Document baVk6EQmQ4nNQ7XojKgedeYZ1

Compliance Evaluation Inspection Report USPS Western Nassau Process & Distribution Facility & Vehicle Maintenance Facility 830 Stewart Avenue Garden City, NY March 5, 2024 Written by: X RONALD Digitally signed by RONALD LOCKWOOD LOCKWOOD 11:17:42 -04'00' Date: 2024.04.25 Enforcement Officer ECAD-CAPSB-CAS USEPA R2 Approved by: X KATHLEEN MALONEBOGUSKY Digitally signed by KATHLEEN MALONE-BOGUSKY Date: 2024.04.25 11:33:34 -04'00' Chief - Compliance Assurance Section ECAD-CAPSB-CAS USEPA R2 1 USPS Western Nassau VMF CEI Report 2024 This page has intentionally been left blank 2 USPS Western Nassau VMF CEI Report 2024 COMPLIANCE EVALUATION INSPECTION REPORT U.S. Environmental Protection Agency, Region 2 Enforcement and Compliance Assurance Division 290 Broadway, 21st floor New York, New York 10007-1866 Locational Information Facility Name: USPS Western Nassau Vehicle Maintenance Facility (VMF) Facility Address: 830-A Stewart Ave, Garden City, NY 11599-0001 Latitude & Longitude: 40.733582, -73.603274 ICIS & other Program ID Codes as appropriate FRS: 110004325089 ICIS: 1800022326 RCRA HW: NY0180000408 Sector Information Federal Facility: SIC: NAICS: Yes 4311 (U.S. Postal Service) 49111 (U.S. Postal Service) Environmental Sensitivity Information Potential Flood-Prone Area: No (See Appendix B: FEMA Flood Map) Sole Source Aquifer: Yes (See Appendix C: Sole Source Aquifer Map) Potential EJ Concerns: No (See Appendix D: EJ SCREEN) Inspection Information Date of Inspection: March 5, 2024 Inspector: Ron Lockwood Inspector-in-Training: Kevin Dyer Facility Representative(s): Name Andrew W. Tolkach Ann Marie Byrnes, CPEA Title Mgr. Vehicle Maintenance Facility Environmental Programs Analyst Phone (516) 228-7609 /7068 516-228-7502 Email andrew.w.tolkach@usps.gov annmarie.byrnes@usps.gov Corrections/Updates for EPA Databases: N/A 3 USPS Western Nassau VMF CEI Report 2024 Table of Contents 1. INTRODUCTION ........................................................................................................................ 5 2. FACILITY TOUR .......................................................................................................................... 6 3. RECORD REVIEW.......................................................................................................................7 4. CLOSING MEETING ................................................................................................................... 9 5. REGULATORY CONCERNS ......................................................................................................... 9 6. ENVIRONMENTAL ASSISTANCE .............................................................................................. 10 7. REQUESTED INFORMATION ................................................................................................... 10 APPENDICES: .............................................................................................................................. 11 A: Photographs ............................................................................................................... 11 B: FEMA Flood Map ........................................................................................................ 11 C: Sole Source Aquifer Map ............................................................................................ 11 D: EJ Screen.....................................................................................................................11 4 USPS Western Nassau VMF CEI Report 2024 1. INTRODUCTION The Region 2 office of the Environmental Protection Agency (EPA) inspected this facility to evaluate its compliance under Subtitle C (hazardous wastes) and Subtitle I (underground storage tanks) of the Resource Conservation and Recovery Act (RCRA). The last RCRA Subtitle I compliance evaluation inspection was conducted on April 24, 2018, and, under the Energy Policy Act of 2005 (EPAct), inspections of all underground storage tank (UST) facilities are required every three years. The facility has no manifests in the eManfest system and is listed as a very small quantity generator (VSQG) of hazardous wastes. A notification call was made to Ms. Byrnes the day before the inspection as she is the Environmental Programs Analyst for the U.S. Postal Service's Office of Sustainability that oversees environmental compliance at postal facilities in the New Jersey and lower New York area, including Nassau and Suffolk Counties. Inspector Ron Lockwood and Inspector-in-Training Kevin Dyer arrived at 11:00 AM, presented EPA credentials to Mr. Andrew W. Tolkach, Manager of the Vehicle Maintenance Facility, and Ms. Ann Marie Byrnes and offered in- and outbriefings, and the opportunity to claim confidential business information. Ms. Byrnes and Mr. Tolkach provided the following facility background: There are approximately 26 employees who work in two shifts starting at 4:00 AM and ending at 11:30 PM. There is one 15,000-gallon UST, which was installed in 2020 and registered with the Nassau County Department of Health in 2022. The UST is constructed of double walled fiberglass reinforced plastic (FRP) as is all the piping. All sumps and spill buckets are double walled. There are no emergency generators. Universal waste consists of fluorescent bulbs, lithium batteries and car batteries. I (Ron Lockwood) informed them that we would be visiting their universal waste storage areas as well as their UST and fuel dispensers. I let them know that we would conduct a closing meeting following the on-site portion of the inspection to discuss any concerns noted during the facility tour and to explain the next steps in the inspection process, including the issuance of this written report. At this point I concluded the opening meeting and began the facility tour. 5 USPS Western Nassau VMF CEI Report 2024 2. FACILITY TOUR Hazardous Wastes Spray Paint Booth - There is a spray booth that is used to touch up vehicles on occasion. The paints used are all water based. There were no open or used paint cans being stored at the time. There is a Safety-Kleen paint gun cleaner in the corner. The mixed spent solvent is collected in a satellite accumulation area in a 5-gallon steel double-walled (i.e., drum within a drum) container (See, Photo 1), which was labeled as "Hazardous Waste" with an accumulation start date of 4/7/22. No other information was listed on the label or provided by the facility as to what solvent is being used. The label states the solvent characteristic as flammable. The facility has not manifested any hazardous waste in over three years. Universal Wastes Lithium Batteries - Lithium batteries generated from small devices are collected in a 5-gallon pail located in a general use room (See, Photo 2). The area is clearly marked "Universal Waste Accumulation Storage Area" (See, Photo 3). There were no batteries being stored at the time of the inspection. Vehicle Batteries - These batteries are stored outside in a gated shed (i.e., no walls) with a steel roof. The batteries are stored on plastic secondary containment pallets (See, Photo 4). No signage identifying the area as a universal waste storage area was observed. The two universal waste batteries being stored on the pallets were also not labeled as universal waste. Fluorescent Lightbulbs - All bulbs are changed and managed by Cleanlites. At the time of the inspection there were no universal waste bulbs stored or awaiting pick-up. Used Oil Used oil collected from empty containers and spent filters are collected in two 55-gallon steel drums (See, Photos 5 & 6). The drums are stored on top of secondary containment plastic pallets. There was no visible signage identifying that the area is used for storing used oil. Once the containers and spent filters are drained into the 55-gallon drums, they are then transferred to a 450-gallon steel above ground storage tank (AST), which was clearly labeled "Used Oil" (See, Photo 7). The 55-gallon drums used to store used oil drained from the filters and containers were not labeled "Used Oil." Underground Storage Tanks Automatic Tank Gage - A Veeder-Root TLS-450 Plus automatic tank gauge (ATG) is installed to 6 USPS Western Nassau VMF CEI Report 2024 monitor the 15,000-gallon UST. The ATG is located in the control room across from Mr. Tolkach's office. An audible alarm sounded when the overfill alarm test was performed (See, Photo 8). The ATG displayed a "WATER WARNING" alarm in the "DEF* Annular," which has been active since 11/14/2023 at 6:20 AM (See, Photo 9). Ms. Byrnes stated the alarm was due to a rain event that caused liquid to enter the interstitial space of the tank, and the liquid could not be pumped out until proper hazardous waste removal can be performed due to the possibility of contamination with diesel fuel. No scheduled date was given for the liquid removal. *DEF consists of deionized water and urea, which help turn nitrous oxide into water and nitrogen. It is the key ingredient in starting the chemical reaction that keeps gases produced during diesel engine operation out of the environment. DEF is not regulated under the UST regulations. Fill Pipe - The fill port for the UST is located just outside the eastern facing side of the building, within a bollard-protected area of the large surface lot. The fill port utilizes double-walled containment and a coaxial stage-1 vapor recovery system (See, Photo 10). Other overfill prevention devices includes an auditory overfill alarm (See, Photo 11) and an automatic shutoff device/flapper valve (See, Photo 12). Sumps - The turbine sump for the UST is located just a couple feet south of the fill port. The sump is double walled (See, Photo 13) and contains a liquid sensor, which was propped up approximately 2 inches from the bottom of the sump (See, Photo 14). This issue was brought up with Mr. Tolkach and Ms. Byrnes and on 3/15/24 a photo showing the corrected sensor mounting was provided (See, Photo 15). Dispensers - The facility contains two diesel dispensers located just a couple dozen feet Southeast of the fill port and sump. The interiors of the dispensers both have under-dispenser containment with liquid sensors properly installed (See Photos 16 & 17) and shear valves. The system utilizes pressurized piping to the dispensers and is free from debris or liquid build-up. 3. RECORD REVIEW UST Registration - The 15,000-gallon fiberglass reinforced plastic (FRP) diesel UST was issued a registration permit by the Nassau County Department of Health (NCDOH) on 06/01/22. However, the NCDOH states the UST was put into service on 8/1/2020. UST Class A, B, C Operator Training - Operator training records were provided for all Class A, B, and C operators with the following dates for their most recent training: Class A/B Operator - Andrew Tolkach, most recent training date 9/18/2023 Class C Operators: o Stephan Ferrandino, 1/6/2022 - 26 years on job o Jason Rios, 1/6/2023 - 2 years on job 7 USPS Western Nassau VMF CEI Report 2024 o William Thomas, 1/6/2023 - 3 years on job o Havernach Davis, 1/6/2023 - 3 years on job o Paul Stankowitz, 1/30/2024 - 1 year on job Following the onsite inspection, I (Inspector Lockwood) asked Ms. Byrnes if the facility could provide training records for the Class A, B, and C operators to document they were trained when the UST Operator training requirements became effective on October 13, 2018, and/or when they assumed duties. Ms. Byrnes provided the Class A/B operator certificate for Joseph DiGenarro dated 2/2/2017. Mr. DiGenarro was the previous VMF manager prior to his retirement in 2022; at which point, Ms. Byrnes (a Class A/B operator since 11/2/2016) was the interim A/B operator until Mr. Andrew Tolkach completed his Class A/B operator training on 9/18/23. The first trained Class C operator was Mr. Stephen Farrandino, who was trained in 2017. Mr. Farrandino has been the facility's class C operator continuously since the requirement became effective. All Class C operators take an "EPACT/Underground Storage Tank (UST) Class C Operator Training" using HERO, the USPS on-line training program. The course has a 10-question exam and requires 80% correct to receive a passing grade. All initial and retraining records can be retrieved from the EPACT/UST HERO training program upon request. Note: while retraining for Class C operators is not a requirement, USPS Class C operators can "refresh" their responsibilities when deemed necessary; hence, the 2022 training date noted above for Mr. Stephen Farrandino even though he was initially trained in 2017. The facility keeps a hardcopy list of designated Class A, B, and C operators, along with training certificates for the Class A and B operators. One Class C operator, Paul Stankowitz, was absent from the printed list of facility operators. This was addressed with facility managers at the closing meeting and a corrected list was provided on 3/15/24 (See, Photo 18). Annual UST Release Detection Equipment Testing - On 3/15/2024, via email, the facility provided annual release detection equipment testing records for the last three years, dated 06/06/2023, 5/25/2022, and 5/24/2021 conducted by WildoPES (third party). The annual operability tests of the release detection method's electronic and mechanical components included: Tank (interstitial monitoring, product inventory control) ATG Emergency Shutoff Annular Sensor Sump Sensor Automatic Line Leak Detector (ALLD) Spill Bucket(s) Integrity Overfill (Drop Tube with Flapper Valve, High Level Alarms - both external and internal) Piping Sump (Containment Sump, Fill Sump, Vent Sump) Dispensers (Shear Valve, UDC Sump Sensor, Containment Sump) 8 USPS Western Nassau VMF CEI Report 2024 Passing test results for all areas are reported. Monthly UST Walkthrough Inspection Records - Walkthrough inspection records reviewed onsite; however, August 2023, November 2023, December 2023, and February 2024 were missing. The missing walkthrough inspection records were emailed on 3/15/2024; however, the August 2023 report was missing page 2. The monthly walkthrough records include the following: Overfill - high level alarm testing (outside alarms and ATG alarm). Spill Prevention/Containment - fill port obstruction, fill cap secure, sumps and spill bucket integrity and cleanliness. UST Release Detection 30-day Monitoring Records- The results of the previous 12 months of release detection monitoring for both the tank and pressurized piping are kept in a binder as well as stored in the Veeder Root System. I reviewed the paper records onsite, which showed passing results. The release detection method used for the tank as noted above is an ATG and for the piping is interstitial monitoring. 4. CLOSING MEETING Following the facility tour, Mr. Tolkach, Ms. Byrnes, Inspector-in training Kevin Dyer and I returned to Mr. Tolkachs' office for the closing meeting. We discussed our observations and areas of potential concerns (See, Section 5 below). I explained that a report will be written covering the observations of the inspection, which will be sent to them within 70 days. This concluded EPA's inspection and Mr. Dyer and I left the facility. 5. REGULATORY CONCERNS Based on observations made during the inspection and/or a review of records related to the inspection, the following regulatory concerns were identified under RCRA Subtitle C and RCRA Subtitle I: REGULATORY, STATUTORY OR PERMIT REFERENCE FIELD OBSERVATION RCRA Subtitle C 6 NYCRR 374-3.2 (e)(1) - Universal waste batteries (i.e., The two universal waste vehicle batteries being stored on the each battery), or a container in which the batteries are pallets in the gated shed were not labeled as universal waste contained, must be labeled, or marked clearly with any - batteries or waste batteries or used batteries. Also, no one of the following phrases: "universal waste - signage identifying the shed being used to store universal battery(ies)," or "waste battery(ies)," or "used waste vehicle batteries as a universal waste storage area was battery(ies)." observed. 9 USPS Western Nassau VMF CEI Report 2024 REGULATORY, STATUTORY OR PERMIT REFERENCE FIELD OBSERVATION 6 CRR-NY 374-2.3 (c)(4)(i) - Every container and The 55-gallon drums used to store used oil drained from the aboveground used oil tank used to store used oil at a filters and containers were not labeled "Used Oil" generator facility must be clearly labeled or marked with the words "Used Oil". In addition, every aboveground tank used to store oil at a generator facility must be labeled with the design capacity and working capacity of the tank. RCRA Subtitle I 40 CFR 280.35(1)(ii)(C). A liquid sensor is mounted and Liquid sensor inside double walled sump propped up remains at the lowest point in the sump. approximately 2 inches from the bottom of the sump. 40 CFR 280.245(a): Owners and operators of USTs must maintain a list of designated operators, which, at a minimum, must (1) identify all current Class A, B, and C operators for the facility; and (2) include the names, Class of operator trained, date assumed duties, date each completed initial training, and any retraining Corrective Action: On 3/15/24 a photo showing the corrected sensor mounting was provided (See, Photo 15). The facility keeps a hardcopy list of designated Class A, B, and C operators, along with training certificates for the Class A and B operator; however, at the time of the inspection, one Class C operator, Paul Stankowitz, was absent from the printed list of facility operators. Corrective Action: A corrected list was provided to EPA on 3/15/24 (See, Photo 18). 6. ENVIRONMENTAL ASSISTANCE To increase the Federal community's understanding and compliance with applicable environmental requirements, EPA, along with other Federal agencies, sponsor Fed Center, the Federal government's home for comprehensive environmental stewardship and compliance assistance information for Federal facility managers and their agencies. Fed Center can be accessed via the worldwide web at https://www.fedcenter.gov/. Also, as an owner and operator of an underground storage tank, you may want to download and review EPA's guidance document entitled "Must for USTs" at https://www.epa.gov/ust/musts-usts. 7. REQUESTED INFORMATION Below are the documents and other relevant information that EPA is requesting to complete this compliance evaluation. Once received, the information will be reviewed. 10 USPS Western Nassau VMF CEI Report 2024 The identity of the spent solvent used to clean the spray guns. No manifests submitted for over three years and the only identifier on the label indicates a flammable hazardous waste. Update on the "Water Warning" in the DEF Annular active alarm that has been active since November 14, 2023. Clarification on why there is an 8/1/2020 date for the UST being put into service but the permit date is listed as 6/1/2022. APPENDICES: A: Photographs B: FEMA Flood Map C: Sole Source Aquifer Map D: EJ Screen 11 USPS Western Nassau VMF CEI Report 2024 Photo 1 A. Photographs Photo 2 12 USPS Western Nassau VMF CEI Report 2024 Photo 3 Photo 4 13 USPS Western Nassau VMF CEI Report 2024 Photo 5 14 USPS Western Nassau VMF CEI Report 2024 Photo 6 15 USPS Western Nassau VMF CEI Report 2024 Photo 7 16 USPS Western Nassau VMF CEI Report 2024 Photo 8 17 USPS Western Nassau VMF CEI Report 2024 Photo 9 18 USPS Western Nassau VMF CEI Report 2024 Photo 10 19 USPS Western Nassau VMF CEI Report 2024 Photo 11 20 USPS Western Nassau VMF CEI Report 2024 Photo 12 21 USPS Western Nassau VMF CEI Report 2024 Photo 13 22 USPS Western Nassau VMF CEI Report 2024 Photo 14 23 USPS Western Nassau VMF CEI Report 2024 Photo 15 24 USPS Western Nassau VMF CEI Report 2024 Photo 16 25 USPS Western Nassau VMF CEI Report 2024 Photo 17 26 USPS Western Nassau VMF CEI Report 2024 Photo 18 27 USPS Western Nassau VMF CEI Report 2024 Appendix B: Federal Emergency Management Agency (FEMA) 100 Year Flood Zone and EPA's Region 2 Composite Flood Risk Layer The facility is not located within a FEMA 100-year flood zone area. 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