Document Znd5RojXR0Jw1Z102eG7BV1a0

RCRA Inspection Report 1) Inspector and Author of Report Raj Aiyar Environmental Engineer Phone: 404-562-8993 aiyar.raj@epa.gov 2) Facility Information Safety-Kleen Systems, Inc. 120 Richardson Drive Jackson, Mississippi 39209 3) Responsible Officials Michael Jansa Branch General Manager Jansa.michael@cleanharbors.com U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch RCRA Enforcement Section 61 Forsyth Street, S.W. Atlanta, Georgia 30303 EPA ID#: MSD000776765 NAICS #: 562112-Hazardous Waste Collection Keith Miller District Manager Keith.miller@safety-kleen.com Tom Cozzie Environmental Compliance Manager Cozzie.thomas@safety-kleen.com (561) 850-4357 4) Inspection Participants Keith Miller, Safety-Kleen Systems, Inc. Leigh Tanner, MDEQ Raj Aiyar, USEPA 5) Date of Inspection February 25, 2025, 9:15 a.m. 6) Applicable Regulations1 Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927), and 40 Code of Federal Regulation (C.F.R.) Parts 260 - 270, 273, 278, & 279; Mississippi Code of 1972, Miss. Code Ann. 17-17-1 et seq.; Mississippi Hazardous Waste 1 As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions will be to the authorized State program. However, for ease of reference, the federal citations will follow in brackets. Management Regulations, 11 Miss. Admin. Code Pt. 3, R. 1.1-1.24; and Hazardous Waste Permit MSD000776765 (RCRA Permit). Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.1 [40 C.F.R. 260.10], a large quantity generator of hazardous waste (LQG) is a generator who generates greater than or equal to 1,000 kilograms (2,200 pounds) of non-acute hazardous waste in a calendar month. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.21 [40 C.F.R. 273.9], a small quantity handler of universal waste (SQHUW) is a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or without having interim status, as required by Section 17-17-27(4) of the Mississippi Code of 1972, Miss. Code Ann. 17-17-27(4) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.17], an LQG may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 17-17-27(4) of the Mississippi Code of 1972, Miss. Code Ann. 17-1727(4) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to 11 Miss. Admin. Code Pt. 3, R1.3 [40 C.F.R. 279.40], 11 Miss. Admin. Code Pt. 3, R1.3 [40 C.F.R. Part 279, Subpart E] applies to all used oil transporters, including owners and operators of used oil transfer facilities. Pursuant to 11 Miss. Admin. Code Pt. 3, R1.3 [40 C.F.R. 279.1], a used oil transfer facility means any transportation related facility including loading docks, parking areas, storage areas and other areas where shipments of used oil are held for more than 24 hours but not longer than 35 days during the normal course of transportation or prior to an activity performed pursuant to 11 Miss. Admin. Code Pt. 3, R1.3 [40 C.F.R. 279.20(b)(2)]. 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine Safety-Kleen Systems, Inc. compliance with the conditions of its RCRA EPA-RCRA CEI Report February 25, 2025 Page 2 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Hazardous Waste Permit MSD000776765 (RCRA Permit), the applicable requirements of RCRA and the corresponding Mississippi regulations. This was an EPA lead inspection. 8) Facility Description Clean Harbors, Inc. acquired Safety-Kleen Systems, Inc. in 2008, and is primarily known for solvent recycling. The Safety-Kleen Systems, Inc. Jackson Facility, (Safety-Kleen, SK or the Facility) functions as a transfer facility and accumulation point for spent solvents, fluids, used oils, and other wastes generated by SK's customers. The Facility is approximately two acres, and operations commenced at this site in 1979. The Facility is comprised of an Office Building, Container Storage Warehouse, Return and Fill Station, Tank Farm, Container Storage Flammable Storage Shelter, and an above ground Used Oil Storage Tank area (Figure-1). SK currently has seven employees and operates one shift five days a week. The City of Jackson supplies the potable water and provides domestic waste service. The Facility is an LQG and a permitted hazardous waste Treatment, Storage, and Disposal Facility (TSDF) with their latest notification dated February 25, 2025. Hazardous wastes managed at the facility include but are not limited to hazardous wastes with one or more of the EPA waste codes D001, D004-D011, D018, D019, D021-D030, D032-D043, F002, F003, F004 and F005. SK's RCRA Permit was issued by the Mississippi Department of Environmental Quality (MDEQ) on August 31, 2012. The RCRA Permit was scheduled to expire on August 30, 2022, but RCRA Permit Condition I.E.3. allows for the RCRA Permit and all conditions to remain in effect beyond the RCRA Permit expiration date if the Permittee submits a timely, complete application and, through no fault of the Permittee, the Executive Director has not issued a new RCRA Permit. SK submitted a permit renewal application in February 2022, and the application is currently under review by MDEQ. Two container storage areas are used for the storage of hazardous waste. The Container Storage Warehouse (CSW) is permitted to store 4,464 gallons of hazardous waste with one or more of the EPA waste codes F002, F004, D001, D004 through D011, D018, D019, D021 through D030, and D032 through D043. The Container Storage Flammable Storage Shelter (CSFSS) is permitted to store 2,184 gallons of hazardous waste with one or more of the EPA waste codes F003, F005, D001, D004 through D011, D018, D019, D021 through D020, and D032 through D043. The Facility manages a Tank Farm with four horizontal above ground storage tanks within a secondary containment system. Two of these tanks are permitted to store spent parts washer wastes (Tank #1 and Tank #2), and two are designated to store clean solvent (Tank #3 and Tank #4). Tank #1 is an 8,000-gallon storage tank located on the west side of the Tank Farm; Tank #2 is a 4,000-gallon storage tank located on the north side of the Tank Farm; Tank #3 is an 8,000gallon storage tank located on the east side of the Tank Farm; and Tank #4 is a 4,000-gallon storage tank located on the south side of the Tank Farm. Tank #1 and Tank #2 store spent parts washer wastes, which are identified with the EPA waste codes D001, D002, D004 through D011, D018, D019, D021 through D030, D032 through D043, and F002 through F005. EPA-RCRA CEI Report February 25, 2025 Page 3 of 33 Safety-Kleen Systems EPA ID# MSD000776765 In addition, the Solvent Return and Fill Station, which is comprised of three Dumpster/Drum Washing Stations, is permitted as a miscellaneous Subpart X hazardous waste unit. The unit is permitted to manage up to 12,000 gallons per day of spent part washer wastes, which are identified with the EPA waste codes D001, D002, D004 through D011, D018, D019, D021 through D030, D032 through D043, and F002 through F005. Each Dumpster/Drum Washing Station is a square metal box that opens like clam shell and is about the same size as two 55gallon containers. Each station is equipped with a sump that is connected by piping to the adjacent permitted Hazardous Waste Storage Tanks. The unit is not designed to accumulate or store hazardous wastes. The maximum design capacity of each station is 25 gallons, and the maximum working capacity is 19 gallons. SK ships their hazardous waste corrosive liquids, hazardous waste combustible liquids and hazardous waste paint related material to another Safety-Kleen Systems facility (ILD980613913) in Illinois. SK ships their hazardous waste combustible liquids to Safety-Kleen Systems Denton Recycle Center (TXD077603371) in Texas and to SK's Lexington facility (SCD077995488) in South Carolina. 9) Previous Inspection History SK was last inspected by the MDEQ on October 19, 2023, and by the EPA on February 28, 2023. The EPA documented one violation for tank marking during the inspection, and the Facility returned to compliance on June 8, 2023. 10) Opening Conference On February 25, 2025, EPA inspector Raj Aiyar, accompanied by MDEQ inspector Leigh Tanner, arrived at SK at approximately 9:15 a.m. Keith Miller, District Manager New Orleans Branch, immediately received the inspectors. Keith Miller stated that Michael Jansa was the Branch Manager for the Jackson site; however, since he was unavailable, Keith Miller was acting as the Branch Manager until Michael Jansa's return. The inspectors were later joined by Tom Cozzie, Environmental Compliance Manager from SK's corporate office (via phone) for the opening conference. The inspectors introduced themselves, showed their credentials to Keith Miller, and explained the purpose of the visit. The inspectors described the anticipated use of a digital camera during the inspection and provided a request for records. The EPA inspector explained that the Small Business Regulatory Enforcement Fairness Act's classification of a "small business" is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. A copy of the EPA's information sheet for small businesses can be found at https://www.epa.gov/sites/production/files/2017-06/documents/smallbusinessinfo.pdf. The EPA inspector also discussed the facility's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. The facility did not assert a business confidentiality claim. Keith Miller provided an overview of the Facility's history and current operations during the opening conference. The inspection participants also discussed health and safety protocols and EPA-RCRA CEI Report February 25, 2025 Page 4 of 33 Safety-Kleen Systems EPA ID# MSD000776765 required personal protective equipment before the Facility representative led the inspectors on a tour of the Facility operations. 11) Inspection Observations Frac Tank The inspectors observed a 20,000-gallon double-walled Frac Tank (Photo-1) used to store petroleum based oily water mixture that is not regulated as a RCRA hazardous waste. The outer wall of the tank provides a secondary containment. The tank is enclosed with a modular polyethylene spill containment creating a tertiary containment as well as serving as a secondary containment. On March 27, 2025, EPA requested additional information via email regarding the Frac Tank which included the source of the petroleum based oily water mixture, waste profile of the oily water mixture and storage and disposal of the oily water mixture. SK responded via email on April 2, 2025, to the additional information request and stated that the source of the petroleum-based oily water mixture in the Frac Tank is primarily from oil/water separators from SK's automotive and fleet customer's sites. SK manages all the waste stored in the Frac Tank as nonhazardous based on the generator knowledge and the waste profile. Other non-hazardous waste may be accepted on a case-by-case basis. The waste profile, (Clean Harbors Profile No. MEM-OWW-002745), shows the petroleum base oily water's composition is fuel oil, motor oil and water. The used oil and water mixture from the Frac Tank is shipped approximately once every 1-2 weeks as used oil and water (per 40 CFR Part 279) to Valicor Environmental Services (TN000000) located in Memphis, Tennessee for reclamation. To minimize sludge accumulation in the Frac Tank, SK transports high solid streams directly from their generators/customers to the waste disposal sites (without offloading into the Frac Tank). According to the Facility personnel, the Frac Tank is cleaned as needed, which is approximately once per year, and the solids generated from the tank clean-out are sent to Waste Management Clearview Landfill as nonhazardous waste. The inspection team inspected the spill containment unit enclosing the Frac Tank to verify that it was continuous and impervious. The inspectors observed oily debris and oil-stained water puddles, which appeared to be from a recent rain event, inside the containment unit (Photo-2, Photo-3, Photo-4 and Photo-5). The inspectors also observed the spill containment unit to be in disrepair in several places, including two flattened corners that indicated visual signs of breaches in the containment system. The inspectors also observed absorbent socks placed in the outer perimeter of the spill containment system not completely enclosing the Frac Tank (Photo-6 and Photo-7). Downgradient from the Frac Tank, the inspectors observed a stormwater concrete channel (Photo-8) that drains into a drainage ditch (Photo-9, Photo-10, Photo-11 and Photo-12) which subsequently discharges to an unnamed tributary of a creek on the west side of the property. The inspectors observed oily water in the drainage ditch at several locations down gradient from the Frac Tank containment system. SK claimed in their response that the Frac Tank was a EPA-RCRA CEI Report February 25, 2025 Page 5 of 33 Safety-Kleen Systems EPA ID# MSD000776765 "Zero Discharge System" referring to a wastewater treatment approach designed to eliminate the discharge of liquid waste into the environment. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 279.45(h)], upon detection of a release of used oil to the environment that is not subject to the requirement of part 280, Subpart F of this Chapter and which has occurred after the effective date of the recycled used oil management program in effect in the State in which the release is located, the owner/operator of a transfer Facility must perform the following cleanup steps: (1) Stop the releases (2) Contain the released used oil; (3) Cleanup and manage properly the released used oil and other materials' and (4) If necessary, repair or replace any leaking used oil storage containers or tanks prior to returning them to services. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 279.45(e)(2)], existing aboveground tanks used to store used oil at transfer facilities must be equipped with a secondary containment system and the entire containment system, including walls and floors, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater or surface water. SK provided additional response via email on April 2, 2025, stating that the SK Branch will conduct employee training on housekeeping to ensure that the area around the Frac Tank is kept orderly and that all incidental drips during the loading/unloading process are fully captured and contained. In addition, the Frac Tank enclosure area will be cleaned, and all absorbent socks will be replaced on a regular basis. Facility staff will monitor this area as part of their daily inspection and will clean the area and replace the absorbent socks, as needed. These requirements will be reviewed on an annual basis to ensure ongoing compliance. A hazardous waste satellite accumulation area (SAA) (Photo-13) was located adjacent to the front of the Frac Tank. During the inspection, the inspectors asked if the waste accumulated in the satellite accumulation area (SAA) is nonhazardous then why is the content of the SAA drum managed as hazardous and this was further followed up via email to SK on March 27, 2025. Safety Kleen responded via email on April 2, 2025, that "Wastes accumulated in the satellite drum are not strictly limited to the oily water program. The satellite accumulation area drum located near the frac tank may also be used for facility-generated waste including debris, PPE, absorbent, and other materials, and is sent for disposal rather than oil recovery. Due to wide range of wastes managed at the site and to ensure any hazardous waste is properly managed and handled, the contents are conservatively managed as hazardous waste." On April 12, 2025, additional follow-up was conducted by EPA regarding the SAA stating that waste generated facility-wide being put in the satellite container may not be at point of generation or under the control of the operator. SK responded via an email on April 15, 2025, that "The Jackson facility maintains satellite accumulation areas in several different locations for collection of wastes, such as wipes, PPE and other debris, generated in proximity to the satellite accumulation container. Facility personnel will use the satellite container nearest the point of generation of the wastes as matter of convenience. Each satellite accumulation area is monitored during operating hours on closed-circuit television, so control of the area is maintained when an operator is not near or does not have eyes on the satellite container" wastes accumulated in EPA-RCRA CEI Report February 25, 2025 Page 6 of 33 Safety-Kleen Systems EPA ID# MSD000776765 the Frac Tank's satellite accumulation area (SAA) are not strictly limited to the Frac Tank area. It may also be used for Facility-generated waste, including debris, PPE, absorbent, and other materials, and is sent for disposal rather than for oil recovery. Facility personnel will use the satellite container nearest the point of generation of the waste as a matter of convenience. Due to the wide range of wastes managed at the site and to ensure any hazardous waste is properly managed and handled, the contents are conservatively managed as a hazardous waste. Each satellite accumulation area is monitored during operating hours on closed-circuit television, so control of the area is maintained when an operator is not near or does not have eyes on the satellite container". The inspectors observed one 55-gallon drum in this SAA. The drum was identified with a faded hazardous waste label, but it was not marked with an indication of the hazard(s) of the contents. The SAA was equipped with a spill kit, fire extinguisher and an eye wash station. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. On April 1, 2025, the Facility sent a photo of the container which showed that the hazardous waste label had been replaced and that the container was marked with indication that the contents are "Flammable" (Photo-14). Retain Storage Area The inspectors observed three yellow flammable cabinets in the Retain Storage Area. According to the Facility personnel, the cabinets hold retain samples from the Used Oil Tank, the Rail Cars and the Frac Tank (Photo-15). SK provided additional information via email on June 9, 2025, stating that SK does not collect or hold any retain samples from their hazardous waste tanks. The yellow cabinets hold retain samples from the current month, as well as previous three months. At the start of a new month, the samples from the oldest month are placed into the accumulation drum and at that point, they are considered waste. According to the Facility personnel, the customer retains samples from the Frac Tank, Rail Cars and the Used Oil Tank are managed as hazardous waste out of abundance of caution. The drum maintained at the retain sample cabinets SAA is filled approximately every three months. The drum changeover occurs whenever the drum is full or once per quarter. The inspectors observed one closed 55-gallon drum in this SAA. The drum was labeled with the words "Hazardous Waste" and with indication of the hazards of the contents as "toxic/ignitable". Container Storge Warehouse (CSW) The CSW is permitted to store up to maximum of 4,464 gallons of hazardous waste with the EPA waste codes F002, F004, D001, D004 through D011, D018, D019, D021 through D030, and D032 through D043. The waste may include Spent Immersion Cleaner (F002, F004), DryCleaning Wastes (D001, F002), Spent Antifreeze, Loading Unit Sediment, Parts Washer Wastes and Metal Halide Light Bulbs (Photo-16). EPA-RCRA CEI Report February 25, 2025 Page 7 of 33 Safety-Kleen Systems EPA ID# MSD000776765 The inspectors observed signs at the entrance indicating hazardous waste storage and "No Smoking." At the time of the inspection, the inspectors observed four 55-gallon containers of F003 waste; one 55-gallon container of D007 waste; seven fiberboard boxes containing chemical blend discard. The fiberboard boxes containing chemical blend discard were later determined to be nonhazardous. SK's Permit does not allow F003 waste to be stored in the Container Storage Warehouse. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition I.A. any storage of hazardous waste not authorized in this Permit is prohibited. Specifically, RCRA Permit Condition III.B.1, authorizes the Permittee to store the following wastes in containers at the Facility which includes Spent Immersion Cleaner, Dry Cleaning Wastes, Spent Antifreeze, Loading Unit Sediment, Metal Halide Light Bulbs and Parts Washer Wastes (F002, F004, D001, D004 through D011, D018, D019, D021 through D030, D032 through D043) in the CSW. RCRA Permit Condition III.B.1 does not authorize the Permittee to store wastes with the EPA Hazardous Waste Number F003 in the CSW. In addition, the inspectors observed approximately 19 empty containers. All the waste containers were observed to be stored on pallets and stacked no more than two high. All the hazardous waste containers were observed to be closed, labeled, dated with adequate aisle space between rows, unless noted otherwise. The inspectors observed three closed fiberboard boxes labeled "universal lamps containing mercury": one 8-foot box; and two 4-foot boxes. However, the same boxes had "Hazardous Waste" labels and accumulation start date(s) (Photo-17). The inspectors asked whether the contents of the boxes containing waste lamps were managed as universal waste and/or as RCRA hazardous waste. SK responded via email dated February 28, 2025, indicating that the broken waste lamps had been characterized by the generator as hazardous waste for the purpose of storage and disposal. SK provided a copy of a manifest (020399926) dated February 14, 2025, as an example demonstrating that broken waste lamps were typically managed as hazardous waste shipped to another Clean Harbors facility for disposal. Based on SK's email response on February 28,2025, it was confirmed that the contents in the three fiberboard boxes were managed as hazardous waste and not as universal waste. Although the fiberboard boxes appeared to be intact and nonleaking at the time of inspection, there were concerns regarding the integrity and compatibility of the container with the hazard waste stored in the container made of or lined with materials which will not react with, and compatible with the hazardous waste stored such that there is no release of the hazardous waste to the environment during storage and transportation. Pursuant to RCRA Permit MSD000776765 Module III.-Containers, RCRA Permit Condition III.D and 11 Miss. Admin. Code Pt. 3, R. 1.22 [40 C.F.R. 264.172], an owner or operator must use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired. EPA-RCRA CEI Report February 25, 2025 Page 8 of 33 Safety-Kleen Systems EPA ID# MSD000776765 The inspectors observed the insulation of the north wall in the CSW in disrepair (Photo-18). In addition, the inspectors observed insulation in other parts of the building also in disrepair (Photo-19 and Photo-20). The inspectors observed several large tears of insulation in the permitted storage area and near the eye wash station showing deterioration of the general facility conditions. Since ignitable wastes (D001) were being stored in the permitted storage area, the inspectors were concerned that the deteriorating Facility condition may lead to a potential environmental or human health hazard. Pursuant to RCRA Permit MSD000776765 Module II.-General Facility Conditions, RCRA Permit Condition II.E. General Inspection Requirements and 11 Miss. Admin. Code Pt. 3, R. 1.22 [40 C.F.R. 264.15(c)], an owner or operator must remedy any deterioration or malfunction of equipment or structures which the inspection reveals on a schedule which ensures that the problem does not lead to an environmental or human health hazard where a hazard is imminent or has already occurred, remedial action must be taken. On March 10, 2025, the Facility sent a picture of the repaired insulation in the CSW (Photo-21). However, based on the picture, a temporary repair appeared to have been made. The repair did not appear to be completed in its entirety. SK needs to evaluate the entire warehouse building for appropriate repair and scheduled maintenance as part of complying with the SK's Permit condition as per the attached plans and specifications. The CSW was equipped with spill kit, fire extinguisher and an eye wash station. Tank Farm The next site visited was the Tank Farm Area, where the inspectors observed four horizontal above ground storage tanks within a secondary containment system (Photo-22). Tank #1 (8,000-gallons) and Tank #2 (4,000-gallons) are each permitted to store spent parts washer wastes. Although the Permit identifies the permitted 8,000-gallon hazardous waste storage tank as Tank #1, the inspectors observed that the tank was physically marked with the number "2". To maintain consistency with the Permit, this report will refer to the permitted storage tanks by the identification references found in the Permit. Each of the hazardous waste storage tanks was labeled with the words "Hazardous Waste." Tank #3 (8,000-gallons) and Tank #4 (4,000-gallons) are used to store clean solvents. Tank #3 was physically marked with the number "1," and Tank #4 was labeled as "Out of Service." The inspectors observed a standalone metal containment system with a lid in place that housed the tanks' hose connection couplings. The inspectors observed the tanks ancillary equipment identified with color-coded tags and the piping associated with the tank's ancillary equipment were also color-coded to indicate the type of liquid flowing through them. Green represented the flow of clean solvent; Brown represented the flow of spent hazardous waste solvent; and Aqua represented out of service. The inspectors observed the brown painted ancillary equipment tags and the rust were not as clearly distinguishable as with other painted tags. Inspectors observed one instance where the tag was not clearly visible since it was partially covered with a paint (Photo-23). The SK personnel stated that the Facility maintained Piping and Instrumentation Diagram (P&ID) schematics for the tank systems. EPA-RCRA CEI Report February 25, 2025 Page 9 of 33 Safety-Kleen Systems EPA ID# MSD000776765 The inspector observed that the north end of Tank #1 (8000-gallon permitted hazardous waste tank) had paint peeling and paint blisters (Photo-24 and Photo-25). In addition, the inspectors observed paint peeling and signs of rust on the ancillary piping associated with Tank #4 (an out of service tank) (Photo-26), and signs of rust and corrosion on the valve of Tank #1 (Photo-27). These conditions were not noted on the Daily Tank Inspection Log and repairs were not made immediately. (See Daily and Weekly Tank Inspections under the Records Review section below.) Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the permittee shall inspect the tank systems, in accordance with the inspection schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3 as part of those in inspection. Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.3, the Permittee shall inspect the following components of the tanks system once each operating day: the aboveground portions of the tank system, if any, to detect corrosion or release of waste. Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the permittee shall inspect the tank systems, in accordance with the inspection schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3 as part of those in inspection. Pursuant to Permit Attachment II-3. 3.0 Preparedness and Prevention Plan, 3.2 Inspection Procedures, a. Tank Inspections, the piping and secondary containment for tanks will be checked for leaks, cracks, or other deterioration. Any damage to the tanks, piping (such as rust, seepage or loose fixtures) or secondary containment must be noted and repairs initiated immediately. On March 10, 2025, the Facility sent a photo of the hazardous waste storage Tank #1 repainted (Photo-28). On April 2, 2025, SK responded via email indicating that the only ancillary piping with surface rust was on an out of service tank and stated that necessary repair would be conducted prior to putting the tank back in service. SK further indicated that because the surface rust was not at a level causing concern over the integrity of the tank/equipment, the items were not "failed" on the inspection forms. SK also mentioned that when an item is failed, it is flagged and tracked electronically through completion and monitored regularly by the onsite personnel. The inspectors next observed the secondary containment system of the Tank Farm. The inspectors observed surface cracks along parts of the concrete containment (Photo-29 and Photo-30), there appeared to be damages to the sealants. The inspectors observed cracks, paint disrepair (e.g. chips, cracks etc.), rust, corrosion, damage to the sealant and weathering. These conditions were not noted on the Daily Tank Inspection Log and repairs were not made immediately. Both the tank system and the containment wall appear to need a fresh coat of paint and/or sealant. The inspectors recommended the cracks in the secondary containment should be cleaned, prepped and properly sealed. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition IV.C.2, the permittee shall design, construct and operate the secondary containment system, in accordance with the detailed design plans and descriptions contained in Permit Attachment III-1. Permit EPA-RCRA CEI Report February 25, 2025 Page 10 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Attachment III-1 states that the secondary containment for the tank farm consists of a concrete slab that has been sealed with a chemically resistant coating. Parts Washers Storage Parts washers from customers were located beside the solvent tank farm. They were waiting to be refurbished and returned to the customers (Photo -31). The Spill Prevention Control and Countermeasure Plan (SPCC Plan), dated October 13, 2021, provides details on the equipment, workforce, practices and steps taken to prevent, control and provide adequate countermeasures to a discharge. The SPCC Plan includes Site Layout and a Drainage Map. A copy of the Site Layout and Drainage Map, Figure 2 is included in this RCRA CEI report (Page-33) This designated storage area for the parts washers is not identified on the Site Layout and Drainage Map, Figure 2. The Site Layout and Drainage Map was not revised immediately. In accordance with 40 C.F.R. 264.52(b), If the owner or operator has already prepared a SPCC Plan in accordance with part 112 of this chapter, or some other emergency or contingency plan, he need only amend that plan to incorporate hazardous waste management provisions that are sufficient to comply with the requirements of this part. The owner or operator may develop one contingency plan which meets all regulatory requirements. EPA recommends that the plan be based on the National Response Teams' Integrated Contingency Plan Guidance ("One Plan"). When modifications are made to non-RCRA provisions in an integrated contingency plan, the changes do not trigger the need for a RCRA permit modification. 40 C.F.R. 264.54(c)- in its design, constructions, operation, maintenance, or hazardous waste constituents, or changes the response necessary in an emergency. As stated in Safety Kleen's Contingency Plan 4.2.5 Government Agencies and Local Authorities to be Notified, arrangements are to be made to familiarize the police department, fire department and local emergency response teams with the layout of the service center. By not amending the map immediately and providing the updated Contingency Plan to government agencies and local authorities the emergency response team were not made aware of the layout changes. The layout in The Spill Prevention Countermeasures Control Plan (SPCC Plan) was also not updated. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.J.3, the Permittee shall review and immediately amend, if necessary, the Contingency Plan, as required by MSHWM REG 264.54. Specifically, 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.54(c)] requires the contingency plan to be reviewed and immediately amended, if necessary, whenever the facility changes - in its design, construction, operation, maintenance, or other circumstances - in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency. Solvent Return and Fill Station The Return and Fill Station is identified as a miscellaneous hazardous waste management unit in the RCRA Permit and is comprised of a loading dock, one 374-gallon wet dumpster, two 164gallon drum washers/wet dumpsters, a drum spritzer and associated ancillary equipment. (Photo-32). The 374-gallon washer is no longer in use but still is located in this station. In this area, employee's empty drums of spent solvents into a vessel, rinse the empty drums via a EPA-RCRA CEI Report February 25, 2025 Page 11 of 33 Safety-Kleen Systems EPA ID# MSD000776765 spray system, and then refill the drums with a clean recycled or virgin solvent product (Photo33). Waste solvent from the Solvent Return and Fill Station is pumped into Tank #1, an 8,000gallon hazardous waste solvent storage tank located in the Tank Farm. There was no activity on going during the inspection at the Solvent Return and Fill Station. Inspectors observed a SAA containing one 55-gallon container of hazardous waste in this area (Photo-34). The container was observed to be closed, labeled as "Hazardous Waste," and marked with an indication of the hazards of the contents. The Solvent Return and Fill Station was equipped with a fire extinguisher. Container Storage Flammable Storage Shelter (CSFSS) The CSFSS is permitted to store up to maximum of 2,184 gallons of hazardous waste with the EPA waste codes F003, F005, D001, D004 through D011, D018, D019, D021 through D020, and D032 through D043. The waste may include various paint wastes (D001, F003, F005), solvents and other chemicals. Due to characteristic nature of the waste, the storage shelter is separated from the office/warehouse. The waste from the storage shelter is periodically transported to a Safety-Kleen recycle center or to a reclaimer. Regenerated solvent may be stored in this storage shelter and distributed to Safety-Kleen's customers to be used as a product. The storage shelter had a sign at the entrance "Flammable" and a fire extinguisher (Photo-35). The storage shelter is constructed of steel with a steel door and a steel grated floor over a twofoot-deep metal secondary containment system. The inspectors observed several containers of paint thinner products and waste flammable containers inside the storage shelter (Photo-36). Used lacquer thinner (waste) is typically stored in this shed in 5-, 16-, 30- and 55-gallon containers due to its flammable nature. SK also stores 5-gallon cans of paint thinner which are returned to the Facility due to damage. The paint thinners are considered to be a product because it is unused. All the containers were observed to properly closed, labeled and dated. No leaks or spills were observed in the storage shelter. 10-day Storage Shelter Although this is shown on the Site Layout and Drainage Map, Figure 2 (Page-33), this building was not observed on the day of inspection. Safety-Kleen explained that in 2017 the ceilings and walls were removed and disposed, but the containment base remained (Photo-37). The Site Layout and Drainage Map, Figure 2 had not been revised. As stated in Safety Kleen's Contingency Plan 4.2.5 Government Agencies and Local Authorities to be Notified, arrangements are to be made to familiarize the police department, fire department and local emergency response teams with the layout of the service center. By not amending the map immediately and providing the updated Contingency Plan to the government agencies and local authorities, the emergency response team were not made aware of the layout changes. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.J.3. Amendments to Plan, the Permittee shall review and immediately amend, if necessary, the Contingency Plan, as required by MSHWM REG 264.54. Specifically, 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.54(c)] requires the contingency plan to be reviewed and immediately amended, if necessary, whenever the facility changes - in its design, construction, operation, EPA-RCRA CEI Report February 25, 2025 Page 12 of 33 Safety-Kleen Systems EPA ID# MSD000776765 maintenance, or other circumstances - in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency. Used Oil Filter Roll Off Container Although the Used Oil Filter Roll Off Container is shown on the Site Layout and Drainage Map, Figure 2 (Page-33), adjacent to the 10-day Storage Shelter, this building was also not observed on the day of inspection. The Site Layout and Drainage Map was not revised immediately. As stated in Safety Kleen's Contingency Plan 4.2.5 Government Agencies and Local Authorities to be Notified, arrangements are to be made to familiarize the police department, fire department and local emergency response teams with the layout of the service center. By not amending the map immediately and providing the updated Contingency Plan to government agencies and local authorities the emergency response team were not made aware of the layout changes. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.J.3. Amendments to Plan, the Permittee shall review and immediately amend, if necessary, the Contingency Plan, as required by MSHWM REG 264.54. Specifically, 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.54(c)] requires the contingency plan to be reviewed and immediately amended, if necessary, whenever the facility changes - in its design, construction, operation, maintenance, or other circumstances - in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency. Used Oil Tank Used oil is accumulated in a 20,000-gallon aboveground storage tank (AST) (Photo-38). Inspectors observed the tank was closed and labeled as "Used Oil." This AST is also of doublewalled carbon steel construction. The inspectors observed a metal containment system with a lid is in place to contain the tank's hose connection couplings. The inspectors observed oily sheen on a stormwater puddle on the north and oily debris on the west side of the used oil tank (Photo-39, Photo-40 and Photo-41). The inspectors observed absorbent material spread across much of the area to capture the oil on the gravel-internal containment. Based on the site observation and discussion with Keith Miller, it appeared that source of the leaks and spills appeared to be primarily during the tanker loading/unloading operation. The inspectors discussed about better housekeeping using drip pans, spill trays and prompt cleanup upon detecting a spill. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 279.45(h)], upon detection of a release of used oil to the environment that is not subject to the requirement of part 280, Subpart F of this Chapter and which has occurred after the effective date of the recycled used oil management program in effect in the State in which the release is located, the owner/operator of a transfer Facility must perform the following cleanup steps: (1) Stop the releases (2) Contain the released used oil; (3) Cleanup and manage properly the released used EPA-RCRA CEI Report February 25, 2025 Page 13 of 33 Safety-Kleen Systems EPA ID# MSD000776765 oil and other materials' and (4) If necessary, repair or replace any leaking used oil storage containers or tanks prior to returning them to services. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 279.45(e)(2)], existing aboveground tanks used to store used oil at transfer facilities must be equipped with a secondary containment system and the entire containment system, including walls and floors, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater or surface water. Near the Used Oil Tank, the inspectors observed one 55-gallon container of oily rags and debris (Photo-42). The container was observed to be closed and labeled as "Hazardous Waste" and with indication of the hazards of the contents as a "DOT Class 9" miscellaneous label. The inspectors asked why the waste is managed as hazardous waste, when the tank contains used oil. SK personnel stated that they conservatively manage the waste as hazardous waste. The inspectors further stated that the DOT Class 9 label does not indicate any specific hazards associated with the waste. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)(ii)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. On February 28, 2025, the Facility sent a photo of the corrected label along with indication of the hazards of the contents as "Flammable" (Photo-43). 12) Records Review Some records were not available for review at the time of inspection; however, there were other records SK failed to provide during the inspection. The records that were not available during the inspection included May 5, 2023, Class 1 Permit Modification for changes to the Facility's Contingency Plan/Community Letter; 2023 and 2024 Jackson Emission Monitoring Record; Contingency Plan- Quick Reference Guide, Emergency Contact Information, Bulk Solvent Manifests ( 2022, 2023 and 2024); Spill Prevention, Control and Countermeasures Plan (SPCC Plan), Calibration Records for Leak Detection and Repair (LDAR) Monitoring, LDAR Monitoring for the Return and Fill Station, Subpart CC Annual Inspection Logs, LDAR Heavy Liquid P&IDs, Hazardous Waste Tank Integrity Testing Reports, and Personnel training . The SK's Branch Manager was unavailable during the inspection and others at the Facility could not locate the records. The records were later provided via emails. The description of the records and their date of submission from SK to EPA and MDEQ are included in Attachment 1- Email Log of this report (Page-32). Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition I.E.8.b., the Permittee shall allow the Executive Director, or an authorized representative, upon the presentation of credentials and other documents to have access to and copy, at reasonable times any records that must be kept under the conditions of this Permit. EPA-RCRA CEI Report February 25, 2025 Page 14 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition I.I., the Permittee shall maintain at the facility, until closure is completed and certified by an independent, registered professional engineer, the following documents and all amendments, revisions and modifications to these documents: I.I.1. Waste Analysis Plan, as required by MSHWM REG 264.13 and this Permit. I.I.2. Inspection schedules, as required by MSHWM REG 264.15(b)(2) and this Permit. I.I.3. Personnel training documents and records, as required by MSHWM REG264.16(d) and this Permit. I.I.4. Contingency Plan, as required by MSHWM REG 264.53(a) and this Permit. I.I.5. Operating record, as required by MSHWM REG 264.73 and this Permit. I.I.6. Closure Plan, as required by MSHWM REG 264.112(a) and this Permit. I.I.7. Annually adjusted cost estimate for facility closure, as required by MSHWM REG 264.142(d) and this Permit. I.I.8. All other documents required by Module I, Permit Condition I.E.9. RCRA Permit SK maintains the RCRA Permit and permit application onsite at the facility and was available for inspection. Manifests The bulk solvent manifests from 2022 through 2024 including signed copies from a designated facility were provided via email on February 25, 2025. Inspectors reviewed hazardous waste manifests from 2022 through 2024 and records for shipment of non-hazardous waste to a solid waste landfill and to the wastewater treatment plant were reviewed. The manifests included signed copies from the designated facility and land disposal notification. Contingency Plan & Spill Prevention Control and Countermeasures (SPCC) Plan The Contingency Plan (The Plan) and the SPCC Plan, dated October 2021, were available onsite for review. As noted earlier in the report, there are areas in the SPCC Plan that needed updating such as the Site Layout and Drainage Map. Specifically, the Site Layout and Drainage Map of the SPCC Plan did not include the SAAs observed near the Frac Tank and the Used Oil Tank. On May 5, 2023, Safety Kleen submitted a Modification Class One to MDEQ notifying the Contingency Plan was updated to reflect the name of the Emergency Coordinator. The Plan also included the emergency coordinator's contact information, emergency contact numbers, evacuation procedures, emergency arrangement descriptions, emergency equipment locations, and spill response. At the time of the EPA and MDEQ joint inspection, these plans were in the binder behind the cover and signature pages of the 2017 Plan. Quick Reference Guide (QRG) EPA-RCRA CEI Report February 25, 2025 Page 15 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Besides serving as a permitted TSD Facility, SK also serves as a large quantity generator of hazardous waste since they generate hazardous waste onsite in their SAAs and also store hazardous wastes in their central accumulation areas. In addition, SK also had amended their Contingency Plan on May 5, 2023. Hence SK is required to maintain as well as submit the QRG of the Contingency Plan to all the local emergency responders. As part of the requirement, SK provided record of Class 1 Permit Modification - Facility Contingency Plan dated May 5, 2023, and copy of the QRG and all revisions to all local emergency responders. Records showed a copy of the Class 1 Permit Modification- Facility Contingency Plan dated May 5, 2023, sent to the Police Department, University Medical Center, Hinds County Board of Supervisors and November 24, 2020 Class 1 Permit Modification letter to the Jackson Fire Department. The QRG did not include a map of the facility showing where hazardous wastes are generated, accumulated and treated and routes for accessing these wastes. The QRG included a MapQuest map showing names of the street. The street map of the Facility failed to show the surrounding businesses, schools and residential areas in relation to its location in order to understand how best to get to the Facility and also evacuate citizens and workers in event of an emergency. The QRG indicated that the water is provided by the local municipal water source, but it failed to indicate the locations of the water supply (e.g. fire hydrant and its flow rate). The QRG also failed to identify the on-site notification systems (e.g. a fire alarm that rings off site, smoke alarms). Pursuant to [40 C.F.R. 262.17(a)(6)], which incorporates [40 C.F.R. 262.262(b)] and is a condition of the LQG Permit Exemption, A large quantity generator that is amending its contingency plan must at that time submit a quick refence guide of the contingency plan to the local emergency responders. The quick reference guide must include the following elements: (1) A map of the facility showing where hazardous waste are generated, accumulated and treated and routes for accessing these wastes; (b) A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and also to evacuate citizens and workers; (c) The locations of water supply (e.g., fire hydrant and its flow rate); and (d) The identification of on-site notification systems (e.g. fire alarm that rings off-site, smoke alarms). Waste Analysis Reports and Profiles The Waste Profile Sheet (MEM-OWW-002745) was provided via email on April 2, 2025. It showed the composition for the petroleum based oily water mixture for the Frac Tank. The Waste Profile Sheet indicated chemical composition to be comprised of fuel oil, motor oil and water. Based on the waste profile, pH results at the time of pick-up, and results of the Halogen Leak Detector, the petroleum based oily water is categorized as nonhazardous. The Waste Material Profile Sheet Profile No. 150055 provided on June 10, 2025, via email described the waste as 150/PRF/PDF Solvent and the process generating the waste as change out solvent used for cleaning soiled parts. The waste profile sheet identified Tetrachloroethylene as a characteristic waste. In addition, SK provided a copy of analytical report by Waypoint Analytical dated March 25, 2025, for samples collected from a vacuum EPA-RCRA CEI Report February 25, 2025 Page 16 of 33 Safety-Kleen Systems EPA ID# MSD000776765 truck. The waste stream included waste codes identified in SK's Permit and were observed to be below the regulatory levels for Toxicity. Training Records The inspectors reviewed job descriptions and employee names that were provided for Branch Manager, Material Handler Lead, and Sales and Service Representatives. Each job description included the requisite skill, education, or other qualifications, and duties of facility personnel assigned to that position. SK provided a list of course names of the type of both introductory and continuing hazardous waste training completed by each person filling the positions listed above. The inspectors reviewed records of employee hazardous waste training completed from January 2022 through February 2025. Records were maintained that document the training, and the type of both introductory and continuing hazardous waste training completed by each person filling the positions listed above. However, the hazardous waste training program did not include job specific training for completing the RCRA permit-required inspection forms. This training would include using guidelines for rust, corrosion, and paint disrepairs, as well as procedures for when management is to be notified that a deficiency was noted and when management is to be alerted for repairs needed before a potential failure occurs. These instructions, guidelines, and procedures are to be applied the same facility wide and in alignment with RCRA regulations. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.F. Personnel Training 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.16], the Permittee shall conduct personnel training, as required by MSHWM REG 264.16. This training program shall follow the attached outline, Permit Attachment II-4. Section 5.2.1 Training Content, Frequency and Techniques which includes RCRA-permit inspection records training. Weekly Inspection Records: The inspectors reviewed the weekly inspection logs of the container storage areas since January 2024 which included the CSFSS and the CSW. The inspection log includes a checklist to record observations about leaking containers, aisle space, container labels, curbing, floor, sumps, loading and unloading areas and deterioration of containers caused by corrosion or other factors. Daily & Weekly Tank Inspection Records The inspectors reviewed available records of daily and weekly inspections of the RCRA Permitted Container Storage Area, Security, Tank System BB Equipment, Return and Fill Area, and Operation Changes, and Emissions Monitoring that is submitted annually. Based on records reviewed, the tank system's equipment (Subpart BB) is inspected daily. However, the electronic file containing the records shows that none of the leaks, cracks, and other deteriorations that were observed on the day of inspection were noted in the inspection records. As a result, SK's management was not notified of the existing rust, corrosion, and cracks; and therefore, necessary repairs and maintenance were not completed immediately. EPA-RCRA CEI Report February 25, 2025 Page 17 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the Permittee shall inspect the tank systems, in accordance with the Inspection Schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3. as part of those inspections. Specifically, Permit Attachment II-3. 3.0 Preparedness and Prevention Plan. 3.2 Inspection Procedures. a. Tank inspections, states that the piping and secondary containment for the tanks will be checked for leaks, cracks, or other deterioration. Any damage to the tanks, piping (such as rust, seepage or loose fixtures) or secondary containment must be noted and repairs initiated immediately. Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the Permittee shall inspect the tank systems, in accordance with the inspection schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3 as part of those inspections. Specifically, Section IV.F.3.a. and c., requires the Permittee to inspect aboveground portions of the tank system, if any, to detect corrosion or releases of waste; and construction materials and the area immediately surrounding the externally accessible portion of the tank system, including the secondary containment system, to detect erosion or signs of releases of hazardous waste (e.g., wet spots, dead vegetation). The Tank System BB Equipment inspection for all tagged and non-tagged points per area plan or system drawing specification are logged in the daily and weekly inspection forms. A sample form is enclosed in Section E Equipment Information, Subsection E.1 Example Facility Inspection Record and Procedure as part of the RCRA Part B Permit Renewal Application for Safety-Kleen The inspection form titled CO Tank Sys BB Equipment (Weekly) lists the inspection items as all tagged and non-tagged tank system identified BB equipment points per area plan, check for evidence of failure (e.g., all-inclusive review of all equipment pumps, valves, flanges, connections, unions, couplings, or caps for potential leaks, active leaks, sticking, wear, does not operate smoothly, other). When leaks are detected, a weatherproof identification tag is attached to the leaking equipment with ID # and the date leak was detected. The identification may be removed after repair. However, this inspection form does not appear to include the inspection of the secondary containment for cracks and gaps, rust, corrosion and paint disrepair. Pursuant to the RCRA Permit MSD000776765, Module IV. Tanks, Section IV.F.4, the Permittee shall document compliance with the Permit Conditions IV.F.3 and place this documentation in the operating record for the facility [MHWMR 264.195(d)]. Specifically, Section IV.F.3.a. and c., requires the Permittee to inspect aboveground portions of the tank system, if any, to detect corrosion or releases of waste; and construction materials and the area immediately surrounding the externally accessible portion of the tank system, including the secondary containment system, to detect erosion or signs of releases of hazardous waste (e.g., wet spots, dead vegetation). A copy of the electronic file containing the visual tank inspection records for 2022, 2023 and 2024 provided by Safety-Kleen included date, time of inspection, inspection status, inspection type, inspection frequency (5-days) and inspection area and the work ticket number. The EPA-RCRA CEI Report February 25, 2025 Page 18 of 33 Safety-Kleen Systems EPA ID# MSD000776765 inspection area in the electronic record file was identified as the outdoor tank farm, rather than tank specific. The records for 2022 and 2024 indicated that Tank System BB Equipment inspections were being conducted. However, there were over 50 instances for Subpart BB equipment failure in the 2023 report. Although work tickets were included in the report, a determination could not be made whether repairs were scheduled and completed. There were no records available on site or provided documenting that the repairs were initiated and completed based on the work tickets. Pursuant to RCRA Permit MSD000776765, Module VIII-RCRA Organic Air Emission Requirements, Section VIII. C.4. and Appendix H: Control of Organic Air Emissions of the Permit, when a leak is detected, the failed portion of the system will be immediately repaired, and the inspector will complete a "Leak Detection and Repair Record." Although visual tank inspections were conducted on a daily and weekly basis, the records did not include an annual visual inspection of the fixed roof and its closure devices for the tanks identified in Appendix K, Table A-2 of the approved permit application for defects that could result in air pollution emissions. Defects include, but are not limited to visible cracks, holes, or gaps in the roof sections or between the roof and the tank wall; broken, cracked or otherwise damaged seals or gaskets on closure devices and broken or missing hatches, access covers, caps or other closure devices. Pursuant to RCRA Permit MSD000776765, Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the Permittee shall inspect the tank systems, in accordance with the Inspection Schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3 as part of those inspections. Specifically, Permit Attachment II-3 Inspection Schedule, 3.0 Preparedness and Prevention Plan, Section 3.2 Inspection Procedures g. Air Emission Standards, states that tanks and containers are subject to Level 1 control equipment under Subpart CC. Visual Inspection of containers and hazardous waste tanks will be completed and documented as required by 40 CFR 264.1084. The Safety-Kleen Permit requires that the initial inspection of the tank shall be conducted when the tanks first became subject to Subpart CC rule and annually thereafter. Pursuant to RCRA Permit MSD000776765, Section VIII.A.1., Subpart CC applies to all tanks, containers and miscellaneous units identified in Appendix K, Table A-2 of the approved permit application, and in the State RCRA Permit, except as provided for in MHWMR 264.1 and 264.1080(b). Specifically, 11 Miss. Admin. Code Pt. 3, R. 1.22 [40 C.F.R. 264.1084(c)(4)] requires the owner or operator to inspect the air emission control equipment in accordance with the following requirements: (i) The fixed roof and its closure devices shall be visually inspected by the owner or operator to check for defects that could result in air pollutant emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in the roof sections or between the roof and the tank wall; broken, cracked, or otherwise damaged seals or gaskets on closure devices; and broken or missing hatches, access covers, caps, or other closure devices. EPA-RCRA CEI Report February 25, 2025 Page 19 of 33 Safety-Kleen Systems EPA ID# MSD000776765 (ii) The owner or operator shall perform an initial inspection of the fixed roof and its closure devices on or before the date that the tank becomes subject to this section. Thereafter, the owner or operator shall perform the inspections at least once every year except under the special conditions provided for in paragraph (l) of this section. (iii) In the event that a defect is detected, the owner or operator shall repair the defect in accordance with the requirements of paragraph (k) of this section. (iv) The owner or operator shall maintain a record of the inspection in accordance with the requirements specified in 264.1089(b) of this subpart. RCRA Organic Air Emission Records The inspectors requested three years (2022, 2023, 2024) of the emission monitoring records for the Return and Fill Unit, calibration records, and the most recent Tank integrity test report for the hazardous waste tanks. None of these records were available for review at the time of inspection. The Facility later provided records via email on April 15, 2025. Pursuant to RCRA Permit MSD000776765, Section VIII.C.5., records of the design, monitoring and repair of the Return/Fill Dumpster/Washing Unit shall be maintained in the on-site facility operating records for three (3) years. The emission monitoring records for 2022, 2023 and 2024 included readings for all three dumpster units, all valves, solvent pump and other ancillary equipment. Besides the Return and Fill Unit, the Leak Detection and Repair (LDAR) monitoring records included ancillary equipment associated with the tanks. The ancillary equipment associated with the spent parts washer waste storage tanks (Tank #1 and Tank #2), included flanged coupling, various types of valves and camlock coupling. The records did not indicate any instrument readings of 10,000 ppm or greater constituting a leak. The LDAR records for 2023 indicated that monitoring equipment (Mini Rae 2000) was not calibrated on the day of LDAR monitoring for the Return and Fill Station and the Tanks. Records indicated that the equipment was calibrated on November 28, 2023, approximately six days prior to actual date of monitoring on December 5, 2023. Pursuant to RCRA Permit MSD000776765, Section VIII.C.3., the Facility shall monitor for leaks in accordance with the procedures of Reference Method 21 in MHWMR Part 60 each year, about all joints, seals, seams, connectors, pumps, valves or other equipment ancillary to this unit. An instrument reading of 10,000 ppm or greater shall constitute detection of a leak. Specifically, Method 21 in MHWMR-Part 60 requires that the instrument shall be calibrated before use on each day of its use by the procedures specified in Reference Method 21. Safety Kleen, in an email dated April 15, 2025, provided the following information for Subpart BB equipment in heavy liquid service: "According to 40 CFR 264 Subpart BB, as referenced in the facility's permit conditions, visual monitoring is prescribed for equipment in "heavy liquid" service. The rule specifies the use of a monitoring device such as a PID in accordance with Reference Method 21 to confirm a suspected leak (based upon the visual inspection); however, EPA-RCRA CEI Report February 25, 2025 Page 20 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Safety-Kleen determined that the PID would not detect a leak due to the maximum volatile organic concentration, in vapor phase, of the waste material in the equipment at the Jackson facility and therefore will initiate repairs upon the visual observation of a leak. We are still attempting to determine why the leak detection monitoring by Method 21 was requested for the equipment (as referenced in the transmittal letter with the annual monitoring report). As noted above, the leak detection monitoring is conducted on equipment at the waste storage tanks as well as ancillary to the return and fill station." Daily Tank Inspection Records The inspectors reviewed daily digital inspection logs for the storage tank system of the Tank Farm and all ancillary equipment beginning from the Return and Fill Unit since January 2024 until present. According to the Facility personnel, the daily storage tank system inspection covers overall Tanks and the Return and Fill Unit. The daily tank inspection log included a checklist to record observations about the high-level alarm, rigid piping and supports/ground, transfer pumps and hoses and associated equipment including spill kits and emergency alarm. The daily tank inspection log did not include reading from temperature and pressure gauges for ensuring that the tanks operated in accordance with its design. Although the daily inspection checklist referenced secondary containment, it was not clear whether it included secondary containment for the Tank Farm and/or the Return and Fill Unit. Pursuant to RCRA Permit MSD000776765, Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1, the Permittee shall inspect the tank systems, in accordance with the Inspection Schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions and IV.F.3 as part of those inspections. Specifically, Section IV.F.3.b. requires the Permittee to gather data from monitoring and leak detection equipment (e.g., pressure or temperature gauges) to ensure that the tank system is being operated according to its design; Permit Attachment II-3 required any damage to the tanks, piping(such as rust, seepage or loose fixtures) or secondary containment must be noted and repaired immediately. Once each operating day, inspect data gathered from monitoring and leak detection equipment (e.g. pressure or temperature gauges, monitoring wells) to ensure that the tank system is being operated according to its design. Tank Integrity Inspections The inspectors requested records of the last tank integrity inspections. Safety-Kleen provided two hazardous waste Tank Internal Inspection Reports via email on April 15, 2025, for hazardous waste tanks integrity inspection conducted in June 2024. The tank integrity testing was conducted by Clean Harbors Inspection Services. The tank inspections were conducted by Steel Tank Inspector (STI) Michael J. Bradshaw, (STI # AST-7308; Certification Expiration date # 05/10/2029). Both tanks are permitted to store parts washer waste consisting of D001, D002, D004 through D011, D018, D019, D021 through D030, D032 through D043, F002 through F005 waste. EPA-RCRA CEI Report February 25, 2025 Page 21 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Records indicated that Tank #1 had horizontal orientation, built in 1993 with a storage capacity of 8000-gallons. The tank was made of steel and concrete with secondary containment. Upon review of the two reports, it was noted that the comment, "Coating Failure", on the integrity tests appears to be used whenever any findings for coating conditions on the concrete foundation are observed. This finding was observed during inspection of both tanks. Based upon Tank #1's findings: 1) the foundation's coating condition failure, 2) the Outer Shell findings of a.) corrosion on the west side on the floor of the tank to the head, b.) atmospheric venting's finding vent screen is damaged and needs repair/replaced; 3) Head/End finding: corrosion on west head to floor causing leak, the inspectors concluded the tank appeared to be in poor condition. Recommendations included that the tank be removed from service and repaired prior to returning to service; coating on the concrete should be cleaned, properly prepped and re-coated at the earliest convenience. MDEQ requested electronically on April 30, 2025, for Safety Kleen to provide the "lockout tagout" records that demonstrate the tank was removed from service, when, what repairs were made, when the tank was returned to service, and the P.E. certification prior to returning the tank to service pursuant to 40 CFR 264.196(f). This request is still pending. The second tank integrity report was for the Used Solvent West (Tank #2). Records indicated that this tank also had horizontal orientation, built in 1993 with a storage capacity of 4000gallons. It was made of steel and concrete with secondary containment. During the tank inspection, the tank was found to be in fair overall condition. However, the inspector identified coating failure on the foundation. Recommended actions include cleaning the foundation surface thoroughly, properly preparing the concrete substrate, and applying new protective coating to the foundation. There were no records of repair provided for either tank, and the tank operating record did not include a certification from a qualified Professional Engineer in accordance with 40 C.F.R. 270.11(d) indicating that the repaired system is capable of handling hazardous waste without release for intended life of the system. Based on the site inspection and review of the tank integrity inspection report, it appears that storing hazardous waste in the tank system could cause Tank #1, Tank #2, or the containment system to rupture, leak, corrode or fail. Pursuant to the RCRA Permit MSD000776765, Section IV.C.2., the Permittee shall design, construct, and operate the secondary containment system, in accordance with the detailed design plans and descriptions contained in Permit Attachment III-1 [MHWMR 264.193(b)-(f)]. Specifically, Permit Attachment III-1 requires the Permittee to operate secondary containment free of cracks, debris in dike, deterioration, leaks, corrosion and paint failure. Pursuant to the RCRA Permit MSD000776765, Subpart IV.D.1, the Permittee shall not place hazardous wastes or treatment reagents in the tank system if they could cause the tank, its ancillary equipment, or a containment system to rupture, leak, corrode, or otherwise fail [MHWMR 264.194(a)]. EPA-RCRA CEI Report February 25, 2025 Page 22 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Pursuant to the RCRA Permit MSD000776765, Section IV.E.5, in the event of a leak or a spill from the tank system, from a secondary containment system, or if a system becomes unfit for continued use, the Permittee shall remove the system from service immediately and, for all major repairs to eliminate leaks or restore the integrity of the tank system, the Permittee must obtain a certification by an independent, qualified, registered professional engineer that the repaired system is capable of handling hazardous waste without release for the intended life of the system before returning the system to service. MDEQ Annual Report The Annual Reports show that Safety-Kleen ships their waste corrosive liquids, waste combustible liquids and waste paint related material to Safety-Kleen (ILD980613913) and waste combustible liquids to Safety-Kleen Systems Denton Recycle Center (TXD077603371) and to Safety-Kleen Systems Inc. (SCD077995488). Annual reports for 2021, 2022, 2023, and 2024 were reviewed. No issues with reported information were found. 13) Closing Conference An exit briefing was conducted at the conclusion of the inspection. Keith Miller, SK, Tom Cozzie, SK, Leigh Tanner, MDEQ, and Raj Aiyar, EPA, participated in the exit briefing. The observations made during the inspection were discussed and the inspection was concluded. Tom Cozzie committed to providing the missing records via email before the end of the week. (See Attachment 1: Email Log - Summary of email correspondence and records submission.) 14) Summary of Observations Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 279.45(h)], upon detection of a release of used oil to the environment that is not subject to the requirement of part 280, Subpart F of this Chapter and which has occurred after the effective date of the recycled used oil management program in effect in the State in which the release is located, the owner/operator of a transfer Facility must perform the following cleanup steps: (1) Stop the releases (2) Contain the released used oil; (3) Cleanup and manage properly the released used oil and other materials' and (4) If necessary, repair or replace any leaking used oil storage containers or tanks prior to returning them to services. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 279.45(e)(2)], existing aboveground tanks used to store used oil at transfer facilities must be equipped with a secondary containment system and the entire containment system, including walls and floors, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater or surface water. The inspectors observed oily water in a drainage ditch at several location down gradient from the Frac Tank containment system. The inspectors observed oily debris and oil-stained water puddles inside the containment unit. The inspectors observed the spill containment unit to be in disrepair at several places including two flattened corners that indicated visual signs of EPA-RCRA CEI Report February 25, 2025 Page 23 of 33 Safety-Kleen Systems EPA ID# MSD000776765 breaches in the containment system. The inspectors observed absorbent socks placed in the outer perimeter of the spill containment system not completely enclosing the Frac Tank. The inspectors observed oily sheen on a stormwater puddle on the north and oily debris on the west side of the used oil tank. The inspectors observed absorbent material spread across much of the area to capture the oil on the gravel-internal containment. Pursuant to 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 262.15(a)(5)], which is a condition of the SAA Permit Exemption, a generator is required to mark or label its containers with an indication of the hazards of the contents. The inspectors observed one 55-gallon drum in an SAA near the Frac Tank. The drum was identified with a faded hazardous waste label, but it was not marked with an indication of the hazard(s) of the contents. One 55-gallon container in a SAA near the Used Oil Tank labeled as "Hazardous Waste" and with indication of hazards of the contents as a "DOT Class 9" miscellaneous label. DOT Class 9 label does not indicate any specific hazards associated with the waste. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition I.A. any storage of hazardous waste not authorized in this Permit is prohibited. Specifically, RCRA Permit Condition III.B.1, authorizes the Permittee to store the following wastes in containers at the Facility which includes Spent Immersion Cleaner, Dry Cleaning Wastes, Spent Antifreeze, Loading Unit Sediment, Metal Halide Light Bulbs and Parts Washer Wastes (F002, F004, D001, D004 through D011, D018, D019, D021 through D030, D032 through D043) in the CSW. RCRA Permit Condition III.B.1 does not authorize the Permittee to store wastes with the EPA Hazardous Waste Number F003 in the CSW. The inspectors observed four 55-gallon containers of F003 waste stored in the Container Storage Warehouse. SK's Permit does not allow F003 waste to be stored in the Container Storage Warehouse. Pursuant to RCRA Permit MSD000776765 Module III.-Containers, RCRA Permit Condition III.D and 11 Miss. Admin. Code Pt. 3, R. 1.22 [40 C.F.R. 264.172], an owner or operator must use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired. The inspectors observed hazardous waste (D009) to be stored in the fiberboard boxes. The inspectors had concerns regarding integrity and compatibility of the fiberboard containers storing hazardous waste. Pursuant to RCRA Permit MSD000776765 Module II.-General Facility Conditions, RCRA Permit Condition II.E. General Inspection Requirements and 11 Miss. Admin. Code Pt. 3, R. 1.22 [40 C.F.R. 264.15(c)], an owner or operator must remedy any deterioration or malfunction of equipment or structures which the inspection reveals on a schedule which ensures that the EPA-RCRA CEI Report February 25, 2025 Page 24 of 33 Safety-Kleen Systems EPA ID# MSD000776765 problem does not lead to an environmental or human health hazard. Where a hazard is imminent or has already occurred, remedial action must be taken. The inspectors observed the insulation of the north wall in the CSW in disrepair. In addition, the inspectors observed insulation in other parts of the building also in disrepair. The inspectors observed several large tears of insulation in the permitted storage area and near the eye wash station showing deterioration of the general facility conditions. Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the permittee shall inspect the tank systems, in accordance with the inspection schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3 as part of those in inspection. Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.3, the Permittee shall inspect the following components of the tanks system once each operating day: the aboveground portions of the tank system, if any, to detect corrosion or release of waste. Pursuant to RCRA Permit MSD000776765 Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1., the permittee shall inspect the tank systems, in accordance with the inspection schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions IV.F.3 as part of those in inspection. Pursuant to Permit Attachment II-3. 3.0 Preparedness and Prevention Plan, 3.2 Inspection Procedures, a. Tank Inspections, the piping and secondary containment for tanks will be checked for leaks, cracks, or other deterioration. Any damage to the tanks, piping (such as rust, seepage or loose fixtures) or secondary containment must be noted and repairs initiated immediately. The inspectors observed that the north end of Tank #1 (8000-gallon permitted hazardous waste tank) had paint peeling and paint blisters. In addition, the inspectors observed paint peeling and signs of rust on the ancillary piping associated with Tank #4 (an out of service tank)), and signs of rust and corrosion on the valve of Tank #1). These conditions were not noted on the Daily Tank Inspection Log and repairs were not made immediately. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition IV.C.2, the permittee shall design, construct and operate the secondary containment system, in accordance with the detailed design plans and descriptions contained in Permit Attachment III-1. Permit Attachment III-1 states that the secondary containment for the tank farm consists of a concrete slab that has been sealed with a chemically resistant coating. The inspectors observed surface cracks along parts of the concrete containment. There also appeared to be damages to the sealants. The inspectors observed cracks, paint disrepair (e.g. chips, cracks etc.), rust, corrosion, damage to the sealant and weathering. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.J.3, the Permittee shall review and immediately amend, if necessary, the Contingency Plan, as required by MSHWM REG 264.54. Specifically, 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.54(c)] requires the contingency plan to be reviewed and immediately amended, if necessary, whenever the facility changes - in its design, construction, operation, maintenance, or other circumstances - in a way that materially increases the potential for fires, explosions, or releases of EPA-RCRA CEI Report February 25, 2025 Page 25 of 33 Safety-Kleen Systems EPA ID# MSD000776765 hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency. The designated storage area for the parts washers is not identified on the Site Layout and Drainage Map, Figure 2. The Site Layout and Drainage Map has not been revised. By not amending the map immediately and providing the updated Contingency Plan to government agencies, and local authority, the emergency response team were not made aware of the layout changes. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.J.3. Amendments to Plan, the Permittee shall review and immediately amend, if necessary, the Contingency Plan, as required by MSHWM REG 264.54. Specifically, 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.54(c)] requires the contingency plan to be reviewed and immediately amended, if necessary, whenever the facility changes - in its design, construction, operation, maintenance, or other circumstances - in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency. Although the 10-day Storage Shelter is shown on the Site Layout and Drainage Map, Figure 2, this building was not observed on the day of inspection. The Site Layout and Drainage Map had not been revised. By not amending the map immediately and providing the updated Contingency Plan to government agencies, and local authority, the emergency response team were not made aware of the layout changes. Although the Used Oil Filter Roll Off Container is shown on the Site Layout and Drainage Map, Figure 2 adjacent to the 10-day Storage Shelter, this building was not observed on the day of inspection. The Site Layout and Drainage Map had not been revised. By not amending the map immediately and providing the updated Contingency Plan to government agencies, and local authority, the emergency response team were not made aware of the layout changes. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition I.E.8.b., the Permittee shall allow the Executive Director, or an authorized representative, upon the presentation of credentials and other documents to have access to and copy, at reasonable times any records that must be kept under the conditions of this Permit. Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition I.I., the Permittee shall maintain at the facility, until closure is completed and certified by an independent, registered professional engineer, the following documents and all amendments, revisions and modifications to these documents: I.I.1. Waste Analysis Plan, as required by MSHWM REG 264.13 and this Permit. I.I.2. Inspection schedules, as required by MSHWM REG 264.15(b)(2) and this Permit. I.I.3. Personnel training documents and records, as required by MSHWM REG264.16(d) and this Permit. EPA-RCRA CEI Report February 25, 2025 Page 26 of 33 Safety-Kleen Systems EPA ID# MSD000776765 I.I.4. Contingency Plan, as required by MSHWM REG 264.53(a) and this Permit. I.I.5. Operating record, as required by MSHWM REG 264.73 and this Permit. I.I.6. Closure Plan, as required by MSHWM REG 264.112(a) and this Permit. I.I.7. Annually adjusted cost estimate for facility closure, as required by MSHWM REG 264.142(d) and this Permit. I.I.8. All other documents required by Module I, Permit Condition I.E.9. The SK's Branch Manager was unavailable during the inspection and others at the Facility could not locate the records. The record that were not available during the inspection included May 5, 2023, Class 1 Permit Modification for changes to the Facility's Contingency Plan/Community Letter; 2023 and 2024 Jackson Emission Monitoring Record; Contingency Plan- Quick Reference Guide, Emergency Contact Information, Bulk Solvent Manifests ( 2022, 2023 and 2024); Spill Prevention, Control and Countermeasures Plan (SPCC Plan), Calibration Records for Leak Detection and Repair (LDAR) Monitoring, LDAR Monitoring for the Return and Fill Station, Subpart CC Annual Inspection Logs, LDAR Heavy Liquid P&IDs, Hazardous Waste Tank Integrity Testing Reports, and Personnel training. Pursuant to [40 C.F.R. 262.17(a)(6)], which incorporates [40 C.F.R. 262.262(b)] and is a condition of the LQG Permit Exemption, A large quantity generator that is amending its contingency plan must at that time submit a quick refence guide of the contingency plan to the local emergency responders. The quick reference guide must include the following elements: (1) A map of the facility showing where hazardous waste are generated, accumulated and treated and routes for accessing these wastes; (b) A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and also to evacuate citizens and workers; (c) The locations of water supply (e.g., fire hydrant and its flow rate); and (d) The identification of on-site notification systems (e.g. fire alarm that rings off-site, smoke alarms). The QRG did not include a map of the facility showing where hazardous wastes are generated, accumulated and treated and routes for accessing these wastes. The QRG included a MapQuest map showing names of the street. The street map of the Facility failed to show the surrounding businesses, schools and residential areas in relation to its location in order to understand how best to get to the Facility and also evacuate citizens and workers in event of an emergency. The QRG indicated that the water is provided by the local municipal water source, but it failed to indicate the locations of the water supply (e.g. fire hydrant and its flow rate). The QRG failed to identify the on-site notification systems (e.g. a fire alarm that rings off site, smoke alarms). Pursuant to RCRA Permit MSD000776765, RCRA Permit Condition II.F. Personnel Training 11 Miss. Admin. Code Pt. 3, R. 1.3 [40 C.F.R. 264.16], the Permittee shall conduct personnel training, as required by MSHWM REG 264.16. This training program shall follow the attached outline, Permit Attachment II-4. Section 5.2.1 Training Content, Frequency and Techniques which includes RCRA-permit inspection records training. EPA-RCRA CEI Report February 25, 2025 Page 27 of 33 Safety-Kleen Systems EPA ID# MSD000776765 The hazardous waste training program did not include job specific training for completing the RCRA permit-required inspection forms. The Permittee failed to comply with Section 5.2.1 Training Content, Frequency and Techniques which included inspection records training. Pursuant to RCRA Permit MSD000776765, Section VIII.C.5., records of the design, monitoring and repair of the Return/Fill Dumpster/Washing Unit shall be maintained in the on-site facility operating records for three (3) years. The inspectors requested three years (2022, 2023, 2024) of the emission monitoring records for the return and fill unit, calibration records, and the most recent Tank integrity test report for the hazardous waste tanks. None of these records were available for review at the time of inspection. Pursuant to RCRA Permit MSD000776765, Section VIII.C.3., the Facility shall monitor for leaks in accordance with the procedures of Reference Method 21 in MHWMR Part 60 each year, about all joints, seals, seams, connectors, pumps, valves or other equipment ancillary to this unit. An instrument reading of 10,000 ppm or greater shall constitute detection of a leak. Specifically, Method 21 in MHWMR-Part 60 requires that the instrument shall be calibrated before use on each day of its use by the procedures specified in Reference Method 21. The LDAR records for 2023 indicated that monitoring equipment (Mini Rae 2000) was not calibrated on the day of LDAR monitoring for the Return and Fill Station and the Tanks. Records indicated that the equipment was calibrated on November 28, 2023, approximately six days prior to actual date of monitoring on December 5, 2023. Pursuant to RCRA Permit MSD000776765, Module IV.F. - Inspection Schedule and Procedures, Section IV.F.1, the Permittee shall inspect the tank systems, in accordance with the Inspection Schedule, Permit Attachment II-3, and shall complete the items in Permit Conditions and IV.F.3 as part of those inspections. Specifically, Section IV.F.3.b. requires the Permittee to gather data from monitoring and leak detection equipment (e.g., pressure or temperature gauges) to ensure that the tank system is being operated according to its design; Permit Attachment II-3 required any damage to the tanks, piping(such as rust, seepage or loose fixtures) or secondary containment must be noted and repaired immediately.., once each operating day, inspect data gathered from monitoring and leak detection equipment (e.g. pressure or temperature gauges, monitoring wells) to ensure that the tank system is being operated according to its design. The daily tank inspection log since January 2024 until present did not include reading from temperature and pressure gauges for ensuring that the tanks operated in accordance with its design. Although the daily inspection checklist referenced secondary containment, it was not clear whether it included secondary containment for the Tank Farm and/or the Return and Fill Unit. Pursuant to the RCRA Permit MSD000776765, Section IV.C.2., the Permittee shall design, construct, and operate the secondary containment system, in accordance with the detailed EPA-RCRA CEI Report February 25, 2025 Page 28 of 33 Safety-Kleen Systems EPA ID# MSD000776765 design plans and descriptions contained in Permit Attachment III-1 [MHWMR 264.193(b)-(f)]. Specifically, Permit Attachment III-1 requires the Permittee to operate secondary containment free of cracks, debris in dike, deterioration, leaks, corrosion and paint failure. Pursuant to the RCRA Permit MSD000776765, Subpart IV.D.1, the Permittee shall not place hazardous wastes or treatment reagents in the tank system if they could cause the tank, its ancillary equipment, or a containment system to rupture, leak, corrode, or otherwise fail [MHWMR 264.194(a)]. Pursuant to the RCRA Permit MSD000776765, Section IV.E.5, in the event of a leak or a spill from the tank system, from a secondary containment system, or if a system becomes unfit for continued use, the Permittee shall remove the system from service immediately and, for all major repairs to eliminate leaks or restore the integrity of the tank system, the Permittee must obtain a certification by an independent, qualified, registered professional engineer that the repaired system is capable of handling hazardous waste without release for the intended life of the system before returning the system to service. Safety-Kleen provided two hazardous waste Tank Internal Inspection Reports via email on April 15, 2025, for hazardous waste tanks integrity inspection conducted in June 2024. The report for Tank #1 showed foundations coating condition failure; the Outer Shell findings of corrosion on the west side on the floor of the tank to the head; atmospheric venting's finding vent screen damaged needing repair/replacement; Head/End finding: corrosion on west head to floor causing leak, the inspector concluded the tank appeared to be in poor condition. The report indicated the tank to be removed from service and repaired prior to returning to service; coating on the concrete should be cleaned, properly prepped and re-coated at the earliest convenience. MDEQ requested on April 30, 2025, for Safety Kleen to provide with the "lockout tagout" records that demonstrate the tank was removed from service, when, what repairs were made, when the tank was returned to service, and the P.E. certification prior to returning the tank to service pursuant to 40 CFR 264.196(f). This request is still pending. The report for Tank #2 identified coating failure on the foundation. The report also mentioned taking action include cleaning the foundation surface thoroughly, properly preparing the concrete substrate, and applying new protective coating to the foundation. In addition, there were no records of repair provided for either tank, and the tank operating record did not include a certification from a qualified Professional Engineer in accordance with 40 C.F.R. 270.11(d) indicating that the repaired system is capable of handling hazardous waste without release for intended life of the system. 15) List of Attachments Attachment 1: Email Log - Summary of email correspondence and records submission Figure 1: Aerial map of SK Facility EPA-RCRA CEI Report February 25, 2025 Page 29 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Figure 2: SPCC Plan Site Layout/Emergency Evacuation Attachment 2: Photo Log - Photographs taken on February 25, 2025 16) Signed Digitally signed by RAJAGOPAL RAJAGOPAL AIYAR AIYAR Date: 2025.07.15 09:09:21 -04'00' Raj Aiyar Environmental Engineer 17) Concurrence Araceli B. Chavez RCRA Enforcement Section EPA-RCRA CEI Report February 25, 2025 Page 30 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Attachment 1 - Email Log Summary of email correspondence and records submission Date of Submission February 25, 2025 From To SK EPA & MDEQ February 28, 2025 SK EPA & MDEQ March 3, 2025 Mar 10, 2025 April 2, 2025 April 2, 2025 April 3, 2025 April 3, 2025 June 9, 2025 SK EPA & MDEQ SK EPA &MDEQ SK EPA & MDEQ SK EPA &MDEQ EPA SK SK EPA Description May 5, 2023, Class 1 Permit Modification for changes to the Facility' Contingency Plan/Community Letters; 2023 and 2024 Jackson Emissions Monitoring; Contingency Plan- Quick Reference Guide; 2023 and 2024 Jackson Emission Monitoring Letter to EPA; LDAR Heavy Liquids P&IDs; Emergency Contact Information; Bulk Solvent Manifests (2022, 2023 and 2024) Manifests or shipping papers for non-hazardous wastes from the vacuum truck collection services to Waste Management Clearview Landfill and to Valicor; Hazardous Waste Manifest and Labels for Boxes of Lamps; Photographs of labels on two drums of Branch debris; Facility Closure Plan; Job Description for personnel at the Facility; Training Records for 2022 to 2025 for Facility Personnel; Insurance Policies as renewed for 2024-2025; Financial Rating for Clean Harbors Inc as reported to MDEQ in December 2024 SPCC Plan; Compliance Plan for RCRA Subpart AA, BB and CC from the Approved Permit Application for the most recent Permit renewal dated August 2012. Repaired insulation in storage warehouse and before and after images of waste storage tanks showing repainting of area with peeling paint. Waste Profile Sheet, Clean Harbors Profile No. MEM-OWW-002745- VAC Services Waste to Valicor; Way Point Analytical Data - 25-037-0012 for Vac Truck Collected Waste dated 03/25/2025; Inspection and Corrective Action SPCC Plan dated October 2021; NPDES, Additional Insight regarding Frac Tank CA to provide personnel training; EPA's recommendation to provide Branch Manager's Inspection; EPA's recommendation for Frac Tank Training; EPA's concern regd. effectiveness of the Frac Tank's secondary containment Acknowledged the recommendation by EPA for implementing Best Management Practices and Insight to Training at the Facility Waste Material Profile Sheet- Profile No. 150055 EPA-RCRA CEI Report February 25, 2025 Page 31 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Figure 1 Arial view of Safety-Kleen EPA-RCRA CEI Report February 25, 2025 Page 32 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Figure 2 SPCC Plan: Site Layout/Emergency Evacuation Plan EPA-RCRA CEI Report February 25, 2025 Page 33 of 33 Safety-Kleen Systems EPA ID# MSD000776765 Attachment 2 - Photo Log 43 Photos taken on: February 25, 2025 Photos taken by: Raj Aiyar, USEPA and Leigh Tanner, MDEQ Photos taken with: KODAK PIXPRO FZ53 EPA Property Tag: SX9091 Photo-1 21,000-gallon Frac Tank Photo-4 Sec. Containment in Disrepair Photo-2 Secondary Containment in Disrepair Photo-5 Debris in Secondary Containment Photo-3 Oily Debris in Secondary Containment Photo-6 Spill Boom near Frac Tank EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 1 of 8 Safety-Kleen Systems EPA ID# MSD982769903 Photo-7 Spill Boom near Frac Tank Photo-10 Oily Sheen in the drainage ditch Photo-8 Concrete Stormwater Channel Photo-11 Oily Sheen in the drainage ditch Photo-9 Drainage ditch Photo-12 Oily sheen in the drainage ditch EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 2 of 8 Safety-Kleen Systems EPA ID# MSD000776765 Photo-13 SAA Drum near Frac tank with no Photo-16 Permitted Storage Area IOH Photo-14 SAA Drum with IOH near Frac tank Photo-17 Universal Waste Lamps Photo-15 Customer Sample Retention Cabinet Photo-18 Insulation in disrepair (Permitted Storage Area) EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 3 of 8 Safety-Kleen Systems EPA ID# MSD000776765 Photo-19 Insulation in Disrepair (Permitted Storage Area) Photo-22 Hazardous Waste Tank Farm Photo-20 Insulation in Disrepair (Permitted Storage Area) Photo-23 illegible tags Photo-21 Insulation Repaired (Permitted Storage Area) Photo-24 Tank #1 Coating Peeling EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 4 of 8 Safety-Kleen Systems EPA ID# MSD000776765 Photo-25 Tank #1 Coating Peeling Photo-28 Tank #1 Repainted Photo-26 paint peeling and signs of rust Photo-29 Cracked Secondary Containment Photo-27 Signs of Rust on the Tank Valve Photo-30 Cracked Secondary Containment EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 5 of 8 Safety-Kleen Systems EPA ID# MSD000776765 Photo-31 Used Parts Washer Station Photo-33 Drum Washer/Wet Dumpster Photo-32 Return and Fill Loading Dock Photo-34 SAA Container (Return and Fill Station) EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 6 of 8 Safety-Kleen Systems EPA ID# MSD000776765 Photo-35 Container Storage Flammable Storage Shelter Photo-38 20,000-gallon Used Oil Tank Photo-36 Inside Storage Shelter Photo-39 Absorbent Material on the gravel Photo-37 10-day Storage Shelter Photo-40 Stormwater Puddle with Oily Sheen EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 7 of 8 Safety-Kleen Systems EPA ID# MSD000776765 Photo-41 Oily Debris on the West Side Photo-43 SAA Container with Flammable Label Photo-42 SAA Container with a DOT Class 9 Label EPA-RCRA CEI Report February 25, 2025 Attachment 2 - Page 8 of 8 Safety-Kleen Systems EPA ID# MSD000776765