Document bB3YroLaqBLdqw5JpngzrkzM3

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At Safety-Kleen Systems, Inc. 4526 Towne Court Saint Charles, Missouri 63303 EPA ID Number: MOD095486342 On March 22, 2022 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assistance Division 1.0 INTRODUCTION I performed a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Safety-Kleen Systems, Inc., (Safety-Kleen) located in Saint Charles, Missouri, on March 22, 2022. I conducted the RCRA inspection under the authority of RCRA Section 3007(a), as amended, and the RCRA hazardous waste management permit issued to Safety-Kleen. During the inspection, I collected the information and data necessary to determine compliance with the applicable RCRA regulatory and statutory requirements. This report and attachments present the results of the inspection. Safety-Kleen was last inspected for compliance with RCRA on September 24, 2021, by the Missouri Department of Natural Resources (MDNR). The MDNR report was not available for review at the time of this report writing. 2.0 PARTICIPANTS Safety-Kleen Robert Dunn, Branch Manager Mori Sorenson, Vice President Environmental Compliance (exit conference) Missouri Department of Natural Resources Brandon Backus, Environmental Specialist Tyler Rowden, Environmental Specialist Brian Agenbroad, Environmental Specialist Environmental Protection Agency Region 7 Kenneth Herstowski, Environmental Engineer, ECAD/CB/RCRA (Lead Inspector) INSPECTION PROCEDURES Prior to arriving at Safety-Kleen, I rallied with Messrs. Backus, Agenbroad and Rowden at an offsite location. At about 07:59, we arrived at Safety-Kleen. A drive-by visual observation was completed from Towne Court with no findings. We proceeded to the Safety-Kleen office to ask for Mr. Dunn as the facility contact. Mr. Dunn arrived shortly thereafter, and Messrs. Backus, Agenbroad and Rowden and I introduced ourselves and explained the purpose of the visit was to conduct a RCRA CEI. We adjourned to a meeting area where I proceeded with the entrance conference. I explained the purpose and procedures of the RCRA CEI to Mr. Dunn. I provided a copy of RCRA Section 3007 which provides inspection authority. I presented Mr. Dunn with a copy of Title 18 United States Code, Sections 1001 and 1002, which provides for penalties if false and/or misleading information is provided to Federal representatives, and for the possession and use of fraudulent documents. Mr. Dunn was made aware of his confidentiality rights and was informed that a Confidentiality Notice would be provided at the end of the inspection for them to make a confidential business information claim. Mr. Dunn acted as the primary facility representative during the inspection. I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.1D), unless noted differently. I completed checklists and other inspection related documents and collected photocopies that are included as attachments to this report. I collected six photographs with a digital camera and prepared a photographic log (attachments 1and 2). I monitored for volatile organic emissions with a Thermo Fisher Scientific TVA2020 organic vapor analyzer utilizing a flame ionization detector (hereafter referred to as the "EPA FID"). I viewed potential volatile emission points with an optical gas imaging camera (a FLIR model GF320 - hereafter the "EPA Gas Imaging Camera"). I obtained copies of records from the facility as detailed in the sections that follow. During the inspection, discussions consisted of the facility operations, wastes generated, waste management practices, and an evaluation of RCRA air emissions compliance. I conducted a visual inspection of the hazardous waste storage tank including ancillary equipment and facilities and the two hazardous waste container storage areas. I obtained aerial photographs of the facility using Google Earth (attachment 3) and a facility map (attachment 4). A Notice of Preliminary Findings (NOPF) was issued to the facility at the conclusion of the inspection (attachment 5). Documents and records were collected during the inspection and a Receipt for Documents and Samples was prepared and signed by Mr. Dunn (attachment 6). A Confidentiality Notice in which the facility did not claim any records or documents as confidential business information was prepared and signed by Mr. Dunn (attachment 7). A site-specific inspection checklist was prepared and completed. March 22, 2022 At about 07:59, Messrs. Backus, Agenbroad and Rowden and I arrived at the Safety-Kleen facility and conducted a drive by inspection. No issues were identified from the drive by inspection. We proceeded to the facility parking lot and entered the office entrance. I introduced myself, stated our purpose to conduct a RCRA CEI, and asked to see Mr. Dunn. Mr. Dunn was summoned and arrived shortly after. We introduced ourselves to Mr. Dunn and stated the purpose of the visit was to conduct a RCRA CEI. We adjourned to a meeting area for the opening conference. I presented my EPA credentials and Messrs. Backus, Agenbroad and Rowden presented their identification. I explained the purpose and procedures of the inspection. After the entrance discussions, Messrs. Backus, Agenbroad and Rowden and I conducted a visual inspection of the facility. Mr. Dunn accompanied us during the visual inspection. The areas reviewed included: 2 x Spent solvent return and fill area. x Hazardous waste storage tank. x Hazardous waste container storage area. x Hazardous waste flammable storage area x Used oil filter drums and bins. Following the visual inspection, I requested and reviewed records (attachment 8). After completing the records review, I summarized my findings and recommendations in an exit conference with Messrs. Dunn and Sorenson. I provided Mr. Dunn with a Confidentiality Notice and a Receipt for Documents and Samples which he signed as acknowledgement of receipt. I provided Mr. Dunn with a copy of the Confidentiality Notice (yellow copy of the completed carbonless transfer set) and Receipt of Documents and Samples (yellow copy of the completed carbonless transfer set). I reviewed and discussed my findings detailed in the NOPF. I provided Mr. Dunn the NOPF which he signed as acknowledgement of receipt. I provided a copy of the NOPF with "Instructions for Responding to a Notice of Preliminary Findings (NOPF)" printed on the reverse of the copy to Mr. Dunn (yellow copy of the completed carbonless transfer set). I discussed providing a response to the NOPF. I described my process and timeline for converting field and record review observations into an inspection report. I provided and discussed compliance assistance information. 3.0 FINDINGS AND OBSERVATIONS 3.1 General Information/Facility Description Safety-Kleen is located in Saint Charles, Missouri, in an area zoned for commercial use. Residences are approximately 0.1 mile1 southwest, 0.13 mile east, and 0.15 mile southeast. The site is approximately 2 acres. The site has three buildings (attachment 3). One approximately 7,115 square foot building contains offices and product storage, the second approximately 4,000 square foot building is a warehouse for product storage and a hazardous waste storage area, and the third is a standalone structure for hazardous waste storage. The site has two tank farms. One contains the hazardous waste storage tank, one clean mineral spirits parts washer solvent tank and one out of service used oil tank. Adjacent to this tank farm is the solvent return and fill dock. The second tank farm contains four out of service used oil/oily water tanks. Mr. Dunn stated the facility stopped providing bulk used oil services some time before 2021. The facility is surrounded by security fencing with locked access gates. Safety-Kleen is a wholly owned subsidiary of Clean Harbors, Inc. Clean Harbors through the Safety-Kleen brand offers an array of environmental services and complementary products to a range of customers including automobile repair shops, car and truck dealers, metal fabricators, machine manufacturers, fleet maintenance shops and other automotive, industrial, and retail customers. Safety-Kleen business offers a line of specially designed parts washers to customer locations and then delivers recurring service that includes machine cleaning and maintenance and the disposal of the spent solvent. Safety-Kleen picks up and transports hazardous and nonhazardous containerized waste for recycling or disposal, primarily through Clean Harbors' network of recycling and waste treatment and disposal facilities. Safety-Kleen collects used oil filters for recycling. At the Saint Charles facility, the core activities include distribution of parts washer machinery and degreasing solvents and washes, paint solvents, collection of spent parts washer solvent and washes, used oil filter collection, and containerized waste services (photographic wastes, spent paint solvents and paint wastes, dry 1 Distances and areas estimated using Google Earth Pro 3 cleaning wastes, and spent carburetor cleaners). The Saint Charles facility operates a less than 10-day transfer facility for containerized hazardous waste within the warehouse hazardous waste storage area. 3.2 RCRA Status The Notification Acknowledgement/Verification Report (attachment 9) indicates that Safety-Kleen is a large quantity generator of hazardous waste, a hazardous waste transfer facility, and a treatment/storage/disposal facility. Additionally, Safety-Kleen is a small quantity handler of universal waste. Safety-Kleen was issued the current RCRA hazardous waste management permit (RCRA Permit) for storage of hazardous wastes at two container storage areas and in one above ground storage tank on December 17, 2019. The RCRA Permit will expire December 16, 2029, unless an application for a new hazardous waste permit is submitted in accordance with 40 Code of Federal Regulation (CFR) 270.51. 3.3 Hazardous Waste Streams and Management Safety-Kleen generates hazardous wastes which exhibit one or more hazardous waste characteristics of ignitability, corrosivity, or toxicity. The EPA hazardous waste codes managed by Safety-Kleen are shown on the Notification Acknowledgement/Verification Report (attachment 9). Mr. Dunn did not identify changes to the information in the Notification Acknowledgement/Verification Report during this inspection. The following table summarizes the wastes with the highest generation rates. Waste Stream and Waste Handling Table: Safety-Kleen Systems, Inc. - Saint Charles, MO Name of Waste Stream 1) Spent Solvent 2) Branch Debris Generating Process Pickup of spent solvent from customers; in drums bulked into hazardous waste storage tank Dumpster Sludge, adsorbents, rags and personal protective equipment waste from customer pickups and onsite waste management Hazardous Determination Hazardous (D001, D018, D039, D040) by product/process knowledge and/or testing Estimated Annual Generation Rate 376.09 tons (2021) Hazardous waste D001, D004 -, D011, D018, D019, D021 D030, D032 D043, F002, F003, F005 150 pounds (2021) product/process knowledge and/or testing On-Site Management Off-Site Management Stored in 15,000-gallon hazardous waste tank upon receipt; shipped offsite about every two months Safety-Kleen Dolton, IL ILD980613913 (recycling) 55-gallon satellite accumulation drum at return/fill dock, transferred to container storage area when full; shipped offsite Clean Harbors Environmental Systems, Inc., Kimball, NE NED981723513 (incineration) 4 Safety-Kleen annually recharacterizes hazardous wastes in accordance with a waste analysis plan in the RCRA Permit. The annual recharacterization completed each year is used as the basis for the hazardous waste codes used in the following year. I obtained the hazardous waste recharacterization reports for 2020, 2021, and 2022 (attachment 10). I observed no apparent issues or findings related to hazardous waste characterization. Safety-Kleen is a small quantity handler of universal waste which is discussed in Section 3.11. Safety-Kleen manages used oil filters collected from customer which is discussed in Section 3.12. 3.4 Container Storage Area The Container Storage Area is located at the southern half of the warehouse (attachment 4). The RCRA Permit Container Storage Area capacity limit is 4,280 gallons. Messrs. Backus, Agenbroad and Rowden and I visually inspected the Container Storage Area on March 22, 2022, accompanied by Mr. Dunn. I observed containers of unused products, hazardous and non-hazardous waste in the Container Storage Area. Mr. Dunn stated that the waste paint solvent containers (photograph 5, attachment 1) against the south wall of the Container Storage Area were in storage and the other observed containers of hazardous and non-hazardous waste were transfer wastes. All observed containers of hazardous waste were closed, labeled with "Hazardous Waste," and in good condition. I visually inspected the condition of the secondary containment which was in good condition. I observed the secondary containment collection sumps were free of liquids. I observed a telephone that can be used to summon assistance, a spill kit and fire extinguishers. I observed "No Smoking" signs at the exterior entrance to the Container Storage Area. I observed no apparent issues or findings related to the Container Storage Area. See Section 3.10.1 for the discussion of air emission requirements for the Container Storage Area. 3.5 Flammable Storage Shed The Flammable Storage Shed is a covered and enclosed structure located at the south end of the warehouse (attachment 4). The RCRA Permit Flammable Storage Shed capacity limit is 2,186 gallons. Messrs. Backus, Agenbroad and Rowden and I visually inspected the Flammable Storage Shed on March 22, 2022, accompanied by Mr. Dunn. No waste containers were present (photograph 3, attachment 1). I observed the secondary containment collection sumps were free of liquids. I observed an alarm button that can be used to summon assistance, a spill kit and fire extinguishers. I observed "No Smoking" signs at the exterior entrance to the Flammable Storage Shed. I observed no apparent issues or findings related to the Flammable Storage Shed. 3.6 Used Mineral Spirits Tank The Used Mineral Spirits Tank stores hazardous waste and is located in a tank farm with two other above ground tanks on the southeast portion of the facility (attachment 4). The three tanks are all within single concrete secondary containment. The middle tank in the tank farm is used to store bulk parts washer [mineral spirits] solvent. The tank at the east end of the tank farm was used to store used oil but is out of service according to Mr. Dunn. The Used Mineral Spirits Tank is an above ground storage tank and is located in the 5 west end of the tank farm. Piping to transfer hazardous waste into the tank from the spent solvent return dumpster is above ground between the return/fill dock and the tank farm and is insulated. The Hazardous Waste Tank is a vertical carbon steel fixed roof tank designed and constructed to Underwriter Laboratories Standard 142. The tank is nominally 15,000 gallons capacity with a maximum working capacity of 14,250 gallons corresponding to a liquid level of 22 feet. The tank has a flat top and bottom and is installed on a beam supports to elevate the bottom of the tank from the secondary containment. The tank has two 24-inch manways for access into the tank - one shell manway near the base of the tank and one manway in the roof of the tank and various threaded couplings for equipment and piping connections. The tank is equipped with a pressure/vacuum vent located on the roof of the tank to relieve pressure from working and breathing losses. The 24-inch manway on the top of the tank is gasketed and is provided with 4-inch-long shoulder bolts to allow for emergency venting of the tank. The Used Mineral Spirits Tank has no ladder or other means to access the top of the tank. The tank is equipped with mechanical [tape] level indicator and buzzer and strobe light high-level alarm. Hazardous waste is pumped into the hazardous waste storage tank from the spent solvent return dumpster through a fill pipe extending through the top of the tank. Hazardous waste is removed from the hazardous waste storage tank via piping attached near the base of the tank. The Used Mineral Spirits Tank was last inspected for tank integrity on April 1, 2021 (attachment 11). Messrs. Backus, Agenbroad and Rowden and I visually inspected the Used Mineral Spirits Tank and Return/Fill Dock on March 22, 2022. We were accompanied by Mr. Dunn. Mr. Dunn stated that the Used Mineral Spirits Tank had been emptied the previous day and a contractor was on site to conduct tank entry and maintenance/repair. The contractor's safety zone prevented us from conducting close inspection of the Used Mineral Spirits Tank and Return/Fill Dock. I did observe the tank was labeled "Hazardous Waste" and that water was present in the secondary containment from a rain storm the previous night. I observed no apparent issues or findings related to the Used Mineral Spirits Tank. See Sections 3.8 and 3.10.2 for the discussion of air emission requirements for the Used Mineral Spirits Tank. 3.7 Satellite Accumulation in Containers Safety-Kleen has one Satellite Accumulation2 container located adjacent to the spent solvent return dumpsters. One container is used for sludge removed from the sump in the spent solvent return dumpster which is referred to as "dumpster sludge," absorbents, rags, and personal protective equipment. When full, satellite accumulation container is transferred to the Container Storage Area for subsequent shipment off site. Messrs. Backus, Agenbroad and Rowden and I visually inspected the Branch Debris Satellite Accumulation Container on March 22, 2022. We were accompanied by Mr. Dunn. 2 Satellite accumulation is a term of art for the situation where the generator accumulates hazardous waste in containers at or near any point of hazardous waste generation. The pertinent requirements are found at 40 CFR 262.34(c)(1), et seq. (10 CSR 25-5.262(1)). 6 Notice of Preliminary Finding (NOPF) 1 - 40 CFR 265.173(a): Satellite Accumulation container not closed. 10 CSR 26-5.262(1) &)5c)(1)(i) The State of Missouri has adopted by reference the EPA's requirements for generators of hazardous waste found at 40 Code of Federal Regulations (CFR) Part 2623. The requirement at 40 CFR 262.34(c)(1)(i) allow generators to accumulate up to 55 gallons hazardous waste in containers at or near the point of generation Satellite Accumulation. In accordance with 40 CFR 262.34(c)(1)(i), Satellite Accumulation must comply, in pertinent part, "...with 265.171, 265.172, and 265.173(a) of this chapter" The requirement at 40 CFR 265.173(a) found in 40 CFR Part 265, Subpart I, Use and Management of Containers, requires "A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste." I observed the Branch Debris container located on the Return/Fill Dock. The container was a 55-gallon open head drum provided with a latching style lid for the addition of hazardous waste into the container. The lid included three pull down/toggle style latches that were not closed/latched (photograph 2, attachment 1). The container was in good condition and labeled "Hazardous Waste" (note the label is not visible in the photograph on the right side of the container). Mr. Dunn directed his warehouse man to close the container. I returned to view the closed container after the exit conference with Mr. Dunn. I observed two of the three latches were closed. I observed the third latch located on the front of the lid was missing the shackle that provides the closure for the lid (photograph 6, attachment 1). 3.8 Subpart BB Leak Detection and Repair The EPA promulgated requirements for the control of air emissions from equipment leaks at 40 CFR Part 265, Subpart BB (hereafter "Subpart BB"). The State of Missouri has adopted by reference the EPA's requirements for owners and operators of hazardous waste treatment, storage, and disposal facilities found at 40 CFR Part 2654. Safety-Kleen, as a large quantity generator of hazardous waste, is subject to the requirements of Subpart BB. I requested the current list of equipment subject to Subpart BB. Mr. Dunn provided an isometric drawing of the Used Mineral Spirits Tank that included a Subpart BB equipment listing (attachment 12). Safety-Kleen has determined the used mineral spirits is a heavy liquid (attachment 13). As such, the equipment is subject to visual inspection for visual, audible, or olfactory evidence of leaking. Safety-Kleen conducts daily visual inspection of the Subpart BB equipment for leaks. Messrs. Backus, Agenbroad and Rowden and I visually inspected the Subpart BB equipment associated with the Used Mineral Spirits Tank on March 22, 2022. We were accompanied by Mr. Dunn. Mr. Dunn stated that the Used Mineral Spirits Tank had been emptied the previous day and a contractor was on site to conduct tank entry and maintenance/repair. The contractor's safety zone prevented us from conducting close inspection and monitoring of the Used Mineral Spirits Tank subpart BB equipment. I did observe the pump used to transfer hazardous waste from the Return/Fill Dock into the Used Mineral Spirits Tank (photograph 1, attachment 1). I did not observe visual evidence of a leak at the pump. I observed equipment identification tags on the Subpart BB equipment at this location. 3 See 10 CSR 25-5.262, Standards Applicable to Generators of Hazardous Waste, incorporating by reference the requirements in 40 CFR Part 262, July 1, 2013. 4 See 10 CSR 25-7.265(1) which incorporates by reference 40 CFR Part 265, Subpart BB- Air Emission Standards for Equipment Leaks. Missouri has adopted the provisions of 40 CFR Part 265, as in effect on July 1, 2013. 7 I observed no apparent issues or findings related to Subpart BB for equipment associated with the Used Mineral Spirits Tank. 3.9 Method 21 Monitoring I calibrated a Thermo Fisher Scientific TVA-2020 (EPA FID) (attachment 14) and MDNR personnel calibrated a Thermo Fisher Scientific TVA-2020 (MDNR FID) used for Method 215 monitoring the morning of March 22, 2022, prior to our arrival at the facility. Both the EPA FID and MDNR FID have a flame ionization detector and a photoionization detector to measure organic vapor concentrations. Only the flame ionization detector was calibrated and operated for the Method 21 monitoring, i.e., the photoionization detector was switched off. 3.10 Subpart CC Air Emissions The EPA promulgated requirements for the control of air emissions from tanks, surface impoundments, and containers at 40 CFR Part 264, Subpart CC (hereafter "Subpart CC"). The State of Missouri has adopted by reference the EPA's requirements for owners and operators of hazardous waste treatment, storage, and disposal facilities found at 40 CFR Part 2646. 3.10.1 Containers Safety-Kleen is subject to Subpart CC for containers used to store or accumulate hazardous waste with a volatile organic concentration of 500 ppm or greater. The required air emission controls are specified in 40 CFR Part 264, Subpart CC, and Special Permit Condition V, Air Emission Standards for Tanks and Containers [40 C.F.R. Part 264, Subpart (sic) BB and CC], of the RCRA Permit. Messrs. Backus, Agenbroad and Rowden and I visually inspected the Container Storage Area on March 22, 2022, accompanied by Mr. Dunn. I observed seven hazardous waste containers in Container Storage Area (photograph 5, attachment 1). The volume of the observed containers was less than 0.1 cubic meters. Such containers do not have specific design or operational requirement for air emission controls pursuant to 40 CFR 264.1086. I observed no apparent issues or findings related to Subpart CC for the observed seven containers of hazardous waste stored in the Container Storage Area. 3.10.2 Tanks Safety-Kleen is subject to Subpart CC for tanks used to store or accumulate hazardous waste with a volatile organic concentration of 500 ppm or greater. The required air emission controls are specified in 40 CFR Part 264, Subpart CC, and Special Permit Condition V, Air Emission Standards for Tanks and Containers [40 C.F.R. Part 264, Subpart (sic) BB and CC], of the RCRA Permit. The hazardous waste tank is required to comply with Tank Level 1 controls. The hazardous waste tank has a capacity of 15,000 gallons. I obtained Safety-Kleen's determination of the vapor pressure of the spent solvent (attachment 13). Level 1 controls are applicable to tanks with capacity less than 75 m3 (19,812.9 gallons) that store waste with vapor pressure less than 76.6 kilopascals. 5 Method 21 - Determination of Volatile Organic Compound Leaks is found at 40 CFR Part 60, Appendix A. 6 See 10 CSR 25-7.264(1), Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities, which incorporates by reference 40 CFR Part 264, Subpart CC - Air Emission Standards for Containers. Missouri has adopted the provisions of 40 CFR Part 264, as in effect on July 1, 2013. 8 The hazardous waste tank does not have a means of access to inspect the top of the tank therefore I was unable to visually inspect the top of the tank. The equipment located on the top of the tank includes an emergency vent, conservation (pressure/vacuum) vent, waste piping attachment and tank level equipment. Safety-Kleen is required to inspect the top of the tank once per year 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. Potential NOPF - 40 CFR 264.1084(c)(4)(iv): No documentation of annual Subpart CC tank inspections. RCRA Permit Condition V.B Special Permit Condition V.B requires "The Permittee shall comply with the applicable requirements of 40 C.F.R. Part 264 Subpart CC, for all units identified in Table 3." Table 1 - Units Subject to Subpart CC Standards Unit Identification Unit Type Subpart CC Control Option Used Mineral Spirits Tank Aboveground Storage Tank Tank Level 1 Container Storage Area Container Storage Area Container Level 1 Flammable Storage Shed Container Storage Area Container Level 1 The requirements applicable to Level 1 tanks are found at 40 CFR 264.1084(c) which include, inter alia, annual visual inspection of the tank fixed roof and closure devices 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. The requirement at 40 CFR 40 CFR 264.1084(c)(4)(iv) requires "The owner or operator shall maintain a record of the inspection in accordance with the requirements specified in 264.1089(b)..." I requested copies of the last three annual Subpart CC inspection records for the Used Mineral Spirits Tank. Mr. Dunn was not able to provide the record at the time of my site visit. In the exit conference, Mr. Dunn stated he would email the requested records to me. At the time of the writing of this report, the requested records have not been received. 3.11 Universal Waste The Saint Charles facility is a small quantity handler of universal waste and universal waste transporter. SafetyKleen collects universal waste from customer facilities, transports and stores the universal waste at the Saint Charles facility and ships the waste to a destination facility. Mr. Dunn stated that the Saint Charles facility does not generate any onsite universal waste. Messrs. Backus, Agenbroad and Rowden and I visually inspected the Container Storage Area on March 22, 2022. We were accompanied by Mr. Dunn. I observed one container of universal waste lamps. The container was a box containing four-foot fluorescent lamps. The universal waste container was in good condition, closed and labeled with the universe waste contents. I observed no apparent issues or findings related to the management of universal waste lamps. 9 3.12 Used Oil Mr. Dunn stated that the Saint Charles stopped collecting used oil and oily wastewater from customer facilities some time prior to his employment at the facility, i.e., before 2021. Mr. Dunn stated the facility continues to collect and manage used oil filters at the Saint Charles facility. 55-gallon metal open head drums are provided to customers in which the customer can accumulate the used oil filters. Safety-Kleen collects the filled drums from customers transporting them to the Saint Charles facility. The drums of used oil filters are stored in the southeast area of the facility (east of the tank farm containing the Spent Mineral Spirits Tank) (attachment 3). Also located in this area are bulk containers into which the drums of used oil filters are emptied for offsite shipment (photograph 4, attachment 1). Messrs. Backus, Agenbroad and Rowden and I visually inspected the Container Storage Area on March 22, 2022. We were accompanied by Mr. Dunn. I observed fifteen 55-gallon drums of used oil filters and six bulk used oil filter containers (note that the first five containers in the photograph contained used oil filters). The containers were in good condition and labeled "Used Oil." I observed no apparent issues or findings related to the management of used oil filters. 3.13 Hazardous Waste Transporter Transfer Facility Safety-Kleen operates a hazardous waste transfer facility in the Container Storage Area (attachment 3). Pursuant to 40 CFR 263.127, transporters who store manifested shipments of hazardous waste for less than ten days can do so without a hazardous waste permit. Safety-Kleen transports hazardous waste in Safety-Kleen operated vehicles using EPA RCRA transporter identification number TXR000081205 (attachment 15). Messrs. Backus, Agenbroad and Rowden and I visually inspected the Container Storage Area on March 22, 2022. We were accompanied by Mr. Dunn. I observed the containers of transfer waste in the Container Storage Area. The containers were closed, labeled "Hazardous Waste," included the required generator information and United States Department of Transportation hazardous material marking consistent with the contents. The containers had Clean Harbors tracking labels attached to each of them that include bar coding that tracks the movement of the containers in the Safety-Kleen operating record. Mr. Backus and I reviewed the transporter manifests for waste shipments in 2022. Safety-Kleen was identified as the transporter on the manifests and had signed the manifest when the waste was consigned to Safety-Kleen. I obtained a copy of the manifest that were last shipped off site on March 17, 2022 (attachment 16). I observed no apparent issues or findings related to hazardous waste transporter requirements. 3.14 Inspections Safety-Kleen conducts inspections of the facility in accordance with an inspection schedule in the RCRA permit. The inspections are electronically recorded and uploaded to the Clean Harbors inspection system for storage and retrieval. I obtained a log of the inspections conducted for the period of September 24, 2021, through March 21, 2022 (attachment 17). I obtained copies of the electronic inspection checklists for March 21, 7 See 10 CSR 25-6.263, Standards for Transporters of Hazardous Waste, which incorporates by reference 40 CFR Part 263, Standards Applicable to Transporters of Hazardous Waste, as in effect on July 1, 2013. 10 2022 (attachment 18). Occasionally the electronic checklist cannot be completed and instead a paper checklist is used. I obtained copies of the paper checklists utilized in March 2022 (attachment 19). I observed no apparent issues or findings related to my review of inspection records. 3.15 Contingency Plan I asked Mr. Dunn if the contingency plan had been implemented or updated since the MDNR inspection of September 24, 2021. Mr. Dunn stated that neither event had occurred. I reviewed the contingency plan while I was on site on March 22, 2022. I observed no apparent issues or findings related to my review of the contingency plan. 3.16 Training Requirements Safety-Kleen has hired one new person since the September 24, 2021, CEI by MDNR. I observed that person in training at the time of my inspection. Mr. Dunn stated that the 2022 annual RCRA refresher training was planned for the end of March 2022. Initial and refresher training is done remotely located trainer and may be done individually or in a small group at the Saint Charles facility. I observed no apparent issues or findings related to my review of personnel training. 3.17 Manifests I discussed hazardous waste manifest recordkeeping with Mr. Dunn. Safety-Kleen maintains copies of hazardous waste manifests on site. These include manifests where Safety-Kleen is the generator, the designated treatment, storage, and disposal facility (TSDF), and the initial transporter. Since June 30, 2018, the Saint Charles facility has submitted TSDF manifests to the EPA's E-Manifest system. I reviewed the manifest information in the E-Manifest system from June 15, 2021, through March 22, 2022. I observed no apparent issues or findings related to my review of Safety-Kleen's hazardous waste manifests. 4.0 COMPLIANCE ASSISTANCE I provided Safety-Kleen with the following compliance assistance information: Section 3007 Inspections Sheet (EPA Handout) RCRA Facility Access Information Sheet (EPA Handout) United States Code 1001/1002 Annotated (EPA Handout) Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections (EPA Handout) U.S. EPA Small Business Resource Information Sheet (EPA Handout) Tampering Pollutes Our Air (EPA Handout) Clean Air Act Vehicle Aftermarket Defeat Devices and Tampering (EPA Handout) EPA Enforcement Alert National Compliance Initiative Focus on RCRA Air Emissions JXQH (EPA Handout) COMPLIANCE ADVISORY Reduction of Hazardous Waste Air Emissions April 2018 (EPA Handout) Leak Detection and Repair: A Best Practices Guide (EPA Handout) 11 5.0 SUMMARY I conducted an inspection of Safety-Kleen as a large quantity generator of hazardous waste, a treatment/storage/disposal facility, transfer facility, small quantity handler of universal waste, and used oil transfer facility. The following preliminary finding is noted as discussed above: Notice of Preliminary Finding (NOPF) 1 - 40 CFR 265.173(a): Satellite Accumulation container not closed. 10 CSR 26-5.262(1) &)5c)(1)(i) Potential NOPF - 40 CFR 264.1084(c)(4)(iv): No documentation of annual Subpart CC tank inspections. RCRA Permit Condition V.B Other than the items noted above, no other preliminary findings were noted. However, the EPA may review my findings further after the inspection, which may change or add to my findings. Remainder of page intentionally blank 12 Digitally signed by KENNETH KENNETH HERSTOWSKI HERSTOWSKI Date: 2022.03.28 08:19:49 -05'00' _______________________________________________________________ Kenneth Herstowski Date Environmental Engineer ________________________________________________________________ Amber Whisnant Date Chief, RCRA Section, Chemical Branch Enforcement and Compliance Assistance Division Attachments 1. Inspection [6] Photographs (7 pages) 2. Photograph Log (1 page) 3. Safety-Kleen Aerial Photographs (3 pages) 4. Safety-Kleen Facility Map (2 pages) 5. Notice of Preliminary Findings (2 pages) 6. Receipt for Documents (1 page) 7. Confidentiality Notice (1 page) 8. Records Request (2 pages) 9. Notification Acknowledgement/Verification Report (1 page) 10. Annual Recharacterization Reports (3 pages) 11. Hazardous Waste Tank Report (31 pages) 12. Used Mineral Spirits Tank Isometric Drawing (1 page) 13. Used Mineral Spirits Heavy Liquid and Vapor Pressure Determination (33 pages) 14. EPA FID Calibration (1 page) 15. Safety-Kleen Transport EPA ID Number (1 page) 16. Transfer Waste Manifests (20 pages) 17. Inspection Log (61 pages) 18. Electronic Inspection Checklists (21 pages) 19. Paper Inspection Checklists (9 pages) 13