Document a4rMej80j9oxbwvVREG7bXBLR

n EA~ un;tedStatos ~~ Environmental Proti!Ctlon ,., Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date: Media: Regulatory Program(s) 07/24/2017 RCRA Hazardous Waste Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: United States Department of Agriculture Dale Bumpers National Rice Research Center 2955 Highway 130 East Stuttgart, Arkansas 72160 2955 Highway 130 East Stuttgart, Arkansas 72160 Arkansas County Joel Ledbetter (870) 672-8255 I Safety & Occupational Health Specialist joel.ledbetter@ars. usda.gov FRS Number: ld entification/ Pe rm it Number: Media Number: NAICS : SIC: ARR000011932 54171 Personnel participating in in spection: Joyce John son USEPA Enforcement Officer Angela Hays US EPA Enforcement Officer Ryan Hayde n ADEQ Inspector Joel Ledbetter USDA Saf ety & Occupational Health Specialist Shelia Parker USDA Southeast Area Environmental Manager Matt McEntire USDA Support Scientist Rob ert ldeker EPA Lead Inspector Signature/Date & a USDA Mainten ance Supervisor JovcfJ~nson /' 214-665-8548 214-665-2285 501-682-0875 870-672-8255 662-686-3745 870-672- 8268 870-672-8266 II/;b/;7 Date Supervisor Signature/Date ~ _L7 Gu:{~ ore / If/;~I /;.r-- Date 6ENFORM-019-R7 (2/15/2017) 1 USDA /Dale Bumpers National Rice Research Center Inspection Date 07/24/2017 Section I-INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Joyce Johnson and Angela Hays arrived at the United States Department of Agriculture- Dale Bumpers National Rice Research Center (Rice Research Center) located at 2955 Highway 130 East, Stuttgart AR 72160, at approximately 2:00pm on July 24, 2107, for an unannounced inspection. We met with Joel Ledbetter, Safety & Occupational Health Specialist, at the Opening Conference. Joyce Johnson presented her credentials to Mr. Ledbetter and informed him EPA has a requirement to inspect a certain number of federal facilities each year and this particular facility was chosen to determine compliance with the Resource Conservation and Recovery Act (RCRA). FACILITY DESCRIPTION The Dale Bumpers National Rice Research Center (Rice Research Center) conducts research to help the U.S. rice industry remain competitive in the global marketplace by assuring high yields, superior grain quality, pest resistance, and stress tolerance in rice cultivars. Research at the facility includes: 1) conventional and genomic techniques; 2) evaluating and rejuvenating over 18,000 rice cultivars collected from around the world; 3) developing improved genetic stocks, germplasm and cultivars; 4) identifying biological properties; 5) conducting grain chemistry research; 6) exploring the genetic diversity; 7) molecular plant pathology; and 8) conducting studies to learn of physiological processes. (Photograph 1) Section II- OBSERVATIONS The facility physical review consisted of multiple locations: Rice research labs, hazardous waste collection areas, satellite accumulation points (SAPS), Universal Waste collection areas, a greenhouse. (Photographs 2-10) Laboratories Rice laboratories Ll, L2a, L12, L15, and L18 were evaluated during this inspection. Laboratories Ll, L15 are L18 are active and generating hazardous waste. Laboratories L2A and L12 were not generating hazardous waste during the time of the inspection. Mr. Ledbetter stated that projects are scheduled to start in about six (6) months. The waste stream generation log shows that petroleum ether, acetonitrile HPLC, chloroform, and 1M sodium hydroxide are either being stored and/or generated in these areas. The generation log also shows that 3% Pyridine, 5% cupric acetate, and 50% isooctane is being stored and/or generated in an area of Ll even though the generation log states this waste is not being generated. (Appendix 3) Satellite Accumulation Points (SAPs} One (1) SAP was observed in the Lllaboratory area. Ferric sulfate, xylene orange, methanol, hexanes, pyridine, cupric acetate, isooctane and petroleum ether are generated for lipid 2 USDA /Dale Bumpers National Rice Research Center Inspection Date 07/24/2017 analysis and extraction. Mr. Ledbetter stated that Labs L2A, L12 are currently inactive and that chemicals and/or hazardous wastes acetonitrile HPLC and chloroform used for analysis and DNA extraction are being stored only. (Photograph 3} Chloroform and sodium hydroxide for DNA extraction and salt tolerance are generated in the laboratories US and L18. Generation totals in liters for the above mentioned chemicals can be found in Appendix 3. Universal Waste Two (2} containers of used dry cell batteries were observed. The containers were labeled properly. (Photographs 6, 7 and 8} A copy of the certification to recycle is located at Appendix 5 of the inspection report. Used oil is stored in a 270-gallon tank located outside ofthe Aquaculture Research Center. (Photograph 9}. The used oil is collected from tractors and vehicles used by and belonging to this facility and the Harry K. Dupree Stuttgart National Aquaculture Research Center. The last shipment was on March 27, 2016. (Appendix 6}. Waste Disposal The most recent hazardous waste shipment from this facility was on September 2, 2014. The previous shipment was in 2004. Hazardous waste from this facility was combined (mixed) with the hazardous waste from the Aquaculture Research Center. The facilities have separate EPA identification numbers. The manifest has the identification number for the Aquaculture Research Center. The transporter is RINECO Transportation and the designated facility is Clean Harbors in El Dorado, Arkansas. (Appendix 4} Records Review Manifest #007699874FLE (Appendix 5} o Page 1, Block #3. Facility Emergency Response telephone number is missing. o Page 1, Block #18. Transporter's EPA ID number is missing. o Page 2, Block 27a, Line 3. Waste code is missing. o Page 3, Block 27a, Line 2. Waste code is missing. Hazardous Waste Profile Sheets have numerous discrepancies. (Appendix 7} o Page 1. Toxicity and listed waste boxes should be checked to match the EPA waste codes listed. o Page 2. The unused n-nitroso-n-methylurea is a listed waste (U-177}. o Page 3. Listed waste box is not checked. o Page 4. Ignitable and listed waste boxes are not checked. o Page 6. PB Buffer is ignitable. o Page 8 and 13. Pyrethrum TR is ignitable. If it is in a spray can, it is also reactive. o Page 9. Toxicity box is not checked. o Page 10 states that the acrylamide is "used". If it is unused it should be U007. o Page 11 and 14. Chloroform is mischaracterized. If it is used it would be D022. The boxes are not checked. 3