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REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At Neenah Foundry Company dba Deeter Foundry Co 5945 North 70th Street Lincoln, NE 68507 (402) 464-7466 ext. 4723 EPA ID Number: NED007272701 On November 27 and 28, 2023 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement & Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division, I performed a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Neenah Foundry Company dba Deeter Foundry Co (Deeter), located in Lincoln, Nebraska, on November 27 and 28, 2023. I conducted the inspection under the authority of RCRA Section 3007(a), as amended. During the inspection, I collected the information necessary to determine compliance with the applicable regulatory and statutory requirements. This report and attachments present the results of the inspection. Based on the information obtained during the inspection, I inspected the facility as a Large Quantity Generator (LQG) of hazardous waste, small quantity handler of universal waste, and used oil generator. Deeter was last inspected by the Nebraska Department of Energy and Environment (NDEE) on July 21, 2021. Three violations were observed or cited as a result of the NDEE July 2021 inspection. The last EPA inspection was conducted on February 23, 2017. Nine violations were observed or cited as a result of the 2017 EPA inspection. 2.0 PARTICIPANTS Deeter: Nate Pendell, Manager, Manufacturing Manager Tony Goff, Director of Operations Craig LeNoble, Environmental Director U.S. Environmental Protection Agency (EPA): Timothy Evans, Life Scientist, ECAD Region 7 3.0 INSPECTION PROCEDURES On November 27, 2023, at approximately 2:10 p.m., I arrived at Deeter. A drive-by, visual inspection was conducted on the south and east perimeters of the facility; the north and west perimeters of the facility are not accessible from the public right-of way. No issues were observed as part of the drive-by, visual inspection. I was greeted by Deb Bitzer in the facility offices. I informed Ms. Bitzer that I worked for EPA and that I was at Deeter to conduct a RCRA hazardous waste inspection. I asked Ms. Bitzer if I could speak with Mike Renton, who was listed as site contact on the Notification Acknowledgement/Verification Report form (Attachment 6). Ms. Bitzer stated that Mr. Renton was no longer employed at the facility, but she would contact Mr. Pendell and ask him to assist me. I was greeted by and met Mr. Pendell and was then escorted to a conference room for an in-briefing. Mr. Pendell and I were joined by Mr. Goff. I presented Messrs. Pendell and Goff with my business card and credentials. Mr. LeNoble joined the in-briefing by telephone. I then explained the purpose and procedures of the inspection. As part of the in-briefing, I presented Mr. Pendell with a copy of the RCRA Facility Access Information Sheet, March 2013, which provides inspection authority. I explained my need to collect accurate information and presented Mr. Pendell with a copy of Title 18 U.S. Code, Sections 1001 and 1002. Messrs. Pendell, Goff, and LeNoble were made aware of Deeter's confidentiality rights and informed that a Confidentiality Notice would be provided at the end of the inspection to make, or not to make, any claims. During the inspection, discussions consisted of wastes generated and waste management practices. Document photocopies and photographs were collected as inspection documentation (see Attachments 1-16, including Photos 1-9). November 27, 2023 Messrs. Pendell and Goff acted as the primary facility representatives. I conducted a visual inspection of the following areas on November 27, 2023 (see Attachment 2 for a facility aerial view and facility diagram): x Melt Floor, Southwest Corner x GMD Cupola Baghouse - Flyash Collection x Less Than 90-Day Accumulation Area/ Baghouse Waste x 20-Yard Roll-Off Containers/Northeast Corner of Yard - Steel, Borings, Trash, Fly Ash Bags x Sand Supersacks, North Side of Belt Yard x Slag Bin x Oily Rags and Material Dumpster x Outside, Adjacent to East Make Up Air Unit (MAU) - Used Oil Tank x West Wall of Maintenance Shop - Bulk Fluid and Used Oil Storage x Sand Lab 2 November 28, 2023 On November 28, 2023, at approximately 8:30 a.m., I arrived at Deeter and met Messrs. Pendell, Goff, and LeNoble. Messrs. Pendell, Goff, and LeNoble acted as the primary facility representatives. I conducted a visual inspection of the following areas on November 28, 2023: x West Warehouse (Listed as "Warehouse Store's" on Facility Site Plan, Attachment 2) x East Warehouse (Listed as "Metal Storage Building" on Facility Site Plan, Attachment 2) Information collected during the inspection was documented in a field note logbook. The records that were reviewed are as noted and discussed below. I followed the inspection procedures established in the RCRA CEI Standard Operating Procedure (No. 2321.1E), unless noted differently. Any federal regulatory citations noted in this report are as adopted by reference in the authorized Nebraska regulations. At the conclusion of the inspection, I summarized the findings and recommendations with Messrs. Pendell, Goff, and LeNoble. I provided Mr. LeNoble with a Confidentiality Notice (Attachment 3), which he signed as acknowledgement of receipt. Mr. LeNoble made no confidentiality claims. I also provided Mr. LeNoble with a Receipt for Documents and Samples (Attachment 4) and Notice of Preliminary Findings (NOPF) (Attachment 5), which he signed as acknowledgement of receipt. The following inspection documents were left with Deeter: Confidentiality Notice Receipt of Documents and Samples Notice of Preliminary Findings Instructions for Responding to a Notice of Preliminary Findings EPA Compliance Assistance (Provided by e-mail on November 30, 2023) Security Awareness EPA Industry Sector Notebooks List EPA Environmental Compliance Assistance Centers U.S. EPA Small Business Resources Information Sheet Chemical Facility Anti-Terrorism Standards Managing Used Oil - Advice for Small Businesses 4.0 FINDINGS AND OBSERVATIONS 4.1 General Information/Facility Description Deeter is a foundry, producing iron castings, and is part of Neenah Enterprises Inc., a privately owned foundry company headquartered in Neenah, Wisconsin. Aside from the Lincoln facility, Neenah Enterprises Inc. also operates facilities in Neenah, Wisconsin and Miami, Florida. Neenah Enterprises Inc. serves industrial markets which include, but are not limited to, agriculture, material handling, mining, railroad, transportation infrastructure, utilities, wastewater management, energy, and national defense. 3 Mr. Pendell stated that Neenah serves approximately 1,500 municipalities. Products made specifically by Deeter include, but are not limited to, manhole covers and frames, trench grates and frames, and residential and commercial water valve/meter covers. According to the Deeter website, the facility has been in operation at this site since 1945. Messrs. Pendell and Goff state that Deeter currently employs 95 people in the shop/production areas and 21 office personnel. Deeter conducts melting and casting operations during two 12-hour shifts, four days per week, with additional finishing operations as required. See the 2021 NDEE Hazardous Waste Compliance Evaluation Inspection Report (Attachment 7) and facility website https://groupnei.com/ for additional information related to company locations, manufacturing processes and capabilities, products, and history. 4.2 RCRA Status According to the RCRAInfo database, Deeter has notified as a State of Nebraska and Federal LQG of D006 and D008 characteristic hazardous waste. As part of the opening conference, I provided Mr. Goff with a Notification Acknowledgement/Verification Report form (Attachment 6). Mr. Goff reviewed the form and made no changes to the form. However, during the inspection, it was determined that Mike Renton is no longer the Site Contact; the facility generates D001 characteristic hazardous waste related to hazardous waste aerosol can residual; the facility generated D001 characteristic hazardous waste hydrogen peroxide in May 2023; and the facility generates D003 characteristic hazardous waste associated with generation of unpunctured waste aerosol cans. See Section 4.7 for additional information related to Site Contact Information and hazardous waste aerosol can residual, unpunctured aerosol cans, and hydrogen peroxide. Based upon the amount and type of hazardous waste generated at Deeter, I inspected the facility as an LQG of hazardous waste, small quantity handler of universal waste, and used oil generator. 4.3 Previous Inspection and Related Findings The report of the NDEE inspection on July 21, 2021, included the following potential findings or violations: 1. Title 128, Chapter 10, Section 004.02, 40 CFR 262.34(b) - Accumulating hazardous waste for more than 90 days without a permit or an extension granted by the director. 2. Title 128, Chapter 18, Section 004.02 as referenced by Chapter 10, 004.01H, 40 CFR 265.53(b) - Failure to submit a revised copy of the contingency plan to Local Police, Fire Department, Hospitals, Etc. 3. Title 128, Chapter 7, 009.04A3, 40 CFR 279.22(c)(1) - Failure to ensure containers with a volume of 25 gallons or greater being used to accumulate used oil are labeled or marked with the words "Used Oil". Addressed at the time of inspection. The report of the EPA inspection on February 23, 2017, included the following potential findings or violations: 1. Title 128, Ch 7, 009.04A3, 40 CFR 279.22(c)(1) - Containers Not Clearly Marked with words "Used Oil." 4 2. Title 128, Ch 25, 012.04B, 40 CFR 273.13(d) - Failure to Immediately Clean Up and Place In a Container Any Broken Lamp Or Lamp With Evidence of Breakage/Leakage/Damage That Could Cause A Leak. 3. Title 128, Ch 25,014.03, 40 CFR 273.15(c) - Not Able to Clearly Demonstrate the Length of Time Universal Waste Has Been Accumulated. 4. Title 128, Chapter 10, 004.01A4, 40 CFR 265.174 - Failure to Conduct Weekly Inspections. 5. Title 128, Chapter 18, 005.03, 40 CFR 265.54(d) - Failure to Update List of Emergency Coordinators within Contingency Plan. 6. Title 128, Chapter 18, 005.03, 40 CFR 265.52(e) - Failure to Maintain a List of Emergency Equipment at Facility. 7. Title 128, Chapter 19, 003, 40 CFR 265.16(c) - Failure to Conduct Annual Review of Initial Training. 8. Title 128, Chapter 19 004.02, 40 CFR 265.16(d)(2) - Failure to Maintain Written Job Descriptions for each Position at the Facility Related to Hazardous Waste Management. 9. Title 128, Ch 19 004.03, 40 CFR 265.16(d)(3) - Failure to Maintain a Written Description of the Type and Amount of Both Introductory and Continuing Training That Will Be Given to each Person Filling a Position. 4.4 Changes Since Previous Inspection Changes at the facility included, but were not limited to, the following: x According to Mr. Pendell, Mike Renton, former Maintenance/Environmental Manager, ended his employment with Deeter in approximately July of 2023. Mr. Pendell assumed duties previously performed by Mr. Renton. See Section 4.7 For additional information. x Craig LeNoble has been in his role as Environmental Director with Neenah Enterprises Inc. for approximately two and a half years. x According to Mr. Pendell, the sonoporoxone/black water system was last used in approximately July of 2022. The sonoporoxone/black water system had been used to recover clay from waste sand. 4.5 Waste Streams and Waste Management Cupola furnace operation generates D006 and D008 characteristic hazardous waste cupola quench and baghouse dust. According to facility personnel, scrap metal used to make castings at the facility is the source of cadmium and lead, D006 and D008 characteristic hazardous waste. The facility also generates D001 characteristic ignitable hazardous waste as result of operating an aerosol can puncturing device. According to the facility Manifest Inspectors Report, accessible through RCRAInfo, the facility also generated and shipped D001 characteristic ignitable hazardous waste hydrogen peroxide on 5/24/23 (Attachment 8). According to Mr. Pendell, the unused hydrogen peroxide was associated with the sonoporoxone/black water system, which is no longer in operation. See Sections 4.6.2 and 4.7 for additional information related to hazardous waste aerosol cans, aerosol can residual, and hydrogen peroxide. The facility is also a small quantity handler of universal waste batteries and lamps and used oil generator. 5 Aside from waste streams described within this report, refer to the July 21, 2021, NDEE Hazardous Waste Compliance Evaluation Inspection Report (Attachment 7) for additional information related to waste stream generation and management at the facility. Aside from the one-time generation of D001 hazardous waste hydrogen peroxide in 2023, Mr. Goff did not describe any changes to waste streams generated at the facility, since the previous inspection. 4.6 Areas Visually Inspected Associated with Preliminary Findings 4.6.1 West Warehouse Not Able to Clearly Demonstrate the Length of Time Universal Waste Has Been Accumulated, Title 128 Ch. 25 014, 40 CFR 273.15(c) (NOPF 3) - During inspection of the west warehouse, I observed the following containers being used to accumulate universal waste lamps: x Four, 4-foot cardboard boxes containing approximately 160 lamps among the four boxes (Photos 3-5). All four boxes were closed and labeled with the words "Bad Bulbs", "Used Bulbs", and "Used Lamps." However, the boxes were marked with dates "1-23", "2-23", "3-23", and "4-23." I asked warehouse personnel if they knew when Deeter first began accumulating spent lamps in each of the four boxes. Deeter employees were not sure exactly when lamps were first placed in the boxes. Deeter personnel made a best guess when spent lamps had first been accumulated in the boxes but did not have any documentation or an inventory system to demonstrate an accurate length of time when spent lamps had first been placed into each of the four boxes. Facility personnel marked the boxes with accumulation start dates, "1-1-23", "2-1-23", "3-1-23", and "41-23", addressing NOPF 3 at the time of the inspection (Photos 7-9). 4.6.2 East Warehouse Hazardous Waste Not Containerized, Title 128 Ch. 10 004.01A, 40 CFR 262.34(a)(1)(i) (NOPF 5 Added after Inspection) - During inspection of the east warehouse, I observed what appeared to be aerosol can residual on the floor, wall, and surrounding equipment associated with an aerosol can puncturing device (Photo 6). I also observed what appeared to be an approximately 18-inch oil stain on the floor adjacent to the aerosol can puncturing device. The aerosol can puncturing device was attached to an approximately -full 30-gallon metal drum. The drum was closed and labeled with the words "Hazardous Waste." Facility personnel estimated there to be two to four ounces of what was confirmed to be aerosol can residual on the floor, wall, and surrounding equipment. According to Mr. Pendell, aerosol can residual has been determined to be a D001 characteristic for ignitability hazardous waste. Facility personnel stated that they thought the 18-inch stain was oil. According to Warehouse personnel, approximately seven or eight different aerosol products are used throughout the facility, including but not limited to, contact cleaner, PB Blaster penetrating lubricant, and Marine Coating Acrolon polyurethane coating. During the 2021 NDEE RCRA inspection, Mike Renton, former site contact, stated that it had taken greater than 20 years to generate one drum of hazardous waste aerosol can residual. 6 According to the 2021 NDEE RCRA inspection report, the manifest for the last shipment of aerosol can residual listed Clean Harbors Environmental Services, Inc., located in Kimball, Nebraska, as the designated facility for disposal. It should be noted that Photograph 1 from the 2021 NDEE Hazardous Waste Compliance Inspection Report shows the aerosol can puncturing device and what appears to be aerosol can residual on the floor, wall, and surrounding equipment (Attachment 7). An e-mail was sent to the facility on March 7, 2024, informing the facility of the additional NOPF (Attachment 9). 4.7 Records Review Notification of Regulated Waste Activity Change in Information or Status of Any Person Not Amended, Title 128, Chapter 4, 003.02 (NOPF 1) - During review of the facility Notification Acknowledgement/Verification Report form, I noted that Mike Renton was listed as the Site Contact (Attachment 6). However, according to Mr. Pendell, Mr. Renton ended his employment with Deeter in approximately July of 2023. Mr. Pendell stated that he assumed duties previously performed by Mr. Renton. According to Title 128, Chapter 4, 003.02, "Not later than thirty days after any change in the information or status of any person as described to the Department or EPA in Section 003 of this Chapter, such person shall file an amended notification with the Department, . . ." Hazardous Wastes Handled by Deeter Not Identified or Listed on Notification, Title 128, Chapter 4, 003 (NOPF 6 Added after Inspection) - During review of the facility Notification Acknowledgement/Verification Report form (Attachment 6), I noted that the facility did not list waste code D001 for characteristic ignitable hazardous waste aerosol can residual and hydrogen peroxide, or D003 for characteristic reactive hazardous waste aerosol cans. Generation of D001 hazardous waste aerosol can residual and D003 aerosol cans was observed during the 2021 NDEE RCRA inspection; generation is ongoing at the facility. According to the facility Manifest Inspectors Report, approximately 1.4 tons of D001 characteristic hazardous waste hydrogen peroxide was shipped on May 24, 2023 (Attachment 8). According to Title 128, Chapter 4, 003.02, "Not later than ninety days after the effective date of regulations promulgated under the State Act identifying by its characteristics or listing any substance as hazardous waste subject to these regulations, any person generating or transporting such hazardous waste, as defined in Chapter 2 and Chapter 3, or the owner or operator of a facility for treatment, storage or disposal of such hazardous waste shall file with the Department, on forms furnished by the Department, a notification stating the location and general description of such activity and the hazardous wastes handled . . ." An e-mail was sent to the facility on March 7, 2024, informing the facility of the additional NOPF (Attachment 9). 7 Contingency Plan Contingency Plan Not Updated to Include New Primary Emergency Coordinator, Title 128, Chapter 18 005.03, 40 CFR 265.54(d) (NOPF 2) - During review of the facility's contingency plan, I noted that Mike Renton was listed as the Primary Emergency Coordinator (Attachment 11). The Deeter Hazardous Waste Management Contingency Plan was last revised in March of 2017. According to Mr. Pendell, Mr. Renton, ended his employment with Deeter in approximately July of 2023. The following information was noted as part of my review of the facility contingency plan: x A facility site map which includes the location of: Fire Extinguishers Eye Wash Stations Fire Blankets Emergency Shower/Eyewash Spill Kits Primary Escape Route Secondary Escape Routes x The City of Lincoln Fire and Rescue Department (LFRD) in coordination with the Lincoln Police Department (LPD) will respond to fire and hazardous material incidents at Deeter. Saint Elizabeth Community Health Center is the nearest hospital. A copy of the contingency plan has been submitted to both LFRD and Saint Elizabeth Community Health Center. I was not able to determine if copies of the contingency plan were also submitted to police or the Lancaster County Local Emergency Planning Committee. Aside from the need to update the Primary Emergency Coordinator, no apparent issues were observed or documented during review of the facility contingency plan. Uniform Hazardous Waste Manifests with Associated Land Disposal Restriction (LDR) Notification, Bill of Lading, and Special Waste Disposal Permit Prior to arriving at the facility, I had conducted an on-line inspection of electronic manifests using RCRAInfo. All manifests appeared to be complete and signed by the designated facility. I also reviewed a paper copy of the following manifests and their associated land disposal restriction notification forms: x Manifest 018681788FLE, dated September 13, 2023. The manifest was associated with D006 and D008 hazardous waste cupola quench and baghouse dust. x Manifest 008804514SKS, dated May 24, 2023. The manifest was associated with D001 hazardous waste hydrogen peroxide. I reviewed a bill of lading associated with shipment of universal waste batteries which occurred in April of 2023 and shipments of universal waste batteries and lamps for August and September of 2022, respectively. I reviewed City of Lincoln, Nebraska Special Waste Disposal Permit HSPW00229. The Special Waste Disposal Permit allowed for disposal of oil-contaminated rags, filters, and absorbent material at Bluff Road Landfill, located in Lincoln, Nebraska. 8 No apparent issues were observed during review of manifests, LDRs, universal waste bill of lading, or the Special Waste Disposal Permit. Weekly Inspections According to Mr. Pendell, the facility less than 90-day hazardous waste accumulation area is inspected weekly. Inspections are conducted by Mr. Pendell and Dan Mahloch, Melt Supervisor. According to Mr. Pendell, the inspections are not documented but the inspections are conducted visually and include identification of any leaks and any damage or deterioration of containers. 2021 Comprehensive Biennial Report Biennial Report Not Prepared and Submitted for 2021, Title 128 Chapter 4, 005.01A, 40 CFR 262.41 (NOPF 7 Added After Inspection) - Prior to arriving at the facility, I had attempted to conduct an on-line review of the facility's 2021 biennial report using RCRAInfo. However, no 2021 biennial reporting data was available within RCRAInfo (Attachment 10). According to the facility Manifest Inspectors Report, within RCRAInfo, Deeter generated and shipped approximately 0.6 tons of D006 and D008 characteristic hazardous waste cupola quench and baghouse dust on July 17, 2020, and approximately 3.4 tons of D006 and D008 characteristic hazardous waste cupola quench and baghouse dust on September 11, 2020 (Attachment 8, Pages 5 and 6). The 3.4 tons (6,800 pounds) of D006 and D008 characteristic hazardous waste cupola quench and baghouse dust generated and subsequently shipped on September 11, 2020, would have made Deeter a Large Quantity Generator of hazardous waste for the year 2020. Therefore, Deeter would have been required to submit a biennial report to the State of Nebraska by March 1, 2021. Subsequent to the inspection, NDEE personnel confirmed that Deeter had not submitted a 2021 Comprehensive Biennial Report (Attachment 10). An e-mail was sent to the facility on March 7, 2024, informing the facility of the additional NOPF (Attachment 9). Waste Determination - Cupola Quench and Baghouse Dust According to Messrs. Pendell and Goff, Summit Environmental Technologies, Inc., analytical laboratories performs analyses on GMD cupola quench and baghouse dust. Messrs. Pendell and Goff stated that a composite sample is collected from among 10 super sacks. Sampling events occur approximately three or four times each month. Personnel Training Employees Not Trained on Universal Waste Management, Title 128 Chapter 25, 015, 40 CFR 273.16 (NOPF 4) - During review of facility training documentation, I requested hazardous and universal waste training documentation for Deeter employees. Mr. Pendell provided me with 2020 through 2022 employee training signature sheets entitled "Storm Water Pollution Plan, Spill Prevention and Countermeasures, Hazardous Waste Contingency Plan Training" (Attachment 12). 9 The document indicates hazardous waste training is provided for Deeter employees but does not include universal waste management as a training topic. According to Messrs. Pendell and Goff, universal waste training had not been provided for Deeter employees. Other additional hazardous waste training topics listed on employee training signature sheets include, but are not limited to: x Materials Management and Handling x Spill Cleanup x Location of Spill Supplies x Spill Reporting Procedures x Minimize Hazards to Employees from Hazardous Waste Release x Benchmark Monitoring and Inspections Aside from no universal waste training, no other issues were with RCRA hazardous waste training. Job Descriptions and Associated Hazardous Waste Duties I reviewed job descriptions for the following positions at Deeter: 1. Melt Department Supervisor 2. Warehouse & Inventory Manager 3. Maintenance Technician I did not document any apparent issues during review of the employee job descriptions. However, I did note that greater detail could be added for specific hazardous waste duties related to each position description e.g., Dan Mahloch, Melt Supervisor, was identified as a Deeter employee who signs uniform hazardous waste manifests. However, within the Melt Department Supervisor written position description, duties do not describe preparing or signing manifests. Mr. Mahloch's position description states the following: "Authorized and trained to handle hazardous waste. Responsible for the waste stream management of cupola baghouse dust, slag, and quench tank discharge, including, but not limited to sampling, container inspections, and performance of Hazardous Waste Contingency Plan." Emergency Response Equipment and Preparedness and Prevention During the inspection, I observed ABC-rated fire extinguishers throughout the facility. Fire extinguishers had been inspected by Summit Fire Protection in March of 2023. See the facility Hazardous Waste Management Contingency Plan for a list of emergency response equipment, Section 5, Page 3 (Attachment 11). 10 In the event of an emergency, the facility is equipped with distinct fire and tornado alarms. See Appendix B within the facility Hazardous Waste Management Contingency Plan for an Emergency Action Plan which includes, but is not limited to, a description of the emergency siren system, evacuation routes and designated employee meeting locations, and emergency training (Attachment 11). Deeter employees use mobile phones for communication. No apparent issues were observed with the facility emergency equipment or preparedness and prevention. 5.0 SUMMARY I inspected Deeter as an LQG of hazardous waste, a small quantity handler of universal waste, and a used oil generator. The following preliminary findings were noted as discussed above: 1. Title 128 Ch. 4, 003.02 (NOPF 1) - Change in Information or Status of Any Person Not Amended Through Notification to NDEE. 2. Title 128, Chapter 18, 005.03, CFR 265.54(d) (NOPF 2) - List of Emergency Coordinators Not Updated in Contingency Plan. 3. Title 128 Ch. 25 014, 40 CFR 273.15(c) (NOPF 3) - Not Able to Clearly Demonstrate the Length of Time Universal Waste Has Been Accumulated. Addressed at time of inspection. 4. Title 128 Ch. 25 015, 40 CFR 273.16 (NOPF 4) - Universal Wase Training Not Conducted for Employees. 5. Title 128 Ch. 10 004.01A, 40 CFR 262.34(a)(1)(i) (NOPF 5 Added after Inspection) - Hazardous Waste Not Containerized. 6. Title 128, Chapter 4, 003 (NOPF 6 Added after Inspection) - Hazardous Wastes Handled by Facility Not Identified or Listed on Notification. 7. Title 128 Chapter 4, 005.01A, 40 CFR 262.41 (NOPF 7 Added after Inspection) - Biennial Report Not Prepared and Submitted for 2021. Other than the items noted above, no other apparent preliminary findings were observed or cited. However, EPA post-inspection review of this report may change or add to my findings. TIMOTHY Digitally signed by TIMOTHY EVANS Date: 2024.03.13 _E__V_A_N__S_______14_:3_6:_11_-0_5_'00_' _______ Timothy R. Evans Life Scientist ECAD/CB/RCRA, EPA Region 7 Whisnant, Digitally signed by Whisnant, Amber _A_m__b_e_r_______1_4_:24_:3_4_-0_5'0_0_' _______ Date: 2024.03.19 Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 11 Attachments 1. Digital Image Log (11 pages/9 photos) 2. Arial Photo and Facility Diagram (2 pages) 3. Confidentiality Notice (1 page) 4. Document of Receipt (1 page) 5. NOPF (2 pages) 6. Notification Acknowledgement/Verification Report Form (2 pages) 7. NDEE July 21, 2021, RCRA Inspection Report and Letter of Non-Compliance (28 pages) 8. Manifest Inspectors Report (6 pages) 9. Additional Citations (2 pages) 10. Biennial Reporting (3 pages) 11. Hazardous Waste Management Contingency Plan (16 pages) 12. Employee Training Signature Sheet (1 page) 12