Document b52ZR6vJpDvLG4NoRmmv3YYRo

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At MOFFITT'S INC. 1819 SE Marshall Street Boone, Iowa 50036 (515) 432-6336 EPA ID Number: IAD981706377 On October 18, 2023 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division (ECAD), I conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Moffitt's Inc., located in Boone, Iowa, on October 18, 2023. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. During the inspection, I collected the information and data necessary to determine compliance with the applicable regulatory and statutory requirements. This inspection report and attachments present the results of the CEI. 2.0 PARTICIPANTS Moffitt's Inc.: Chris Moffitt, President (36 years with company) - chris@moffitts.com Presley Moffitt, Controller (5 years with company) Tina Sharp, Body Shop Manager (2 years in role) EPA: Mark Holcomb, Civil Investigator/Inspector (SEE) 3.0 INSPECTION PROCEDURES On October 18, 2023, I arrived unannounced at the facility's main entrance at about 1000 hours. Initially, I conducted a visual reconnaissance of the facility searching for areas of concern observable from the adjacent public roadways and parking lots. I identified no environmental issues or concerns during this preliminary examination. I entered the facility through the main entrance and stopped at the front desk. I introduced myself and asked for the facility manager. I was introduced to Mr. Chris Moffitt, the president. Mr. Moffitt escorted me to his office. Mr. Moffitt stated that he was the primary contact for hazardous waste at this facility and had been with the company for about 36 years. Mr. Moffitt told me the only items of personal protective equipment required for our visual inspection at this facility was eye protection in limited areas. At the opening conference, I presented my EPA ID and credentials to Mr. Moffitt. I next explained the purpose and procedures of the inspection. I then presented Mr. Moffitt with a copy of RCRA Section 3007(a), which provides inspection authority. I explained my need to collect accurate information and presented him with a copy of Title 18 U.S. Code, Sections 1001 and 1002. He was made aware of his confidentiality rights, and I informed him that a Confidentiality Notice would be provided at the end of the inspection to make a confidentiality claim if he so desired. Mr. Moffitt acted as the official facility representative during the inspection. The CEI consisted of a discussion of facility operations, waste generation, and waste management; a visual inspection of active waste generation and management areas; and a review of waste management records and documents. I conducted a visual inspection of the following areas: Service Lane Quick Lane North Lot (outside) Paint Room Paint Mixing Room Paint Booth Body Shop See Attachment #1 for the aerial/map views and facility diagram. Document photocopies and photographs were collected as inspection documentation (see Attachments #1-10 and Photos 113). The photo log is included as Attachment #2. Information collected during the inspection is documented on an Entry/Exit checklist, the hazardous waste compliance checklists, and in a notebook. I reviewed documents including the following: Safety Data Sheets (SDS), bill of ladings, and invoices. I followed the inspection procedures detailed in the RCRA CEI Standard Operating Procedure 2321.01E, unless noted otherwise. At the conclusion of the inspection, I provided Mr. Moffitt with a Receipt for Documents (see Attachment #3) and a Confidentiality Notice (see Attachment #4), which he signed as acknowledgement of receipt. No claim of confidential business information was made by Mr. Moffitt. There were no preliminary findings observed at the time of the inspection, so a Notice of Preliminary Findings form was not generated. I provided inspection and compliance assistance documents to Mr. Moffitt during the inspection, some as paper versions and some in electronic PDF via email post-inspection, that included the following: x RCRA Section 3007(a) (EPA Handout) x Title 18 U.S. Code, Sections 1001 and 1002 (EPA Handout) x Confidentiality Notice (Top page of the completed carbonless transfer set) x Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA In Connection with Inspections (EPA Handout) x Receipt for Documents and Samples (Top page of the completed carbonless transfer set) x Instructions for Responding to a NOPF (EPA Handout) 2 x U.S. EPA Small Business Resource Information Sheet (EPA Handout) x Solvent-Contaminated Wipes Final Rule Chart (EPA Handout) x Recycling Electronics (Iowa Department of Natural Resources - IDNR Handout) x Lead-Based Paint Activities (IDNR Handout) x Excluded Solvent-Contaminated Wipe Rule (IDNR Handout) x Battery Recycling/Disposal (IDNR Handout) x Management of Fluorescent Lamps for Businesses (IDNR Handout) x Incompatible Chemicals (IDNR Handout) x Universal Wastes Including Aerosol Cans (IDNR Handout) x TCLP Waste Determination Testing (IDNR Handout) x Industry Sector Notebooks (EPA Handout) x Environmental Compliance Assistance Centers (EPA Handout) x e-Manifest Fact Sheet (EPA Handout) x RCRA Online A Quick Reference Guide (EPA Handout) x Requirements for Used Oil Management Standards (EPA Handout) x Emergency Response Program (EPA Handout) x Commercial Motor Vehicle Transportation System Security & Safety x Security Awareness (EPA Handout) x Chemical Facility Anti-Terrorism Standards (Homeland Security Handout) x Iowa Life/Changing Iowa Department of Economic Development - Iowa Environmental Guide for Business x How to Register for RCRAInfo Industry Application for Iowa Facilities 4.0 FINDINGS AND OBSERVATIONS 4.1 Facility Information and Operations Moffitt's Inc. is a Ford and Lincoln dealership with a service and collision center, doing business as Moffitt's Ford and Lincoln. The facility is privately owned by Moffitt's Inc. Mr. Moffitt stated that this Moffitt's Inc. facility has been in operation since 1928 at several locations in Boone, Iowa. The current facility is about 35,000 square feet on about 8.2 acres. The facility operates during business day hours Monday-Saturday with 47 staff. Mr. Moffitt stated that he was not aware of any previous RCRA inspections at the facility and there had been no spills or activation of their contingency plan that he was aware of. See Attachment #1 for the facility aerial map views and facility diagram. 4.2 RCRA Status Moffitt's Inc. had not been previously inspected by the EPA for RCRA compliance. According to RCRAInfo, Moffitt's Inc. had most recently notified as a Very Small Quantity Generator (VSQG) on March 20, 2004. I verified the facility address and the site contact information with Mr. Moffitt and updated the EPA RCRA Notification Acknowledgement Verification Report to indicate the primary contact's name and phone number (see Attachment #5). At the time of this inspection, I determined Moffitt's Inc. to be a VSQG of hazardous waste with less than 100 kg, 3 or 220 lbs, of non-acute hazardous waste generated per month, a small quantity handler of universal waste batteries, and a generator of used oil. 4.3 Facility Waste Streams and Management Mr. Moffitt stated that the following waste streams are managed by Moffitt's Inc: Waste Paint and Related Materials - Moffitt's Inc. generates waste paint and solvents in their Paint Booth during the Body Shop repair operations. This waste has been determined to be D001, D007, D008, D018, F003, F005 hazardous waste based on process and product knowledge. Mr. Moffitt stated that the paints used are all water based, not enamel. The facility uses a paint thinner to clean paint guns that is purchased from Heritage-Chrystal Clean, LLC. in 55-gallon drums and described as "Paint Thinner 55G" on the invoice (see Attachment #6, page 2), and labeled with "UN1263" and "Flammable Liquid" on the product drum (see Photo 11). Mr. Moffitt estimates the annual generation of this waste to be about 1/10 of a 55-gallon drum every 1-2 months, or about 20-40 pounds per month. The most recent Bill of Lading (see Attachment #6, page 1) dated September 27, 2023, showed one drum of 350 pounds shipped by Heritage-Crystal Clean, LLC, being transported to Heritage-Crystal Clean, LLC (Indianapolis, Illinois) for H141 treatment (Storage and Transfer). During the visual inspection, I observed a black 55-gallon steel drum in the Paint Mix Room. The drum had no labels and was in good condition with no obvious damage or leaks observed (see Photo 11). The drum about 1/10 full of waste paint and solvent. Mr. Moffitt stated that the previous full drum had been picked up about one month ago. Used Oil - Moffitt's Inc. generates about 15-20 gallons of used oil per day from maintenance operations in the Service Lane. The used oil is stored in two 500-gallon steel tanks. The tanks receive used oil from the Quick Lane rapid oil change area next door via pipes. When near full, the used oil in the tanks is collected and transported by Jebro Inc. (Sioux City, Iowa) for recycling. See Attachment #11 for a Bill of Lading dated October 11, 2023, for 435 gallons of used oil being transported by Jebro Inc. During the visual inspection, I observed two black steel used oil tanks in the Service Lane area (See Photos 1-3). Both tanks were in good condition, labeled with "Used Oil", and free of any obvious damage or leaks. Used Oil Filters - Moffitt's Inc generates about 300 spent oil filters per month. The filters are hot drained, crushed, and sent for recyling as scrap metal. Pickett's Salvage (Paton, Iowa) recycles the scrap metal. At the time of the inspection, I did not observe any used oil filters being generated or accumulated onsite. Cloth Rags - Moffitt's Inc generates about 200 soiled cloth rags per month during maintenance cleaning. The soiled rags are collected in six metal step cans throughout the maintenance facility. Mr. Moffitt stated that the soiled rags are not used with solvents or chemicals and are nonhazardous waste based on product and process knowledge. The soiled rags are collected weekly by A&M (Spencer, Iowa), a commercial laundry service. During the visual inspection, I observed a yellow 5-gallon step can used for soiled cloth rags that was about full. The rags appeared dry to the touch (see Photo 9). 4 Disposable Paper Wipes - Moffitt's Inc. generates about 200-400 disposable paper wipes per month. The facility determines the soiled wipes to be non-hazardous waste based on product and process knowledge. Tina Sharp (Body Shop Manager) stated that the paper wipes are primarily used in the body shop area for cleaning and detailing (see Photo 13). They do not use solvents or chemicals with the wipes. The soiled wipes are dry and disposed of in the general trash. Aqueous Parts Washer Solution - Moffitt's Inc. generates a spent water-based parts washer soap solution from the single parts washer located in the Service Lane area and used in maintenance operations (see Photo 8). The facility considers the spent parts washer water-based soap solution to be non-hazardous waste based on process and product knowledge. Mr. Moffitt stated that the facility skims about one-quart of oil from the spent solution every two-months. The skimmed oil is managed as used oil and added to the used oil tanks. The remainder of the spent soap solution goes down the drain for disposal as non-hazardous waste. Spent Lead-Acid Batteries - Moffitt's Inc. generates about 15-20 spent lead-acid batteries per month from maintenance operations. The batteries are managed under 40 CFR 266 Subpart G. Spent Ford Motorcraft batteries are returned to their Motorcraft distributer for recycling. The non-Motorcraft batteries are sent to Arnold's Auto Parts (Boone, Iowa) for a core exchange. During the visual inspection, I observed one spent lead-acid battery on a shelf in the Parts Room (see Photo 10). The battery appeared to be in good condition with no obvious leaks. An additional spent battery was noted in the Service Lane floor (see Photo 9), also in good condition with no obvious leaks. Spent Tires - Moffitt's Inc. generates about 4-10 spent tires per day. The spent tires are considered non-hazardous waste based on product knowledge. Onsite, the spent tires are stored in the outside North Lot (see Photo 5) and are picked up for recycling monthly by Liberty Tire Recycling (Pittsburgh, PA) (see Attachment #10 for a September 13, 2023, invoice, 229 spent tires were shipped). Paint Booth Air Filters - Moffitt's Inc. generates an 8-foot by 20-foot paint booth air filter about once every one to three months, based on usage (see Photo 12). The paint used is water based (non-enamel) and the air filters are not considered to be hazardous waste based on product and process knowledge. The dry spent paint air filters are disposed of in the general trash. Aerosol Cans - Moffitt's Inc. generates a very small number of RCRA-empty aerosol cans per month from maintenance operations. Most of these cans appear to be non-halogenated brake cleaner (see Photo 4). This waste stream is considered non-hazardous based on product and process knowledge (see Attachment #8 for an SDS). The cans are RCRA-empty, punctured, and disposed of in the general trash. During the visual inspection, I did not observe any spent aerosol cans being generated or accumulated on-site. Scrap Metal - Moffitt's Inc. generates about 1,500 pounds of scrap metal per month. The scrap metal is processed for recycling by Pickett's Salvage (Paton, Iowa) (see Attachment #9 for invoice). During the visual inspection, I observed the scrap metal stored in a 20-cubic-yard rolloff in the North Lot, about full (see Photo 6). 5 General Trash - Moffitt's Inc. generates non-hazardous general trash from maintenance and business operations. The facility estimates it generates about one 4-cubic-yard dumpster once a week. The waste trash is picked up weekly by Walter's Sanitation (Boone, Iowa) and transported to Boone County Landfill (Boone County, Iowa). During the visual inspection I observed two 1/3 full dumpsters in the North Lot (see Photo 7). 4.4 Other Areas Reviewed Outside Facility Perimeter - I conducted a limited inspection of the outside perimeter of the facility and observed no hazardous waste storage tanks or containers except as noted above. See the aerial and map views in Attachment #1. 5.0 SUMMARY OF FINDINGS No preliminary findings or compliance issues observed at the time of the inspection. However, further EPA review may include findings. Digitally signed by MARK MARK HOLCOMB HOLCOMB (Affiliate) (Affiliate) Date: 2023.11.27 14:20:38 ______________-0_6'0_0_' _________________________ Mark Holcomb Civil Investigator, SEE Mike Martin - signing for Digitally signed by Mike Martin - signing for Amber Whisnant Amber Whisnant Date: 2024.01.30 10:35:09 -06'00' __________________________________________ Amber Whisnant RCRA Section Chief, ECAD/Chemical Branch Attachments: 1) Facility Aerial Map Views (4 pages) 2) Photo Log (13 photos and 15 pages) 3) Receipt for Documents (1 page) 4) Confidentiality Notice (l page) 5) EPA RCRA Notification Acknowledgement/Verification Report (1 page) 6) Invoice and Bill of Lading- Waste Paint and Related Materials (2 pages) 7) Bill of Lading - Used Oil (1 page) 8) SDS - Brake Cleaner (9 pages) 9) Receipt - Scrap Metal (2 pages) 10) Invoice - Scrap Tires (1 page) 6