 8). ii. It was observed an extinguisher with current inspection tag, and a phone station with Emergency Numbers posted on the wall. However, none of the emergency numbers were working except for the EH&S Office. iii. Six (6) 4-liter ambar and glass containers stored inside a cabinet sink area, only four were labeled as "Unwanted Materials" and with their accumulation start dates. However, three (3) were not labeled as "Universal Wastes," nor dated with is accumulation start dates including various small bottles contained in a plastic tray. Some waste containers were labeled as "Hazardous Waste" but not dated with their accumulation start dates nor managed as "Unwanted Material." (N/UM/, N/D) (see Picture No. 9). iv. Four (6) 4-liter ambar and glass containers stored inside a cabinet sink area not labeled as "Unwanted Materials," and dated as of August 23, 2022, March 1, 2021, February 24, 2023, and other non-dated with their accumulation start dates which exceeded over six months of the LMP collection protocols. In addition, there were two (2) 5-gallon white containers with spent solvents that were not labeled as "Unwanted Materials," nor dated with their Status: Final 18 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 accumulation start dates. Some waste containers were labeled as "Hazardous Waste" but not dated with their accumulation start dates nor managed as "Unwanted Material." (N/UM/, N/D) (see Picture No. 10). 3.1.4 Chemical Engineering Research Laboratory (Absorption Analysis - Exterior Building) IQ-01 M EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. One (1) 4-liter ambar container with a spent mobile phase (ACN/Water 90/10) connected to a high-performance liquid chromatography (HPLC),its holding jacket labeled as "Waste," but not dated with its accumulation start date nor managed as "Unwanted Material" (N/UM/, N/D) (see Picture No. 11). 3.1.5 Chemical Engineering Research Laboratory (X-Rays) IQ-01 I EPA RCRA inspectors proceeded to inspect this research laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.1.6 Chemical Engineering Research Laboratory (Biomaterials "BioMa2RT") IQ-01 G EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. Two (2) 750 ml plastic bottles and a 200 ml Erlenmeyer beaker containing "Coomassie Blue Ink Waste" with spent methanol solvent not labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM/, N/D) (see Picture No. 12). ii. One (1) styrofoam box (1' x 1' x 2') containing discarded vials not properly labeled as "Unwanted Materials," nor dated with its accumulation start date as required in the LMP protocols (N/UM/, N/D) (see Picture No. 13). iii. One (1) 1-liter plastic bottle with yellow-colored PBS spent solvent not properly labeled as "Unwanted Materials," nor dated with its accumulation start date as required in the LMP protocols (N/UM/, N/D) (see Picture No. 13). iv. One (1) -liter plastic bottle with spent methanol solvent not labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM/, N/D) as required in the LMP protocols (N/UM/, N/D) (see Picture No. 13). 3.1.7 Chemical Engineering Research Laboratory (Rheometer) IQ-101 M EPA RCRA inspectors proceeded to inspect this research laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. Status: Final 19 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 3.1.8 Chemical Engineering Research Laboratory (Material Analysis Cellular Culture) IQ-101 N EPA RCRA inspectors proceeded to inspect this research laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.1.9 Chemical Engineering Research Laboratory (Polymer Synthesis) IQ-101 O EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. Two (2) 4-liter plastic containers with a spent petroleum ether and terpolymer labelled as "Unwanted Materials," and dated with their accumulation start dates of May 15, 2022, which exceeded over six months of the LMP collection protocols. (UM/, N/D) (see Picture No. 14). 3.1.10 Chemical Engineering Research Laboratory (Cellular Culture) IQ-101 B EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. Two (2) 1-gallon containers with a spent solvents labeled as "Hazardous Wastes," but not dated with its accumulation start date nor managed as "Unwanted Material." (N/UM/, N/D). ii. Storage of chemical reagents at laboratory cabinets was conducted without following any safety protocols or compatibility characteristics (Flammable and Corrosives) of the reagents failing to minimize the possibility of a fire, explosion, or any chemical violent reaction. 3.1.11 Chemical Engineering Research Laboratory (Cellular Culture) IQ-101 A EPA RCRA inspectors proceeded to inspect this research laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.1.12 Chemical Engineering Research Laboratory (Biofilm) IQ-103 A EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. In a yellow cabinet there were three (3) 4-L ambar containers with Methanol stored "on the same tray" next to one (1) 500-ml bottle with Formic Acid and next to one (1) 1-gallon plastic bottle container Ethy Alcohol 70% without following any safety protocols or compatibility characteristics (Flammable and Corrosives) of the reagents failing to minimize the possibility of a fire, explosion, or any chemical violent reaction (see Picture No. 15). Status: Final 20 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 3.1.13 Chemical Engineering Research Laboratory (Unit Operations) IQ-103 EPA RCRA inspectors proceeded to inspect this research laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.1.14 Chemical Engineering Research Laboratory (Biochemical Engineering) IQ-102 A EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. One (1) 2-gallon plastic container with a spent Ethanol aqueous waste not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 16). ii. Storage of chemical reagents at laboratory cabinets was conducted without following any safety protocols or compatibility characteristics (Flammable, Corrosives and Toxics - NaOH, Hydrochloric Methylcellulose, KCl) of the reagents failing to minimize the possibility of a fire, explosion, or any chemical violent reaction (see Picture No. 17). 3.1.15 Chemical Engineering Research Laboratory (Catalyst Materials) IQ-102 D EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. Three (3) 1-L ambar bottles containing unknown wastes, one labelled as "Unwanted Materials," and dated with its accumulation start date of February 28, 2022, which exceeded over six months of the LMP collection protocols. The other two were not labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM/, N/D) (see Picture No. 18). ii. Two (2) -L ambar bottles containing unknown wastes, one labelled as "Unwanted Materials," and not dated with its accumulation start date (UM/, N/D). The other was not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 18). iii. Two (2) 4-L ambar containers with unknown wastes not labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM/, N/D). iv. One (1) 2.5-gallon plastic container with unknown wastes no labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D). 3.1.16 Pharmacy Building FARM 109 EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: i. One (1) 40-gallon cardboard drum containing wastes with "Active Ingredients" not labelled as "Unwanted Materials," and dated with its accumulation start date of January 22, 2021, which exceeded over six months the LMP collection protocols (N/UM/, D) (see Picture No. 19). Status: Final 21 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 ii. One (1) 40-gallon blue drum containing wastes with "No Active Ingredients" not labelled as "Unwanted Materials," and dated with its accumulation start date of July 17, 2020, which exceeded over six months the LMP collection protocols (N/UM/, D) (see Picture No. 20). iii. One (1) 30-gallon drum containing "Waste Operation Laboratory Pharmaceuticals." not labelled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D). 3.2 CIVIL ENGINEERING SURVEYING DEPARTMENT This building houses construction and environmental research laboratories, teaching classrooms with cabinets used for the storage of chemical substances, chemicals storage areas, and the storage room for the accumulation of chemical and toxic reagents. This building also houses some "Satellite Accumulation Areas" (SAA) managed as "Unwanted Materials," under the Laboratory Management Plan. Dra. Ingrid Padilla is a Research Professor and Laboratory Coordinator in charge of the Environmental Engineering Laboratory, and Dr. Jos L. Flores Interim Director of the Civil Engineering and Surveying Department of the UPR Mayagez Campus. 3.2.1 Environmental Engineering Laboratory EPA RCRA inspectors proceeded to inspect this research laboratory area. The EPA Inspectors observed the following at this location: 3.2.1.1 Satellite Accumulation Area No. 1 - Room CI 018 i. Two (2) 5-gallon white containers with Methanol, Ethyl Acetate, Dichloromethane and Acetone both labelled as "Hazardous and dated with its accumulation start date of March 1, 2023, but not labeled as "Unwanted Materials" (N/UM/, D) (see Picture No. 21). ii. Two (2) 4-L ambar bottles containing Acetone and both labelled as "Hazardous Wastes,"" and dated with its accumulation start date of January 15, 2023, but none labelled as "Unwanted Materials," (N/UM/, D) (see Picture No. 22). iii. One (1) 4-L ambar bottle containing Methanol, Ethyl Acetate, Dichloromethane and Acetone labelled as "Hazardous and dated with its accumulation start date of November 10, 2022, which exceeded over six months the LMP collection protocols nor labeled as "Unwanted Materials," (N/UM/, D) (see Picture No. 23). iv. One (1) 4-liter ambar container stored in the extractor hood THF (Tetrahydrofuran) and dated as May 5, 2012, not in use and abandoned and not managed as "Unwanted Materials," without a hazardous waste determination of the content of the container. I mentioned that THF is common peroxide-forming after degradation if not used within 12 months (N/UM/, N/D) (see Picture No. 24). 3.2.1.2 Satellite Accumulation Area No. 2 - Room CI 018 i. Two (2) 5-gallon white containers with organic wastes both labelled as "Hazardous Waste," and dated with its accumulation start date but not labeled as "Unwanted Materials" (N/UM/, N/D) (see Picture No. 25). Status: Final 22 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 ii. Four (4) 4-L ambar bottles containing Methanol, Titanium Nitrate, Methyl Glycol, Triethyl Amine all labelled as "Hazardous Wastes," and some dated with its accumulation start date of November 11, 2022, which exceeded over six months the LMP collection protocols. The other bottles were not dated, and all were not labelled as "Unwanted Materials," (N/UM/, N/D) (see Picture No. 25). iii. One (1) 4-L ambar bottle containing Methanol mixed with Water dated 2015, not labelled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D). iv. One (1) 4-L ambar bottle containing Acetone not labelled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D). v. One (1) -L ambar bottle containing an Unknow Hazardous Waste not labelled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D). 3.2.1.3 Old Chemical Reagents Storage Area (Blue Cabinet "Flammable") - Room CI 018 Upper Tray i. Two (2) 4-L ambar bottles containing Dichloroethane leaking and covered with moisture, dated January 22, 2011, and August 2019, respectively.Dichloroethane decomposes into carbon dioxide and in present of a source of heat it can produce toxic and corrosive fumes including hydrogen chloride and methylene chloride (see Picture No. 26). ii. One (1) 4-L ambar bottle containing Acetone dated April 4, 2014, which is highly flammable (see Picture No. 27). iii. One (1) 1-gallon metal can with Sodium Borohydride, dated January 01, 2011, leaking on the tray, fully corroded, covered with water moisture and appeared to be decomposing forming sodium hydroxide and hydrogen. I explained that based upon chemical literature, the heat of this reaction may be sufficient to ignite the hydrogen and burns vigorously once ignited (see Picture No. 28). iv. One (1) 4-L ambar bottle containing Titanium Isopropoxide, dated August 2019, which is incompatible with strong oxidizing agents and strong acids (see Picture No. 29). v. One (1) 4-liter ambar container stored in the tray containing THF (Tetrahydrofuran), dated 2012, which is very unstable and a common peroxide-forming agent after degradation if not used within 12 months. Lower Tray vi. One (1) 4-L ambar bottle containing Methanol, dated March 2015, which vapors decompose to form carbon monoxide gas and hydrogen gas (see Picture No. 30). vii. One (1) 4-L ambar bottle containing Hexanes, dated 2022, 4, 2014, which is highly flammable. viii. One (1) 4-L plastic bottle containing Ethanol (Alcohol 95%), dated March 2015, which is highly flammable, not in use, and abandoned (see Picture No. 30). 3.2.1.4 Old Chemical Reagents Storage Area (Blue Cabinet "Corrosive") - Room CI 018 Upper Tray Status: Final 23 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 i. Four (4) 4-L ambar bottles containing Acetic Anhydride (Aceti Acid Glacial) dated from years 2009 thru 2011, in deteriorated conditions and labels being vanished, not in use and abandoned (see Picture No. 31). ii. Three (3) 4-L ambar bottles containing Hydrochloric Acid, dated January 27, 2020, some in deteriorated conditions and labels being vanished (see Picture No. 32). I explained that Acetic Anhydride was not compatible with Hydrochloric Acid and should not be stored together where they can be inadvertently mixed or where a spill or leak can cause danger. iii. One (1) -L ambar bottle containing Poly (acrylic acid) 50% Solution, dated 2010, with label being vanished. Middle Tray iv. Two (2) 2.5-L and -L plastic and ambar bottles containing Phosphoric Acid, dated 2014, some old and in deteriorated conditions, not in use and abandoned (see Picture No. 33). v. One (1) 1-L ambar bottle containing Hydrochloric Acid, dated 2001, with label being vanished, not in use and abandoned (see Picture No. 34). vi. One (1) 500-ml ambar bottle containing Triton X-100, dated 2015, which is a nonionic surfactant that has a hydrophilic polyethylene oxide, harmful if swallowed, should not be stored together where strong acids can be inadvertently mixed or where a spill or leak can cause danger and possibility of hazardous reactions. vii. One (1) 1-L ambar bottle containing Titanium Sulfate Solution, dated 2006, with label being vanished, not in use and abandoned. 3.2.1.5 Old Chemical Reagents Storage Area (Brown Cabinet "Flammable") - Room CI 018 Upper Tray i. Six (6) 4-L ambar bottles containing Hexane, and n-Hexane, dated from 2005 - 2016 (see Picture No. 35). ii. Four (4) 2-L ambar bottles containing Dichloromethane, and Iso-hexane, dated from 2016 - 2023 (see Picture No. 35). iii. Four (4) 1-L ambar bottles containing Methanol HPLC, Dichloromethane, and Iso-hexane, dated from 2016 - 2023. iv. One (1) 1-L ambar bottle containing Butanoic Acid, dated 2006, with label being vanished (see Picture No. 34). I mentioned that flammable and combustible liquids should not be stored together where acids can be inadvertently mixed or where a spill or leak can cause danger and possibility of hazardous reactions. Middle Tray v. Eight (8) 4-L plastics and ambar bottles containing Methanol, Water HPLC Grade, Ehtyl Acetate, and Xylene, dated from 2005 - 2014. The Ethyl Acetate was labeled as "Non in Use Contaminated," (see Picture No. 36). vi. One (1) 2.5-L ambar bottle containing Methyl Acetate, dated 2010, (see Picture No. 36). Status: Final 24 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Lower Tray vii. Seven (7) 2-L ambar bottles containing Methanol, Hexane, Methylpentane, Isopentyl Acetate, and Ethylene, dated from 2005 - 2016. One of the bottles containing Isopentyl Acetate was labeled as "Avoid Problems - Ask," (see Picture No. 37). viii. Two (2) 4-L ambar bottles containing Methanol and Trichloroethylene, dated from 2005 - 2015. ix. Five (5) 1-L ambar bottles containing Hexane, Pentane, and Methyl Tert-butyl Ether (MBTE), dated from 2005 - 2019." MTBE has been characterized as an animal carcinogen, (see Picture No. 38). 3.2.1.6 Solid Chemical Reagents Storage Area (Metal Grid Cabinet) - Room CI 018 On March 9, 2024, EPA Inspectors proceeded to inspect the Solid Chemical Reagents Storage Area (Metal Grid Cabinet) located in the Civil Engineering and Surveying Department which is used to store chemical reagents used in the performance of research experiments mainly in the Environmental Engineering Laboratory. At the time of the RCRA Inspection, EPA Inspectors observed numerous expired chemicals (since before 1986), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more) in shelves without any physical means to protect each other from incompatibility of waste characteristics. As observed by EPA Inspector there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents. According to Assistant Students to Dra. Ingrid Padilla and Prof. Ricardo Berrios, all these chemical reagents were not in use and discarded a long time ago from various laboratory research seasons and were stored in this area and never declared as "solid waste material," or notified to the Health, Occupational and Environmental Safety Office (OPASO). There was no hazardous waste determination being performed on abandoned, expired, not in use, discarded hazardous chemical waste inventory before its final disposal nor have been managed under the Laboratory Management Plan. As observed by EPA Inspectors, there were no Safety Data Sheets (SDSs) available at the storage area for most of the expired, abandoned, not in use chemical reagents that should be inventoried for final disposition. It was recommended by the inspectors that SDSs should be evaluated to determine the proper characterization and determination of the expired and discarded solid waste. Among the chemical reagents identified from a safety distance stored without segregation included Sodium Hydroxide, Arsenic, Potassium Dichromate, Ethylene Glycol, Pyridine, Ammonium Chloride, Ammonium Bromide, Potassium Iodide, Mercury Chloride, Antimony Potassium, Hydroxylamine Hydrochloride, Sodium Arsenate, Potassium Chromate, Ethyl Alcohol, Sodium Persulfate, Nickel Chloride, Dichloromethane, Potassium Arsenate, Arsenic Trichloride, Sodium Iodide, Arsenic Acid, Formaldehyde, and various 4-Liter bottles containing flammable and combustible liquids which were no longer intended to be used (see Pictures No. 38, 39, and 40). It was determined by EPA Inspectors that there was an actual or potential of fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. As warranted by the potential threat of potential releases or explosion of hazardous waste, and under the authority of the Status: Final 25 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Comprehensive, Environmental Response, Compensation, and Liability Act (CERCLA), on March 9, 2023, EPA issued a Field Notice of Federal Interest (FNFI) to UPR-Mayagez Campus requesting the responsible party to take corrective actions. Additionally, EPA requested that hazardous waste be disposed of as required by RCRA requirements. Based upon EPA's determination, unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents' threats were described as described below. i. The release and/or threatened release noticed herein, observed during a Site visit on March 9, 2023, to the Environmental Engineering Laboratory (R-018) at the University of Puerto RicoMayagez Campus, consists of several containers that were identified to be leaking, not properly labeled, haphazardly stored, without secondary containment and not segregated by chemical compatibility. ii. The USEPA requested that by noon of March 10, 2023, the Respondent reported to the EPA, Region II, at the address, email and telephone number indicated in the FNFI, perform removal activities, in conformance with 42 U.S.C. 9601 (23), which removal activities had been performed and/or those removal activities which Respondent planned to perform immediately, to prevent, correct, clean up, minimize or mitigate the above-described release and/or threatened release. Also, to continue with any mitigation actions, already implemented, that restricts access to this room. Labeling, markings and change in access keys were also recommended. UPR Mayagez Campus' officials secured the Environmental Engineering Laboratory with signs and maintained personnel as well as professors and students away from the room area. They were coordinating with Stericycle Puerto Rico to assist with the characterization, segregation, packaging, transportation, cost estimates and final disposition will be performed under the oversight of the EPA On Scene Coordinator. Table No. 2 depicts the inventory of chemical reagents recorded during EPA Inspection provided by Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office to request quotation from Stericycle Puerto Rico for final disposition. As observed by EPA Inspector, there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents and some were not in use, expired and discarded a long time ago from various laboratory experiments and were stored, abandoned in this area and never declared as "solid waste material," or notified to the Health, Occupational and Environmental Safety Office (OPASO). Table No. 2 - Chemical Waste Inventory at the Environmental Engineering Laboratory - March 9, 2023 Chemical Reagent Name Year Unit 1,10-phenanthroline ferrous sulfate complex 1,2-propanediol Status: Final 2013 mL 2009 mL Estimated Quantity 120 500 26 Quantity Number 1 Location HVC 76 Storage Code Risk Minimum 1 Flam Blue Flammable CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 2-propanol 2,2-bipyridine 2,2,4-trimethylpentane 2015 L 2009 g - L 2,3,5-triphenyltetrazolium 2009 g chloride 2,3,5-triphenyltetrazolium 2006 g formazan 2,4-dinitrophenylhydrazine 2009 g 2,6-pyridinedicarboxylic acid 2010 g 3,5-dinitrosalicylic acid 2009 g acetic acid, sodium salt 2009 g acetone 2019 L acetone 2016 L acetonitrile, anhydrous 2008 L agar 2011 g alginic acid, sodium salt 2011 g alumina 2002 g aluminum hydroxide 2013 g aluminum oxide, powder 2000 g aluminum sulfate hydrate 2011 g ammonium acetate 2009 g ammonium acetate 1998 g ammonium bromide cetyl 2005 g dimethyl ethyl 20 25 1 25 5 100 10 500 500 1 20 4 1000 500 2500 1 500 500 500 500 1500 1 Flam Blue 1 HVC 67 1 Flam Crema 1 Fridge 1 HVC 76 1 Flam Blue 1 Cabinet 19 1 HVC 67 1 Fridge 1 Flam Blue 1 Flam Blue 2 Flam Blue 1 Dry Keeper 1 Cabinet 19 1 HVC 76 1 HVC 67 1 HVC 76 1 HVC 67 1 Cabinet 19 1 HVC 67 3 Fridge Flammable Toxic Flammable Risk Minimum Risk Minimum Flammable Toxic Corrosive Flammable Flammable Flammable Flammable Risk Minimum Toxic Risk Minimum Corrosive Risk Minimum Corrosive Toxic Toxic Corrosive Status: Final 27 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 ammonium bromide, cetyl 2005 g trimethyl ammonium chloride, cetyl 2013 mL dimethyl ethyl 25% sol ammonium calibration soln - mL ammonium chloride hydroxide buffer <1986 onz ammonium nitrate 2013 g ammonium molybdate 1992 g ammonium phosphate dibasic <1986 g ammonium ptoluenesulfonate - g ammonium sulfate isa 2008 mL antimony potassium tartrate 1990 g arsenic standard mL arsenic std. for AA 2012 mL boric acid 2010 g boric acid <1986 g bromocresol green 1991 g cadmium 1990 g cadmium standard solution - mL cadmium sulfate hydrate 1999 g crystals calcium carbonate, 99+% 2014 g 3500 500 1000 50 500 500 400 25 950 500 500 500 1000 1000 2 100 300 500 200 7 HVC 67 Corrosive 1 HVC 67 Corrosive 2 Cabinet 17 Corrosive 2 HVC 67 Corrosive 1 HVC 67 Reactive/Oxidizer 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 Cabinet 17 1 HVC 67 Toxic Toxic 1 HVC 67 Corrosive 1 Cabinet 19 Corrosive 1 HVC 77 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 3 Cabinet 17 Corrosive 1 HVC 67 Toxic 2 HVC 76 Risk Minimum Status: Final 28 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 calcium chloride, anhydrous 96% 2017 kg calcium chloride, anhydrous 96% 2014 g calcium chloride, anhydrous 2013 g calcium chloride 2011 g calcium chloride dihydrate 2011 g calcium chloride dihydrate 2011 g calcium hydroxide, 95% 2010 g calcium sulfate, -325 mesh 2004 g carbon (charcoal) activated powder 2002 g carbon activated WPX Pulv <1986 g carbon activated BL PULV <1986 g carbon activated D/S react <1986 g A carbon activated D/S react <1986 g C carbon activated F-200 <1986 g sodium salt hydrate 2014 g cetylpyridinium chloride 2005 g chloride calibration solution 2002 mL chromium (III) AA std. - mL cyclohexane <2006 L citric acid 2011 g 10 2500 500 500 1000 6000 1000 100 125 200 800 175 400 1100 250 1 1000 500 1 100 1 HVC 76 1 HVC 76 1 HVC 76 1 HVC 76 1 Cabinet 19 2 Cabinet 19 1 HVC 67 1 HVC 76 1 HVC 76 1 HVC 76 2 HVC 76 1 HVC 76 1 HVC 76 1 HVC 76 1 Incubator 2 HVC 67 2 HVC 67 1 HVC 67 1 Flam Crema 1 Cabinet 19 Risk Minimum Risk Minimum Risk Minimum Risk Minimum Risk Minimum Risk Minimum Corrosive Risk Minimum Risk Minimum Risk Minimum Risk Minimum Risk Minimum Risk Minimum Risk Minimum Corrosive Corrosive Corrosive Flammable Corrosive Status: Final 29 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 cobalt chloride 1995 g 450 cobalt oxide 1994 g 100 copper 1994 g 250 copper std soln 2003 mL 325 cupric sulfate, anhydrous 1999 g 500 dextrose anhydrous <1986 g 500 dibutyl phthalate 2013 mL 500 dichloromethane 2012 L 3 dioctyl phthalate 2009 mL 500 EDTA magnesium salt 2000 g 100 ethyl acetate 2010 L 2.5 ethylene glycol 2011 L 4 ethylenediaminetetraaceti 2009, g 500 c acid, 99% 2012 ferric chloride, anhydrous 2001 g 500 ferric chloride, 6-hydrate 2009 g 500 ferroin indicator solution 1997 mL 100 ferrous ammonium sulfate 1993 g 400 (6-) hyd. ferrous chloride, 4-hydrate 2009 g 250 ferrous sulfide 2010 g 500 ferrozine iron reagent, 2009 g 5 hydrate 98% fluorine fc-77 2005 mL 25 1 Cabinet 19 1 HVC 76 1 HVC 76 4 Cabinet 17 1 Cabinet 19 1 HVC 76 1 HVC 67 3 Flam Crema 1 HVC 67 1 HVC 76 1 Flam Crema 4 HVC 76 2 HVC 67 1 HVC 67 1 HVC 67 1 HVC 76 1 Cabinet 19 1 Cabinet 19 1 1 HVC67 1 HVC 67 Risk Minimum Risk Minimum Risk Minimum Risk Minimum Toxic Risk Minimum Toxic Flammable Toxic Risk Minimum Flammable Risk Minimum Toxic Risk Minimum Corrosive Risk Minimum Risk Minimum Corrosive Flammable Toxic Corrosive Status: Final 30 CEPD-RCRA-23-0440 formaldehyde, 37% aqueous solution formalin turbidity standard glucose anhydrous, D(+) dextrose glutamic acid (L-) glycerin Hexane, HPLC Plus Hexane n-hexane hexane hexane, pentanal hexane, HPLC 95% hexane, 95% humic acid humic acid humic acid humic acid hydrochloric acid, 32% hydrochloric acid 6N hydrogen peroxide 30% hydrogen peroxide 30% Status: Final Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 2009 mL 500 1 HVC 67 Flammable - mL 4500 6 Cabinet 17 Risk Minimum - g 3600 1 Cabinet 19 Risk Minimum 2001 g <1986 mL 2018 L 2018 L 2016 L 2012 L 2011 L 2010 L <2005 L 2016 g 2016 g 2014 g 2009 g 2009 L 2001 L 2014 mL 2013 mL 500 400 1 7.5 16 3 2.5 4 3 10 10 10 100 2.5 1 1000 500 31 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 Flam Blue Flammable 3 Flam Flammable Crema 4 Flam Flammable Crema 3 Flam Flammable Crema 1 Flam Flammable Crema 2 Flam Flammable Crema 3 Flam Flammable Crema 1 Cabinet 19 Toxic 1 Cabinet 19 Toxic 1 Cabinet 19 Toxic 1 Cabinet 19 Toxic 1 Corrosives Corrosive 1 Corrosives Corrosive 2 Fridge Corrosive 1 Fridge Corrosive CEPD-RCRA-23-0440 hydrogen peroxide 30% hydrogen peroxide solution 30% imidazole immersion oil iodine iodine solution N/10 (Expire 1999) iron (II) sulfate heptahydrate iron (III) sulfate hydrate, 97% iron (III) chloride iron powder 99% isopentyl acetate lead nitrate lead oxide lithium chloride magnesium chloride, 6hydrate magnesium sulfate heptahydrate magnesium sulfate hydrate manganese metal manganese sulfate monohydrate manostat chromerge Status: Final Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 2013 mL 500 2011 mL 300 1 Fridge 3 Corrosives Corrosive Oxidizer 20118 g 2010 2002 g 1997 L 1000 100 1 1 HVC 67 Corrosive 1 HVC 67 Corrosive 1 HVC 67 Risk Minimum 2009 g 500 1 HVC 67 2006 g 500 1 Cabinet 19 Risk Minimum 2013 g 2009 g 2007, L 2009 2005 g <1986 g <1986 lb 2014 g 1000 500 6 100 450 5 500 1 Cabinet 67 Corrosive 1 Flam Blue Flammable 3 Flam Flammable Crema 1 HVC 67 Reactive/Oxidizer 1 HVC 67 Reactive/Oxidizer 1 HVC 76 Risk Minimum 1 Cabinet 19 Risk Minimum 2001 g 500 1 HVC 76 Risk Minimum 2010 g 1000 1 HVC 76 Risk Minimum 1992 g 450 2011 g 500 1 HVC 76 Risk Minimum 1 HVC 67 Toxic - mL 500 32 24 HVC 67 Toxic CEPD-RCRA-23-0440 mercuric chloride mercuric sulfate mercury monohydrate methanesulfonic acid methanol, HPLC Grade methanol, HPLC Grade methyl orange methyl Flammable methyl Flammable, 0.2% methylene blue methyl-tert butyl ether mineral stabilization nalidixic acid, 99% nalidixic acid, 99% nalidixic acid, 99% naphthalene, 99% nickel chloride nickelous sulfate, 6hydrate N, N-diethyl-pphenylenediamine nitrate calibration standard o-phenanthroline pentafluorobenzoic acid Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 1990 g 50 1988 g 100 2009 g 100 2018 mL 100 2016 L 8 2015 L 4 <1986 g 450 <1986 oz 1 <1986 oz 4 <1990 g 100 - L 4 - mL 50 2016 g 5 2014 g 5 2014 g 5 1997 g 250 1999 g 500 2009 g 125 1 HVC 67 1 HVC 67 1 HVC 67 1 Cabinet 19 2 Flam Blue 4 Flam Blue 1 HVC 67 1 HVC 76 1 HVC 67 1 HVC 76 1 Flam Blue 1 Cabinet 17 1 HVC 67 1 HVC 67 1 HVC 67 1 HVC 67 1 HVC 67 1 HVC 67 Toxic Toxic Toxic Corrosive Flammable Flammable Toxic Risk Minimum Risk Minimum Risk Minimum Flammable Risk Minimum Toxic Toxic Toxic Toxic Toxic Toxic 2009 g 25 2 HVC 67 Toxic 2002, mL 2012 2010, mL 2011 2007 g 500 1000 10 1 Cabinet 17 Reactive/Oxidizer 2 Cabinet 19 1 HVC 67 Toxic Status: Final 33 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 pentane pentane 2019 L - L phenol 2011 L phenol Flammable-D 1991 mL phenolphthalein soln. 1% (Expire 09/1998) - mL phosphoric acid, 85% 2014 L pipes, piperazine-N, N'bis(2-ethanesulfonic ac 2009 g poly (acrylic acid) 50% solution 2010 g potassium antimonyl tartrate hydrate 1994 g potassium bi-iodate 1991 g potassium bromate <1986 g potassium chloride 1990 g potassium chloride isa 2008 mL potassium chloride fill soln - mL potassium chloroplatinate <1986 g potassium chromate <1986 g , 1997 potassium citrate 1999 g potassium dichromate 1999, g <1986 potassium hydrogen phthalate 1995 g potassium hydrogen phthalate 1991 g 2 1 1 50 500 2.5 100 250 100 75 450 500 950 375 2 300 400 1500 500 100 1 Flam Blue Flammable 1 Flam Flammable Crema 1 Corrosives Corrosive 1 HVC 76 Risk Minimum 1 Flam Blue Flammable 1 Corrosives Corrosive 1 HVC 76 Risk Minimum 1 Flam Blue Corrosive 1 HVC 67 Toxic 1 HVC 76 Risk Minimum 1 HVC 67 Reactive/Oxidizer 1 Cabinet 19 Risk Minimum 2 Cabinet 17 Risk Minimum 2 Cabinet 17 Risk Minimum 2 HVC 67 Toxic 2 HVC 67 Reactive/Oxidizer 1 HVC 76 Risk Minimum 3 HVC 67 Reactive/Oxidizer 1 HVC 76 Risk Minimum 2 HVC 76 Risk Minimum Status: Final 34 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 potassium hydroxide 2002 kg potassium iodide, 5% 1986 mL potassium persulfate <1986 g potassium phosphate monobasic 1991 g potassium phosphate dibasic, 98+% 2014 g potassium phosphate dibasic 2011 g potassium phosphate, 97% 1995 g potassium reference soln - mL potassium sulfate <1986 g p-xylene <2005 L rhodamine 20% 2018 L sand, Corrosive quartz 2019 g scandium 2001 mL silica gel 2019 g silica gel - g silica gel desiccant, Reagent 8mesh - g silver sulfate <1986 g sodium acetate, anhydrous 1999 g sodium aluminate 2010 g sodium arsenite 2011 g sodium azide 2011 g sodium bicarbonate 1994 g 3 100 1000 2000 1000 500 500 500 2265 1.5 2 500 500 100 100 2500 25 400 100 100 500 3500 1 HVC 67 Corrosive 1 HVC 67 Risk Minimum 2 HVC 67 Reactive/Oxidizer 2 Cabinet 19 Risk Minimum 2 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 67 Corrosive 1 Cabinet 17 Risk Minimum 1 HVC 76 Risk Minimum 1 Flam Flammable Crema 2 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 67 Corrosive 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 67 blue 1 Cabinet 19 Risk Minimum 2 HVC67 Corrosive 1 HVC 67 Toxic 1 Cabinet 19 Reactive/Oxidizer 2 Cabinet 19 Risk Minimum Status: Final 35 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 sodium borate 1991 g sodium borohydride 98% 2009 g sodium bromide 2012 g sodium chloride 2013 g sodium deuteroxide 2016 g sodium hydroxide - L sodium m-Arsenite 1997 g sodium metaphosphate 2004 g sodium molybdate dihydrate 2010 g sodium nitrate isa 2008 mL sodium nitrite <2004 g sodium persulfate 2002 g sodium phosphate dibasic 2009 g heptahydrate sodium phosphate dibasic 1991 g heptahydrate sodium phosphate monobasic, anhydrous 2009 g sodium sulfite 2008 g sodium tetraborate decahydrate 2009 g sodium tetrachloropalladate 2009 g sodium thiosulfate <1986 g , 1993 sodium thiosulfate, anhydrous <1986 kg 500 500 100 12000 10 2 70 500 100 950 250 500 500 500 500 100 500 5 1500 1 1 HVC 76 Risk Minimum 1 Flam Blue Flammable 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 Cabinet 19 Corrosive 2 HVC 67 Corrosive 1 HVC 67 Toxic 1 HVC 76 Risk Minimum 1 Cabinet 19 Risk Minimum 3 Cabinet 17 Risk Minimum 1 HVC 67 Reactive/Oxidizer 1 HVC 67 Reactive/Oxidizer 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 Cabinet 19 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 67 Toxic 1 HVC 67 Toxic 3 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum Status: Final 36 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 starch corn <1986 g 400 starch soluble <1986 g 400 sulfuric acid, 95-98% 1996 L 2.5 sulfamic acid - g 100 sulfuric acid, 1N 2009 L 1 tartaric acid, DL- - g 10 tetrabutyl ammonium 2009 g 250 hydroxide 40% tetrachloroethylene <2006 mL 100 tetrachloroethylene <2005 L 4 thiamine monophosphate 2010 g 25 chloride dihydrate tin 1994 g 100 titanium (iv) oxide anhydrous 2016 g 500 titanium (iv) oxide nanopowder 2018 g 100 titanium (iv) oxide sulfate 2015 g 500 titanium sulfate solution 2006 g 400 toluene - L 4 trichloroethylene 2005 L 8 trichlorotrifluoroethane <2005 L 3.5 Triton X-100 2015 mL 500 tween 80 polyxyethylene- 1996 mL 500 20 urea 2014 kg 1 1 HVC 76 Risk Minimum 1 HVC 76 Toxic 1 Explosives Corrosive 1 HVC 67 Corrosive 1 Explosives Corrosive 2 HVC 67 Toxic 1 HVC 67 Corrosive 1 HVC 67 Toxic 1 Flam Flammable Crema 1 Dry Keeper Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 67 Toxic 1 HVC 67 Toxic 1 HVC 67 Corrosive 1 Flam Blue Corrosive 1 Flam Blue Reactive/Oxidizer 4 HVC 67 Flammable 1 HVC 76 Toxic 1 HVC 67 Corrosive 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum Status: Final 37 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 water 2014 L 4 zinc (granular) <1986 g 700 zinc 1994 g 250 zinc (dust) <1986 g 450 zinc (metal) <1994 g 450 zobells soln, Flammableox - mL 500 standard solns 1 Flam Risk Minimum Crema 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 HVC 76 Risk Minimum 1 Cabinet 17 Reactive/Oxidizer 3.3 CHEMISTRY DEPARTMENT BUILDING This building houses the general chemistry, analytical chemistry, physicochemical, organic, inorganic, biochemistry, and chemical instrumental laboratories, teaching classrooms with cabinets used for the storage of chemical reagents, a chemical storage warehouse, and hazardous waste satellite accumulation areas (SSA) located in most chemical laboratories managed under the Laboratory Management Plan. This building also houses the research and development laboratories. Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office, served as the UPR Mayagez Campus' representative. Since this building houses numerous laboratories, a map depicting laboratory locations and personnel in charge was requested to the Department Director to minimize the complexity of the compliance inspection. 3.3.1 Chemical Laboratory Preparations Q-009 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: i. At the Satellite Accumulation Area under a laboratory cabinet there were numerous (approximately over twenty-eight 28) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories not properly labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 41). In addition, the storage of these "Unwanted Materials" was conducted without following any safety protocols or compatibility characteristics (Flammable, Corrosives and Toxics - NaOH, Sulfuric Acid, Sodium thiocyanate, Nitric Acid, Pentane) of the spent reagents failing to minimize the possibility of a fire, explosion, or any chemical violent reaction. It was discussed with Ms. Fernndez that the responsibility of the laboratory technician within the laboratory is to prepare the label and verify that labels are placed on all containers of "Unwanted Material" stored in the laboratory. Containers will not be removed from a Status: Final 38 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 laboratory unless the "CHEMATIX" label is attached to the container. As observed by EPA Inspector non-Chematix labels were affixed to each container (see Picture No. 42). ii. Under a laboratory cabinet there were five (5) 4-liter crystal and ambar bottle containing spent Pentane, Iron (III) Chloride, Methyl Orange Ferric and other unknown wastes generated at the laboratories not properly labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 42). 3.3.2 Chemical Laboratory Volatile Warehouse (Flammable) Q-008 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.3.3 Chemical Laboratory Acids Warehouse (Corrosive) Q-058 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.3.4 Chemical Laboratory Soil and Agronomy Q-007 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.3.5 Chemical Laboratory Instrumental Analysis Q-051 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: i. One (1) 4-liter ambar container with a spent mobile phase (ACN/Water 90/10) connected to a high-performance liquid chromatography (HPLC) no labeled as "Unwanted Material" nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 43). ii. At the Satellite Accumulation Area there were numerous (approximately over ten 10) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories properly labeled as "Unwanted Materials," and dated with its accumulation start date but not segregated by compatible characteristics (Nitric Acid, Chlorobenzene) (UM, D) (see Picture No. 44). 3.3.6 Chemical Laboratory Analytical and Pharmaceutical Research Q-023 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Status: Final 39 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 i. One (1) 4-liter ambar container with a spent Hydranal Composite and Methanol labeled as "Unwanted Material," dated with its accumulation start date of April 13, 2016, which exceeded over six months the LMP collection protocols (N/UM, N/D) (see Picture No. 45). ii. Two (2) 4-liter ambar containers with a spent Hydranal Composite Waste, one also labeled as "Viejo - Old," both were no labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 46). iii. One (1) 500-ml containers with a spent Methanol Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). iv. One (1) 4-liter ambar container with a Methanol Solvent Waste labeled as "Unwanted Material," and dated with its accumulation start date of July 31, 2016, which exceeded over six months the LMP collection protocols (N/UM, N/D) (see Picture No. 47). v. One (1) 500-ml container with a spent Cyclohexane Waste labeled as "Unwanted Material," and dated with its accumulation start date of March 3, 2015, which exceeded over six months the LMP collection protocols (N/UM, N/D). vi. Two (2) 4-liter ambar containers with a spent Hydranal Composite Waste, and the other with Methanol Waste, both were labeled as "Unwanted Material," (no "CHEMATIX" label) and both dated with its accumulation start of December 19, 2016, and July 31, 2025, respectively, which exceeded over six months the LMP collection protocols (UM/, N/D) (see Picture No. 48). 3.3.7 Chemical Laboratory Physical Chemistry Q-050 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: i. At the Satellite Accumulation Area (SAA No. 1) under a laboratory cabinet there were numerous (approximately over eight 8) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories not properly labeled as "Unwanted Materials," (no "CHEMATIX" label) nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 49). ii. One (1) 500-ml container with a spent Napthalene not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). iii. One (1) 500-ml container with a Napthalene Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). iv. One (1) 750-ml container with a Phase Diagram Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 50). v. One (1) 250-ml container with a spent Acid labeled as "Unwanted Material," and dated with its accumulation start of September 14, 2018(N/UM, N/D) which exceeded over six months the LMP collection protocols (N/UM, N/D). vi. Two (2) 4-liter ambar containers with a spent Unknown Waste, both labeled as "Unwanted Material," but properly dated with its accumulation start date of March 2023 (N/UM/, N/D) (see Picture No. 51). vii. At the Satellite Accumulation Area (SAA No. 2) on top of a laboratory cabinet table there were four (4) 4-liter ambar containers with a spent Unknown Waste, all labeled as "Unwanted Status: Final 40 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Material," but not properly dated with their accumulation start dates (UM/, N/D) (see Picture No. 52). 3.3.8 Chemical Laboratory Molecular Spectroscopy Q-048 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes since this laboratory was closed at the time of the EPA Inspection. 3.3.9 Chemical Laboratory Physical Chemistry Q-046 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: i. At the Satellite Accumulation Area on top of a laboratory cabinet table there were numerous (approximately over sixteen 16) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories most of them properly labeled as "Unwanted Materials," but not dated with their accumulation start dates (UM/, N/D) (see Picture No. 53). ii. Two (2) 4-liter ambar containers with a spent solvent waste both labeled as "Unwanted Materials," and dated with their accumulation start dates of September 27, 2021, and September 22, 2021, respectively, which exceeded over six months the LMP collection protocols. One (1) 500-ml container with a spent Napthalene not labeled as "Unwanted Material," (UM, N/D) (see Picture No. 54). iii. Two (2) 4-liter crystal containers with a spent solvent waste both labeled as "Unwanted Materials," and dated with their accumulation start dates of September 27, 2021, and September 22, 2021, respectively, which exceeded over six months the LMP collection protocols. One (1) 500-ml container with a spent Napthalene not labeled as "Unwanted Material," (UM, N/D) (see Picture No. 55). iv. Three (3) 4-liter crystal containers with a spent solvent waste both labeled as "Unwanted Materials," and dated as September 27, 2021, September 22, 2021, February 27, 2023, and which exceeded over six months the LMP collection protocols (see Picture No. 56). v. Two (2) 4-liter ambar containers with a spent Acetone and Organic Ink waste both labeled as "Unwanted Materials," and dated with their accumulation start dates of February 13, 2022, and March 3, 2023, respectively, which exceeded over six months the LMP collection protocols. (UM, N/D) (see Picture No. 57). vi. Two (2) 4-liter crystal containers with a spent Acetone and Ethylacetate waste both labeled as "Unwanted Materials," (but one without the proper "CHEMATIX" label as required by the LMP) and one dated with its accumulation start date of April 18, 2022, and the other was not dated. The contained labeled with the proper Chematix label, and dated on April 18, 2022, exceeded over six months the LMP collection protocols (UM, N/D) (see Picture No. 58). 3.3.10 Chemical Laboratory Q-044 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Status: Final 41 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes since this laboratory was "Not-In-Use" at the time of the EPA Inspection. 3.3.11 Chemical Laboratory Equipment Storage Room Q-035 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.3.12 Chemical Laboratory Bio-Inorganics Q-116 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor there were numerous (approximately over eleven 11) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories most of them properly labeled as "Unwanted Materials," but not dated with their accumulation start dates of February 3, 2022, and year 2019, respectively, which exceeded over six months the LMP collection protocols (UM/, N/D) (see Picture No. 59). ii. Four (4) 4-liter ambar containers with a spent solvent waste all labeled as "Unwanted Materials," and all dated with their accumulation start dates of February 3, 2022, which exceeded over six months the LMP collection protocols (UM, N/D). iii. Two (2) 4-liter crystal containers with a spent solvent waste both labeled as "Unwanted Materials," and all dated with their accumulation start dates of February 3, 2022, which exceeded over six months the LMP collection protocols (UM, N/D). iv. Four (4) Lab pack crystal containers with a spent solvent waste all labeled as "Unwanted Materials," and all dated with their accumulation start dates of February 3, 2022, or year 2019, respectively, which exceeded over six months the LMP collection protocols (UM, N/D). Tray No. 2 - Satellite Accumulation Area v. Inside an extractor hood there were numerous (approximately over ten 10) "Unwanted Materials," containing discarded or spent solid and liquids chemical reagents (i.e., Cyanide, Ethanol, Benzene) generated at the laboratories, not properly labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM/, N/D) (see Picture No. 60). vi. Four (4) 4-liter ambar containers with a spent solvent waste all labeled as "Unwanted Materials," and all dated with their accumulation start dates of February 3, 2022, which exceeded over six months the LMP collection protocols (UM, N/D). vii. One (1) 750-ml container with Ferricyanide Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). Status: Final 42 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 viii. Two (2) 500-ml containers with a Solid Waste not labeled as "Unwanted Material," but dated with their accumulation start dates of February 24, 2022, which exceeded over six months the LMP collection protocols (UM/, N/D). ix. One (1) 750-ml container with Peptone Bacteriological Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). x. Two (2) 1-liter container with Unknown Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). xi. One (1) 1-gallon container with Discarded Vials labeled as "Unwanted Material," but dated with their accumulation start dates of February 24, 2022, which exceeded over six months of the LMP collection protocols (UM/, N/D) (see Picture No. 61). xii. One (1) -gallon container with Microbial Medium not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 61). xiii. One (1) 250-ml container with Unknow Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). 3.3.13 Chemical Laboratory Bio-Inorganics Q-112 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were numerous (approximately over nine 9) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories, not properly labeled as "Unwanted Materials," nor dated with their accumulation start (N/UM/, N/D) or segregated by compatible characteristics (Acids, Bases, Organic Wastes) (see Picture No. 62). ii. One (1) 4-liter ambar container with a spent Acids not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). iii. One (1) 4-liter plastic container with a Chemical Wastes not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 63). iv. One (1) 1-liter ambar container with a spent Bases not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). v. One (1) 250-ml container with Organic Waste not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). vi. Four (4) 100-ml Erlenmeyer beakers and flasks with Unknown Waste, none labeled as "Unwanted Material," nor dated with their accumulation start dates (N/UM, N/D). 3.3.14 Chemical Laboratory Inorganic Chemistry Q-110 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Status: Final 43 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Tray No. 1 - Satellite Accumulation Area i. On top of a laboratory cabinet table there were numerous (approximately over thirteen 13) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories, few of them properly labeled as "Unwanted Materials," but not dated with their accumulation start dates (N/UM, N/D) (see Picture No. 64). ii. One (1) 4-liter ambar container with a spent solvent waste not labeled as "Unwanted Materials," and dated with its accumulation start date of February 6, 2017, which exceeded over six months the LMP collection protocols (N/UM, N/D). iii. Two (2) 1-liter ambar containers with spent solvent wastes not labeled as "Unwanted Materials," but dated with their accumulation start dates of February 8, 2017, which exceeded over six months the LMP collection protocols (N/UM, N/D). iv. One (1) 500-ml container with Hydrochloric Acid mixed with Amonium Hydroxide, not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). v. One (1) 500-ml container with Unknown Wastes, not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). vi. One (1) 500-ml container with Unknown Wastes, not labeled as "Unwanted Material," but dated with its accumulation start date of January 2, 2023 (N/UM, D). vii. One (1) 1-liter ambar container with Unknown Wates, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). viii. One (1) 1-liter ambar container with spent solvent with Iron, Potassium Hexacyanoferrate (III), and Iridium, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 65). ix. On3 (1) -gallon white container with "Solid Material," not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). x. One (1) discarded thermometer containing mercury, not labeled as "Unwanted Material," nor dated with its accumulation start date or properly protected to control mercury releases or spills content (N/UM, N/D). xi. One (1) 4-liter crystal container with Unknown Wates, not labeled as "Unwanted Material," but dated with its accumulation start date of September 9, 2019, which exceeded over six months the LMP collection protocols (N/UM, N/D). xii. One (1) 500-ml container with spent Ethanol Waste, not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). xiii. One (1) Erlenmeyer beaker, "open", containing discarded vials, not labeled as "Unwanted Material," nor dated with its accumulation start date (N/UM, N/D). 3.3.15 Chemical Laboratory Environmental Chemistry Q-106 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area Status: Final 44 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 i. One (1) 4-liter ambar container with a spent Methylene Chloride waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 66). ii. There were various styrofoam boxes containing Dissolve Oxygen Demand "High Range" test which uses Potassium dichromate as active ingredient (a strong base) and mercury. It was uncertain how COD vials were being disposed of since they are characterized as highly hazardous (see Picture No. 67). 3.3.16 Chemical Laboratory Electroanalytical Research Q-165 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. One (1) 1-gallon ambar container with a spent Sulfuric Acid waste, labeled as "Unwanted Materials," leaking, and dated with its accumulation start date of September 28, 2021, which exceeded over six months the LMP collection protocols (UM, N/D) (see Picture No. 68). ii. One (1) -gallon plastic container with "Drug Waste", not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). 3.3.17 Chemical Laboratory Organic Synthesis Research Q-163 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. On the laboratory floor there were numerous (approximately over twelve 12) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories, not properly labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM/, N/D) (see Picture No. 69). ii. Five (5) 4-liter ambar containers with spent solvent wastes, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). iii. Five (5) 250-ml containers with spent solvent wastes, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). iv. One (1) 1-gallon white container with a Solid Waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). v. One (1) 5-gallon white pail containing Unknown Waste Solvent, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). vi. Two (2) 4-liter and 250-ml ambar containers stored in shelves containing THF (Tetrahydrofuran), not in use or managed as "Unwanted Material," not dated and without a hazardous waste determination of the content of the containers. I mentioned that THF is common peroxide- forming after degradation if not used within 12 months. Status: Final 45 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 3.3.18 Chemical Laboratory Q-161 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes since this laboratory SAA was "Empty" at the time of the EPA Inspection. 3.3.19 Chemical Laboratory Research Q-159 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were numerous (approximately over ten 10) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories, not properly labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM, N/D) (see Picture No. 70). ii. One (1) 1-liter ambar container with a spent Dichloromethane waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). iii. One (1) 4-liter ambar container with a spent Ethanol waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). iv. One (1) 4-liter ambar container with a spent Benzene waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). v. One (1) 1-liter ambar container with a spent Hexane waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). vi. One (1) 1-liter ambar container with a spent Platinum waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). vii. Three (3) 50-ml crystal containers with a spent Diary Propionitrile (DPN) and Polyphosphate Kinase (PPK2) enzymes, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). viii. One (1) 250-ml crystal container with a spent Xylene waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). ix. One (1) 100-ml Erlenmeyer beaker with an Unknown Solid Waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). 3.3.20 Chemical Laboratory Surface and Materials Research Q-157 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 3.3.21 Chemical Laboratory Surface and Materials Research Q-155 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed Status: Final 46 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were numerous (approximately over eighteen 18 "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories, few properly labeled as "Unwanted Materials," or dated with their accumulation start dates (N/UM, N/D) (see Picture No. 71). ii. Two (2) 4-liter ambar containers with spent Silver Chloride and Sulfuric Acid wastes, labeled as "Unwanted Materials," and dated with its accumulation start date of July 20, 2013, which exceeded over six months the LMP collection protocols (UM, N/D). iii. One (1) 1-liter ambar container with a spent Matubo and Toluene waste, labeled as "Unwanted Materials," dated with its accumulation start date of July 20, 2013, which exceeded over six months of the LMP collection protocols (UM, N/D). iv. One (1) 2-liter ambar container with a spent Methyl Sulfoxide waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). v. One (1) 1-liter ambar container with a spent Hydrogen Peroxide waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). vi. One (1) 1-liter ambar container with a spent Methanol (MeOH) waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). vii. One (1) 1-liter ambar container with a spent Diethyl Ether waste, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). viii. One (1) 1-liter ambar container with contaminated used oil, not labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM, N/D). ix. One (1) -liter ambar container with "Hazardous Waste", not labeled as "Unwanted Materials," and dated with its accumulation start date of August 17, 2009, not managed as Unwanted Material or complying with the Laboratory Management Plan (N/UM, N/D) (see Picture No. 72). x. Over fifteen (15) small beakers and containers (Lab Packs) with Unknown Hazardous Waste, not labeled as "Unwanted Materials," nor dated with their accumulation start dates (N/UM, N/D). 3.3.22 Chemical Laboratory General Chemistry Q-228 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over four 4) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). Cabinet - Satellite Accumulation Area Status: Final 47 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 ii. Inside a cabinet there were various (approximately over eight 8) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 3.3.23 Chemical Laboratory General Chemistry Q-268 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over four 4) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 3.3.24 Chemical Laboratory General Chemistry Q-266 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over eight 8) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 3.3.25 Chemical Laboratory General Chemistry Q-230 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over six 6) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 3.3.26 Chemical Laboratory General Chemistry Q-258 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed Status: Final 48 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over three 3) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). Cabinet - Satellite Accumulation Area ii. Inside a cabinet there were various (approximately over four 4) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 3.3.27 Chemical Laboratory General Chemistry Q-238 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over four 4) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 3.3.28 Chemical Laboratory General Chemistry Q-240 EPA RCRA inspectors proceeded to inspect this chemical laboratory area. The EPA Inspectors observed the following at this location: Tray No. 1 - Satellite Accumulation Area i. Inside an extractor hood there were various (approximately over five 5) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories that were recently corrected by properly labeling them as "Unwanted Materials," and dated with their accumulation start dates (UM, D). 4 CLOSING MEETING (DAY 2 - MARCH 9, 2023) At 5:30 pm in the afternoon, a closing meeting was held for the day at the Chancellor's Office. EPA Inspectors met with Ms. Maria Isabel Fernndez, Health, Occupational and Environmental Safety Office Status: Final 49 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Director, and Ms. Damaris Santiago, Health, Occupational and Environmental Safety Specialist, Dr. Omar Molina, Dean of Administration Department, and Dr. Agustn Rulln (over the phone) Chancellor of the University of Puerto Rico, Mayagez-Campus. EPA Inspectors discussed the potential releases and/or threat of releases observed during the Inspection visit on March 9, 2023, at the Environmental Engineering Laboratory (R-018) of the University of Puerto Rico-Mayagez Campus. Our observations consisted of several chemical reagent containers that were identified to be leaking, deteriorated, expired (i.e., 1986), abandoned, not in use, not properly labeled, haphazardly stored, without secondary containment and not segregated by chemical compatibility. Based on the laboratory conditions, that may present an imminent and substantial endangerment to health or the environment. EPA Inspectors reiterated on the notification regarding EPA's environmental emergency area about an imminent risk situation at various locations at the time of the Inspection. Ms. Fernndez had spoken in various occasions with Mr. Carlos Huertas, EPA On-Scene Coordinator, and they agreed that the Agency would include additional environmental risk areas identified at the Campus and included them for removal and clean up activities as part of the original FINFI (Notice to Responsible Party) under CERCLA. The UPR Mayagez Campus committed to sending an action plan to address all environmental risk areas identified in laboratories and warehouse areas on or before noon on March 10, 2023. EPA Inspectors brought to the attention of Dr. Agustn Rulln, Chancellor, that during the Inspection, and according to what was observed in the Alzamora Farm pesticides warehouse (i.e., Dimethoate, Malathion, Azadirachtin), pesticide containers and boxes seemed abandoned, deteriorated, and expired or non in use pesticide materials. Containers appeared to have been impacted by rain events since aluminum windows were open and stored materials were adjacent to open windows. It was EPA Inspectors concern that exposure to some pesticides can cause rapid, fatal organophosphate poisoning with headache, sweating, nausea and vomiting, diarrhea, loss of coordination, muscle twitching, and potential death. It was recommended that emergency procedures should also manage the proper disposal of uncontrolled releases of pesticides at the Alzamora Farm pesticides warehouse. As discussed with Dr. Agustn Rulln, and as determined by EPA Inspectors during the Inspection, there were numerous laboratories managed under EPA Academic Laboratories Subpart K, which were not in compliance with the UPR Mayagez-Campus Laboratory Management Plan (LMP). It was explained that Subpart K provides standards for managing hazardous waste in academic laboratories at eligible academic entities as an alternative to the satellite accumulation area generator regulations or to traditional hazardous program. The Academy Laboratory Subpart K is an optional and flexible program that the Campus chose to implement under a LMP which better suites the specific activities conducted at the academic and research laboratories. However, it was observed that most of the Campus' laboratories do not comply with the requirement protocols of the LMP, and that was very worrying to EPA Inspectors, since the program should protect public health and the environment in the Campus. At the meeting, Dr. Agustn Rulln, committed himself to issue a University's Declaration of a State of Emergency to address as matter of urgency all necessary corrective measures to be carried out corresponding and meeting compliance with all the findings and statements made by EPA. Status: Final 50 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Additionally, EPA Inspectors requested that hazardous wastes generated from disposal and removal activities are required to comply with RCRA requirements. 5 FACILITY WALKTHROUGH (DAY 3 - MARCH 10, 2023) 5.1 CENTRAL ACCUMULATION AREA (CAA) EPA RCRA inspectors proceeded to inspect the Central Accumulation Area which houses all non-hazardous and hazardous wastes collected at the Campus under the Laboratory Management Plan (LMP) program. The Central Accumulation Area is a metal hangar warehouse (100 ft X 100 ft) with reinforced concrete floor used to store hazardous waste that are transferred to this location. It contains an explosion proof Hazmat Storage Building divided by means of steel metal walls into three independent compartments. It is in an isolated area away from Campus activities, and pedestrian accessible areas. It is also secured and protected around its perimeter. It is always closed, and with posted signs with the words, "Hazardous Waste Accumulation Area - Restricted Area Authorized Personnel Only," including emergency phone numbers (see Pictures No. 73 and 74). As observed, the base floor was free of cracks or gaps, and it was designed to contain leaks and spills in a collection sump. The room is well vented and provided with ambient controlled temperature in the area and emergency alarm and spill control equipment (see Picture No. 75). As referred in the Laboratory Management Plan (LMP), all unwanted materials must be moved only by OSSOA authorized personnel to the Central Accumulation Area (CAA). Once the unwanted material is moved to the CAA, the hazardous waste determination shall be made within four (4) days of the material arriving at the CAA. Within this four-day time frame, OSSOA personnel would determine if the material is eligible for re-use, recycling or will be handled as a nonhazardous waste. Mr. Williams Lozado, EH&S Officer, and Mr. Luis Ayala, EH&S Specialist, are the only persons in charge of this storage area, and all hazardous wastes, radioactive wastes, or extremely hazardous substances to be stored in the area need to be approved and coordinated through them. After the hazardous waste determination is made, all applicable requirements in the CAA will apply pursuant to 40 CFR 262.16. Mr. William Lozada is certified by the Puerto Rico Police and possesses an explosives licence. Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office, served as the UPR Mayagez Campus' representative. 5.1.1 Unwanted Materials Receiving Area As referred in the LMP, once the unwanted material is received in the CAA, the hazardous waste determination is be made within four (4) days of the material arriving at the CAA, dated with its accumulation start date, and store up to 180-days to be disposed of with Capitol Environmental Services, Inc., as a Small Quantity Generator pursuant to 40 CFR 262.16. It was observed that that some of the hazardous waste identified by the UPR-Mayagez Campus's representative at CAA were not properly labeled, without accumulation start dates, some were not shown clearly. Additionally, it was observed that some of the containers were not in good conditions or sealed to secure of any potential releases of waste content (see Pictures No. 76 and 77). Some containers were not RCRA coded (i.e., "D001") nor identified with its hazard communication pictograms as required by RCRA regulations (see Picture No. Status: Final 51 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 78). However, they were separated by physical means to protect each other from incompatibility of waste (e.g., spent acids, caustic soda). 5.1.2 Hazardous Wastes Flammable Area EPA RCRA inspectors proceeded to inspect this Central Accumulation Area. The EPA Inspectors observed the following at this location: i. Seven (7) 15-gallon blue drums containing flammable liquid wastes (Ethanol, Methanol, AcetoneD001), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates on October 6, 2022, December 13, 2022, February 28, 2023, November 18, 2022 (2), March 8, 2023, and August 16, 2022, respectively (see Picture No. 79). All drums were clearly labeled, coded as "D001,"and identified with its hazard communication pictograms as, "Flammable Liquids," (see Picture No. 80). ii. Five (5) 5-gallon white drums containing flammable liquid wastes (Ethanol, Methanol, AcetoneD001), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates on February 8, 2023, March 8, 2023, August 3, 2023, March 7, 2023, and February 6, 2023, respectively (see Picture No. 81). All drums were clearly labeled, coded as "D001", and identified with its hazard communication pictograms as, "Flammable Liquids," (see Picture No. 82). iii. One (1) 55-gallon white drum with flammable liquid waste (Methanol, Ethyl Acetate, Acetone, Dichloromethane), clearly labeled with the words, "Hazardous Waste," and dated on June 6, 2022, not coded as "D001," nor identified with its hazard communication pictograms as, "Flammable Liquids," (see Picture No. 83). EPA Inspectors indicated that the storage accumulation time exceeded over 180-day, as required for a Small Quantity Generator. 5.1.3 Hazardous Wastes Corrosive Area EPA RCRA inspectors proceeded to inspect this Central Accumulation Area. The EPA Inspectors observed the following at this location: i. Six (6) 5-gallon white drums containing corrosive liquid wastes (Sodium Hydroxide, Hydrochloric Acid, Hydrogen Peroxide, and Sulfuric Acid-D002), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates on September 1, 2022, August 17, 2022 (2), September 15, 2022, December 15, 2022, and August 17, 2022, respectively. All drums were clearly labeled, coded as "D002," and identified with its hazard communication pictograms as, "Corrosive Liquids," (see Picture No. 84). ii. Three (3) 15-gallon blue drums containing corrosive liquid wastes (Sodium Hydroxide, Hydrochloric Acid, Hydrogen Peroxide, and Sulfuric Acid-D002), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates on November 29, 2022, December 16, 2022, and December 13, 2022, respectively. All drums were clearly labeled, coded as "D002," and identified with its hazard communication pictograms as, "Corrosive Liquids," (see Picture No. 85). iii. One (1) 1-gallon crystal bottle containing corrosive liquid wastes (Acetic Acid, Glacial-D002), clearly labeled with the words, "Hazardous Waste," and dated with its accumulation start date on Status: Final 52 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 March 9, 2023. The bottle was not clearly labeled, nor coded as "D002," nor identified with its hazard communication pictograms as, "Corrosive Liquids," (see Picture No. 86). iv. Three (3) 15-gallon blue/white drums containing corrosive liquid wastes (Sodium Hydroxide, Hydrochloric Acid, Hydrogen Peroxide, and Sulfuric Acid-D002), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates on April 29, 2022, May 12, 2022, and January 11, 2022, respectively. All drums were not clearly labeled or coded as "D002," nor identified with its hazard communication pictograms as, "Corrosive Liquids," EPA Inspectors indicated that the storage accumulation time for the three drums exceeded the 180-day requirement for a Small Quantity Generator (see Picture No. 87). 5.1.4 Hazardous Wastes Toxic Area EPA RCRA inspectors proceeded to inspect this Central Accumulation Area. The EPA Inspectors observed the following at this location: i. Six (6) 500-ml, 250-ml, and 100-ml small ambar containers containing toxic solid wastes (Ampicin, Potasium Chromate, Hydroxide, and Butyronitrile), clearly labeled with the words, "Hazardous Waste," and all dated with their accumulation start dates on October 21, 2022. All containers were not clearly identified with its hazard communication pictograms as, "Toxic Solids." At time of the RCRA Inspection all pictograms were posted on the containers (see Picture No. 88). ii. Four (4) 5-gallon white containers and one (1) cardboard box with discarded alkaline batteries, open and not clearly labeled with the words, "Universal Waste," nor dated with their accumulation start dates. None of the containers or the box were clearly identified with its hazard communication pictogram as, "Corrosive Solids," (see Picture No. 89). iii. Two (2) plastic trays with discarded alkaline and computer lithium batteries, open and not clearly labeled with the words, "Hazardous Waste," nor dated with their accumulation start dates. None of the trays were clearly identified with its hazard communication pictogram as, "Ignitable and Reactive Solids," (see Picture No. 89). 5.1.5 Hazardous Wastes Explosive (Reactive) Area EPA RCRA inspectors proceeded to inspect this Central Accumulation Area. The EPA Inspectors observed the following at this location: i. Inside a metal cabinet there were five (5) carboard boxes and one plastic four-pack containing discarded bengale flares, not clearly labeled with the words, "Hazardous Waste," nor dated with their accumulation start dates. All boxes were not clearly identified with its hazard communication pictograms as, "Explosive Solids," (see Picture No. 90). ii. Inside a metal secured cabinet there were explosive reagents (i.e., Nitric Acid, Potassium Permanganate, Ammonium Hydroxide, Sulfuric Acid, etc.) controlled and licensed by the Puerto Rico Police Department Explosives Unit. All reagents were well maintained, controlled and in compliance. Status: Final 53 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 5.1.6 Hazardous Wastes Alarm System Area EPA RCRA inspectors proceeded to inspect this Central Accumulation Area. The EPA Inspectors observed the following at this location: The Central Accumulation Area which houses all hazardous wastes collected and transported from UPRMayagez Campus for storge and final disposition by Capitol Environmental Services, is equipped with fire alarms, emergency system and security system. At the time of the Inspection, EPA inspector requested that the emergency and alarm system were tested to simulate a real case scenario of an emergency incident. UPR EHS officer proceeded to activate the alarm system, and once the alarm system stared sounding all fire suppressant material was concurrently activated and descended upon all of us in the CAA (see Picture No. 91). Therefore, it was concluded that the emergency system is fully functional. EPA Inspector stated that pursuant to 40 CFR 262.16(b)(8)(iii) all communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment must be tested and maintained as necessary to assure its proper operation in time of emergency. 5.1.7 Hazmat Storage Building Hazardous Wastes Outside Area EPA RCRA inspectors proceeded to inspect this Central Accumulation Area. The EPA Inspectors observed the following at this location: Room No. 1 i. Nine (9) 55-gallon blue/white drums containing corrosive liquid wastes (Chiller Washing Water - D002), clearly labeled with the words, "Hazardous Waste," and all dated with their accumulation start dates of January 12, 2023. All drums were clearly labeled, coded as "D002," and identified with its hazard communication pictograms as, "Corrosive Liquids," (see Picture No. 92). ii. Inside a metal cabinet there were five (5) 5-gallon containers with corrosive reagents (i.e., Sodium Hydroxide) secured by EH&S Officers. All reagents were well maintained, controlled and in compliance (see Picture No. 93). Room No. 2 iii. There were approximately thirty (30) decommissioned extinguishers for disposal without no hazardous waste determination made on them nor managed as hazardous waste due to its hazard content. Nine (9) 55-gallon blue/white drums containing corrosive liquid wastes (Chiller Washing Water - D002), Room No. 3 iv. Six (6) 1-gallon crystal containers containing radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," being stored for years without no hazardous waste determination made on them nor managed as hazardous waste due to its radioactive-corrosive hazard content as indicated by Ms. Maria Fernndez (see Picture No. 94). She added that no Hazardous Waste Disposal Contractor Status: Final 54 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 in the Island would transport or dispose of radioactive waste and that is the reason those wastes have been stored for years (see Picture No. 95). v. Inside a plastic tray there were three (3) 50-ml (30-g) crystal containers containing radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," being stored for years without no hazardous waste determination made on them nor managed as hazardous waste due to its radioactivecorrosive hazard content (see Picture No. 96). As observed by EPA Inspectors, most of the waste stored in this room consisted of Uranyl Acetate, Nitrate of Uranyl, and Carbon 14 radioactive-corrosive wastes generated by Marine Science, Chemistry and Biology Departments. EPA Inspectors stated that a certified Radiation Safety Officer is needed at the Campus for the proper management of these radioactive wastes, and they should also contact the Department of Energy (DOE) for regulatory requirements. EPA Inspectors also advised to contact the Nuclear Regulatory Commission (NRC) to request how all these radioactive wastes should be removed from UPR Mayagez Campus for the proper management and final disposition. EPA Inspectors noted that some of the hazardous wastes identified at the Central Accumulation Area were not properly labeled, without accumulation start dates, and some were not clearly shown. Additionally, it was observed that some of the containers were not in good conditions or sealed to secure of any potential releases of waste content, and no hazardous communication pictograms were posted on the containers at the time of the Inspection. In general, EPA Inspectors observed at the Central Accumulation Area the list of names and telephone numbers in case of an emergency at visible locations, specifically, nearby the hazardous waste storage trailer, cabinets, and receiving areas. There were telephones in place and two-way communication system. In additon, the CAA was equipped with alarm systems, sprinkler systems, and extinguishers nearby areas where hazardous wastes were stored. Table No. 3 depicts the inventory of Flammable Hazardous Wastes recorded at Central Accumulation Area during EPA Inspection provided by Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office. Table No. 3 -Inventory of Flammable Hazardous Wastes Recorded at the Central Accumulation Area - March 10, 2023 Name Container Capacity Categorization Date Dimethyloctadecyl[3-(trimethoxysilyl) propyl] ammonium Chloride 60% in methanol 100 ml 7-Sep-22 Status: Final 55 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Water 90%, Methanol, Ethanol, Toluene, Tetrahydrofuran, Chloroform, Pyridine, 4-Picoline, Strontium Chloride, Cupric Chlorate, Berilium Sulfate 500 ml Styrene Pyridine Sephadex LH-20 diried in Methanol, Ethanol and Isopropanol Methanol, Ethanol, Isopropanol, Acetonitrile, Ethyl Acetate, Petroleum Ether, Acetone, Chloroform, Vegetal Oil Quinaldine Fumonisin B Hydranal std Electrospray and APCI Performance Mathanol, Ethanol, Propanol, 2-Propanol, 2-Butanol, Dichlrobenzene, 0-Xylene Water, Caffeine, Hydrochloric Acid 1M, Ethanol, Tert-Butyl Chloride, Methanol, Acetone, Acetic Acid, Nitroaniline Water, Hydrochloric Acid, Fluoridric Acid, Nitric Acid, Methanol, Ferric Chloride 1 L 1 L 2.5 kg 2.5 L 1 L 10 l 40 ml 5 ml ampules 1L 4L 4L Sodium Hydroxide, Ethyl Acetate, Hydrochloric Acid, Sodium Carbonate Hexane, Oxibenzona, Methanol, 2-Propanol, Butanol, Acetonitrile, Formaldehyde Calcium Chloride, Sodium Chloride, Manganese Chloride, Barium Chloride, Cupric Bromide, Copper Chloride, Nickel Chloride, Calcium Chloride, Zinc Chloride, Water, Triethylamine, Dimethylacetamide, 2-Bromopropionyl Bromide, Aniline 3%, Potassium Permanganate 1.0M, Ferric Chloride, Potassium Chloride, Sodium Hydroxide 1.0M, Hexylimidazole, Sulphuric Acid, Acetic Anhydride, Dichlromethane, Hydrochloric Acid, Methanol, Hexanol, Ethyl Ether, Pentane, Acetone, Triethylamine, Dichloromethylsilane, Methyl tert-Butyl Ether, Hexane, Dieldrine, Dimethl sulfate, Aldrine, Siloxanes, Endrine, Status: Final 56 15 gal 15 gal 15 gal 7-Sep-22 16-Agosto-22 30-Nov-22 30-Nov-22 30-Nov-22 12-dic-22 9-Mar-23 9-Mar-23 7-Mar-23 8-Feb-23 8-Feb-22 8-Feb-22 18-Nov-22 13-dic-22 16-agosto-22 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Acetonitrile, Bromacil, Cadmium Selenide, Ammnium Hydroxide, Titanium Dioxide, Phenolphthalein, Propanol, Ethanol, Petroleum Ether, Ethyl Acetate Hexane, Methyl Tert-Butyl Ether, Dichloromethane, Acetonitrile, Ethyl Ether, Methyl Red, Sodium Acetate, Phenolphthalein, Ethanol, Methanol, 1-Butanol, 2-Butanol, 2Propanol, Cyclohexane, p-Dichlorobenzene, Naphthalene, Tetrahydrofuran, Methylamine, Acetone, Chitosan, Silver Nitrate, Pectin, Citric Acid, Titanium Dioxide, Potassium Nitrate, Sodium Molybdate, Potassium Disulfate, Potassium Antimony Tartrate, EDTA, Cadmium, Bensenesulphonic Acid, 2,5-Dihydroxybenzoic Acid, cas 7263-92-0 Mercuric Chloride, Hydrochloric Acid, m-Cresol Purple, Methanol, Hydrogrn Sulphide, Ethyl Acetate, Dichloromethane, Acetone Water, Methanol, Ethyl Acetate, Dichloromethane, Acetone, Hexadecyltrimethylammonium bromide, Dodecyl Trimethyl Ammonium Bromide, Sodium Chloride, Gold Chloride, 1Octanethiol, 1-Decanethiol, 11-Mercapto-1-undecanol, 11Amino-1-undecanol, Ethanol, Polymethyl Pentone, Acetonitrile, Triethylamine, Titanium Oxide, Hydrochloric Acid, 2-Propanol, Acetic Acid, Urea, Octasulfonic Acid, Ammonium Formate, Zinc Oxide, Titanium Oxide Spartan Products. Contains: Methylene Chloride and Perchloroethylene Spartan Products. Contains: Methylene Chloride and Perchloroethylene Mercuric Chloride, Hydrochloric Acid, m-Cresol Purple, Methanol, Hydrogrn Sulphide, Ethyl Acetate, Dichloromethane, Acetone Water, 2-Propanol, Acetonitrile, Methanol Methanol, Ethanol, Waer, Titanium Oxide, Oxybenzene 15 gal 55 gal 15 gal 15gal 5gal 5 gal 5 gal 5 gal 12-dic-22 29-julio-22 28-Feb-23 8-Mar-23 8-Mar-23 1-Mar-23 8-Mar-23 8-Mar-22 Table No. 4 depicts the inventory of Corrosive Hazardous Wastes recorded at Central Accumulation Area during EPA Inspection provided by Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office. Status: Final 57 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Table No. 4 -Inventory of Corrosive Hazardous Wastes Recorded at the Central Accumulation Area - March 10, 2023 Name Container Capacity Categorization Date Mercury 10 ml 14-dic-22 Cesium Chloride solution 1L 14-dic-22 Cadmium, Sodium Hydrosulfide, Indole-3-Acetic Acid, Gibberillic 1 kg Acid, Cadmium Sulfide, Lead metal, Ferric Oxide, Calcium Carbonate 30-Nov-22 Pyridine, Sodium Hydroxide, Hydrochloric Acid, Water 1L 30-Nov-22 Sodium Sulfide 1 kg 24-agosto-22 Ammonium Nitrate 500g 23-Feb-23 1,1-Diethyl-4,4-carbocyanine iodide, 1,1-Diethyl-2,2- 4L dicarbocyanine iodide, 1,1'-Diethyl-2,4'-cyanine iodide, 3,3- Diethyloxadicarbocyanine iodide, 3,3-Diethyloxacarbocyanine iodide, 3,3-Diethylthiatricarbocyanine iodide, 1,1-Diethyl-2,2- carbocyanine iodide 30-Nov-22 Folin Phenol solution, Acid Phenol Magnesium Sulfate, Calcium Sulfate, Zinc Sulfate, Magnesium Chloride, Cobalt Chloride, Sodium Sulfate, Manganese Sulfate, Zinc Nitrate, Cupric Sulfate, Barium Chloride, Nickel Sulfate, Calcium Chloride, Sand Rif Ampicin Butyrinitrile Formamide Potassium Chromate Cycloheximide Phenyl Mercaptan 2.5L 1 kg 25g 100 ml 500 ml 500g 10g 500ml 14-dic-22 3-Feb-23 21-Oct-22 21-Oct-22 21-Oct-22 21-Oct-22 21-Oct-22 21-Oct-22 Status: Final 58 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Mercury Wetted contact relay Acetic Acid Water, Cu, Ni, Fe, Manganese Chloride, Zinc Chloride, Selenium, Nitric Acid 3% Water, Cu, Ni, Fe, Manganese Chloride, Zinc Chloride, Selenium, Nitric Acid 3% Titanium Oxide, Zinc Sulfate, Ethanol, Cadmium, Methyl Blue, Nitric Acid Mercury, Nitric Acid 3% Hydrofluoric Acid, Nitric Acid, Water Water, Arsenic, Strintium, Antimony, Cobalt, Calcium, Magnesium, Magnesium Standard, Scandium Std., Nitric Acid 5% 2.5 kg 2.5L 1L 500 ml 2.5L 100 ml 1L 1L Sodium Dodecyl Sulfate Manganese Sulfate, Sodium Hydroxide, Sulfuric Acid, Sodium Iodide, Potasiium Iodide, Potassium Iodate, Thiosulfate Manganese Sulfate, Sodium Hydroxide, Sulfuric Acid, Sodium Iodide, Potasiium Iodide, Potassium Iodate, Thiosulfate, Sodium Bisulfite 0.20%, Acetato de Zinc 30%, Potassiun Ferrocyanide, Honey Sodium Chloride, Magnesium Sulfate, Zinc Sulfate, Gallium Oxide, Zirconium Oxide, Sodium Carbonate, Copper Oxide, Sodium Hydroxide, Potassium Permanganate, Potassium Chloride, Ammonium Chloride, Hydrochloric Acid, Nickel Chloride, Methyl Orange, Nitric Acid, Ferric Nitrate, Sodium Thiocyanate, Copper Sulfate, Ferric Chloride, Ferric Salicilate, Aspirin, Acetic Anhidride, Salicylic Acid, Sulfuric Acid, Nitrates of: Nickel, Barium, Iron, Zinc, Copper, Lead and Calcium Chlorides of: Iodine, Bromine, Potassium, Nickel, Calcium 100g 15 gal 15 gal 15 gal Methanol, Sodium Hydroxide, Magnesium Sulfate, Thioglycolic Acid, Zinc Sulfate, Manganese Sulfate, Water, Sodium Sulfide, Hydrochloric Acid, Sodium Hydroxide, Copper Nitrate, Phenol, Ammonium Iron Sulfate, Sulfuric Acid, Potassium Dichromate, Ethanol, silver Nitrate, Cadmium, Nitric Acid 15 gal Status: Final 59 8-Mar-23 9-Mar-23 9-Mar-23 9-Mar-23 9-Mar-23 9-Mar-23 7-Mar-23 9-Mar-23 9-Mar-22 27-Jul-2022 27-Jul-2022 29-Nov-22 25-Oct-2022 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Hydrochloric Acid 4.8 M, Bromothymol Blue Hydrochloric Acid, sulfuric Acid, Phosphoric Acid, Potassium Dichromate, Potassium Permanganate, Sodium Hydroxide, Calcium Chloride, Barium Chloride, Manganese Chloride, Sodium Chloride, Potassium Chloride Wash water from central air conditioning plant: Contains: Hydrochloric Acid, Trce of Copper and Iron Water, Methyl Orange, Hydroquinone, Phenanthroline, Sulfuric Acid, Manganese Sulfate, KHP, Sodium Citrate, Ammonium Sulfate, Methylene Blue, Sodium Hydroxide, Sodium Iodide, Potassium Iodide, Potassium Iodate, Sodium Phosphate, Potassium Nitrate, Ammonium Chloride, Sodium Bicarbonate, Zinc Sulfate, Copper Sulfate, POtassium Chloride, Calcium Carbonate, Strontium Chloride, Nickel Chloride, Silver Nitrate, Magnesium Chloride, Nitric Acid, Calcium Chloride, Barium Chloride, Iron Chloride, Hydrogen Peroxide, Manganse Oxide, Lead Nitrate, Zinc Nitrate, Cupric Nitrate 15 gal 15 gal 55 gal 55 gal 29-Aug-2022 16-Aug-2022 12-Jan-2023 25-Jan-2023 Water, Ludox HS-40, Bis(pentamethylcyclopentadienyl)Cobalt (III) 5 gal Water, Sodium Hydroxide 40%, Boric Acid 4%, Sulfuric Acid, 5 gal Missouri Catalyst, Hydrogen Peroxide 30%, Hydrochloric Acid 0.20 N Sodium Thiosulfate, Clorox, Potassium Iodide, Hydrochloric Acid, 5 gal Sodium Hydroxide, Potassium Hydrogen Phtalate, Water, Sulfanilamide, Sulfuric Acid, Barium Chloride Sulfanilamide, Ammonium Sulfate, Hydrochloric Acid, Potassium 5 gal Phosphate, Nitrite Standard, N-(1-naphtyl)-ethylenediamine Potassium Permanganate, Sodium Hydroxide, Water 5 gal 1-Sep-22 17-Aug-2022 15-Dic-2022 17-Jan-2023 25-Jan-2023 5.2 BUILDINGS AND LAND DEPARTMENT The Buildings and Land Department houses the carpentry, wood & cabinets shop, steel metal shop, plumbing, air conditioning repair shop, painting shop, electrical and light repair shop, light automobile mechanic services, and physical maintenance and cleaning departments which supports all Campus' activities. This building also houses various warehouses for raw material products and equipment Status: Final 60 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 replacement parts. Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office, served as the UPR Mayagez Campus' representative. 5.2.1 Mechanic Shop Light mechanic repairs and preventive maintenance to vehicles fleet is performed at this Mechanic Shop. At the time of the Inspection, EPA Inspectors met with Mr. Ramon Collazo, Automotive Technician, and Mechanic Shop Supervisor. Services at this Mechanic Shop mainly include used oil and spent oil filter changes, and batteries' replacement, among other light repair jobs. Oil and filter changes are part of the vehicle's preventive maintenance program. Used oil is placed in 5-gallon containers and transferred to an on-site 200-gallon double wall Used Oil Tank. The Used Oil is later disposed of by a local used oil collector company. At the time of the inspection, Mr. Collazo informed that the quantity of used oil generated at the facility is relatively small and depends on the numbers of units in service. Used Oil impacted materials are disposed of as domestic garbage. Mr. Collazo indicated that the quantity of used oil impacted materials generated at the facility was unknown. No hazardous waste determination has been made on the used oil impacted materials before disposal of and mixed with their solid waste. Approximately twenty (20) used oil filters are generated from vehicles' preventive maintenance program monthly. Used oil filters are not punctured and/or crushed, but they are hot drained between 24 - 48 hours before been disposed of with the local used oil collector company. At the time of the Inspection, Mr. Collazo indicated that he did not know about the transporter who picks up the used oil filters. EPA RCRA inspectors proceeded to inspect this Mechanic Shop Area. The EPA Inspectors observed the following at this location: i. One (1) 55-gallon blue drum open with impacted material with used oil not marked with the words, "Used Oil" (see Picture No. 97). ii. One (1) 5-gallon black pail with used oil not marked with the words, "Used Oil" (see Picture No. 98). iii. One (1) 200-gallon double wall Used Oil Steel Tank marked with the words, "Used Oil." However, there were old and new used oil spills and stains on the concrete floor of the used oil and it seemed that multiple used oil spills have occurred continuously, since the floor around the tank was impregnated with used oil and dust debris. EPA inspector stated that pursuant to 40 CFR 279.22(d), requires that upon detection of a release of used oil to the environment, a generator must stop the release, contain the released of used oil; and clean up and manage properly the released used oil and other materials (see Picture No. 99). iv. One (1) 30-gallon container part-washer machine which uses CB-100 degreaser (e.g., biodegradable water-based cleaner and degreaser) to clean up auto parts. At the time of Inspection, the part-washer machine was out of service for the last three months, and mechanics were using diesel as a replacement to clean auto parts at the part-washer station (see Picture No. 100). v. One (1) 55-gallon black drum open on top with spent used oil filters impregnated with used oil not marked with the words, "Used Oil" (see Picture No. 101). Status: Final 61 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 5.2.2 Refrigeration Shop At the Refrigeration Shop services include diagnosing, testing, and repairing refrigeration equipment as needed based on the UPR Mayagez Campus to ensure their refrigeration equipment runs properly. At the time of the Inspection, EPA Inspectors met with Mr. Jose L. Torres, Refrigeration Technician, and Mr. Pedro Mas. Mr. Mas stated that discarded equipment such as compressors and air conditioning parts are disposed of at the Mayagez Municipal Landfill. Other scrap metals components are disposed of with Homeca Recycling, Inc. EPA RCRA inspectors proceeded to inspect this Refrigeration Shop Area. The EPA Inspectors observed the following at this location: i. One (1) 55-gallon blue drum with a yellow drainage tray on top with used oil generated from draining compressors, not marked with the words, "Used Oil" (see Picture No. 102). ii. Two (2) 1,000 pounds steel tanks with discarded refrigerants, not marked with the words, "Used Refrigerant" (see Picture No. 103). EPA Inspectors explained that pursuant 40 CFR 261.4(b)(12) chlorofluorocarbons (CFC) refrigerants that cannot be reclaimed must be evaluated to determine if they exhibit any of the characteristics of a hazardous waste (i.e., ignitability, corrosivity, reactivity, and toxicity). Therefore, those exhibiting such characteristics must be handled according to regulations established under RCRA. Non-CFC refrigerants destined for reclamation or recycling that involves filtering, cleaning, or purifying the refrigerants prior to reuse may be considered wastes and must also be evaluated to determine if they are hazardous wastes and managed accordingly. 5.2.3 Cleaning Warehouse Shop EPA RCRA inspectors proceeded to inspect the Cleaning Warehouse Shop which stores cleaning products for the sanitation and maintenance of Campus Buildings. Mr. Wilfredo Vargas Rivera, Warehouse Technician, and Mr. Ramon E. Cardona, Warehouse Shop Supervisor, served as the UPR Mayagez Campus' representative and escort. EPA Inspectors requested the inventory of product purchased that has historically been used for cleaning purposes in the Campus (see Picture No. 104). Table No. 5 summarizes the inventory of cleaning products and hazardous chemical solvents stored in the Cleaning Operations Shop, Table No. 5 - Inventory of Cleaning Products and Hazardous Chemical Solvents March 9, 2024 Product Name Qt. Volume Product Name Qt. Volume Multi Acid Bowl & Urinal Cleaner 9 Bottles Germicidal Bowl Cleaner 6 Bottles Consume - Disinfectant for 4 toilers and urine bowls Bottles Premium Wood Polish Boxes 9 Bottles Status: Final 62 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Bowl cleaner - Cleaning 9 Acid for toilers and urine bowls Toilet Bowl Cleaner Remove 15 Rust & Minerals Stainless Steel Polish & Cleaner 8 Graffiti Remover 3 Hand Sanitizer (Alcohol) 1 Cans Dem-Tech ACTIV Germicidal 4 Boxes Detergent Plastic Cans Bleach Regular Cans Boxes Cans Gallon Water Based Shine Maintainer Air Wick Deodorant HDQ Neutral Disinfectant 7 Container 3 Bottles 10 Cans 1 Gallon It was observed by EPA Inspectors that many of the cleaning solvent products were concentrated and contained hazardous substances as active ingredients (see Picture No. 105). After thorough evaluation of the products Safety Data Sheets (SDSs), some of the cleaning products could be potentially hazardous to the environment if disposed of inappropriately. As observed by EPA Inspectors throughout the campus locations, and at the time where cleaning operations were undertaking, many of the cleaning solvents were not diluted as indicated in the product instructions and placed directly on surfaces to clean or to disinfect surfaces or floors. Many of the cleaning material impacted such as rags with solvents were disposed of with domestic garbage as well as left over from non-used products. EPA Inspectors instructed Mr. Cardona to train his employees in the proper management and disposal of these hazardous wastes (i.e., contaminated rags). EPA Inspectors reiterated that products containing hazardous substances as active ingredients, and as specified in the product's SDSs, must be managed in a manner to avoid the disposal into the environment as a hazardous waste. Additionally, hazardous waste determinations must be done before residual waste or impacted materials are disposed of as solid waste. It was also observed that the list products used at the shop were non-biodegradable products such as stripper furniture, oil cleaning, bowl cleaning, bacteria control, and degreasers (i.e., waxes) were applied on floors, bathrooms, common areas throughout the Campus. It was stated by Mr. Cardona that most of the inventory of products is always in use, and that expired products, if any, are disposed of as hazardous waste such as stripper remover wax, and degreasers for stains. However, no hazardous waste determination has been performed on discarded solid waste from cleaning operations identified throughout the Campus before its final disposition. 5.2.4 Fields and Roads Shop The Fields and Roads Shop provides maintenance and preventive services to Campus green areas. At the time of the Inspection, EPA Inspectors met with Mr. Eduardo Ibarrondo, Shop Supervisor. EPA RCRA inspectors proceeded to inspect this Fields and Roads Shop Area. The EPA Inspectors observed the following at this location: i. One (1) 30-gallon container part-washer machine which uses mineral spirit degreaser to clean up equipment parts served by Oil Energy System. At the time of Inspection, the part-washer machine Status: Final 63 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 was out of service for a long period of time, and mechanics were using diesel as a replacement to clean equipment parts at the part-washer station (see Picture No. 106). ii. One (1) 20-gallon black container open on top with spent used oil filters impregnated with used oil, not marked with the words, "Used Oil" (see Picture No. 107). iii. One (1) 55-gallon blue drum with a white drainage tray on top with used oil generated from draining landscape equipment, not marked as "Waste Oil," and without the words, "Used Oil" (see Picture No. 108). iv. One (1) 55-gallon white drum with a yellow drainage tray on top with used oil generated from draining landscape equipment, marked with the words, "Aceite Usado" (see Picture No. 109). v. One (1) 55-gallon white drum with rags impregnated with used oil, not marked with the words, "Used Oil" (see Picture No. 110). EPA inspector recommended to keep good housekeeping practices to avoid spills (apparently of used oil) on the floor. No hazardous waste determination has been made on the solid waste mixed with rags impregnated with used oil as observed in the inside the drum. 5.2.5 Universal Waste Storage Area EPA RCRA inspectors proceeded to inspect the Universal Waste Storage Area which stores spent fluorescent-lamps, batteries, ballasts, high-density halogen bulbs, sodium lamps, LED light cards, electrical pig tails, and emergency flooding light bulbs for the lighting maintenance of Campus Buildings and open areas. The EPA Inspectors observed the following at this location: i. One (1) 40-gallon container and three (3) 5-gallon pails, all open with broken fluorescent lamps (e.g., approximately over 20 spent broken bulbs each), mixed with crushed fluorescent lamps and high-density halogen bulbs showing evidence of breakage, leakage, and damage that could potentially cause a release of mercury or other hazardous constituents to the area (see Picture No. 111). ii. One (1) white plastic tray (1'x1'x 2') with crushed fluorescent lamps and high-density halogen bulbs showing evidence of breakage, leakage, and damage that could potentially cause a release of mercury or other hazardous constituents to the area (see Picture No. 112). iii. Sixty (60) square cardboard boxes (1'x1'x 4') packing over sixty (60) 4-foot spent fluorescent lamps, some open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates (see Picture No. 113). iv. Thirty (30) square cardboard boxes (1'x1'x 8') packing over sixty (60) 8-foot spent fluorescent lamps, open, not labeled with the words, "Universal Waste" or dated with their accumulation start dates (see Picture No. 114). v. Three (3) square cardboard boxes (1'x1'x 2'), one packing spent high-density halogen bulbs, the other packing electrical pig tails, and another one with LED light cards, not labeled with the words, "Universal Waste," or "Universal Waste-Mercury Containing Equipment," nor dated with their accumulation start dates (see Picture No. 115). Status: Final 64 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 vi. Two (2) green plastic trays (2'x2'x2') packing over twenty-five (25) U-shaped spent fluorescent lamps, open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates (see Picture No. 116). vii. One (1) 55-gallon white drum and one (1) square cardboard boxes (1'x1'x 4') packing over twenty (20) 4-foot and 8-foot spent fluorescent lamps, both open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates (see Picture No. 117). viii. Two (2) 55-gallon black steel drums with lids containing "Ballast" which were removed from aluminum frames. None of the drums were clearly labeled with the words, "Universal WasteMercury Containing Equipment," or dated (see Picture No. 118). ix. Two (2) cardboard box (1'x1'x 2') open with high-density halogen, open and not labeled with the words, "Universal Waste," or dated with their accumulation start (see Picture No. 119). x. One (1) cardboard box (1'x1'x 2'), open, with LED light cards, and not labeled with the words, "Universal Waste-Mercury Containing Equipment," or dated (see Picture No. 120). EPA Inspectors stated that any spent fluorescent lamp that is broken or shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment must immediately be cleaned up and placed in containers pursuant to 40 CFR 273.13(d)(2). We also stated that mercury-containing ballast must be managed in a way that prevents releases of any universal waste or component of a universal waste to the environment and must be placed in a container as a universal waste. Mmercury-containing equipment that shows evidence of leakage, spillage, or damage that could cause leakage must immediately be cleaned up and placed in appropriate containers pursuant to 40 CFR 273.13(c)(1). In addition, EPA Inspectors stated that each drum containing mercury-containing equipment must be labeled or marked clearly with the words, "Universal Waste-Mercury Containing Equipment," "Waste Mercury-Containing Equipment," or "Used Mercury-Containing Equipment." Similarly, each lamp or a container or package in which lamps are contained must be labeled or marked clearly with the words, "Universal Waste-Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." At the time of the RCRA Inspection, there were various broken fluorescent lamps inside drums, cardboard boxes and plastic trays mixed high-density halide bulbs without control or containment, showing evidence of breakage, leakage, and damage that caused releases of mercury or other hazardous constituents to the area at the Universal Waste Storage Area, not managed as per 40 CFR 273.13(d)(2). Additionally, there were various ballasts or mercury containing equipment inside cardboard boxes showing evidence of breakage, leakage, and damage that could potentially cause a release of mercury or other hazardous constituents to the area not managed as per 40 CFR 273.13(c)(1). At the time of the RCRA Inspection, there were various 55-gallon black steel drums and cardboard boxes containing "Ballast" or mercury containing equipment, none of the drums or boxes were clearly labeled with the words, "Universal Waste-Mercury Containing Equipment," as required pursuant to 40 CFR 273.14(d)(1). Status: Final 65 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 5.2.6 Paint Shop Warehouse The Paint Shop Warehouse provides painting jobs and maintenance to Campus Buildings and open areas (i.e., parking and sidewalks). At the time of the Inspection, EPA Inspectors met with Mr. Carmelo Diaz Rivera, Shop Supervisor. The EPA Inspectors observed the following at this location: i. Approximately nine-five (95) to over one hundred (100) 1-gallon paint pails were decommissioned since there were damaged due to the long period of time that they were not in use during the COVID-19 that became expired, deteriorated and many pails rusted because they were abandoned and not in use. Therefore, most of the paint pails were damaged and could not be used for painting. Most to the decommissioned pails were organic solvent based. No hazardous waste determination had been made on the contents to all the 5-gallon paint pails at the Paint Shop (see Picture No. 121). ii. It was noted that the practice to dispose of used brushes was to clean them up with solvent thinner, if it was no longer usable, then allow them to dry, and then dispose of as domestic garbage. This could be considered as illegal treatment of hazardous wastes (see Picture No. 122). At the time of the Inspection, EPA Inspectors recommended to the Paint Shop Supervisor to have available the Safety Data Sheet (SDS) for the type of paints (i.e., solvents, oil, and water base) being in use at the Campus, and to have knowledge and control of their content by implementing inventories of paint material in use to avoid paint waste being dumped into the environment. It was explained to Mr. Diaz that clean brushes with thinner and allowing them to dry and then disposed of as domestic garbage could be considered illegal treatment. EPA Inspectors added that on-site treatment and disposal of hazardous waste without a permit or interim status is a potential violation of both statutory and regulatory requirements. EPA Inspectors explained that treatment means any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume. Since paint brushed are cleaned up with solvent thinner, these discarded brushes are considered hazardous wastes which are being treated on-site. 5.2.7 Carpentry Shop The Carpentry Shop provides carpentry jobs and maintenance to Campus Buildings and open areas. At the time of the Inspection, EPA Inspectors met with Mr. Fernando Montalvo, Shop Supervisor. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. Status: Final 66 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 5.2.8 Plumbing Shop The Plumbing Shop provides plumbing jobs and maintenance to Campus Buildings and open areas. At the time of the Inspection, the shop was closed, and EPA Inspectors made a general view of the Plumbing Shop. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.2.9 Welding Shop The Welding Shop provides welding jobs and maintenance to Campus Buildings and open areas. At the time of the Inspection, the shop was closed, and EPA Inspectors made a general view of the Welding Shop (see Picture No. 123). The EPA Inspectors observed the following at this location: i. Over ten (10) 100-lbs, 75-lbs and 25-lbs gas cylinders stored in a concrete shed and secured with a cyclone fenced gates. There was oxygen, ethylene and other compressed gase cylinders stored in this shop used for welding jobs (see Picture No. 124). Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.3 DEPARTMENT OF AGRICULTURE - ALZAMORA FARM The Alzamora Farm was founded in 1946 for teaching purposes. It is currently used by undergraduate and graduate students, teachers, and employees as a teaching center and as a medium and support for research in the areas of agriculture and farming. The farm has a sales area of ornamental plants, medicinal plants, fruit trees and compost. The funds generated from these sales go into the Alzamora Farm general fund, which is used to purchase necessary equipment and agricultural materials in the laboratories and to spread plants. This farm also houses various warehouses, animal farms and ornamental plants areas. Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office, served as the UPR Mayagez Campus' representative. 5.3.1 Mechanic Shop The Mechanic Shop provides maintenance and preventive services to Agricultural equipment and vehicles. At the time of the Inspection, EPA Inspectors met with Mr. Elvin Ronda, Shop Supervisor. Services at this Mechanic Shop mainly include used oil and spent oil filter changes, and batteries' replacement, among other light repair jobs. Oil and filter changes are part of the vehicle's preventive maintenance program. Used oil is placed in 55-gallon drums from oil and filter changes during maintenance. The Used Oil is later disposed of by a local used oil collector company. Used Oil impacted materials are disposed of as domestic garbage. Mr. Ronda indicated that the quantity of used oil impacted materials generated at the facility was unknown. No hazardous waste determination has been made on the used oil impacted materials before disposal of and mixed with their solid waste. Used oil filters are not punctured and/or crushed, but they are hot drained between 24 - 48 hours before been disposed of with the local used oil collector company. Status: Final 67 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 EPA RCRA inspectors proceeded to inspect this Mechanic Shop Area. The EPA Inspectors observed the following at this location: i. Over ten (10) 4-foot spent fluorescent lamps, on the floor without control or containment showing evidence of breakage, leakage, and damage that could potentially cause a release of mercury or other hazardous constituents to the area (see Picture No. 125). ii. One (1) 55-gallon red drum open on top, with spent used oil filters impregnated with used oil not marked with the words, "Used Oil" (see Picture No. 126). iii. One (1) 55-gallon black steel drum, open, with used oil and not marked with the words, "Used Oil" (see Picture No. 127). iv. Two (2) 55-gallon blue plastic drums, one with a draining tray holding a spent oil filter. Both drums had used oil and were not marked with the words, "Used Oil"(see Picture No. 128). v. Two (2) 55-gallon blue plastic drums, with spent degreaser, not labeled with their waste content. No hazardous waste determination had been made on the contents of the two 55gallon drums at the Mechanic Shop (see Picture No. 129). vi. Five (5) vehicle and truck batteries on the floor discarded, without control or containment showing evidence of breakage, leakage, and damage that could potentially cause a release of Sulfuric Acid, and were not labeled with the words, "Hazardous Wastes," nor date with their accumulation start dates (see Picture No. 130). vii. One (1) Tractor 6600 parked outside of the shop releasing used oil on the ground from an engine leak. EPA Inspectors advised to stop, control, and clean up immediately the used oil release on the ground (see Picture No. 131). EPA Inspectors recommended to keep good housekeeping practices to avoid spills (apparently of used oil) on the floor. No hazardous waste determination had been made on the solid waste mixed with rags impregnated with used oil or discarded batteries as observed in the area. At the time of the Inspection, EPA Inspectors met with Mr. Jose Muoz Rivera, Farm Agronomist. 5.3.2 Pesticide Warehouse The Pesticide Warehouse is located at the Alzamora Farm and is used to store insecticide, fungicide, and herbicide products. At the time of the Inspection, the warehouse seemed abandoned, deteriorated and pesticide materials were either with expired dates or not being used. It was also seemed that pesticide materials were impacted by rain events since aluminum windows were open and stored materials were located adjacent to the windows. EPA Inspectors learned that the last application for most pesticides at the warehouse was logged in its Application Registry as of February 9, 2018 (see Picture No. 132). EPA RCRA inspectors proceeded to inspect this Pesticide Warehouse Area. The EPA Inspectors observed the following at this location: i. One (1) 2.5-gallon container with "Poast" herbicide which is a postemergence herbicide for control of annual and perennial grass weeds manufactured by BASF. The container seemed deteriorated and abandoned (see Picture No. 133). Status: Final 68 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 ii. Seven (7) 1-liter containers with Neem Oil "Dyna Gro" which is an organic solution used as a pesticide against insects, mites, or fungi in plants. The containers seemed not in use or abandoned (see Picture No. 134). iii. Two (2) 2.5-gallon container with "M-Pede" insecticide that provides excellent contact control of various insects. The container seemed not in use or abandoned (see Picture No. 135). iv. One (1) 55-gallon black steel drum with "Dipel DT" insecticide used for caterpillar control. The drum seemed not in use or abandoned (see Picture No. 136). v. One (1) cardboard box containing 20-liter "Hi-Yield" insecticide for termites, fleas, ticks, carpet beetles, and cockroaches manufactured by Hedwin, Baltimore, MD. The box seemed deteriorated, abandoned, and leaking on the shelf (see Picture No. 137). vi. One (1) 3-shelf metal storage rack containing ("Insecticides"): i) eight (8) plastic bags broken containing powder insecticide (Dipel Dry); ii) two (2) 1-lb bottles with Dipel 150 Dust insecticide; iii) two (2) 1-gallon containers with Vydate L insecticide; iv) two (2) 1-gallon containers with Malathion 56 EC insecticide; v) one (1) 2.5-gallon with Carbaryl insecticide; vi) one (1) l-liter bottle with Cygon 2E insecticide; vii) one (1) l-liter bottle with Mavrik insecticide; vii) one (1) 2-liter bottle with Alias 2F insecticide; and, vii) one (1) 5-gallon container with unknow insecticide; and six (6) 2.5-gallon and 1-gallon containers with unknow insecticide. All containers seemed deteriorated and abandoned and some were leaking on the shelves (see Picture No. 138). vii. One (1) 3-shelf metal storage rack containing ("Fungicides"): i) one (1) 2.5-gallon with Physan 2.0 fungicide; ii) two (2) 2.5-gallon with Banrot 40 WP fungicide; and iii) nine (9) 2-5-gallon and 1gallon containers with unknown fungicides (i.e., Ridomil, Tilt, Cabrio, Ethephon 2.0, Nutonex, Crymax, Systec 1998, Difel 150, Bravo 500 and M-Pde-C). All containers seemed deteriorated and abandoned and some were leaking on the shelves (see Picture No. 139). At the Alzamora Farm pesticide storage area, EPA Inspectors found pesticides stored in shelves which were made of metals and were corroded. Some pesticides were leaking on the shelves or the floor, in particular one box containing 20-liter "Hi-Yield" insecticide for termites, fleas, ticks, carpet beetles, and cockroaches and one 2.5-gallon container with unknown insecticide severely deteriorated and in detrimental conditions. There were other pesticides with torn labels inside plastic bags that appeared not to be in use or abandoned. The pesticide storage area had no weathering protection and was out of control releasing pesticides into the air and surrounding soils due to the detrimental conditions of the pesticide warehouse. As a result, the agronomist Jos Muoz Rivera made an inventory of the stored materials (March 15, 2023) (see Picture No. 140). The inventory was reviewed and updated and managed as follows: i. Pesticides products in good condition would be transferred to the Isabela Experimental Station. ii. Pesticide products in good condition would be transferred to the Department of Crops and Agro- Environmental Sciences of the Campus. iii. Pesticide products in good condition for which there is no use will be disposed of with the Health, Occupational and Environmental Safety Office for hazardous waste determination and characterization. iv. Materials in poor condition will be disposed of with the Health, Occupational and Environmental Safety Office for hazardous waste determination and characterization. Status: Final 69 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 5.4 CAMPUS HOTEL EPA RCRA Inspectors proceeded to inspect the Campus Hotel which stores cleaning products for the sanitation and maintenance of Hotel Buildings. Mr. Orlando Bellido, Hotel Shop Supervisor, served as the UPR Mayagez Campus' representative and escort. EPA Inspectors observed that many of the cleaning solvent products were concentrated and contained hazardous substances as active ingredients (see Pictures No. 141 and 142). After thorough evaluation of the products Safety Data Sheets (SDSs), some of the cleaning products could be potentially hazardous to the environment if disposed of inappropriately. EPA Inspectors instructed Mr. Bellido to train his employees in the proper management and disposal of these hazardous wastes (i.e., contaminated rags). EPA Inspectors reiterated that products containing hazardous substances as active ingredients, and as specified in the product's SDSs, must be managed in a manner to avoid the disposal into the environment as a hazardous waste. 5.5 PRINTING DEPARTMENT EPA RCRA inspectors proceeded to inspect the Printing Department which provide services of photocopies, printing, banners, flyers, handouts, pamphlets and manuals reproduction, and other special digitalized printing (i.e., maps, aerial photos. Mr. Jose Luis Caban, Printing Department Supervisor, served as the UPR Mayagez Campus' representative and escort. According to the information provided all photocopying, offset printing, screen printing of the Campus is done by computer digitalized process. All printing ink used to reproduce the imprint is water based therefore it does not contain hazardous ingredients. The Printing Office uses Digital Xerox machines in which ink cartridges are replaced on a tolling agreement with Xerox (see Picture No. 143). Old ink cartridges are collected by Xerox and replaced with new ones on a rotational basis. Mr. Caban indicated that the printing used to be offset by pressing machine (see Picture No. 144). He also indicated that wastes used to be generated from used rags impregnated with Supreme Plate Cleaner which were collected and sent to be laundered and reused. Also is generated Arabic Gum from cleaning press operations. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.6 SWIMMING POOL AREA EPA RCRA inspectors proceeded to inspect the Swimming Pool Area which is used asa the Health and Physical Fitness Center Facility for teaching and practicing swimming styles and surviving skill in water. Mr. Felix Vega, Swimming Pool Supervisor, served as the UPR Mayagez Campus' representative and escort. EPA Inspectors' were looking for existing conditions and control of chlorine gas cylinders which was considered a hazardous chemical of concern located in the swimming pool area. In a brief description, chlorine gas is primarily a respiratory irritant. In sufficient concentration, the gas irritates the mucous Status: Final 70 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 membranes, the respiratory tract, and the eyes. In extreme cases difficulty in breathing may increase to the point where death can occur from respiratory collapse or lung failure. The characteristic, penetrating odor of chlorine gas usually gives warning of its presence in the air. Also at high concentrations, it is visible as a greenish yellow gas. Mr. Felix Vega explained that all choline treatment at the swimming pool area is contracted out and is based on solid dosage of Sodium Chloride (NaCl) by a Pulsar 4 System (see Picture No. 145). The Pulsar 4 System controls and applies chemicals as needed to the pool water on a routine basis. This service is contracted out in which the contractor brings all the chemicals and feed the tanks, and therefore, there is not any chemical storage room at the swimming pool area (see Picture No. 146). Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.7 HEALTH FITNESS CENTER (NEW GYM) EPA RCRA inspectors proceeded to inspect the Health Fitness Center (New Gym) which provide athletic and physical fitness classes and a gym to Campus students. Mr. Juan G. Rivera, Center Administrator, served as the UPR Mayagez Campus' representative and escort. As observed by EPA Inspectors, raw material products that are used in this area mainly for cleaning such as waxes, finishing stripper, interlock metal degreaser, mechanic degreaser, spray cans (containing propane), and industrial floor cleaner for heavy stains and oily areas as stored in a brown cabinet secured lock (see Picture No. 147). Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.8 NURSING SCHOOL DEPARTMENT The Nursing Department houses the nursing school laboratories and teaching classrooms which are used to simulate medical emergencies and routine day care of hospital patients (see Picture No. 148). Mr. Michael Colon Rosado, Nursing School Administrator, served as the UPR-Mayagez Campus' representative and escort. As stated by Mr. Colon, vegetal blood is used for every simulated test or procedure performed by students at their nursing laboratories. Spent vegetal blood and spent related equipment (i.e., needles, syringes, gloves, and gauzes, among others) are discarded in red bags and containers which are later disposed of as biomedical waste by Stericycle Puerto Rico biomedical contractor (see Picture No. 149). Additionally, biomedical wastes such as spent needles and syringes, artificial spent lactose injection, saline water, glucose, and vegetal blood are generated at this department. Mr. Colon stated that no mercury-based thermometers or mercury containing equipment (i.e., sphygmomanometers) are generated by the school, only the disposition of simulated biomedical waste Status: Final 71 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 At this time, Mr. Colon accompanied EPA RCRA inspectors on a walk-through of the Nursing Department at the following areas: 5.8.1 Nursing Skills Laboratory The EPA RCRA inspectors proceeded to inspect the nursing skill laboratory. As observed by EPA Inspectors, spent synthetic blood (vegetable blood), spent needles, spent syringes, spent gauzes, spent cottons, spent artificial lactose solution serum, spent glucose solution serum, and spent normal saline serum are generated as part of the activities performed in this laboratory. All the above-mentioned wastes are collected at the laboratory in biomedical plastic red bags, and in red containers for sharp waste materials. Thereafter, all biomedical wastes are collected by Stericycle Puerto Rico for final disposition (see Picture No. 150). 5.8.2 Nursing Department Warehouse Area The EPA RCRA inspectors proceeded to inspect the warehouse area of the Nursing Department. There were just nursing school supplies for teaching classrooms. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.9 CAMPUS HEALTH MEDICAL SERVICES BUILDING The Health Medical Service Department provides dental and clinical services to the Campus' community. EPA Inspectors met Ms. Ileana Lebron, Medical Technician, and Ms. Mildred Rosa Rodriguez, Graduated Nurse. According to Ms. Lebron, used needles, syringes, gloves, gauzes are generated from medical services provided to either students and/or employees. Around a hundred (100) student patients are attended monthly. All medical waste generated is discarded as Biomedical Waste in red bags and in red containers for discarded sharp objects. As part of the activities conducted at the Medical Service Department, the facility generates biomedical waste which is disposed of by Stericycle Puerto Rico for final disposition. The UPR-Mayagez Campus has never notified EPA nor submitted a revised hazardous waste activity (i.e., EPA Form 8700-12) for the management of hazardous waste pharmaceuticals (40 CFR Part 266 Subpart P - Hazardous Waste Pharmaceuticals) generated at healthcare facilities and managed at reverse distributors. Ms. Lebron informed EPA RCRA inspectors that mercury thermometers are no longer used at present, since free-mercury thermometers are being acquired. A hazardous waste determination has been made on one mercury thermometer that is not currently in use and would be collected by the Health, Occupational and Environmental Safety Office for final disposal. As recommended by EPA Inspectors spent or expired pharmacy drugs or medicines should be disposed of as biomedical waste if they are not considered a hazardous waste (i.e., RCRA Characteristics or Listed under 40 CFR Part 261 Subpart C and D) with Stericycle Puerto Rico. She also informed that preventive maintenance is provided to their ambulance fleet by the Buildings and Land Department at the University Campus. Status: Final 72 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Ms. Torres accompanied us on a walk-through of the Medical Services Department. The following areas were visited: 5.9.1 Emergency Room EPA Inspectors observed red bags and red plastic containers used to store and dispose of biomedical waste properly labeled with such words. Controlled pharmacy drugs and medicines were stored together with some expired controlled pharmacy drugs which are disposed of as biomedical waste (see Picture No. 151). As reiterated by EPA Inspectors spent or expired pharmacy drugs or medicines should be disposed of as pharmacy drugs if they are not considered a hazardous waste (i.e., RCRA Characteristics or Listed under 40 CFR Part 261 Subpart C and D) with Stericycle Puerto Rico. 5.9.2 Clinical Laboratory EPA Inspectors observed that Safety Data Sheets (SDS's) were available at the Clinical Laboratory and were available for review. Observations at this area rendered no concerns. 5.9.3 Biomedical Waste Storage Area At the time of the inspection, biomedical waste generated was stored in Biomedical Waste red bags and containers to be disposed with Stericycle Puerto Rico. Observations at the Biomedical Waste Storage Area rendered no concerns. EPA Inspectors stated that expired medicines and/or pharmacy chemicals are always discarded as a Biomedical Waste. Some of the expired medications have hazardous waste characteristics and a proper hazardous waste determination must be made on expired medicines (see Picture No. 152). It was recommended that proper documentation should be maintained characterization of expired medicines as hazardous or non-hazardous wastes (i.e., biomedical wastes). 5.10 PHYSICS DEPARTMENT 5.10.1 Physics Laboratory Spectrometry (Geology) F-107 EPA RCRA inspectors proceeded to inspect this Geology Laboratory area. Ms. Yelitza Gonzalez, Laboratory Supervisor, served as the UPR Mayagez Campus' representative and escort. The EPA Inspectors observed the following at this location: i. Two (2) 4-liter ambar container with a spent Phosphoric Acid (100%) inside a blue plastic bin, no labeled as "Unwanted Material", dated with their accumulation start dates of July 18, 2003, and July 11, 2003, respectively, which exceeded over six months the LMP collection protocols (N/UM, D) (see Picture No. 153). In addition, both containers seemed abandoned and not being used, based onthe date posted on the containers. ii. One (1) 4-gallon bucket with a spent vials containing Phosphoric Acid (100%), not labeled as "Unwanted Material" nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 154). Status: Final 73 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 iii. One (1) 250-ml Erlenmeyer flask and discarded vials containing Phosphoric Acid (100%) inside a blue plastic bin, not labeled as "Unwanted Material" nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 155). 5.10.2 Physics Research Laboratory F-129 EPA RCRA inspectors proceeded to inspect this Physics Laboratory area. Mr. Omar Vazquez, Laboratory, Technician, served as the UPR Mayagez Campus' representative and escort. At the time of the RCRA Inspection, EPA Inspectors observed numerous expired chemicals (since before 2004), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more before 2004) in shelves without any physical means to protect each other from incompatibility of waste characteristics. As observed by EPA Inspector there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents. According to the Laboratory Technician, all these chemical reagents were not in use or discarded since years from 1970, 1980, and 1990 thru 2004 from various laboratory research seasons and were stored in this area and never declared as "solid waste material," or notified to the Health, Occupational and Environmental Safety Office (OPASO). There was no hazardous waste determination being performed on abandoned, expired, not in use, discarded hazardous chemical waste inventory before its final disposal nor have been managed under the Laboratory Management Plan. The EPA Inspectors observed the following at this location: i. At this laboratory the following chemical reagents, just to name a few, were found stored in a white solids' cabinet: sodium acetate, aluminium acetate, sodium sulfide, lithium hydroxide, tin (II) oxide, amonium hydroxide, demethyl carbonate, acetic acid glacial, propylene carbonate, toluene, oleylamine, 2-ethylhexanoic acid, acetonitrile, sulfuric acid, nitric acid, phosphoric acid, chloroform, silicone (IV) oxide, strontium carbonate, calcium nitrate magnesium carbonate, phosphoric pentaoxide, titanium (IV) oxide, triethylphosphine sulfide, boron oxide, lanthanum oxide, neodymium (V) oxide, bismuth metal, activated carbon, erbium (III) oxide, 4aminobenzophenone, silicon (II) oxide, calcium carbonate, sodium dodecyl sulfate, zinc acetate anhydrous, cesium chloride, chromium metal, arsenic metal, fluorene, sodium hydroxide, potasium hydroxide, cupric oxide, magnesium carbonate, gadolinium acetate, zinc sulfide, sodium chloride, pentacene, lithium carbonate, magnesium chloride among many other chemical reagents (see Picture No. 156). ii. Sodium hydroxide stored next to Polyvinylpyrrolidone; possible incompatible chemical reagents stored together without any mean of physical segregation. Sodium hydroxide should not be stored near acetaldehyde, acetic acid, hydrochloric acid, hydrofluoric acid, nitric acid, sulfuric acid, water, and other organics (see Picture No. 157). iii. Potassium Acetate stored next to Iron Acetate "moisture sensitive" possible incompatible chemical reagents stored together without any mean of physical segregation. Iron Acetate is air sensitive and recommended to be stored under inert gas (see Picture No. 158). iv. Potassium chloride stored next to Citric acid; possible incompatible chemical reagents stored together without any mean of physical segregation. Potassium chloride incompatible with acids, sulfuric acid, and citrates (see Picture No. 159). Status: Final 74 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 v. At this laboratory the following chemical reagents, just to name a few, were found stored in a gray solids cabinet: Nitroaniline stored next to ammonium, and cobalt (II) chloride which turns pink on exposure to air and moisture sensible and should be stored under nitrogen. All these chemical reagents were stored together without any mean of physical segregation nor hazardous determination made on them (see Picture No. 160). vi. In the gray solids' cabinet, there were unknown chemical reagents stored next to acids (i.e., tartaric acid, some seemed abandoned, not in use or stored in lieu of being disposed of as a hazardous (see Picture No. 161). vii. In the gray solids' cabinet, there was Potassium dichromate (i.e., oxidizers), stored next to Strontium hydroxide (i.e., inorganic bases) possible incompatible chemical reagents stored together without any mean of physical segregation nor hazardous waste determination (see Picture No. 162). viii. In the gray solids' cabinet, there was Lithium oxide stored next to Oxalic acid, and Lithium bromide (do nor store near acids nor bases) and Niobium (IV) oxide (i.e., oxidizers) possible incompatible chemical reagents stored together without any mean of physical segregation nor hazardous waste determination (see Picture No. 163). ix. In the gray solids' cabinet, there was a bottle of Hydrofluoric acid, broken, and leaking acid on cabinet shelf stored next to Sodium bromide, Sodium thiosulfate (violently reacts with strong oxidizers, and acids) and Silica gel incompatible with HF, incompatible chemical reagents stored together without any mean of physical segregation nor hazardous waste determination (see Picture No. 164). Table No. 6 summarizes the inventory of chemical solvents stored at the Physics Laboratory F-129 and recorded on March 10, 2023. Table No. 6 - Inventory of Chemical Solvents Stored at Physics Laboratory F-129 March 10, 2023 Container Description Container Size Number of Containers Status Propylene Carbonate 99% 250.00 g 2 Shelved Oleylamine tech. 70% 500.00 g 2 Shelved Ammonium Hydroxide ACS 28-30% 1.00 kg 2 Shelved Dimethyl carbonate 99% 500.00 g 2 Shelved Acetic Acid Glacial 2.50 L 14 Shelved Acetic Acid 2.5 L 3 Shelved Status: Final 75 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Acetic Acid Glacial 99.7% 2.00 L 1 toluene 1.00 L 2 Ammonium Hydroxide ACS 28-30% 1.00 kg 2 2-ethylhexanoic acid 99% Dimethyl carbonate 99% 4.00 L 2 500.00 g 2 Acetonitrile HPLC Sulfuric Acid 95-98% Nitric Acid 69-70% Chloroform ACS 99.8+% Phosphoric Acid ACS 85% 1.00 L 2 1.00 kg 4 2.50 L 2 1.00 L 2 1.00 kg 2 Sulfuric Acid 95-98% 1.00 kg 4 Shelved Shelved Shelved Shelved Shelved Shelved Shelved Shelved Shelved Shelved Shelved 5.10.3 Physics Research Laboratory F-123 EPA RCRA inspectors proceeded to inspect this Physics Laboratory area. Mr. Omar Vazquez, Laboratory, Technician, served as the UPR Mayagez Campus' representative and escort. At the time of the RCRA Inspection, EPA Inspectors observed numerous expired chemicals (since before 1986), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more before 2004) in shelves without any physical means to protect each other from incompatibility of waste characteristics. As observed by EPA Inspector there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents. According to the Laboratory Technician, all these chemical reagents were not in use or discarded since years from 1970, 1980, and 1990 thru 2004 from various laboratory research seasons and were stored in this area and never declared as "solid waste material," or notified to the Health, Occupational and Environmental Safety Office (OPASO). There was no hazardous waste determination being performed on abandoned, expired, not in use, discarded hazardous chemical waste inventory before its final disposal nor have been managed under the Laboratory Management Plan. The EPA Inspectors observed the following at this location: i. At this laboratory the following chemical reagents were stored in a blue cabinet identified as "Corrosive," and included nitric acid, hydrochloric acid, phosphoric acid, Triton X-100 (octylphenol polyethoxyethanol), acetic acid anhydrous, hydrazine hydrate solution, aceti acid glacial, sulfuric acid, ammonium hydroxide, dimethyl carbonate (flammable), unknown corrosive Status: Final 76 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 solvents, and an abandoned sodium metallic bar not totally submerged in an organic phase and not used since year 2004 (see Picture No. 165). ii. The bottles of acid, flammable and reactive solvents were stored together and seemed very old, very dry, and potentially unstable; the bottles also had leaking metal lids, contained moisture, labels vanished, which introduced the possibility of violent chemical reaction, fumes generation and potential explosion. In addition, other potential for explosion was the abandoned metallic sodium bar found not totally submerged in oil. It was strongly recommended by EPA Inspectors to keep the submerge the metallic sodium in oil. It was also recommended to have an emergency environmental contractor to remove the metallic sodium which were no longer intended to be used (see Picture No. 166). iii. One (1) 1-L ambar bottle containing Triton X-100, which is a nonionic surfactant that has a hydrophilic polyethylene oxide, harmful if swallowed, should not be stored together where strong acids can be inadvertently mixed or where a spill or leak can cause danger and possibility of hazardous reactions (see Picture No. 167). iv. Three (3) 4-L ambar bottles containing Acetic Anhydride (Aceti Acid Glacial) in deteriorated conditions and labels being vanished, not in use and abandoned, not compatible with Sulfuric Acid (see Picture No. 168). v. Two (2) 4-L ambar bottles containing Hydrochloric Acid in deteriorated conditions and labels being vanished (see Picture No. 169). I explained that Acetic Anhydride was not compatible with Hydrochloric Acid and should not be stored together where they can be inadvertently mixed or where a spill or leak can cause danger. vi. One (1) 4-L ambar bottle Ammonium Hydroxide stored in the cabinet may read violently with strong acids such as hydrochloric, sulfuric, and nitric, dimethyl sulfate, halogens and an abandoned sodium metallic bar not totally submerged in an organic phase and not used since year 2004 (see Picture No. 170). As warranted by the potential threat of potential releases or explosion (i.e., sodium metallic bar) of hazardous waste, and under the authority of the Comprehensive, Environmental Response, Compensation, and Liability Act (CERCLA), EPA included in Field Notice of Federal Interest (FNFI) to UPR Mayagez Campus the Physics Laboratories requesting the responsible party to take corrective actions. Additionally, EPA Inspectors requested that hazardous waste be disposed of as required by RCRA requirements. UPR-Mayagez Campus' officials secured the sodium metallic bar and maintained personnel as well as professors and students away from the room. They coordinated with Stericycle Puerto Rico to assist with the control, transportation and properly disposition of the explosive material. Coordination for removal and disposal or any other approved disposal method will be performed under the oversight of the EPA OSC. 5.10.4 Physics Research Laboratories F-458, F-225, F-117C EPA RCRA inspectors proceeded to inspect these Physics Laboratory areas. Mr. Omar Vazquez, Laboratory, Technician, served as the UPR Mayagez Campus' representative and escort. Status: Final 77 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 At the time of the RCRA Inspection, EPA Inspectors observed numerous expired chemicals (since before 2004), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more 2004) in shelves without any physical means to protect each other from incompatibility of waste characteristics. As observed by EPA Inspector there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents. According to the Laboratory Technician, all these chemical reagents were not in use or discarded since years from 1970, 1980, and 1990 thru 2004, from various laboratory research seasons and were stored in this area and never declared as "solid waste material," or notified to the Health, Occupational and Environmental Safety Office (OPASO). There was no hazardous waste determination being performed on abandoned, expired, not in use, discarded hazardous chemical waste inventory before its final disposal nor have been managed under the Laboratory Management Plan. The EPA Inspectors observed the following at these locations: i. At the Satellite Accumulation Area there were numerous (approximately over nine 9) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories not properly labeled as "Unwanted Materials," nor dated with its accumulation start date or segregated by compatible characteristics (N/UM, N/D) (see Picture No. 171). ii. One (1) 4-liter ambar container with a spent Orthophosphoric Acid, next to one (1) 4-liter ambar container with a spent Chloroform, next to a high-performance liquid chromatography (HPLC) bottle labeled as "HPLC Grade 99.8%) and stored next to one (1) 4-liter crystal container with a spent Hydrochloric Acid. All containers were not labeled as "Unwanted Material" nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 172). iii. One (1) -liter ambar container with a spent Hydrogen Peroxide stored, next to one (1) 1-liter ambar container with a spent Octadecene, and next to one (1) 4-L Hexane. There are incompatible chemical reagents stored together without any mean of physical segregation. All containers were not labeled as "Unwanted Material" nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 173). iv. At this laboratory the following chemical reagents, just to name a few, were found stored in a white solids' cabinet: potassium iodide (corrosive), vinyl alcohol (flammable), malonic acid (corrosive), lithium metallic bar (reactive), thiourea (toxic), oleylamine (corrosive) among many other chemical reagents stored together in an incompatible manner where they could be inadvertently mixed or where a spill or leak can cause danger or explosion (see Picture No. 174). v. One (1) 4-liter ambar container with a spent Ethanol mixed with water, abandoned in a laboratory sink and not labeled as "Unwanted Material" nor dated with its accumulation start date (N/UM, N/D) (see Picture No. 175). vi. At this laboratory the following chemical reagents, just to name a few, were found stored in a yellow flammable cabinet: oleylamine (highly corrosive organic chemical), next to one (1) 4-L dimethylformamide (flammable), next one (1) 4-L hexane, next to one (1) 4-L hydrobromic acid (corrosive), next to one (1) 4-L hydrofluoric acid (corrosive) among many other chemical reagents stored together in an incompatible manner where they can be inadvertently mixed or where a spill or leak can cause danger or explosion (see Picture No. 176). vii. At this laboratory the following chemical reagents, just to name a few, were found stored in a bone white solids cabinet: cadmium stearate (toxic) next to malonic acid (highly corrosive Status: Final 78 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 organic chemical) among many other chemical reagents stored together in an incompatible manner where they can be inadvertently mixed or where a spill or leak can cause danger or explosion (see Picture No. 177). viii. At this laboratory the following chemical reagents, just to name a few, were found stored in a white gray cabinet: sodium sulfite, activated carbon, flourene, yttrium nitrate (corrosive to skin and in contact an oxidizing agent may cause fire on contact with combustible material) stored next of potassium dichromate, and strontium hydroxide, strontium acetate, lanthanum chloride (react with water under fire conditions liberating flammable hydrogen gas) next to oxalic acid (corrosive), tritium nitrate (source of beta radiation), niobium(V) oxide (reacts with oxidizing agents and bases), silicon (IV) nitride (may emit toxic fumes of ammonia and ozone with acids may generate flammable hydrogen gas), lithium oxide (corrosive substance that can cause pulmonary edema), mercury oxide, boric acid (corrosive), phosphotungric acid (corrosive), sodium thiosulfate anhydrous among many other chemical reagents stored together in an incompatible manner where they can be inadvertently mixed or where a spill or leak can cause danger or explosion (see Picture No. 178). ix. At this laboratory the following chemical reagents, just to name a few, were found stored in a white gray cabinet: mercuric choride (toxic and corrosive), zinc iodide (highly flammable may ignite spontaneously on contact with air and cause fire or explosion), chromium potassium sulfate (highly toxic), cesium iodide (highly toxic and reacts explosively with water even at low temperatures), ammonium chloride (corrosive), cesium chloride (reactive with the oxygen in the ai or water getting a very vigorous reaction), dimethyl naphthalene (very toxic), aminobenzene (highly flammable), ammonium oxide (can ignite and explode under certain conditions of containment), nitroaniline (toxic and flammable), tetramethylammonium chloride (toxic), sodium tartrate (reacts violently on contact with oxidizers and water), potassium dichromate,(oxidizer), arsenic acid (corrosive and very toxic), ammonium sulfate (toxic), ammonium monohydrogen (toxic), old can pails of molecular sieve, glycerine (flammable), tartaric acid (corrosive), rhodium metal among many other chemical reagents stored together in an incompatible manner where they can be inadvertently mixed or where a spill or leak can cause danger or explosion (see Picture No. 179). x. At this laboratory Inspectors observed numerous expired chemicals (since before 2004), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more 2004) in shelves without any physical means to protect each other from incompatibility of waste characteristics (see Picture No. 180). xi. At this laboratory the following chemical reagents were stored in a blue cabinet identified as "Corrosive," and included one (1) 1-L bottle phosphoric acid (corrosive), and one (1) 1-L bottles hydrochloric acid (corrosive), next to two (2) 1-L bottles of hydrogen peroxide (oxidizer), and next of one (1) 1-L bottle sodium dodecyl sulfate (explosive - dust can form an explosive mixture in air) and not used since year 2004 (see Picture No. 181). xii. At this laboratory the following chemical reagents were stored in a blue cabinet identified as "Corrosive," and included two (1) 4-L bottle hydrochloric acid (corrosive), next to various bottles of ammonium hydroxide (avoid contact with hydrochloric acid which forms a chloramine toxic gas), potassium hydroxide (corrosive) not stored in a compatible manner and not used since year 2004 (see Picture No. 182). Status: Final 79 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 xiii. At this laboratory the following chemical reagents were stored in a blue cabinet identified as "Corrosive," and included one (1) 4-L bottle and various containers with phosphoric acid (corrosive), next to a bottle of nitric acid, next to chromium solution (toxic) and vanadium metal solution (toxic) not stored in a compatible manner and not used since year 2004 (see Picture No. 183). xiv. At this laboratory the following chemical reagents were stored in a blue cabinet identified as "Corrosive," and included two (2) 4-L bottle with hydrochloric acid (corrosive), next to a one (1) 4-L with acetic acid (corrosive but not compatible with inorganic acids), next of one (1) 4-L bottle of ammonium hydroxide (reactive), next to one (1) bottles of acetone (flammable) not stored in a compatible manner and not used since year 2004 (see Picture No. 184). Table No. 7 summarizes the inventory of chemical solvents stored at the Physics Laboratory F-458 and recorded on March 10, 2023. Table No. 7 - Inventory of Chemical Reagents Stored at Physics Laboratory F-458 March 10, 2023 Name Grade Amount Acetone Acetone Acetone Acetic Acid GR Aqua day Colloidal Graphite Aluminum Flux Paste Aluminum oxide Aluminum oxide Ammonium Hydroxide ACS Antimony (III) oxide Balsam Canada Barium carbonate Barium carbonate Barium carbonate Histological grade HPCL grade Certified 99.8% 99.999% 28-30% 0.99999 99.8% 99.8% 99.98% 99.997% 4L 4L x 6 bottles 4L 2.5L 50g 1L 500g x 2 bottles 25g 250g 25g 25g 1Kg 25g 100g Status: Final 80 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Barium carbonate Barium carbonate Barium carbonate Barium titanate Barium titanate (IV) Bismuth oxide Bi 20 Boric Acid Boric Acid Boron Boron oxide Boron Nitride Cadmium nitrate tetrahydrate Cadmium nitrate tetrahydrate Cadmium oxide Cadmium selenide Cadmium sulphide Cadmium telluride Calcium Carbonate Precipitate Light powders Calcium Oxide 99.98% 99.999% 99.8% Powder 99% 99.975% Certified ACS Regent ACS 99.999% 99.98% 98% 98% 99.95% Phosphor grade 99.99% Phosphor grade 99.99% 99.99+% Purified Calcium Oxide Carbonate de Potasium Carborundum Cellulose powder 99.9995% Analysis Status: Final 81 100g 25g 1Kg 25g 100g 250g 1 L 1 L 5g I 00g x 3 bottles 10g 75g 100g 500g 50g 50g 5g 500g 100g 50g 500g CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Cerium (III) 2-ethylhexanoate Ce (OOCC7Hl 5) Chromic-Sulfuric Acid Chromium, AAS Standard Solution Crim 5% HCL Cr 1000ug/ml Chromium, Powder Chromium plates Chromium (III) oxide Chromium (III) oxide CA-10 Conductive Adhesive Part "A" CA-10 Conductive Adhesive Copper Chloride Copper oxide Copper oxide Copper (II) oxide Copper (II) oxide Copper (II) oxide Copper (II) oxide Copper (II) oxide Cupric Sulfate Cupric Sulfate EPO-TEK 419 Pail "A" EPO-TEK 920 Part "B" Erbium (III) oxide Status: Final 99.9% 99.2% 99.995% 99.995% 99+% 99.99% 97% 99.99+% 99% 99.99+% 99.995% 98% N.F. Crystals Certified A.C.S. 99.99+% 82 100 ml IL x 2potes 100ml 1oz 2 run thick, 100g 25g 100g 25g 10g 25g 10g 100g x 3potes 500g 500g 500g 1 Lb 500g 5g CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Ethyl-alcohol reagent, denature Ethyl-alcohol reagent, denature Europium (III) oxide Fullerene Powder C 60 Gadolinium (III) oxide Gadolinium (III) oxide Gallium Ingot Gallium isopropoxide Gallium (III) Nitride Gallium Oxide Gallium (III)Oxide Germanium Dioxide Germanium oxide GeO2 Germanium Pieces Germanium Powder Germanium Lump Glycerine Gold powder Hafnium oxide HF Diluted Used Hydrochloric Acid Hydrochloric Acid Analytical Analytical 99.999% 99.5% 99.9% 99.99+% 99.99% 99% 99.99% 99.99% 99.999% 99.99% Ultrapure 99.9999+% 99.999% 99.99% 99.9% 98% Reagent A.C.S. Hydrofluoric Acid Inigo, Synthetic 48-51% 95% Status: Final 83 4L x3potes 500ml Sg 5g 25g 5g 5g 10g lg x 2 cans 5g 1oz 25g 5g 10g 5g 8oz 500mg 10g 2.5L 2.5L x 4 bottles 2.5L 500ml .25g CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Indium Bar Indium isopropoxide Indium, foil Indium Nitride Indium (III) oxide Indium (III) oxide Indium in D Alloy Flux #2 Indium-tin Oxide Indigo, Synthetic Iron Metal Lanthanum 2-ethylexanoate Lead (II) oxide Lead (II) oxide Lead (II) oxide 5-methyl-2-pynolidinone Molybdenum metal powder Molybdenum metal powder Niobium, AAS standard NbCl in 2%HF Nb 1000ug/ml solution Niobium, foil Niobium (V) oxide Nb2O5, Niobium (V) oxide Niobium powder Nitric Acid (NH_4OH) Diluido Usado 99.999+% 5%W/V 0.99999 99.8% 99.995% 99.999% 99.99% 95% 99.9999% 99.9% 99.99+% 98% 99.8% 0.998 99.99% 99.9+% 99.8% Status: Final 84 25g 25ml 1.0mm 5g x2 bottles 10g 10g 20g 25g 4oz 100 ml 25g 500g 250g l0g 28g 100ml 0.25mm 50g 500g 100g 2.5L CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Nitric Acid Palladium Black Paraffin wax Phosphoric Acid Phosphorus Pentoxide Platinum Platinum, foil Poly-Flux Polymer for lead zirconate-titanate 85% HPLC Grade 99.98% 0.9999 0.9999 poly (methyl-methacrylate) Polyvinyl alcohol Potassium, AAS Standard Solution l000ug/ml KNO3 in 5% HNO3 98-99% Potassium Bromide K2CO3, Potassium carbonate K2CrO4, Potassium chromate Potasium dichlormate carbonate, Potasium Potassium Nitrate A.C.S Regent Potassium niobium oxide KNbO3 Potasium tantalum oxide KTaO3 Potassium isopropoxide KOC3H7 Potassium niobium KNb (OC3 H)6 isopropoxide Status: Final ACS, 99.0% ACS, 99.0% 99.999% 99.998% 99% 99% 85 2.5L lg 1Kg 500ml 25g 2.00x0.125 0.25mm thick 2oz 500g 100g 100ml 25g 500g 100g 100 g 500g 100g x 3bottles 25g x 4 bottles 100ml x 2bottles 100ml x 2 bottles CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Potassium nitrate Potassium nitrate crystal Potassium superoxide powder KTa(OC3H/)6 Potassium tantalum isopropoxide Certified 0.99 99% KtaO3, Potassium tantalum oxide Praseodymium (III, IV) oxide 2-propanol 2-propanol 2-propanol Pyrolytic Graphite Rhodium metal Selenium powder Silica gel Silica gel Silica gel Silica Powder Silicon Silicon carbide Silicone oil SiO2 Silicon (IV) Oxide Silicon (IV) oxide Silver Conductive Paint Status: Final 0.99998 99.999% Optima Certified A.C.S. HPCL grade 0.99999 99.5% 0.99999 99.5% Grade 1 86 500g 500g 50g 1 100ml 25g x 9 bottles 10g 4L x 3bottles 4L x 8 bottles 4L x 2 bottles 2 x 0.25g lg x 3potes 50g l Lb 2.5Kg 1Kg SL 2x0.25 250g 37oz 2Kg 100g 3oz CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Silver Brazing Flux Sodium chloride crystal Sodium Hydroxide Sodium nitrate Certified A.C.S. Certified A.C.S. A.C.S. reagent Sodium nitrate Spectrum Diamond Lapping Oil Spectrum Thinner solvent for use whit diamond Lapping oil Stearic acid Stearic acid SrCO3, Strontium carbonate Sulfuric Acid Sulfuric Acid Used Sulphur powder Tantalum Tantalum AAS Ta 1000ug/ml standard solution Tantalum, foil Tantalum(V) oxide Ta2O5, Tantalum (V) oxide Tantalum powder Tellurium Powder Terbium (III, IV) oxide o-Terphenyl m-Terphenyl A.C.S. 99.0% analysis 99% (Bal%) 0.9995 0.999 0.99 0.9995 99.98% 99.8% 99.999% 99% Status: Final 87 3oz 500g 500g 500g 250g 16oz 1.6oz 500g 8 x 2 bottles 1Kg x 2 2.5L 2.5L 500g 2 x 0.25g 100ml 0.5mm 50g 100g 25g 100 g 2g 100g 100g CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 p-Terphenyl Thulium oxide Tin Tin (IV) oxide Tin (IV) oxide Titanium oxide (TiO2) Titanium (IV) oxide Titanium (IV) oxide Toluene Trichloroethylene Trichloroethylene 1,1,1- Trichloroethylene Tungsten Tungsten metal powder 99% 99.99% 99.9% 99.995% 99.99% 99+% Certified A.C.S. Certified Stabilized Stabilized 99.95 Purified Vanadium AAS Standard Solution V-20 in 5% HNO3 V 1000ug/ml Vanadium (V) Oxide Vanadium pieces Watch oil Wood's Metal Alloy Sticks Yttrium oxide Yttrium oxide Yttrium oxide 99.6% 99.7% 99.5% 99.9999% 99.99% 99.99% Status: Final 88 100g lg 100g 25g 75g 25g 100g 4L 4L x 3 bottles 4L 4L x 4 bottles 113g 100ml 100g 10g 10g 50g 50g 250g CEPD-RCRA-23-0440 Zinc isopropoxide Zn (OOCCH15)0.1(OC3H1)1.9 Zinc Metal Zinc oxide Zinc selenide Zinc sulfide Zirconium oxide Ytterium oxide Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Certified A.C.S. 99% 99.99% 99.99% purified Certified A.C.S. 100ml x 2 bottles 500g 500g 10g 100g 113g bag As warranted by the potential threat of potential releases or explosion (i.e., nitric acid, ammonium hydroxide, lithium metallic bar, sulfuric acid, zinc oxide, hydrogen peroxide, sodium dodecyl sulfate) of hazardous waste, and under the authority of the Comprehensive, Environmental Response, Compensation, and Liability Act (CERCLA), EPA included in the Field Notice of Federal Interest (FNFI) to UPR Mayagez Campus Physics Laboratories, requesting the responsible party to take corrective actions. Additionally, EPA Inspectors requested that hazardous waste be disposed of as required by RCRA requirements. UPR-Mayagez Campus' officials secured the nitric acid, ammonium hydroxide, lithium metallic bar, sulfuric acid, zinc oxide hydrogen peroxide, sodium dodecyl sulfate and maintained personnel as well as professors and students away from the room. They coordinated with Stericycle Puerto Rico to assist with the control, transportation and properly disposition of the dangerous and explosive material. Coordination for removal and disposal or any other approved disposal method will be performed under the oversight of the EPA OSC. 5.11 BIOLOGY DEPARTMENT EPA Inspector met Dr. Benjamin Van Ee, who is the Director of the Biology Department. Dr. Benjamin Van Ee served as the UPR Mayagez Campus' representative and escort. The biology building has four (4) stories. There are Biology Laboratories in each floor. The building has twelve (12) academic classrooms and thirteen (13) investigation research laboratories. 5.11.1 Teaching Laboratory B-020 EPA Inspectors proceeded to inspect this Teaching Laboratory area. Ms. Damaris Santiago, EH&S from Health, Occupational and Environmental Safety Office (OPASO), also served as the UPR Mayagez Campus' representative and escort. In this Teaching Laboratory students perform evaluations of plant tissues under microscope with iodine. and safranin, a biological stain which is used to identified dense vs. Status: Final 89 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 non dense tissues. According to Mr. Van Ee, Director Department, most unwanted materials are vegetative. The EPA Inspectors observed the following at this location: i. A refrigerator with chemical reagents such as phytagel-plant cell culture (tested powder), albumin, saccharose, fructose, hematoxylin, glucose, and kinetin solution (see Picture No. 185). ii. On a testing table, EPA Inspector observed iodized salt, NAOH liquid solution, and HCl stored next to each other (see Picture No. 186). iii. On shelf car numerous bottles of benedict solution. iv. A tissue culture chemical cabinet with three (3) shelve subdivisions containing buffer solution, citric acids, glycerin, amino-3 acetic acid paste, iodine, citric acid monohydrate, D-Sucrose. All these chemicals were in small quantities, and some were leaking. At the time of the RCRA Inspection, EPA Inspectors observed various expired chemicals (since before2010 and 2018), discarded, unlabeled, contaminated, leaking, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more before 2010) in shelves without any physical means to protect each other from incompatibility of waste characteristics (see Picture No. 187). As observed by EPA Inspector there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents. It was recommended by EPA Inspectors to re-evaluate and re-organize reagent compatibility and proper storage and disposal if the reagents were not in use instead of being abandoned. Some of the chemical reagents were unlabeled, leaking and with roughly dated as 2009 and 2010. 5.11.2 Microscopy Research Laboratory B-026 RCRA Inspectors proceeded to inspect this Microscopy Research Laboratory area. In this laboratory, students perform tissue dehydration, tissue population, microtome for fine cut tissue and dissect or stain. The EPA Inspectors observed the following at this location: i. A yellow cabinet identified as "Flammable" with an inventory list of chemicals reagents. ii. Inside this cabinet there were numerous reagent bottles in the first shelf labeled as methanol, butanol, ethanol, propanol, ethyl alcohol, sodium sulfite, paraffin oil, mercuric iodine red and buffer solution non compatible (i.e., Acetic Acid Glacial, Ethanol, Sodium Sulfite, and Mercury Iodide) (see Picture No. 188). iii. In the second shelf had a box of ethyl alcohol 190 proof containing four (4) 1-gallon bottles, and a smaller box containing a yellow buffer solution. Also, behind the boxes there were glass bottles of ethanol and acetic acids (see Picture No. 189). iv. The third and last shelves contained twelve (12) glass 1-gallon bottles of cadmium 10ppm solution. Status: Final 90 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 v. In an extractor hood there was one (1) 1-liter plastic bottle with "COTEX" labeled as "Hazardous Waste'" and dated with its accumulation start date of August 2019 (over 4-5 years old) (see Picture No. 190) At the time of the RCRA Inspection, EPA Inspectors observed various expired chemicals (since < before 1999 and 2001), discarded, unlabeled, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more 1999) in shelves without any physical means to protect each other from incompatibility of waste characteristics (i.e., Benzoic Acid vs. Nitroaniline) (see Picture No. 191). 5.11.3 Molecular Investigation Laboratory (Biotechnology) B-073 EPA Inspectors proceeded to inspect this Molecular Investigation Laboratory (Biotechnology) area. In this laboratory students perform genetic extraction, extraction, purification, and amplification of DNA. Most cabinets have their inventory list of chemical reagents posted. The EPA Inspectors observed the following at this location inside brown cabinets: Cabinet No. 1 (Three shelves) i. In the first shelf had numerous small cap glass bottles with acid fuchsin, amino black 106, Anilin, Bismarck Brown, Carmine Rubrum. ii. In second shelf had crystal violet, Eosin Y certified, Fast green, Giemsa Stain, hematoxylin, mercury, and methylene. iii. In the third shelf had single orange stain, pararosaniline, safranin, Sudan IV, and orcein. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were deteriorated, leaking, corroded, and spilling its content (see Picture No. 192). Cabinet No. 2 (Three shelves) i. In the first shelf had numerous small cap bottles with algae destroyer, 1-Benzylaminopurine, boileezers (dated May 20, 2000), carbowax, and activated charcoal. ii. In the second shelf had gum mastic, gelatin, indole-3-acetic acid, maltose, molecular sieve 5A refill kit, nutrient algae, osmometric standard solution. iii. In the third shelf contained KCL solution, sodium chloride, sucrose, lab-metal paste, urea ACS reagent, gel mount. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were deteriorated, leaking, corroded, and spilling its content. In addition, there was one empy bottle labeled as "Hazardous Wastes" that was removed at the time of the EPA Inspection (see Picture No. 193). Cabinet No. 3 (Three shelves) i. The first shelf had sodium phosphate monobasic-monohydrate bottle, sodium phosphate, and sodium thiosulfate pentahydrate. Status: Final 91 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 ii. The second shelf had TRITON X-100 wetting agent (i.e., Corrosive, and Flammable violent reaction with oxidizers and acids and vapours can form explosive mixtures with air), and uranyl acetate dihydrate reagent (i.e., Radioactive and waste disposal are regulated as radioactive waste). iii. The Third shelf was mostly empty. It only contained a carboard box. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were deteriorated with vanished labels, corroded, and spilling its content. In addition, there were chemical reagents stored for a very long time (i.e., over a year or more November 1, 1992) in shelves without any physical means to protect each other from incompatibility of waste characteristics (i.e., TRITON-100 corrosive vs. Uranyl Acetate-radioactive) (see Picture No. 194). Cabinet No. 4 (Three shelves) i. The first shelf had a box with plus embedding kit of solution a, b and catalyst, as second box with JB-4 Plus S Embedding Kit containing benzoyl peroxide catalyst, small cap bottles of Lacmoid, magnesium sulfate, a box of mercuric chloride reagent, another small cap bottle of manganese sulfate, three (3) bottles of methyl benzoate reagent. ii. The second shelf had nadic methyl anhydride glass bottle, another glass bottle with paraformaldehyde, and a plastic bottle with paraformaldehyde. iii. The third shelf had a glass bottle labeled as paraldehyde, another with sodium acetate, sodium bicarbonate, and sodium meta-bisulfite. At the time of the RCRA Inspection, EPA Inspectors observed that this cabinet was identified as toxic and irritant chemicals. Some of the chemical reagents were deteriorated with vanished labels, corroded, and spilling its content. In addition, there were chemical reagents stored for a very long time (i.e., expiration date April 2015) in shelves without any physical means to protect each other from incompatibility of waste characteristics (i.e., Benzoyl Peroxide - Reactive strong oxidizer which may explode if exposed to heat, shock, or friction vs. Methyl Benzoate-Flammable) (see Picture No. 195). Cabinet No. 5 (Two shelves) i. The top shelf had one (1) 5-gallon container of ethyl alcohol, eosin Y, chloroform reagents, few bottles of ethyl alcohol 200 proof, permount mounting medium containing toluene. ii. The bottom shelf had ethanol anhydrous, formalin, toluene, xylene, tert-butyl alcohol, and ethyl alcohol. At the time of the RCRA Inspection, EPA Inspectors observed that some of the chemical reagents were deteriorated with vanished labels, corroded, spilling its content and stored for several years and without segregation(see Picture No. 196). Cabinet No. 6 (Three shelves) iii. The top shelf hadone (1) 5-gallon container of ethyl alcohol, eosin Y, chloroform reagents, few bottles of ethyl alcohol 200 proof, permount mounting medium containing toluene. Status: Final 92 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 iv. The bottom shelf had ethanol anhydrous, formalin, toluene, xylene, tert-butyl alcohol, and ethyl alcohol. At the time of the RCRA Inspection, EPA Inspectors observed that some of the chemical reagents were deteriorated with vanished labels, corroded, spilling its content, and stored for several years and without segregation (see Picture No. 196). 5.11.4 Biology General Storage Room B-086 EPA Inspectors proceeded to inspect this General Storage Room area. In this room most chemical reagents purchased by the Biology Department are stored in this room in cabinets and supplied to biology laboratories. Most cabinets have their inventory list of chemical reagents posted. The EPA Inspectors observed the following at this location inside brown cabinets: Cabinet No. 1 (Three shelves) i. The first shelf had magnesium sulfate heptahydrate, agarose, amonium acetate, sodium disulfate, black K salt, L-Ascorbic sodium salt, dimethylglyoxime, and Coomassie brilliant blue reagent. ii. The second shelf had containers of sodium chloride, ammonium sulfate, glycerol, cetyltrimethylammonium bromide, polyvinylpyrrrolidone K30, sea sand, agarose, histidine, Lascorbic acid sodium salt, granulated peptone. iii. The third shelf had ultra-pure agave, tri bas crystalline powder, polyvinyl pyrrolidone, agarose, sucrose, sodium dodecyl sulfate, sodium chloride, and MES. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for a very long time (i.e., over a year or more before October 20, 2015) in shelves without any physical means to protect each other from incompatibility of waste characteristics (i.e., Glycerol-Flammable vs. Ammonium Sulfate-Toxic) (see Picture No. 197). In addition, in another cabinet there were other chemical reagents stored in shelves without any physical means to protect each other from incompatibility of waste characteristics deteriorated, leaking, corroded, and spilling its content including Lithium Hydroxide (i.e., highly Corrosive chemical which direct contact can severely irritate and burn the skin and eyes leading to eye damage) next to Potassium Cyanide (i.e., highly toxic and exposure to potassium cyanide can be rapidly fatal) (see Picture No. 198). Cabinet No. 2 (Three shelves) i. The top shelf was identified as irritant and corrosive chemical reagents. This shelf contained potassium phosphate plastic bottles, citric acid (monohydrate), citric acid (anhydrous), and chlorosuccinimide. ii. The second shelf was identified as health hazardous and toxic chemical reagents. This shelf contained: MOPS (99.5%), lithium chloride, sodium phosphate, potassium phosphate, Trizma hydrochloride, boric acid, sodium carbonate and hypoxanthine. iii. The third shelf was identified as irritant and corrosive chemicals. This shelf contained unreadable chemicals, sodium chloride, sodium phosphate, urea, polyethylene glycol, Status: Final 93 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 hydrochloride reagent, sodium hydroxide, potassium iodine and another unreadable chemical. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for a very long time (i.e., over a year or more before November 2006) in shelves without any physical means to protect each other from incompatibility of waste characteristics (i.e., Glycerol-Flammable vs. Sodium Hydroxide-Corrosive dated year 2006) (see Picture No. 199). Freezer Storage Compartment i. Inside the freezer compartment, EPA Inspectors observed a box with testing tubes. Next to the freezer compartment there was one (1) five 5-gallon container labeled as "Hazardous Waste," not dated with its accumulation start date or waste content information (see Picture No. 200). Cabinet No. 3 (Three shelves) i. The top shelf was identified as General Storage for Tissue Culture Chemicals. It contained Casein hydrolysate, amylose, nicotinic acid, pyridoxine plus HCL, Gelzan (dated January 14, 2009) and adenine sulfate. ii. The second shelf was also identified as General Storage. It contained bacteriological grade peptone, 1-naphthaleneacetic acid 97% (dated January 14, 2009), cholesterol, TWEEN 20 polysorbate, phytagel, plant cell culture tested powder, and dimethyl sulfoxide (dated June 2011). iii. The third shelf was identified as irritant-toxic-corrosive. It contained L-arginine (the container was wet at the bottom, but it could not be determined what was leaking), paromomycin sulfate, pyridoxine chloride, putrescine dihydrochloride. At the very back of the shelf it was observed a very rusty can labeled Melittin, from Bee Venon (approximately 70% for HPLC) with evident signs of leaks. The shelf was completely spilled with the leak solution (see Picture No. 201). At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for a very long time (i.e., over a year or more before January 14, 2009) in shelves without any physical means to protect each other from incompatibility of waste characteristics (i.e., TWEEN 20 very Flammable vapours which are heavier than air and may spread near ground to sources of ignition vs. Dimethyl Sulfoxide can produce an explosive reaction when exposed to chlorides vs. 1Naphthaleneacetic Acid 97% Corrosive - Year 2009) (see Picture No. 202). 5.11.5 Biology Chemical Reagents Storage Room EPA Inspectors proceeded to inspect this Chemical Reagents Storage Room area. In this room is where most chemical reagents purchased by the Biology Department are stored in this room in cabinets and supplied to biology laboratories. Most cabinets have their inventory list of chemical reagents posted on the doors of the cabinets. Status: Final 94 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.11.6 Biology Biohazard Chemical Reagents Storage Room B-085 EPA Inspectors proceeded to inspect this Biohazard Chemical Reagents Storage Room area. In this room is where Biohazard chemical reagents are stored to supply biology laboratories. Observations at this area rendered no concerns regarding the generation or management of unwanted waste or hazardous wastes. 5.11.7 Biology Explosive Chemical Reagents Storage Room B-089 EPA Inspectors proceeded to inspect this Explosive Chemical Reagents Storage Room area. In this room is where Explosives are stored. We met Mr. Donato Segui, who is the person in charge and hold the explosive license No. 030-0017-0000 with expiration date of March 15, 2023. The explosive cabinet had an inventory list of chemical reagents posted on the door. The EPA Inspectors observed the following at this location inside the cabinets: Cabinet No. 1 (Two shelves) i. In the first shelf had two (3) 1-liter plastic bottle of sodium hydroxide. ii. In the second shelf had two (3) 1-liter and -liter ambar plastic bottle of ammonium hydroxide. At the time of the RCRA Inspection, EPA Inspectors observed that the cabinet was identified as "Flammable," instead of "Explosive," and some chemical reagents stored in the cabinets did not match with what it was inside the cabinet containing ammonium hydroxide and nitric acids (see Pictures No. 203 and 204). 5.11.8 Biology Academic Laboratories B-120-121 EPA Inspectors proceeded to inspect these Biology Academic Laboratory areas. In this laboratory students perform general biology experiments as complement of biology academic lectures. Most cabinets have their inventory list of chemical reagents posted. The EPA Inspectors observed the following at this location inside extractor hoods and cabinets: i. Various corroded chemical reagent containers. ii. Worn dye pots with advanced deterioration. iii. Numerous hazardous waste materials and non-hazardous waste materials in cabinets without proper identification, labeled or dated as required by Subpart K Laboratory Management requirements. iv. Various chemical reagents not segregated by compatibility characteristics posing a risk to students and academic lectures. Status: Final 95 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 v. Chemical reagent materials not in use and stored for a very long time that must be discarded in lieu of being abandoned. vi. Chemical reagents not stored by compatibility characteristics. vii. Numerous chemical reagents with expired dates. viii. The use of trays, plastic bags or absorbent paper in cabinets without proper identification and management of content or residues. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for several years in shelves without any physical means to protect each other from incompatibility of waste characteristics. There were no unwanted materials or at least not properly identified in the Biology Academic Laboratories. 5.11.9 Parasitology Research Laboratory (Aquatic Biology) B-137 EPA Inspectors proceeded to inspect this Parasitology Research Laboratory and were introduced to Mr. Sean Locke, Associate Professor, and Mr. Carlos Santos Flores, Professor. In this laboratory students perform live animal dissection for histology and molecular biology investigation. They explained that they do have hazardous material which are flammable, and that they do not generate hazardous waste. They have a yellow metal cabinet for hazardous material storage and inside the cabinet EPA Inspector observed the Hydrogen Peroxide, Permount, Hydrochloric Acid, Ethanol, and Mineral Spirits. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for several years in shelves without any physical means to protect each other from incompatibility of waste characteristics. There were no unwanted materials or at least not properly identified in the Aquatic Biology Laboratory. 5.11.10 Microbiology Research Laboratory B-266 EPA Inspectors proceeded to inspect this Microbiology Research Laboratory area and were introduced to Mr. Carlos Rios Velazquez. Mr. Rios is the laboratory Professor of Microbial Microbiology and Microbial Protection, Gene Cloning and Genetics. Accordingly, in this laboratory hazardous material and hazardous wastes are stored and generated from microbiology research. The EPA Inspectors observed the following at this location inside extractor hoods and cabinets: i. Storage of unwanted material in a tray containing one (1) 1-gallon glass bottle with HCL (dated: January 29, 2022) and one (1) 1-gallon glass bottle with Chloroform (dated: July 12, 2022). ii. On a wall there were three (3) storage cabinet of chemical reagents. The cabinet were identified with color codes (blue, brown, white). According to the legend posted on the cabinets; red is for Flammable, blue is for Health Hazards, yellow is for Reactive and Oxidizing reagents, white is for Corrosive and brown for Moderate Hazard. iii. Another chemical reagent storage shelves with five characteristic subdivisions with color coded. iv. There was one more cabinet identified as "acid danger and flammable liquids" Each door contained two subdivisions. The one that read acid danger contained hydrochloride solution, Status: Final 96 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 acetic acid, acetic anhydride, perchloride acid, trifluoroacetic acid. The second door contained dehydrated alcohol, chloroform, N, N-Dimethyl Formamide, amyl alcohol, xylenes, red solution, ethyl alcohol and ethanol. v. Last wall shelves also identified with blue color codes contained biological and chemical reagents. vi. There was one small yellow metal cabinet identified as Flammable. Inside it had: 2-propanol, alcohol, methanol, isopropyl alcohol, and ethanol. At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for several years in shelves without any physical means to protect each other from incompatibility of waste characteristics. There were unwanted materials not properly labeled or dated with their accumulation start date or at least not properly identified in the Microbiology Laboratory. 5.12 AGRICULTURAL SCIENCES DEPARTMENT - JESUS T. PIERO 5.12.1 Plant Physiology Research Laboratory EPA Inspectors proceeded to inspect this Plant Physiology Research Laboratory area. In this laboratory there was a cabinet containing numerous of chemical reagents that were used for various plant and physiology testing. One of the cabinets was identifies as "Physiology of Plant Reactive." The cabinet had six shelves (see Picture No. 205). The EPA Inspectors observed the following at this location inside cabinets: Cabinet No. 1 (Six shelves) i. The first shelf had numerous unreadable chemical reagents. ii. The second shelf there were Sodium oxolate, zinc chloride, potassium chloride, sulfate, malolactic acid. iii. The third shelf contained ammonium sulfate, and potassium phosphate dibasic powder, iv. In the fourth shelf from contained potassium phosphate dibasic powder, potassium phosphate monobasic powder, and cupric sulfate reagent. v. The fifth shelf there were numerous chemical reagents, all were unreadable with vanished or missing labels. vi. In the sixth and bottom shelf there were cardboard boxes with supplies. At the time of the RCRA Inspection, EPA Inspectors observed inside an Extractor Fume Hood that it was identified as Satellite Accumulation Area (SAA) holding hazardous waste. Inside the hood there was one (1) 1-gallon glass container labeled unwanted material with a contact telephone number and accumulation start date of September 2022, but it didn't provide the content information inside the glass bottle (see Picture No. 206). Status: Final 97 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 5.12.2 Phytopathology Research Laboratory AP-102 EPA Inspectors proceeded to inspect this Phytopathology Research Laboratory area. In this laboratory students conduct studies on biology of fungi, Oomycetes, and bacteria, with the aim to understand and predict their functioning in agricultural and natural ecosystems. The EPA Inspectors observed the following at this location inside refrigerators and storage cabinets: i. Inside one of the refrigerators there were stored, with sodium glass bottles dated February 2011, sodium hydroxide and acid solutions, and solution B Griess glass bottles (see Picture No. 207). ii. Inside a 5-shelfe gray cabinet there were gloves, microscope slides, two shelves contained nutrient broth bottles, nutrient agar, maltose agar, BDTM BactoTM Tryptic Soy Broth (SoybeanCasein Digest Medium), agarose, benzoic acid, glucose anhydrous, calcium chloride, pectin, glycerol, beef extract, boric acid, 2,6-dichloro-4-nitroaniline (i.e., "Combustible." many reactions may cause fire or explosion) , and N-Lauroylsarcosinate (sodium salt) (see Picture No. 208). iii. Inside in an extractor fume hood, there were glass bottle containing Amina stored with glycerol in plastic bottles, permethrin in glass bottle, distilled water in glass bottle, glycerol diluted in glass water, and formaldehyde in glass bottles (see Picture No. 209). 5.12.3 Nematology Research Laboratory AP-103 EPA Inspectors proceeded to inspect this Nematology Research Laboratory area. In this laboratory students study the biology of nematodes, and associated organisms, to understand and predict their functioning in agricultural and natural ecosystems. The EPA Inspectors observed the following at this location inside an extractor fume hood and storage cabinets: i. Inside the extractor fume hood there were two (2) 5-gallon white plastic containers and a five (5) gallon container used for the storage of hazardous waste generated at the laboratory. At the time of the RCRA Inspection one container was empty and the other did not identify its residual content nor labeled as "Hazardous Waste," or date with its accumulation start date (see Picture No. 210). ii. Inside the extractor fume hood there three (3) 200-g bottles with discarded reagents without any hazardous determination or characterization as, "Hazardous Waste," or "Unwanted Wastes" as required by the RCRA Subpart K, Management of Laboratory Wastes (see Picture No. 211). 5.12.4 Entomology Research Laboratory AP-100 EPA Inspectors proceeded to inspect this Entomology Research Laboratory area. In this laboratory students work on the physiology of insect/plant interactions and the ecology of parasite/host and predator/prey interactions. Status: Final 98 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 The EPA Inspectors observed the following at this location inside an extractor fume hood and storage cabinets: i. Inside an extractor fume hood there were three (3) 1-gallon crystal containers containing radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," being stored for years without no hazardous waste determination made on them nor managed as hazardous waste due to its radioactive-corrosive hazard content (see Picture No. 212). According to Ms. Maria Fernndez from the Health, Occupational and Environmental Safety Office, and as previously discussed, there are no Hazardous Waste Disposal Contractor in the Island that would transport or dispose of radioactive waste and that is the reason those wastes have been stored for years (see Picture No. 213). ii. Inside a plastic tray there were three (3) 50-ml (30-g) crystal containers containing radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," being stored for years without no hazardous waste determination made on them nor managed as hazardous waste due to its radioactivecorrosive hazard content (see Picture No. 214). At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for a very long time in shelves without any physical means to protect each other from incompatibility of waste characteristics including radioactive-corrosive wastes. There were unwanted materials not properly labeled or dated with their accumulation start date or at least not properly identified in the Agricultural Laboratories. 5.13 MECHANICAL ENGINEERING DEPARTMENT - LUCHETTI BUILDING EPA Inspectors met Ms. Zilma Poueymirou of the Mechanical Engineering Department. Ms. Poueymirou is the Scientific Investigation Technician who was in charge of the laboratory at the time of the RCRA Inspection and served as the UPR Mayagez Campus' representative and escort. The Luchetti Building has one (1) academic teaching laboratory and four (4) investigation research laboratories. 5.13.1 Metallurgy Research Teaching Laboratory L-240 EPA Inspectors proceeded to inspect this Metallurgy Teaching Laboratory area. Ms. Poueymirou explained that most of the testing they perform at the laboratories is related to metallurgy analysis. Usually, they conduct edging oxidation reactions to observe behavior of structure materials by using chemical reagents such as Nitric acid, Hydrochloric Acid, Ferric Chloride, Methanol, Ethanol among other chemical analysis. The EPA Inspectors observed the following at this location inside extractor fume hoods and storage cabinets: i. On a bench working area there were small Erlenmeyer's beakers with metals (steel, aluminum, and brass) submerged in various etching solutions of ferric chloride, hydrochloride acid, and nitric acid/methanol (see Picture No. 215). ii. Inside an extractor fume hood there was one (1) 2.5-gallong plastic container with spent etching solution from washing metal etching testing containing solution wastes of HCl, HF (i.e., very Status: Final 99 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 dangerous since breathing in hydrogen fluoride at high levels or in combination with skin contact can cause death from an irregular heartbeat or from fluid buildup in the lungs), FeCl3, and HNO3(see Picture No. 216). iii. On top of a bench cabinet there was one (1) 4-liter plastic bottle containing spent Nitric acid, Hydrochloric Acid, Ferric Chloride, Methanol, Ethanol from etching chemical analysis properly labeled as "Unwanted Materials," and dated with its accumulation start date of May 6, 2022, which exceeded over six months the LMP collection protocols (see Picture No. 217). 5.13.2 Biosensing and Microfluid Research Laboratory L-123 EPA Inspectors proceeded to inspect this Biosensing and Microfluid Research Laboratory as part of walkthrough of the Mechanical Engineering Building. Mr. Resto and Mr. Ruben Diaz are the Professors in charge of this laboratory area and served as the UPR Mayagez Campus' representative and escort. Biosensing platform is mostly based on microfluid systems. In this laboratory, chemical reagents are used for cleansing purpose and sterilization of biological cells. The EPA Inspectors observed the following at this location inside extractor fume hoods and storage cabinets: i. Inside a 2-shelfe yellow cabinet, labeled as "Flammable," there were one (1) 1-gallon bottle container with Microposit Remover (1165) with expiration date of January 2, 2011; two (2) 1gallon plastic bottle with Isopropyl Alcohol; one (1) 1-gallon glass bottle with ethanol 85%; and one (1) 1-gallon glass bottle with Acetone (see Picture No. 218). ii. Inside a 2-shelfe white cabinet, labeled as "Corrosive," there were one (1) 1-gallon bottle container with Hydrochloride Acid 37% one (1) metal cylindrical can with solid Hydrofluoric Acid and one Erlenmeyer's beakers with pure Hydrofluoric Acid solution (40%) (see Picture No. 219). At the time of the RCRA Inspection, EPA Inspectors observed that some chemical reagents were stored for a very long time in shelves without any physical means to protect each other from incompatibility of waste characteristics. There were unwanted materials were not properly labeled nor dated with their accumulation start date at the Mechanical Engineering Department. 5.14 GENERAL ENGINEERING DEPARTMENT - LUIS STEFANI BUILDING EPA Inspectors met Dr. Marcelo Suarez and Mr. Boris Renteria who are the responsible Professors in charge of the laboratory areas. The Luis Stefani Building houses one (1) academic teaching laboratory and five (5) investigation research laboratories. 5.14.1 General Synthesis Research Teaching Laboratory S-311 EPA Inspectors proceeded to inspect this General Synthesis Research Laboratory area. In this laboratory, synthesis of polymers and ferrites are conducted and tested for various sample materials. The EPA Inspectors observed the following at this location inside extractor fume hoods and storage cabinets: Status: Final 100 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 i. Inside the extractor fume hood there were "Unwanted Materials," including one bottle of acetic, glacial, ACS, 99.7%; one bottle with NaOH, FeCl3, cobalt with start accumulation date of August 31, 2018; one gallon glass bottle with NaOH with start accumulation date of January 12, 2018; one gallon glass bottle with acetic acid glacial with expiration date of March 2019; one glass bottle with hydrochloride acid and three (3) 5-gallon containers with H2O and ferrites not clearly labeled (see Picture No. 220). As observed by EPA Inspectors, the Satellite Accumulation Area inside extractor fume hood or cabinets in the laboratory containing discarded or spent chemical reagents generated at the laboratories were not properly labeled as "Unwanted Materials," nor dated with its accumulation start date (N/UM/, N/D) (see Picture No. 220). In addition, the storage of this "Unwanted Materials" was conducted without following any safety protocols or compatibility characteristics (Flammable, Corrosives and Toxics - Ethyl Acetate, Acetone next to Hydrochloric Acid, Sodium Hydroxide) of the spent reagents failing to minimize the possibility of a fire, explosion, or any chemical violent reaction (see Picture No. 221). In addition, various container bottles were deteriorated and not identified with its content expired and stored for a very long time (i.e., over a year or more August 31, 2018) (see Picture No. 222). 5.14.2 Material Engineering and Characterization Research Laboratory S-110 EPA Inspectors proceeded to inspect this Material Engineering and Characterization Research Laboratory area. The EPA Inspectors observed the following at this location inside extractor fume hoods and storage cabinets: i. Below an extractor fume hood there was a "Corrosive" cabinet storing chemical reagents including hydrochloric acid, acetic anydride glacial acid, sulfuric acid, a metal container identified as SINGH (3-aminopropyltriethoxysilane) in advanced degree of deterioration, one (1) 4-L glass bottle with an unknown solution. I explained that Acetic Anhydride was not compatible with Hydrochloric Acid and should not be stored together where they can be inadvertently mixed or where a spill or leak can cause danger (see Picture No. 223). In addition, various container bottles were deteriorated and not identified with its content expired and stored for a very long time (i.e., over a year or more August 31, 2018) (see Picture No. 224) such as 3-aminopropyltriethoxysilane which is very harmful in contact with skin and can cause serious eye damage. ii. Below an extractor fume hood there was a "Flammable" cabinet storing chemical reagents including iron (III) chloride anhydrous, cooper (II) chloride anhydrous, acetone optima, ethyl acetate, methanol, calcium chloride dihydrate, alginic acid/sodium salt, sodium hydroxide, and cellulose acetate (see Picture No. 225). I explained that acetone optima, ethyl acetate, methanol are not compatible with sodium hydroxide and should not be stored together where they can be inadvertently mixed or where a spill or leak can cause danger. iii. Below a laboratory bench there was satellite accumulation area with discarded hazardous wastes unlabeled, not dated, or managed under the Laboratory Management Plan, which Status: Final 101 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 included three (3) 5-gallon white containers with corrosive wastes (pH > 12.5) stored next other organic solvent wastes unidentified (see Picture No. 226). iv. On a laboratory bench there was a Satellite Accumulation Area with two trays containing numerous "Unwanted Materials," unlabeled, undated, nor identified with its hazardous waste content. Among the chemical reagents identified from a safety distance stored without segregation included Acetone, Cobalt, Acetone, CaFeO4, Cooper, Ethanol, Titanium, Methyl alcohol, Hydrochloric acid, Ethylene glycol, Triethylene glycol, Polyamic acid (packed October 8, 2008), Urea, Magnesium chloride, 1-gallon glass bottle of Acetic acid/ ferrite cobalt, 1-gallon glass bottle of unknown chemical, 1-gallon glass bottle of alumina/Ni-Co/Ni, 1-gallon glass bottle of cobalt/ aluminum/chloride, atrazine, alumina, Isopropyl alcohol, Acetone, Acetic Acid, Sodium Hydroxide, Hydrochloric Acid, Ethanol Amine, and various 4-Liter bottles containing flammable and corrosive liquids which were no longer intended to be used (see Picture No. 227). At the time of the inspection, EPA Inspectors observed numerous expired chemicals (since before 2008), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (i.e., over a year or more) in trays without any physical means to protect each other from incompatibility of waste characteristics. As observed by EPA Inspectors there were corrosive, flammable, reactive, toxic and poison chemical wastes reagents. According to Dr. Marcelo Suarez, Professor, all these chemical wastes were used and discarded a long time ago from various laboratory research experiments and were stored in this area to declare them as "Unwanted Material," or notified to the Health, Occupational and Environmental Safety Office (OPASO). There was no hazardous waste determination being performed on numerous abandoned, expired, not in use, discarded hazardous chemical waste inventory before its final disposal nor have been in compliance with the Laboratory Management Plan (LMP) (see Picture No. 228). As observed by EPA Inspectors, there were no Safety Data Sheets (SDSs) available at the Satellite Accumulation Area for most of the expired, discarded, abandoned, not in use chemical reagents that should be inventoried for final disposition as "Unwanted Materials." There was no "Unwanted Material" labeling, dating, waste codes, compatibility, lack of the use of chemical formulae and use to the terms unknown waste or original container chemical names products as problem areas for satellite accumulation containers under RCRA Subpart K. As stated by EPA Inspectors, labeling on many containers did not provide any useful information to emergency responders in the event a chemical emergency should occur at these areas. Additionally, there was a concern about the lack of awareness of satellite accumulation control requirements under RCRA Subpart K for properly identifying, dating, and labeling the hazardous waste generated at the laboratories. It was recommended by the inspectors that SDSs should be evaluated to determine the proper characterization and determination of the expired and discarded solid waste. EPA Inspectors discussed with Ms. Fernndez that the responsibility of the laboratory technician within the laboratory is to prepare the label and verify that labels are placed on all containers of "Unwanted Material," and dated with the start accumulation date (six months for collection) stored in the laboratory. According to Ms. Fernndez, containers will not be removed from a laboratory unless the Status: Final 102 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 "CHEMATIX" label the is attached to each container. As observed by EPA Inspectors non "Chematix" labels were affixed to each container. 6 DOCUMENTS REVIEW The following documents were reviewed as required by the RCRA Program after the walkthrough inspection and on follow-up e-mails with the requested information: 6.1 MANIFEST RECORDS AND LAND DISPOSAL RESTRICTION FORMS (LDR) Manifests and associated LDRs for all incoming and outgoing shipments for the last three years were reviewed in hard copies. Most of the hazardous waste are sent by Capitol Environmental Services, Inc. to a destination in Elizabeth, New Jersey, and Birmingham, Alabama, USA. It seemed that UPR Mayagez Campus is a Small Quantity Generator since it generates less than 2,000 pounds of hazardous waste every six months and disposed of with Capitol Environmental Services, Inc. All appeared to be properly maintained and in compliance. Table No. 8 summarizes the Manifest and Land Disposal Restriction provided by UPR Mayagez Campus. Table No. 8 - MANIFEST RECORDS AND LAND DISPOSAL RESTRICTION Manifest No. Date Quantity (Lbs) Manifest No. Year 2023 Date Quantity (Lbs) 024521823 JJK Aug 1, 2023 866 - Year 2022 - - 024071778 JJK 022139121 JJK 023032339 JJK Sep 30, 2022 Feb 1, 2022 Jan 13, 2022 1,960 2,300 8,000 023361832 JJK 022139120 JJK Year 2021 Apr 29, 2022 Feb 1, 2022 - 2,120 1,142 - - - - - Year 2020 - - 020977879 JJK Sep 11, 175 020977880 JJK Sep 11, 2020 2,258 2020 020977873 JJK Jul 24, 224 001659624 VES Feb 24, 2020 800 2020 Status: Final 103 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 6.2 WASTE ANALYSIS A Full RCRA analysis was provided by Capitol Environmental Services, Inc. during charactering and profiling hazardous waste at the UPR Mayagez Campus and described in the Land Disposal Restriction Notification Certification Forms. Capitol Environmental Services, Inc. prepared a Detail Report containing information about Toxic Characteristic Leaching Procedure (Test Method SW 1311) tests, and other analytical methods or knowledge of the waste including used oils disposal. All wastestreams generated by the UPR Mayagez Campus were identified, classified, tested, codified, and disposed of as required by the land disposal restrictions (LDRs). The Waste Analysis Plan submitted by Capitol Environmental Service Inc. appeared to be in compliance. 6.3 PERSONNEL TRAINING RECORDS UPR Mayagez Campus provided a Record of Training for the academic staff associated with the "Management of Chemical Wastes in Laboratories," including the management of unwanted wastes under RCRA Subpart K. All training sessions are offered yearly in Subpart K requirements and other hazardous wastes in the laboratories and other university shops. The record documentation of the of university detailed the kind of training, date, and completion status taken by professors, researchers, students, and EH&S personnel during 2023. Also, on March 28, 2023, UPR Mayagez Campus offered another training session with 141 participants. It appeared to be properly maintained and in compliance. 6.4 WEEKLY LOG RECORDS All weekly logs records for daily and weekly inspections at the Central Accumulation Area (CAA) and hazardous waste container storage areas were reviewed and found to comply. 6.5 CONTINGENCY AND EMERGENCY PREPAREDNESS PLAN There was an Emergency Plan of the UPR Mayagez Campus (Certification Number 17-1 8-1 01), dated November 13, 2017, which included and Emergency Plan: Spill of Hazardous Materials and/or Emanations or Gas Escapes and outlines the procedures and activities required for the prevention of, and response to, hazardous material releases at the UPR Mayagez Campus. In general, the plan provided contingency and emergency preparedness procedures in case of an emergency incident. The plan also provided a list of responsible emergency personnel but did not include telephones in case of an emergency and proper procedures in a case of an emergency. As observed the Emergency Plan of the UPR Mayagez Campus did not provide for any attempt to make arrangements with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers and local hospitals, taking into account the types and quantities of hazardous wastes handled at the UPR Mayagez Campus. No arrangements were made with the Local Emergency Planning Committee. Status: Final 104 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 Additionally, the UPR Mayagez Campus was equipped with alarm systems, sprinkler systems, telephones, certified extinguishers nearby areas where hazardous wastes were stored throughout the UPR Mayagez Campus. 7 CLOSING MEETING (DAY 3 - MARCH 10, 2023) At 5:30 pm in the afternoon, a closing meeting was held for the final day of EPA Inspection at the Chancellor's Office. EPA Inspectors met with Dr. Agustin Rulln, Rector of the Mayagez University Campus, Dr. Omar Molina, Dean of Administration Department, Deans from all University Departments (via video conference), Ms. Maria Isabel Fernndez, Health, Occupational and Environmental Safety Office Director, and Ms. Damaris Santiago, Health, Occupational and Environmental Safety Specialist, EPA Inspectors discussed and revisited the potential releases and/or threatened releases observed during the Inspection visit on March 10, 2023, at the Alzamora Farm Pesticides Warehouse, Radioactive Wastes and Physics Department (i.e., F-129, F-458, F-123, F-225) of the University of Puerto RicoMayagez Campus. The main treat consisted of metallic sodium bars (i.e., 2009) that were identified in advanced degree of deterioration, not in use, not properly labeled, haphazardly stored, without appropriate secondary "explosive" containment, not segregated by chemical compatibility that needed to be addressed on an expedited basis (i.e., metallic sodium "bomb" removal operations). EPA Inspectors reiterated that Civil Engineering Department, Alzamora Pesticides, Radioactive wastes, and Physics Laboratories presented an imminent and substantial endangerment to health or the environment. EPA Inspectors re-notified EPA's Emergency Responders about the imminent risk situation at the time of the Inspection, and Mr. Carlos Huertas, EPA On-Scene Coordinator, indicated that emergency incidents should be managed under the Field Notice of Federal Interest (FNFI) issued to UPRMayagez Campus under the authority of the Comprehensive, Environmental Response, Compensation, and Liability Act (CERCLA), on March 9, 2023, requesting the responsible party to take immediate corrective actions. EPA Inspectors informed to Dr. Agustin Rulln, Chancellor of the Mayagez University Campus, that the management of hazardous wastes program at UPR-Mayagez Campus was not satisfactory based upon potential violations, and other applicable hazardous waste regulations that were identified during the EPA Inspection compliance evaluation. In particular, the mismanagement of inventory logs for hazardous waste chemicals, the potential of explosion from chemical incompatibility characteristics, and from the statement that UPR-Mayagez Campus did not generate much hazardous wastes. As observed by EPA Inspectors, UPR-Mayagez Campus does generate hazardous wastes over 1,000 kg per month on a seasonal basis. EPA inspectors emphasized that these potential violations may result in a written notice of violations or any other enforcement actions dictated by the agency. However, EPA Inspectors also emphasized that these potential violations were tentative and are pending administrative review. EPA Inspectors explained that the lag time between the EPA Inspection, and resulting RCRA Inspection Report, could be substantial based on the complexity of the University and many laboratories and areas that were involved and regulated under RCRA requirements (i.e., 2018-2020 Laboratory Management Plan (LMP) and/or 40 CFR 262 Subpart K). At this point, EPA Inspectors reiterated the fact that the Status: Final 105 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 RCRA Report and determination of Agency action for this EPA Inspection would not occur for several months. During the inspection, EPA Inspectors observed that UPR-Mayagez Campus generates solid wastes. However, the UPR-Mayagez Campus has failed to determine if a solid waste is a hazardous waste in many areas that were not covered by Laboratory Management Plan. There were lots of off specification, discarded, abandoned, and outdated materials not properly characterized or disposed of. There were other potential hazardous materials that were disposed improperly (i.e., spent fluorescent lamps, mercury containing equipment, used oil, abandoned radioactive wastes). Therefore, it was very hard to determine the Facility generator classification based upon total waste generated on a monthly basis. There were discrepancies between the inventory logs and the actual containers observed in storage areas of the campus. Additionally, documentation associated with the solid waste disposal practices lacked, and were not available in the central file at the Occupational and Environmental Safety Office. Among the physical locations within the UPR-Mayagez Campus that EPA Inspectors identified as a major concern regarding solid waste management without a pertinent hazardous waste characterization were the Civil Department, Physics Department, Biology Department, Agricultural Sciences, Agronomy, Alzamora Farm, and Mechanics Department, and other Buildings and Land Departments throughout the campus. There was another concern regarding the management of spent fluorescent lamps, and used oils discarded by the University. There were no proper disposal procedures in place for the management of spent fluorescent lamps and discarded used oils. Some of the spent fluorescent lamps were crushed and/or disposed of with proper storage protection. EPA Inspectors stated that the lamps contain small amounts of mercury that could pose potential problems at the site if the university's management practices were not improved. During the inspection, EPA Inspectors observed that UPR-Mayagez Campus failed to properly label, date, or dispose of drums, and containers used to store hazardous waste. Many drums, and containers throughout the UPR-Mayagez Campus were improperly labeled, dated, or not labeled at all posing a potential threat of fire or explosion or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. Failure to mark containers of hazardous waste properly creates a risk to human health and the environment. Among the physical locations within the UPR-Mayagez Campus that EPA Inspectors identified as a major concern regarding the proper labeling, dating of containers with hazardous waste were the Central Accumulation Area for Hazardous Wastes, Civil Engineering, Physics Department, Mechanics Engineering and numerous satellite areas not covered under the Environmental Management Plan (i.e., approximately 40 satellite areas) located at different research laboratories throughout the UPR-Mayagez Campus including the Civil Engineering, Chemistry Department, Biology Department, Agricultural Sciences, Agronomy, and Physics Department, respectively. Under the University Laboratory Management Plan (LMP RCRA Subpart K), EPA Inspectors observed in the satellite areas, there were lacks "Unwanted Material" labeling, dating, waste codes, compatibility, the use of chemical formulae and the use to the terms unknown waste or original container chemical Status: Final 106 CEPD-RCRA-23-0440 Resource Conservation and Recovery Act University of Puerto Rico Mayagez Campus PRD000691063 names products as problem areas for satellite accumulation containers under RCRA Subpart K. As stated by EPA Inspectors, labeling on many containers did not provide any useful information to emergency responders in the event a chemical emergency should occur at these areas. Additionally, there was a concern about the lack of awareness of satellite accumulation control requirements under RCRA Subpart K for properly identifying, dating, and labeling the hazardous waste generated at the laboratories. As observed by EPA Inspectors in various hazardous waste storage and/or unwanted material areas the UPR-Mayagez Campus has failed to store compatible waste in order to avoid any detrimental event that may pose a human threat or environmental impact. It was stated on many occasions by EPA Inspectors that chemicals did not appear to be segregated by compatibility, and that shelving was not self-contained to prevent chemical leaks or spillage from incompatible waste containers. In the Civil Engineering, Physics Department and Alzamora Farm, EPA determined that there was an actual or potential of fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. 8 COMPLIANCE ASSISTANCE EPA Inspectors during the walkthrough the compliance areas discussed with UPR-Mayagez Campus' representatives the specific RCRA program regulations that apply to the University Campus, and how to stay in compliance in case they decide to minimize or recover waste streams and implement waste minimization/pollution prevention procedures as required by RCRA. 9 CONCLUSION & FOLLOW-UP ACTIONS After responding to EPA's observations, inspection of regulated areas and completion of a document session, EPA determined that the hazardous waste management program at UPR-Mayagez Campus was not satisfactory as required by the RCRA program, and that potential violations on applicable hazardous waste regulations were found. Therefore, I communicated to Dr. Agustin Rulln, Rector of the Mayagez University Campus, that any further enforcement action regarding potential violations were tentative and are pending administrative review by EPA. 10 ATTACHMENTS I. Figure 1- Facility Location Map and Figure -2 Aerial Photograph II. Photolog and Camera Roll (include all pictures taken during the inspection) Status: Final 107 CEPD-RCRA-23-0440 Title: Figure 1: University of Puerto Rico--Mayagez Campus, Puerto Rico - Location Map EPA ID: PRD000691063 Project: CEPD-RCRA-23-0440 Title: Figure 2: University of Puerto Rico--Mayagez Campus, Puerto Rico - Aerial Photo EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Picture 1 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 K there was one (1) 1-liter Erlenmeyer Flask with a "Biohazard Waste," unlabeled and without hazardous waste determination if it is managed as an lab waste, the content and the container must be labeled and date as "Unwanted Material." Picture 2 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 K there was one (1) 2-liter container with a yellow-colored spent solvent (PBS) labeled as "Hazardous Waste," and with an accumulation start date of July 13, 2022, not managed as "Unwanted Material" Picture 3 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 K there was one (1) 4-liter amber container with "ACS Reagent 37%" waste labeled as "Unwanted Material" but not dated with its accumulation start date. Picture 4 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 K there was one (1) 2.5-liter plastic container with "DMF/DCM" waste labeled as "Hazardous Waste" but not dated with its accumulation start date nor managed as "Unwanted Material." Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 5 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 J there were eight 4-L containers stored inside a cabinet area all labeled as "Unwanted Materials" and without their dates. However, no compatibility characteristics protocols were followed in the storage area. Picture 6 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 J there were four 4-L containers stored in trays containing THF and 1,4-Dioxane dated as July 16, 2019, and March 3, 2020, not in use and abandoned and not managed as "Unwanted Material," without a hazardous waste determination. Picture 7 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 J there was one (1) 4-liter glass container with a spent mobile phase connected to a HPLC not in use since November 2022, unlabeled and without hazardous waste determination if it managed as an "Unwanted Material." Picture 8 - UPR CHEMICAL ENGINEERING-- At the Lab IQ-101 HI there were six (6) 4-liter ambar containers stored inside a cabinet area only two were labeled as "Unwanted Materials" and one with its accumulation start date of March 3, 26, 2019 which exceeded over six months of the LMP. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 9 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 HI there were six (6) 4-liter ambar and glass containers stored inside a cabinet sink area only four were labeled as "Unwanted Materials" and with their accumulation start dates. However, three (3) were not labeled as "Universal Wastes," nor dated . Picture 10 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 HI there were four (4) 4-L containers stored inside a cabinet sink not labeled as "Unwanted Materials," and dated as of August 23, 2022, March 1, 2021, February 24, 2023, and other non-dated which exceeded over six months of the LMP collection protocols. Picture 11 - UPR CHEMICAL ENGINEERING- At the Lab IQ-01 M there was one (1) 4-liter ambar container with a spent mobile phase (ACN/Water 90/10) connected to a HPLC labeled its holding jacket as "Waste," but not dated with its accumulation start date nor managed as "Unwanted Material" Picture 12 - UPR CHEMICAL ENGINEERING-- At the Lab IQ-01 G there were two (2) 750 ml plastic bottle and 200 ml Erlenmeyer beaker containing "Coomassie Blue Ink Waste" with spent methanol solvent not labeled as "Unwanted Materials," nor dated among other unlabeled and undated wastes. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 13 - UPR CHEMICAL ENGINEERING- At the Lab IQ-01 G there were one styrofoam box containing discarded vials an other waste bottles not properly labeled as "Unwanted Materials," nor dated with its accumulation start date as required in the LMP protocols . Picture 14 - UPR CHEMICAL ENGINEERING- At the Lab IQ-101 O there were two (2) 4-liter plastic containers with a spent petroleum ether and terpolymer labelled as "Unwanted Materials," and dated with their accumulation start dates of May 15, 2022, which exceeded over six months of the LMP collection protocols. Picture 15 - UPR CHEMICAL ENGINEERING- At the Lab IQ-103 A there were three 4-L ambar containers with Methanol stored next to one (1) 500-ml bottle with Formic Acid and next to one (1) 1-gallon plastic bottle container Ethy Alcohol 70% without following any safety protocols or compatibility characteristic. Picture 16 - UPR CHEMICAL ENGINEERING-- At the Lab IQ-102 A there was one (1) 2-gallon plastic container with a spent Ethanol aqueous waste no labeled as "Unwanted Materials," nor dated with its accumulation start date. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 17 - UPR CHEMICAL ENGINEERING- At the Lab IQ-102 A it was observed the storage of chemical reagents at laboratory cabinets was conducted without following any safety protocols or compatibility characteristics (Flammable, Corrosives and Toxics - NaOH, Hydrochloric Methylcellulose, KCl) of the reagents. Picture 18 - UPR CHEMICAL ENGINEERING- At the Lab IQ-102 D there were three 1-L ambar bottles with unknown wastes, one labelled "Unwanted Materials," and dated as February 28, 2022, which exceeded over six months of the LMP collection protocols. The other two were not labeled as "Unwanted Materials." Picture 19 - UPR PHARMACY BUILDING - At the FARM 109 there was one 40-gallon cardboard drum containing wastes with "Active Ingredients" not labelled as "Unwanted Materials," and dated with its accumulation start date of January 22, 2021, which exceeded over six months of the LMP collection protocols. Picture 20 - UPR PHARMACY BUILDING -- At the FARM 109 there was one (1) 40-gallon blue drum containing wastes with "No Active Ingredients" not labelled as "Unwanted Materials," and dated with its accumulation start date of July 17, 2020, which exceeded over six months of the LMP collection protocols. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 21 - UPR CIVIL ENGINEERING- At the Lab CI 018 there were two (2) 5-gallon white containers with Methanol, Ethyl Acetate, Dichloromethane and Acetone both labelled as "Hazardous and dated with its accumulation start date of March 1, 2023, but not labeled as "Unwanted Materials." Picture 22 - UPR CIVIL ENGINEERING- At the Lab ICI 018 there were two (2) 4-L ambar bottles containing Acetone and both labelled as "Hazardous Wastes,"" and dated with its accumulation start date of January 15, 2023, but none labelled as "Unwanted Materials." Picture 23 - UPR CIVIL ENGINEERING- At the Lab CI 018 there was one (1) 4-L ambar bottle containing Methanol, Ethyl Acetate, Dichloromethane and Acetone labelled as "Hazardous and dated as November 10, 2022, which exceeded six months LMP collection protocols nor labeled as "Unwanted Materials." Picture 24 - UPR CIVIL ENGINEERING- At the Lab CI 018 there was one One (1) 4-L container stored in the extractor hood THF (Tetrahydrofuran) and dated as May 5, 2012, not in use and abandoned and not managed as "Unwanted Materials," without a hazardous waste determination of the content. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 25 - UPR CIVIL ENGINEERING- At the Lab CI 018 SSA-1 there were two (2) 5-gallon white containers with organic wastes both labelled as "Hazardous Waste," and dated with its accumulation start date nor labeled as "Unwanted Materials." Picture 26 - UPR CIVIL ENGINEERING- At the Lab CI 018 Blue Cabinet Flammable there were two (2) 4-L bottles containing Dichloroethane leaking and covered with moisture, dated January 22, 2011 which decomposes into carbon dioxide and in present of heat it can produce toxic fumes such methylene chloride. Picture 27 - UPR CIVIL ENGINEERING- At the Lab ICI 018 Blue Cabinet Flammable there was one (1) 4-L ambar bottle containing Acetone dated April 4, 2014, which is highly flammable and not in use. Picture 28 - UPR CIVIL ENGINEERING-- At the Lab CI 018 Blue Cabinet Flammable there was one (1) 1-gallon metal can with Sodium Borohydride, dated January 01, 2011, leaking on the tray, fully corroded, covered with water moisture and seemed decomposed forming sodium hydroxide and hydrogen. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 29 - UPR CIVIL ENGINEERING- At the Lab CI 018 Blue Cabinet Flammable there was one (1) 4-L ambar bottle containing Titanium Isopropoxide, dated August 2019, which is incompatible with strong oxidizing agents and strong acids Picture 30 - UPR CIVIL ENGINEERING- At the Lab CI 018 Blue Cabinet Flammable there was one (1) 4-L ambar bottle containing Methanol, dated March 2015, not in use, abandoned which vapors decompose to form carbon monoxide gas and hydrogen gas Picture 31 - UPR CIVIL ENGINEERING- At the Lab CI 018 Blue Cabinet Corrosive there was one Four (4) 4-L ambar bottles containing Acetic Anhydride (Aceti Acid Glacial) dated from years 2009 thru 2011, in deteriorated conditions and labels being vanished not in use and abandoned. Picture 32 - UPR CIVIL ENGINEERING-- At the Lab ICI 018 Blue Cabinet Corrosive there were three (3) 4-L ambar bottles containing Hydrochloric Acid, dated January 27, 2020, deteriorated conditions and labels being vanished. Acetic Anhydride is not compatible with Hydrochloric Acid and should not be stored Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 33 - UPR CIVIL ENGINEERING- At the Lab CI 018 Blue Picture 34 - UPR CIVIL ENGINEERING- At the Lab CI 018 Blue Cabinet Corrosive there were two (2) 2.5-L and -L plastic and Cabinet Corrosive there was one (1) 1-L ambar bottle containing ambar bottles containing Phosphoric Acid, dated 2014, some old Hydrochloric Acid, dated 2001, with label being vanished, not in and in deteriorated conditions, not in use and abandoned . use and abandoned . Picture 35 - UPR CIVIL ENGINEERING- At the Lab CI 018 Brown Cabinet Flammable there were six (6) 4-L ambar bottles containing Hexane, and n-Hexane, dated from 2005 - 2016. Picture 36 - UPR CIVIL ENGINEERING-- At the CI 018 Brown Cabinet Flammable there were Eight (8) 4-L plastics and ambar bottles containing Methanol, Water HPLC Grade, Ehtyl Acetate, and Xylene, dated from 2005 - 2014. The Ethyl Acetate was labeled as "Non in Use Contaminated." Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 37 - UPR CIVIL ENGINEERING- At the Lab CI 018 Brown Cabinet Flammable there were seven (7) 2-L ambar bottles containing Methanol, Hexane, Methylpentane, Isopentyl Acetate, and Ethylene, dated from 2005 - 2016. One of the bottles containing Isopentyl Acetate was labeled as "Avoid Problems - Ask." Picture 38 - UPR CIVIL ENGINEERING- At the Lab CI 018 EPA Inspectors observed numerous expired chemicals (since < 1986), discarded, contaminated, various unused chemical reagents, deteriorated and stored for a long time in shelves without physical protection each other from incompatibility characteristics. Picture 39 - UPR CIVIL ENGINEERING - At the Lab CI 018 all these chemical reagents were not in use, expired and discarded a long time ago from various laboratory research and were stored in this area and never declared as "solid waste material," or notified to the OPASO for final disposition. Picture 40 - UPR CIVIL ENGINEERING - At the Lab CI 018 there was no hazardous waste determination being performed on abandoned, expired, not in use, discarded hazardous chemical waste inventory before its final disposal nor have been managed under the Laboratory Management Plan. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 41 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-009 there were over twenty-eight (28) bottles and containers with discarded or spent chemical reagents generated at the laboratories not properly labeled as "Unwanted Materials," nor dated with its accumulation start date. Picture 42 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-009 containers will not be removed from a laboratory unless the "CHEMATIX" label is attached to the container. As observed by EPA Inspector non Chematix labels were affixed to each container of "Unwanted Material, No labels, No dates. Picture 43 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-051 Instrumental Analysis there was one 4-liter ambar container with a spent mobile phase (ACN/Water 90/10) connected to a high-performance liquid chromatography (HPLC) no labeled as "Unwanted Material" nor dated with its accumulation start date. Picture 44 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-051 SAA there were 10 bottles of "Unwanted Materials," with spent chemical reagents generated at the laboratories properly labeled as "Unwanted Materials," and dated with its accumulation start date but not segregated by compatible characteristics Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 45 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-023 there was One (1) 4-liter ambar container with a spent Hydranal Composite and Methanol labeled as "Unwanted Material," dated with its accumulation start date of April 4, 2019, which exceeded over six months of the LMP collection protocols. Picture 46 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-023 there were Two (2) 4-liter ambar containers with a spent Hydranal Composite Waste, one also labeled as "Viejo - Old," both were no labeled as "Unwanted Material," nor dated with its accumulation start date. Picture 47 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-023 there was one (1) 4-liter ambar container with a Methanol Solvent Waste labeled as "Unwanted Material," dated with its accumulation start date of July 31, 2016 which exceeded over six months of the LMP collection protocols. Picture 48 - UPR CHEMISTRY DEPARTMENT-- At the Lab Q-023 there were two (2) 4-liter ambar containers with a spent Hydranal Composite Waste, and the other with Methanol Waste, both were labeled as "Unwanted Material," and both dated with their start dates of December 19, 2016, and July 31, 2025. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 49 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-050 at the Satellite Accumulation Area under a laboratory cabinet there were numerous bottes containing discarded or spent chemical reagents generated at the laboratories not labeled as "Unwanted Materials," nor properly dated. Picture 50 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-050 there were two (2) 500-ml containers with a Napthalene Waste and one (1) 750-ml container with a Phase Diagram Waste no labeled as "Unwanted Material," nor dated with its accumulation start date. Picture 51 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-050 there were two (2) 4-liter ambar containers with a spent Unknown Waste, both labeled as "Unwanted Material," but properly dated with its accumulation start date of March 2023. Picture 52 - UPR CHEMISTRY DEPARTMENT-- At the Lab Q-050 (SAA No. 2) on top of a laboratory cabinet table there were four (4) 4-liter ambar containers with a spent Unknown Waste, all labeled as "Unwanted Material," but properly dated with their accumulation start dates. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 53 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-046 SAA there were numerous containers with discarded or spent chemical reagents generated at the laboratories most of them properly labeled as "Unwanted Materials," but properly dated with their accumulation start dates . Picture 54 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-046 there two (2) 4-liter ambar containers with a spent solvent waste both labeled as "Unwanted Materials," and dated as September 27, 2021, and September 22, 2021, which exceeded over six months of the LMP collection protocols. Picture 55 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-046 there were two (2) 4-liter crystal containers with a spent solvent waste both labeled as "Unwanted Materials," and dated as September 27, 2021, and September 22, 2021, which exceeded over six months of the LMP collection protocols. Picture 56 - UPR CHEMISTRY DEPARTMENT-- At the Lab Q-046 were three (3) 4-liter crystal containers with a spent solvent waste both labeled as "Unwanted Materials," and dated as September 27, 2021, September 22, 2021, February 27, 2023 and which exceeded over six months of the LMP collection protocols. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 57 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-046 there were two (2) 4-liter ambar containers with a spent Acetone and Organic Ink waste both labeled as "Unwanted Materials," and dated as February 13, 2022, and March 3, 2023, which exceeded over six months of the LMP collection protocols. Picture 58 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-046 there were two (2) 4-liter crystal containers with a spent Acetone and Ethylacetate waste both labeled as "Unwanted Materials," (one no "CHEMATIX" label) and dated with their accumulation start dates of April 18, 2022, and the other no dated. Picture 59 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-116 there were numerous (approximately over eleven 11) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories labeled as "Unwanted Materials," but not dated February 3, 2022, and year 2019. Picture 60 - UPR PCHEMISTRY DEPARTMENT -- At the Lab Q116 there were numerous over ten 10 "Unwanted Materials," containing discarded chemical reagents (i.e., Cyanide, Ethanol, Benzene) generated at the laboratories not properly labeled as "Unwanted Materials," nor properly dated. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 61 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-116 there was one (1) 1-gallon container with Discarded Vials labeled as "Unwanted Material," but dated with their accumulation start dates of February 24, 2022, which exceeded over six months of the LMP collection protocols. Picture 62 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-112 Inside an extractor hood there were numerous (approximately over nine 9) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories no properly labeled as "Unwanted Materials," nor dated. Picture 63 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-112 there were one (1) 4-liter plastic container with a Chemical Wastes not labeled as "Unwanted Materials," nor dated with its accumulation start date. Picture 64 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-110 there were numerous over ten 13 "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories few of them properly labeled as "Unwanted Materials," but not dated with their accumulation start dates . Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 65 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-110 there was one (1) 1-gallon container with Discarded Vials labeled as "Unwanted Material," but dated with their accumulation start dates of February 24, 2022, which exceeded over six months of the LMP collection protocols. Picture 66 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-106 one (1) 4-liter ambar container with a spent Methylene Chloride waste not labeled as "Unwanted Materials," nor dated with its accumulation start date. Picture 67 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-106 there were were various styrofoam boxes containing Dissolve Oxygen Demand test which uses Potassium dichromate as active ingredient and mercury. It was questionable how COD vials are being disposed of since they are characterized as highly hazard. Picture 68 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-165 there was one (1) 1-gallon ambar container with a spent Sulfuric Acid waste labeled as "Unwanted Materials," leaking, and dated with its accumulation start date of September 28, 2021, which exceeded over six months of the LMP collection protocols. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 69 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-163 on the floor there were numerous (approximately over twelve 12) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories not properly labeled as "Unwanted Materials," nor dated. Picture 70 - UPR CHEMISTRY DEPARTMENT- At the Lab Q-159 inside an extractor hood there were numerous (approximately over ten 10) "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories not labeled as "Unwanted Materials," open and not dated. Picture 71 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-155 inside an extractor hood there were numerous (approximately over eighteen 18 "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories few properly labeled as "Unwanted Materials," nor dated. Picture 72 - UPR CHEMISTRY DEPARTMENT - At the Lab Q-155 there was one (1) -liter ambar container with "Hazardous Waste" not labeled as "Unwanted Materials," and dated as August 17, 2009, not managed as Unwanted Material or complying with the Laboratory Management Plan (LMP). Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 73 - UPR CENTRAL ACCUMULATION AREA- It has posted Picture 74 - UPR CENTRAL ACCUMULATION AREA- It has posted signs with the words, "Hazardous Waste Accumulation Area - signs with the words, "Hazardous Waste Accumulation Area - Restricted Area Authorized Personnel Only," including emergen- Restricted Area Authorized Personnel Only," including emergen- cy phone numbers. cy phone numbers. Picture 75 - UPR CENTRAL ACCUMULATION AREA- The room is Picture 76 - UPR CENTRAL ACCUMULATION AREA- At the at well vented and provided with ambient controlled temperature CAA, it was observed that some containers were not properly in the area and emergency alarm and spill control equipment. labeled, nor accumulation start dates were shown clearly. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 77 - UPR CENTRAL ACCUMULATION AREA- At the CAA, it Picture 78 - UPR CENTRAL ACCUMULATION AREA- At the CAA, it was observed that some of the containers were not in good con- was observed that some containers were its RCRA codes (i.e., ditions or sealed to secure of any potential releases of waste "D001") nor identified with its hazard communication picto- content. grams as required by RCRA regulations Picture 79 - UPR CENTRAL ACCUMULATION AREA- At the CAA, there were seven (7) 15-gallon blue drums containing flammable liquid wastes (Ethanol, Methanol, Acetone-D001), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates Picture 80 - UPR CENTRAL ACCUMULATION AREA-- At the CAA, all drums were clearly labeled, coded as "D001", and identified with its hazard communication pictograms as, "Flammable Liquids." Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 81 - UPR CENTRAL ACCUMULATION AREA- At the CAA, there were five (5) 5-gallon white drums containing flammable liquid wastes (Ethanol, Methanol, Acetone-D001), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates . Picture 82 - UPR CENTRAL ACCUMULATION AREA- At the CAA, all drums were clearly labeled, coded as "D001", and identified with its hazard communication pictograms as, "Flammable Liquids." Picture 83 - UPR CENTRAL ACCUMULATION AREA- At the CAA, there was one (1) 55-gallon white drum with flammable liquid waste, clearly labeled with the words, "Hazardous Waste," and dated on June 6, 2022, not coded as "D001", nor identified with its hazard communication pictograms. Picture 84 - UPR CENTRAL ACCUMULATION AREA-- At the CAA, there were Six (6) 5-gallon white drums containing corrosive liquid wastes (Sodium Hydroxide, Hydrochloric Acid, Sulfuric Acid-D002), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 85 - UPR CENTRAL ACCUMULATION AREA- At the CAA, there were three (3) 15-gallon blue drums containing corrosive liquid wastes (Sodium Hydroxide, Hydrochloric Acid, and Sulfuric Acid-D002), clearly labeled with the words, "Hazardous Waste," and dated with their accumulation start dates . Picture 86 - UPR CENTRAL ACCUMULATION AREA- At the CAA, there was one 1-gallon crystal bottle containing corrosive liquid wastes (Acetic Acid, Glacial-D002), labeled as "Hazardous Waste," and dated on March 9, 2023 but not coded as "D002", nor identified with its hazard communication pictogram. Picture 87 - UPR CENTRAL ACCUMULATION AREA- At the CAA, Three (3) 15-gallon blue/white drums containing corrosive liquid wastes clearly labeled with the words, "Hazardous Waste," but not pictograms and exceeded over 180 dyas accumulation time permitted. Picture 88 - UPR CENTRAL ACCUMULATION AREA-- At the CAA, Six (6) 500-ml, 250-ml, and 100-ml small ambar containers with toxic solid wastes (Ampicin, Potasium Chromate, Hydroxide, and Butyronitrile), labeled as "Hazardous Waste," and all dated es on October 21, 2022, but not labeled with hazard pictograms. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 89 - UPR CENTRAL ACCUMULATION AREA- At the CAA, there two (2) plastic trays with discarded alkaline and computer lithium batteries, open and not clearly as "Hazardous Waste," nor dated with their accumulation start dates and no hazard communication pictogram as, "Ignitable and Reactive Solids." Picture 90 - UPR CENTRAL ACCUMULATION AREA- At the CAA, Inside a metal cabinet there were five (5) carboard boxes and one plastic four-pack containing discarded flares not labeled as "Hazardous Waste," nor dated with their accumulation start dates nor hazard pictograms as, "Explosive Solids." Picture 91 - UPR CENTRAL ACCUMULATION AREA - At the time of the Inspection, EPA inspector requested to test emergency and alarm system when tested all fire suppressant material was concurrently activated and descended upon all of us inside the CAA. Picture 92 - CENTRAL ACCUMULATION AREA -- At the Hazmat Storage Building there were nine (9) 55-gallon blue/white drums containing Chiller Washing Water - D002), clearly labeled with the words, "Hazardous Waste," and all dated with their accumulation start dates of January 12, 2023 and hazard pictograms. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 93 - UPR CENTRAL ACCUMULATION AREA- At the Hazmat Storage Building inside a metal cabinet there were five (5) 5gallon containers with corrosive reagents (i.e., Sodium Hydroxide) secured by EH&S Officers. All reagents were well maintained, controlled and in compliance. Picture 94 - UPR CENTRAL ACCUMULATION AREA- At the Hazmat Storage Building there were six (6) 1-gallon crystal containers with radioactive waste of "Uranyl Nitrate" and "Uranyl Acetate," stored for years without no hazardous waste determination or managed as hazardous waste (radioactive-corrosive). Picture 95 - UPR CENTRAL ACCUMULATION AREA - At the Hazmat Storage Building that no Hazardous Waste Disposal Contractor in the Island would transport or dispose of radioactive waste and that is the reason those wastes have been stored for years. Picture 96- CENTRAL ACCUMULATION AREA -- At the Hazmat Storage Building inside a plastic tray there were three (3) 50-ml (30-g) crystal containers with radioactive waste of "Uranyl Nitrate" and "Uranyl Acetate," stored for years without no hazardous waste determination or managed as hazardous waste. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 97 - UPR BUILDINGS & LAND DEPARTMENT- At the Me- Picture 98 - UPR BUILDINGS & LAND DEPARTMENT- At the Mechanic Shop there was one (1) 55-gallon blue drum open with chanic Shop there was one (1) 5-gallon black pail with used oil impacted material with used oil not marked with the words, not marked with the words, "Used Oil." "Used Oil." Picture 99 - UPR BUILDINGS & LAND DEPARTMENT- At the Mechanic Shop there was one (1) 200-gallon double wall Used Oil Steel Tank marked with the words, "Used Oil." However, there were old and new used oil spills and stains on the concrete floor of the used oil. Picture 100 - UPR BUILDINGS & LAND DEPARTMENT- At the Mechanic Shop there was one (1) part-washer tray-container machine which uses CB-100 degreaser (e.g., biodegradable water-based cleaner and degreaser) to clean up auto parts, but diesel was used as a degreaser in the part-washer machine. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 101 - UPR BUILDINGS & LAND DEPARTMENT- At the Picture 102 - UPR BUILDINGS & LAND DEPARTMENT- At the Mechanic Shop, there was one (1) 55-gallon black drum open on Refrigeration Shop, there was one (1) 55-gallon blue drum with a top with spent used oil filters impregnated with used oil not yellow drainage tray on top with used oil generated from drain- marked with the words , "Used Oil." ing compressors not marked with the words, "Used Oil" Picture 103 - UPR BUILDINGS & LAND DEPARTMENT- At the At the Refrigeration Shop, there were two (2) 1,000 pounds steel tanks with discarded refrigerants not marked with the words, "Used Refrigerant." No hazardous waste determination has been made nor recycling or reclaiming program evidenced. Picture 104 - UPR BUILDINGS & LAND DEPARTMENT-- At the Cleaning Warehouse Shop, EPA inspectors requested the inventory of product purchased that has historically been used for cleaning purposes in the Campus which contain hazardous characteristics. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 105 - UPR BUILDINGS & LAND DEPARTMENT- At the Cleaning Warehouse Shop, many of the cleaning solvent products were concentrated and contained hazardous substances as active ingredients after thorough evaluation of the products Safety Data Sheets (SDSs). Picture 106 - UPR BUILDINGS & LAND DEPARTMENT- At the Fields and Roads Shop there was one (1) 30-gallon container part-washer machine which uses mineral spirit degreaser to clean up equipment parts served by Oil Energy System which was out of service for a long period of time. Picture 107 - UPR BUILDINGS & LAND DEPARTMENT- At the Fields and Roads Shop there was one (1) 20-gallon black container open on top with spent used oil filters impregnated with used oil not marked with the words, "Used Oil." Picture 108 - UPR BUILDINGS & LAND DEPARTMENT-- At the Fields and Roads Shop there was One (1) 55-gallon blue drum with a white drainage tray on top with used oil generated from draining landscape equipment not marked as "Waste Oil," and not with the words, "Used Oil." Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 109 - UPR BUILDINGS & LAND DEPARTMENT- At the Fields and Roads Shop there was one (1) 55-gallon white drum with a yellow drainage tray on top with used oil generated from draining landscape equipment marked with the words, "Aceite Usado." Picture 110 - UPR BUILDINGS & LAND DEPARTMENT- At the Fields and Roads Shop there was one (1) 55-gallon white drum with rags impregnated with used oil not marked with the words, "Used Oil." Picture 111 - UPR BUILDINGS & LAND DEPARTMENT - At the Universal Waste Storage Area there were one (1) 40-gallon container and three (3) 5-gallon pails all open with broken fluorescent lamps mixed with crushed fluorescent lamps and sodium bulbs showing evidence of mercury releases and breakage. Picture 112 - UPR BUILDINGS & LAND DEPARTMENT - At the Universal Waste Storage Area there was one (1) white plastic tray (1'x1'x 2') with crushed fluorescent lamps and sodium bulbs showing evidence of breakage, leakage, and damage that caused releases of mercury or other hazardous constituents to the area. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 113 - UPR BUILDINGS & LAND DEPARTMENT- At the Universal Waste Storage Area there were sixty (60) square cardboard boxes (1'x1'x 4') packing over sixty (60) 4-foot spent fluorescent lamps, some open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates. Picture 114 - UPR BUILDINGS & LAND DEPARTMENT- At the Universal Waste Storage Area there were thirty (30) square cardboard boxes (1'x1'x 8') containing broken 8-foot spent fluorescent lamps, open, not labeled with the words, "Universal Waste" or dated with their accumulation start dates. Picture 115 - UPR BUILDINGS & LAND DEPARTMENT - At the Universal Waste Storage Area there were three (3) cardboard boxes (1'x1'x 2') one withi spent halogen bulbs, the other with pig tails, and another with LED light cards, not labeled with the words, "Universal Waste," or "Mercury Equipment," nor dated. Picture 116 - BUILDINGS & LAND DEPARTMENT -- At the Universal Waste Storage Area there were two (2) green plastic trays (2'x2'x2') packing over twenty-five (25) U-shaped spent fluorescent lamps, open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 117 - UPR BUILDINGS & LAND DEPARTMENT- At the Universal Waste Storage Area there were one (1) 55-gallon white drum and one (1) square cardboard boxes (1'x1'x 4') packing over twenty (20) 4-foot and 8-foot spent fluorescent lamps, both open and not labeled with the words, "Universal Waste." Picture 118 - UPR BUILDINGS & LAND DEPARTMENT- At the Universal Waste Storage Area there were two (2) 55-gallon black steel drums with lids containing "Ballast" which were removed from aluminum frames. None were clearly labeled with the words, "Universal Waste-Mercury Equipment," or dated. Picture 119 - UPR BUILDINGS & LAND DEPARTMENT - At the Universal Waste Storage Area there were two (2) cardboard box (1'x1'x 2') open with high-density halogen open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates. Picture 120 - BUILDINGS & LAND DEPARTMENT -- At the Universal Waste Storage Area there was one (1) cardboard box (1'x1'x 2') open with LED light cards, and not labeled with the words, "Universal Waste-Mercury Containing Equipment," or dated. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 121 - UPR BUILDINGS & LAND DEPARTMENT- At the Paint Shop there were over 100 1-gallon paint pails decommissioned since were damaged due the time during the COVID-19 not in use No hazardous waste determination has been made on the contents of all 5-gallon paint pails at the Paint Shop. Picture 122 - UPR BUILDINGS & LAND DEPARTMENT- At the Paint Shop, it was noted that the practice to dispose of used brushes was to clean them up with solvent thinner, if it is no longer usable, they allow them to dry, and then dispose of with domestic garbage as illegal treatment of hazardous wastes. Picture 123 - UPR BUILDINGS & LAND DEPARTMENT - At the Welding Shop, the shop was closed at the time of the Inspection and EPA inspectors took an overlook view of the shop from the outside area. Picture 124 - BUILDINGS & LAND DEPARTMENT -- At the Welding Shop, there were over ten (10) 100-lbs, 75-lbs and 25-lbs gas cylinders store in a concrete shed and secured with a cyclone fenced gates. There was oxygen, ethylene and other compressed gases stored in this shop and used for welding jobs. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 125 - UPR ALZAMORA FARM- At the Mechanic Shop there were over ten (10) 4-foot spent fluorescent lamps, on the floor without control or containment showing evidence of breakage, leakage, and damage that caused releases of mercury or other hazardous constituents to the area. Picture 126 - UPR ALZAMORA FARM- At the Mechanic Shop there was one (1) 55-gallon red drum open on top with spent used oil filters impregnated with used oil not marked with the words, "Used Oil," (Spanish "Filtros Usados"). Picture 127 - UPR ALZAMORA FARM- At the Mechanic Shop Picture 128 - UPR ALZAMORA FARM- At the Mechanic Shop there was one (1) one (1) 55-gallon black steel drum open with there were two (2) 55-gallon blue plastic drums with used oil not used oil not marked with the words, "Used Oil." marked with the words, "Used Oil." Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 129 - UPR ALZAMORA FARM- At the Mechanic Shop, there were two (2) 55-gallon blue plastic drums, with spent degreaser not labeled with their waste content. No hazardous waste determination has been made on the contents of the two 55-gallon drums at the Mechanic Shop. Picture 130 - UPR ALZAMORA FARM- At the Mechanic Shop there were five (5) vehicle and truck batteries on the floor discarded without control showing evidence of leakage, and damage that releases of Sulfuric Acid, and not labeled with the words, "Hazardous Wastes," nor dated. Picture 131 - UPR ALZAMORA FARM- At the Mechanic Shop there was one (1) Tractor 6600 parked outside of the shop releasing used oil on the ground from an engine leak. EPA inspectors advised to stop, control, and clean up immediately the used oil release on the ground. Picture 132 - UPR ALZAMORA FARM-- At the Alzamora Farm, EPA inspectors learned that the last application used of most pesticides at the warehouse were logged in its Application Registry as of February 9, 2018. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 133 - UPR ALZAMORA FARM- At the Alzamora Farm, there was one (1) 2.5-gallon container with "Poast" herbicide which is a postemergence herbicide for control of annual and perennial grass weeds manufactured by BASF. The container seemed deteriorated and abandoned. Picture 134 - UPR ALZAMORA FARM- At the Alzamora Farm, there were seven (7) 1-liter containers with Neem Oil "Dyna Gro" which is an organic solution used as a pesticide against insects, mites, or fungi in plants. The containers seemed not in use or abandoned. Picture 135 - UPR ALZAMORA FARM- At the Alzamora Farm, there were two (2) 2.5-gallon container with "M-Pede" insecticide that provides excellent contact control of various insects. The container seemed not in use or abandoned. Picture 136 - UPR ALZAMORA FARM-- At the Alzamora Farm, there was one (1) 55-gallon black steel drum with "Dipel DT" insecticide used for caterpillar control. The drum seemed not in use or abandoned. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 137 - UPR ALZAMORA FARM- At the Alzamora Farm, there was one (1) cardboard box containing 20-liter "Hi-Yield" insecticide to termites, fleas, ticks, carpet beetles, and cockroaches manufactured by Hedwin, Baltimore, MD. The box seemed deteriorated, abandoned, and leaking on the shelf. Picture 138 - UPR ALZAMORA FARM- At the Alzamora Farm, there was one (1) 3-shelf metal storage rack containing; i) eight (8) plastic bags broken with powder insecticide (Dipel Dry); ii) two (2) 1-lb bottles with Dipel 150 Dust; iii) two (2) 1-gallon containers with Vydate L and other various not in use insecticides. Picture 139 - UPR ALZAMORA FARM- At the Alzamora Farm, there was one (1) 3-shelf metal storage rack containing ("Fungicides"): i) one (1) 2.5-gallon with Physan 2.0 fungicide; ii) two (2) 2.5-gallon with Banrot 40 WP fungicide; and iii) nine (9) 2 -5-gallon and 1-gallon containers with unknown fungicides. Picture 140 - UPR ALZAMORA FARM- At the Alzamora Farm, the agronomist Jos Muoz Rivera made an inventory of the stored materials (March 15, 2023) of the unknown insecticide severely deteriorated and in detrimental conditions . Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 141 - UPR CAMPUS HOTEL - At the Campus Hotel, EPA inspectors observed that many of the cleaning solvent products were concentrated and contained hazardous substances as active ingredients. Picture 142 - UPR CAMPUS HOTEL - At the Campus Hotel, EPA inspectors reiterated that products containing hazardous substances as active ingredients, and as specified in the product's SDSs, must be managed in a manner to avoid the disposal into the environment as a hazardous waste. Picture 143 - UPR PRINTING DEPARTMENT - At the Printing Shop, all printing ink used to reproduce the imprint is water based therefore it does not contain hazardous ingredients. The Printing Office uses Digital Xerox machines in which ink cartridges are replaced on a tolling agreement with Xerox. Picture 144 - UPR PRINTING DEPARTMENT - At the Printing Shop, Mr. Caban indicated that the printing used to be offset by pressing machine and that wastes used to be generated from used rags impregnated with Supreme Plate Cleaner which were collected and sent to be laundered and reused. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 145 - UPR SWIMMING POOL AREA - At the Swimming Pool Area, all choline treatment at the swimming pool area is contracted out and is based on solid dosage of Sodium Chloride (NaCl) by a Pulsar 4 System . Picture 146 - UPR SWIMMING POOL AREA - At the Swimming Pool Area, the Pulsar 4 System controls and applies chemicals as needed to the pool water, and on a routine basis, and therefore, there is not any chemical storage room at the swimming pool area . Picture 147 - UPR HHEALTH FITNESS CENTER (NEW GYM) - At the Health Fitness Center, raw material products are used in this area mainly for cleaning such as waxes, finishing stripper, interlock metal degreaser, mechanic degreaser, spray cans stored in a brown cabinet secured lock. Picture 148 - UPR NURSING DEPARTMENT - The Nursing Department houses the nursing school laboratories and teaching classrooms which are used to simulate medical emergencies and routine day care of hospital patients. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 149 - UPR NURSING DEPARTMENT - At the Nursing School, spent vegetal blood and spent related equipment (i.e., needles, syringes, gloves, and gauzes, among others) are discarded in red bags and containers which are later disposed of as biomedical waste by Stericycle Puerto Rico biomedical contractor. Picture 150 - UPR NURSING DEPARTMENT - At the At the Nursing School, all biomedical wastes are collected at the laboratory in biomedical plastic red bags, and in red containers for sharp waste materials and collected by Stericlycle Puerto Rico for final disposition. Picture 151 - UPR HEALTH MEDICAL SERVICES BUILDING - At the Health Medical Services, controlled pharmacy drugs and medicines were stored with some expired controlled pharmacy drugs which are disposed of as biomedical waste. Picture 152 - UPR HEALTH MEDICAL SERVICES BUILDING - At the Health Medical Services, expired medicines and/or pharmacy drugs are discarded as a Biomedical Waste. Some of the expired medications have hazardous waste characteristics and a proper hazardous waste determination must be made on them. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 153 - UPR PHYSICS DEPARTMENT- At the Geology Lab F107 there were two (2) 4-liter ambar container with a spent Phosphoric Acid (100%) inside a blue plastic bin no labeled as "Unwanted Material" and dated with their accumulation start dates of July 18, 2003, and July 11, 2003. Picture 154 - UPR PHYSICS DEPARTMENT- At the Geology Lab F107 there was one (1) 4-gallon bucket with a spent vials containing Phosphoric Acid (100%) no labeled as "Unwanted Material" nor dated with its accumulation start date. Picture 155 - UPR PHYSICS DEPARTMENT- At the Geology Lab F107 there was one (1) 250-ml Erlenmeyer flask and discarded vials containing Phosphoric Acid (100%) inside a blue plastic bin no labeled as "Unwanted Material" nor dated with its accumulation start date. Picture 156 - UPR PHYSICS DEPARTMENT- At the Physics Lab F129, there were numerous chemical reagents in a cabinet including sodium acetate, aluminium acetate, sodium sulfide, lithium hydroxide, tin (II) oxide, amonium hydroxide without compatibility or hazard waste determination. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 157 - UPR PHYSICS DEPARTMENT- At the Physics Lab F129, there was sodium hydroxide stored next to Polyvinylpyrrolidone; possible incompatible chemical reagents stored together without mean of physical segregation nor hazardous waste determination. Picture 158 - UPR PHYSICS DEPARTMENT- At the Physics Lab F129, there was potassium Acetate stored next to Iron Acetate "moisture sensitive" possible incompatible chemical reagents stored together without mean of any physical segregation. Iron Acetate is air sensitive and should be stored under inert gas.. Picture 159- UPR PHYSICS DEPARTMENT- At the Lab F-129, there was potassium chloride stored next to Citric acid; possible incompatible chemical reagents stored together without any mean of physical segregation. Potassium chloride incompatible with acids, sulfuric acid, and citrates Picture 160 - UPR PHYSICS DEPARTMENT-- At the Physics Lab F129, there were nitroaniline stored next to ammonium, and cobalt (II) chloride which turns pink on exposure to air and moisture sensible and should be stored under nitrogen. All these chemical reagents stored together incompatibles. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 161 - UPR PHYSICS DEPARTMENT- At the Physics Lab F129, inside the gray solids' cabinet, there were unknown chemical reagents stored next to acids (i.e., tartaric acid, some seemed abandoned, not in use or stored in lieu of being disposed of as a hazardous. Picture 162 - UPR PHYSICS DEPARTMENT- At the Physics Lab F129, there was potassium dichromate (oxidizers), stored next to Strontium hydroxides and lithium hydroxide (inorganic bases) incompatible and stored together without any mean of physical segregation nor hazardous waste determination Picture 163 - UPR PHYSICS DEPARTMENT- At the Physics Lab F129, there was Lithium oxide stored next to Oxalic acid, and Lithium bromide and Niobium (IV) oxide possible incompatible chemical reagents stored together without any mean of physical segregation nor hazardous waste determination. Picture 164- UPR PHYSICS DEPARTMENT-- At the Physics Lab F129, there was Hydrofluoric acid, broken, and leaking acid on cabinet shelf stored next to Sodium bromide, Sodium thiosulfate (violently reacts with strong oxidizers, and acids) and Silica gel incompatible with HF, stored together possible Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 165 - UPR PHYSICS DEPARTMENT- At the Physics Lab F123, chemical reagents were stored in a blue cabinet identified as "Corrosive," and included nitric acid, hydrochloric acid, phosphoric acid, Triton X-100 (octylphenol polyethoxyethanol), acetic acid anhydrous, hydrazine hydrate solution, among others. Picture 166 - UPR PHYSICS DEPARTMENT- At the Physics Lab F123, the bottles of acid, flammable and reactive solvents were stored together with an abandoned sodium metallic bar. All seemed very old, very dry, unstable; had leaking metal lids, moisture, labels vanished, and violent reaction, and explosion. Picture 167- UPR PHYSICS DEPARTMENT- At the Physics Lab F123, one (1) 1-L ambar bottle containing Triton X-100, which is a nonionic surfactant oxide, harmful if swallowed, should not be stored together where acids can be inadvertently mixed or spill or leak can cause danger and possibility of hazardous reactions. Picture 168 - UPR PHYSICS DEPARTMENT-- At the Physics Lab F123, there were three (3) 4-L ambar bottles containing Acetic Anhydride (Aceti Acid Glacial) in deteriorated conditions and labels being vanished, not in use and abandoned not compatible with Sulfuric Acid. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 169 - UPR PHYSICS DEPARTMENT- At the Physics Lab F123, there were two (2) 4-L ambar bottles containing Hydrochloric Acid in deteriorated conditions and labels being vanished not compatible with Acetic Anhydride they can be inadvertently mixed or where a spill or leak can cause danger. Picture 170 - UPR PHYSICS DEPARTMENT- At the Physics Lab F123, there was one (1) 4-L ambar bottle Ammonium Hydroxide stored in the cabinet may read violently with strong acids such as hydrochloric, sulfuric, and nitric, dimethyl sulfate, halogens and an abandoned sodium metallic bar since year 2004. Picture 171 - UPR PHYSICS DEPARTMENT - At the Physics Lab F458, there were numerous "Unwanted Materials," containing discarded or spent chemical reagents generated at the laboratories not properly labeled as "Unwanted Materials," nor dated with its accumulation start date. Picture 172 - UPR PHYSICS DEPARTMENT - At the Physics Lab F458, there was one (1) 4-liter container with a spent Orthophosphoric Acid, next to one (1) 4-liter container with a spent Chloroform, next to a HPLC bottle and stored next to one (1) 4-liter crystal container with a spent Hydrochloric Acid. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 173 - UPR PHYSICS DEPARTMENT- At the Physics Lab F458, there was one (1) -liter ambar container with a spent Hydrogen Peroxide stored, next to 0ne (1) 1-liter ambar container with a spent Octadecene, and next to one (1) 4-L Hexane which are incompatible chemical reagents stored together. Picture 174 - UPR PHYSICS DEPARTMENT- At the Physics Lab F458, there were potassium iodide, vinyl alcohol, malonic acid, lithium metallic bar (reactive), thiourea, oleylamine among many others stored together in an incompatible manner that can be inadvertently mixed or where a spill or leak can cause danger. Picture 175 - UPR PHYSICS DEPARTMENT - At the Physics Lab F458, there was one (1) 4-liter ambar container with a spent Ethanol mixed with water abandoned in a laboratory sink not labeled as "Unwanted Material" nor dated with its accumulation start date. Picture 176 - UPR PHYSICS DEPARTMENT - At the Physics Lab F458, there was oleylamine next to one (1) 4-L dimethylformamide next one (1) 4-L hexane, next to one (1) 4-L hydrobromic acid next to one (1) 4-L hydrofluoric acid among other reagents stored together in an incompatible manner. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 177 - UPR PHYSICS DEPARTMENT- At the Physics Lab F458, there was cadmium stearate (toxic) next to malonic acid (corrosive) among many other chemical reagents stored together in an incompatible manner where they can be inadvertently mixed or where a spill or leak can cause danger or explosion. Picture 178 - UPR PHYSICS DEPARTMENT- At the Physics Lab F458, there were sodium sulfite, activated carbon, flourene, yttrium nitrate stored next of potassium dichromate, and strontium hydroxide, strontium acetate, lanthanum chloride in an incompatible manner at risk of fire or explosion. Picture 179 - UPR PHYSICS DEPARTMENT - At the Physics Lab F458, there was mercuric choride (toxic and corrosive), zinc iodide (highly flammable on contact with air and cause fire or explosion), chromium potassium sulfate (highly toxic), cesium iodide stored in a incompatible manner, old and abandoned. Picture 180 - UPR PHYSICS DEPARTMENT - At the Physics Laboraty, Inspectors observed numerous expired chemical, discarded, contaminated, various unused chemical reagents, deteriorated and stored for a very long time (2004) in shelves without any protection, or incompatibility of waste characteristics Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 181 - UPR PHYSICS DEPARTMENT- At the Physics Labs, there were one (1) 1-L bottle phosphoric acid, and one (1) 1-L bottles hydrochloric acid, next to two (2) 1-L bottles of hydrogen peroxide and to one(1) 1-L bottle sodium dodecyl sulfate (explosive mixture in air) and not used since year 2004. Picture 182 - UPR PHYSICS DEPARTMENT- At the Physics Labs, there were two (1) 4-L bottle hydrochloric acid, next to bottles of ammonium hydroxide, and potassium hydroxide (corrosive) not stored in a compatible manner and not used since year 2004. Picture 183 - UPR PHYSICS DEPARTMENT - At the Physics Labs, there was one (1) 4-L bottle and various containers with phosphoric acid (corrosive), next to a bottle of nitric acid, and to chromium solution (toxic) and vanadium metal solution not stored in a compatible manner and not used since year 2004. Picture 184 - UPR PHYSICS DEPARTMENT - At the Physics Labs, there were two (2) 4-L bottle with hydrochloric acid, next to a one (1) 4-L with acetic acid , next of one (1) 4-L bottle of ammonium hydroxide, next to one (1) bottle of acetone not stored in a compatible manner and not used since year 2004. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 185 - UPR BIOLOGY DEPARTMENT - At the Lab B-020 Picture 186 - UPR BIOLOGY DEPARTMENT - At the Lab B-020 there were a refrigerator with chemical reagents such as phytag- there was on a testing table, EPA Inspector observed iodized el-plant cell culture (tested powder), albumin, saccharose, fruc- salt, NAOH liquid solution, and HCl stored next to each other. tose, hematoxylin, glucose, and kinetin solution. Picture 187 - UPR BIOLOGY DEPARTMENT - At the Lab b-020 there were expired chemicals (since < 2010 - 2018), discarded, unlabeled, contaminated, leaking, various unused chemical reagents, deteriorated and stored for a very long timein shelves without any physical means to protect compatibility. Picture 188 - UPR BIOLOGY DEPARTMENT - At the Lab B-026 there was a yellow cabinet identified as "Flammable" with methanol, butanol, ethanol, propanol, ethyl alcohol, sodium sulfite, paraffin oil, mercuric iodine red and buffer solution non compatible (i.e., Acetic Acid Glacial, Ethanol, Sodium Sulfite). Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 189 - UPR BIOLOGY DEPARTMENT At the Lab B-026 there was a second shelf containing a box of ethyl alcohol 190 proof containing four (4) 1-gallon bottles, and a smaller box containing a yellow buffer solution. Also, behind the boxes there were glass bottles of ethanol and acetic acids. Picture 190 - UPR BIOLOGY DEPARTMENT At the Lab CB-026, in an extractor hood there was one (1) 1-liter plastic bottle with "COTEX" labeled as "Hazardous Waste'" and dated with its accumulation start date of August 2019 (over 3--4 years old) Picture 191 - UPR BIOLOGY DEPARTMENT At the Lab B-026 , there were various expired chemicals (since < 1999 - 2001), discarded, unlabeled, various unused chemical reagents, deteriorated and stored for a very long time in shelves without any physical means to protect each other from incompatibility . Picture 192 - UPR BIOLOGY DEPARTMENT - At the Lab B-073, EPA Inspectors observed that some chemical reagents were deteriorated, leaking, corroded, and spilling its content. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 193 - UPR BIOLOGY DEPARTMENT At the Lab B-073, inside a cabinet there were numerous small cap bottles with algae destroyer, 1-Benzylaminopurine, boileezers (dated May 20, 2000), carbowax, and activated charcoal. Picture 194 - UPR BIOLOGY DEPARTMENT At the Lab B-073, there were chemical reagents were deteriorated with vanished labels, corroded, spilling its content, and stored for a very long time in shelves without any physical means to protect each other from incompatibility of waste characteristics. Picture 195 - UPR BIOLOGY DEPARTMENT At the Lab B-073, there were chemical reagents were deteriorated with vanished labels, corroded, and spilling its content and stored for a very long time (April 2015) without any physical means to protect each other from incompatibility of waste characteristics. Picture 196 - UPR BIOLOGY DEPARTMENT - At the Lab B-073, there were chemical reagents were deteriorated with vanished labels, corroded, spilling its content and stored for a very long time. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 197 - UPR BIOLOGY DEPARTMENT At the Lab B-086, there were some chemical reagents were stored for a very long time (i.e., over a year or more October 20, 2015) in shelves without any physical means to protect each other from incompatibility of waste characteristics. Picture 198 - UPR BIOLOGY DEPARTMENT At the Lab B-086, there were other chemical reagents stored in shelves without any physical means to protect each other from incompatibility of waste characteristics deteriorated, leaking, corroded, and spilling its content. Picture 199 - UPR BIOLOGY DEPARTMENT At the Lab B-086, there were some chemical reagents were stored for a very long time (i.e., over a year or more November 2006) in shelves without any physical means to protect each other from incompatibility of waste characteristics. Picture 200 - UPR BIOLOGY DEPARTMENT - At the Lab B-086, Inside the freezer compartment there was a box with testing tubes. Next to the freezer compartment there was one (1) five 5 -gallon container labeled as "Hazardous Waste," not dated with its accumulation start date or waste content information. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 201 - UPR BIOLOGY DEPARTMENT At the Lab B-086, it was observed a very rusty can labeled Melittin, from Bee Venon (approximately 70% for HPLC) with evident signs of leaks. The shelf was completely spilled with the leak solution. Picture 202 - UPR BIOLOGY DEPARTMENT At the Lab B-086, there were some chemical reagents were stored for a very long time (i.e., over a year or more January 14, 2009) in shelves without any physical means to protect each other from incompatibility of waste characteristics (Explosive vs. Corrosive). Picture 203 - UPR BIOLOGY DEPARTMENT- At the Lab B-086, EPA Inspectors observed that the cabinet was identified as "Flammable," instead of "Explosive," and some chemical reagents stored in the cabinets did not match with what it was inside the cabinet. Picture 204 - UPR BIOLOGY DEPARTMENT- At the Lab B-086, EPA Inspectors also observed that the cabinet stored some explosive chemical reagents such as ammonium hydroxide and nitric acids, and not "Flammable." Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 205 - UPR AGRICULTURAL DEPARTMENT - At the Plant Physiology Laboratory, there were a cabinet containing numerous of chemical reagents that were used for various plant and physiology testing. Picture 206 - UPR AGRICULTURAL DEPARTMENT - At the Plant Physiology Laboratory, inside a hood there was one (1) 1-gallon glass container labeled unwanted material with a contact telephone number and accumulation start date of September 2022, but it didn't provide the content information. Picture 207 - UPR AGRICULTURAL DEPARTMENT - At the Phytopathology Laboratory, inside one of the refrigerators there were sodium glass bottles, date February 2011, stored with sodium hydroxide and acid solutions, and solution B Griess glass bottles. Picture 208 - UPR AGRICULTURAL DEPARTMENT - At the Phytopathology Laboratory, inside a 5-shelve gray cabinet there were nutrient broth bottles, nutrient agar, maltose agar, BDTM BactoTM Tryptic Soy Broth agarose, benzoic acid, glucose anhydrous, calcium chloride, pectin, and glycerol among other reagents. Title: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Pictures taken by: Eduardo Gonzalez March 8 - 10, 2023 Picture 209 - UPR AGRICULTURAL DEPARTMENT - At the Phytopathology Laboratory, there were glass bottle containing Amina stored with glycerol in plastic bottles, permethrin in glass bottle, distilled water in glass bottle, glycerol diluted in glass water, and formaldehyde in glass bottles. Picture 210 - UPR AGRICULTURAL DEPARTMENT - At the Nematology Laboratory, inside the extractor fume hood there were two (2) 5-gallon white plastic containers one container was empty and the other did not identify its residual content nor labeled as "Hazardous Waste," or dated. Picture 211 - UPR AGRICULTURAL DEPARTMENT - At the Nematology Laboratory, inside the extractor fume hood there three (3) 200g bottles with discarded reagents without any hazardous determination or characterization as, "Hazardous Waste," or "Unwanted Wastes." Picture 212 - UPR AGRICULTURAL DEPARTMENT - At the Nematology Laboratory, there three (3) 1-gallon crystal containers with radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," stored for years without no hazardous waste determination nor managed as hazardous waste due to corrosivity. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 213 - UPR AGRICULTURAL DEPARTMENT - At the Nematology Laboratory, there three (3) 1-gallon crystal containers with radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," stored for years without no hazardous waste determination nor managed as hazardous waste due to corrosivity. Picture 214 - UPR AGRICULTURAL DEPARTMENT - At the Nematology Laboratory, inside a plastic tray there were three (3) 50ml (30-g) crystal containers containing radioactive waste of "Uranyl Nitrate" and/or "Uranyl Acetate," being stored for years without no hazardous waste determination. Picture 215 - UPR MECHANICAL ENGINEERING - At the Metallurgy Teaching Laboratory, there were small Erlenmeyer's beakers with metals (steel, aluminum, and brass) submerged in various solutions of ferric chloride, hydrochloride acid, and nitric acid/ methanol. Picture 216 - UPR MECHANICAL ENGINEERING - At the Metallurgy Teaching Laboratory, inside an extractor fume hood there was one (1) 2.5-gallong plastic container with spent etching solution from washing metal etching testing containing solution wastes of HCl, HF, FeCl3, and HNO3 Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 217 - UPR MECHANICAL ENGINEERING - At the Metallurgy Laboratory, there was one (1) 4-liter plastic bottle containing spent Nitric acid, Hydrochloric Acid, Ferric Chloride, Methanol, Ethanol from etching chemical analysis properly labeled as "Unwanted Materials," and dated May 6, 2022. Picture 218 - UPR MECHANICAL ENGINEERING - At the Biosensing and Microfluid Laboratory, inside a yellow cabinet there were one gallon bottle with Microposit Remover dated of January 2, 2011; two (2) 1-gallon bottle with Isopropyl Alcohol; and 1 -gallon glass bottle with ethanol and Acetone. Picture 219 - UPR MECHANICAL ENGINEERING - At the Biosensing and Microfluid Laboratory, inside a 2-shelve white cabinet, labeled as "Corrosive," there were one (1) 1-gallon bottle with Hydrochloride Acid 37% one (1) metal can with solid Hydrofluoric Acid and one beakers with pure Hydrofluoric Acid. Picture 220 - UPR GENERAL ENGINEERING - At the Synthesis Laboratory, there were numerous "Unwanted Material," including acetic, glacial, NaOH, FeCl3, cobalt with start accumulation date of August 31, 2018; and NaOH with start accumulation date of January 12, 2018. None dated, Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 221 - UPR GENERAL ENGINEERING -At the Synthesis Laboratory, there were numerous spent reagents without compatibility characteristics (Flammable, Corrosives and Toxics - Ethyl Acetate, Acetone next to Hydrochloric Acid, Sodium Hydroxide) failing to minimize the possibility of a fire, explosion. Picture 222 - UPR GENERAL ENGINEERING - At the Synthesis Laboratory, there were various container bottles were not identified with its content and stored for a very long time (i.e., over a year or more August 31, 2018) with expiration dates . Picture 223 - UPR GENERAL ENGINEERING - At the Material Engineering and Characterization Lab, EPA Inspectors explained that Acetic Anhydride was not compatible with Hydrochloric Acid and should not be stored together where they can be inadvertently mixed or where a spill or leak can cause danger. Picture 224 - UPR GENERAL ENGINEERING - At the Material Engineering and Characterization Lab, there were various container bottles deteriorated and not identified with its content and stored for a very long time such as 3-aminopropyltriethoxysilane which is extremely dangerous. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023 Picture 225 - UPR GENERAL ENGINEERING -At the Material Engineering and Characterization Lab, there were various chemical reagents including iron III chloride anhydrous, cooper II chloride anhydrous, acetone optima, ethyl acetate, methanol, calcium chloride dihydrate, and sodium hydroxide, incompatible. Picture 226 - UPR GENERAL ENGINEERING - At the Material Engineering and Characterization Lab, there was SAA with discarded hazardous wastes unlabeled, not dated, or managed under the LMP, which included three (3) 5-gallon white containers with corrosive wastes (pH>12.5) stored next organic wastes. Picture 227 - UPR GENERAL ENGINEERING - At the Material Engineering and Characterization Lab, there was a Satellite Accumulation Area with two trays containing numerous "Unwanted Materials," unlabeled, undated, nor identified with its hazardous waste content not in compliance with LMP. Picture 228 - UPR GENERAL ENGINEERING - At the Material Engineering and Characterization Lab, there were discarded, contaminated, unused chemical reagents, stored for a very long time (2008 in trays without any physical means to protect each other from incompatibility of waste characteristics. Title: Pictures taken by: UPR Mayagez Campus, Mayagez, Puerto Rico EPA ID: Project: PRD000691063 CEPD-RCRA-23-0440 Eduardo Gonzalez March 8 - 10, 2023