Document byYOepyg3dzYKk0zdmnY5JOz1
REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION
At
Lloyd Inc. 604 W Thomas Ave Shenandoah, Iowa 51601
(712) 246-4000
EPA ID Number: IAR000505230
On
June 16, 2022
By
Eastern Research Group, Inc.
For
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/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U.S. Environmental Protection Agency (EPA) Region 7, Eastern Research Group, Inc. (ERG) conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Lloyd Inc. (LI) in Shenandoah, Iowa on June 16, 2022. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. Throughout the CEI, data and information were collected to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI.
2.0 PARTICIPANTS
Lloyd Inc.: Roger Buhman, Senior Scientist Research and Development
EPA Representative, ERG: Janosh Wolters, Energy Engineer
3.0 INSPECTION PRECEDURES
After arriving unannounced at LI at approximately 08:50, I performed a drive-by visual inspection of the facility and took a photograph before beginning the inspection and did not note any areas of concern. I then entered the main entrance and introduced myself to the front desk attendant. I explained my reason for being on site is to conduct a RCRA CEI and asked to meet with the facility personnel who manages hazardous waste on site. I was immediately met with Mr. Buhman, Senior Scientist of Research and Development. Mr. Buhman guided me to his office to begin the opening conference. I initiated the opening conference with Mr. Buhman present as LI's representative. I presented Mr. Buhman with my inspector credentials and business card, as well as the business card of the EPA Task Order Contracting Officer Representative, Mr. Trevor Urban. I then presented a copy of RCRA Section 3007(a), which contains EPA's inspection authority. I explained my need to collect accurate information and presented them with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I then presented Mr. Buhman with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed LI's confidentiality rights. I informed Mr. Buhman that I would provide a Confidentiality Notice at the end of this inspection.
The inspection consisted of a discussion of facility operations, waste generation and waste management, a review of waste management records, and a visual inspection of the waste generation and management areas. Mr. Buhman provided a facility layout (see Attachment 1) and explained facility operations and locations of hazardous waste generation and management.
During the visual inspection of the facility, Mr. Buhman guided me throughout the facility in order to conduct thorough evaluations of the facility's areas generating, accumulating hazardous waste, and the laboratory area. The facility consists of one laboratory which generates all the facility's hazardous waste. At the time of the inspection, the facility was not accumulating any universal waste. I conducted an in-depth visual inspection of the hazardous waste accumulation containers, and facility areas.
Five photographs were collected as inspection documentation and are shown in Attachments 2 and 3. Information collected during the inspection is documented on the EPA Inspection Checklist (see Attachment 4). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.01D), unless noted differently. At the conclusion of the inspection, I provided Mr. Buhman with a Confidentiality Notice and Receipt for Documents and Samples which he signed as acknowledgement of receipt (see Attachments 5 and 6, respectively). No confidentiality claims were made by LI.
The following inspection documents and compliance assistance handouts were left with LI:
RCRA Section 3007(a) Title 18 U.S. Code, Sections 1001 and 1002 Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by
EPA in Connection with Inspections Confidentiality Notice (Facility copy)
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Receipt of Documents and Samples (Facility copy) Security Awareness Commercial Motor Vehicle Transportation Security Planning EPA E-Manifest Fact Sheet U.S. EPA Small Business Resources U.S. EPA Publication, Managing Your Hazardous Waste U.S. EPA Publication, Managing Used Oil-Advice for Small Businesses PowerPoint Presentation, 2013 Solvent Wipes Final Rule Pollution Engineering Article, 10 Common Questions for Waste Generators Iowa Department of Natural Resources (IDNR) Waste Exchange Folder and P2 Brochures IDNR Management of Fluorescent Lamps for Businesses Information Sheets IDNR Aerosol Can Disposal for Businesses Information Sheet University of Northern Iowa Waste Reduction Center Information Card Solvent-Contaminated Wipes Final Rule Summary Chart
4.0 FINDINGS AND OBSERVATIONS
Facility Information and Operations
LI began operating in 1964 and currently employs approximately 80 people. The facility operates a single, eight-hour shift, Monday through Friday. The facility has a footprint of approximately 22,000 square feet. LI's operations consist of testing pharmaceutical products. The major raw materials used are water, methanol, and acetonitrile. The only processing operation that generates waste streams is laboratory testing. The following waste streams are produced: flammable liquids, methylene chloride, pyridine, lead, perchloric acid, potassium ferricyanide, and general trash.
4.2 RCRA Status
According to the Hazardous Waste Site Info Verification Report for Inspector (see Attachment 7), LI notified on September 1, 2005 as a federal very small quantity generator (VSQG) of P075, P108, U002, U003, U019, U044, U080, U112, U117, U123, U151, U154, U161, U218, and U220 hazardous wastes. I asked Mr. Buhman to review the Hazardous Waste Site Info Verification Report for Inspector, which I provided prior to records review and visual inspection of the waste generation areas. To the best of his knowledge, Mr. Buhman believed the form was accurate and he did not request any changes or updates. After reviewing the records and walking through the facility, it appears that the facility is operating as a very small quantity generator (VSQG) of D001, D002, D008, D038, U192, and F002 hazardous wastes, and potentially a small quantity handler (SQH) of universal waste. LI waste codes can vary based on the types of chemicals used in analytical testing. The above listed waste codes were the codes I observed the facility generating based on records review from the previous three years. LI generated approximately 630 pounds of hazardous waste per year for the past three years.
LI was previously inspected by an EPA contractor on June 14, 2005. The inspection led to a notice of preliminary findings (NOPFs). The findings were later retracted and no enforcement
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actions were taken by EPA. 4.3 Facility Waste Streams and Management
A Waste Stream and Waste Handling Table for LI is presented below. The table describes waste streams generated, generation process/rates, hazardous waste determinations, and on-site/off-site management. The rest of this page left blank intentionally.
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WASTE
GENERATION HAZARDOUS
ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
WASTE
GENERATION MANAGEMENT
#
DETERMINATION RATE
1
Flammable
Laboratory
D001 (based on process 50 pounds per 55-gallon
Barton Solvents Inc,
Liquids
testing
knowledge and
month
container
(IAD089570063) in Council
(Acetonitrile,
knowledge of the
Bluffs, IA to Coal City Cob
Methanol)
product)
Company, Inc
(TXR000079839) in
Waxahachie, TX to WRR
Environmental Services
(WID990829475) in Eau Clair,
WI for incineration
2
Methylene
Laboratory
F002 (based on process 3 gallons per
1-liter containers, Barton Solvents Inc,
Chloride
testing
knowledge and
year
consolidated into a (IAD089570063) in Council
knowledge of the
15-gallon
Bluffs, IA to Coal City Cob
product)
container
Company, Inc
(TXR000079839) in
Waxahachie, TX to WRR
Environmental Services
(WID990829475) in Eau Clair,
WI for incineration
2
Pyridine/Corrosi Laboratory
D001, D002, D038,
25 pounds per 15-gallon container Clean Harbors Environmental
ve Wastes
testing
U080, U196 and various month
Services, Inc. Plymouth
waste codes (based on
County, MA
process knowledge and
(MAD039322250) in Polk
knowledge of the
County, IA to Clean Harbors
product)
El Dorado LLC in El Dorado,
AR (ARD069748192) for
incineration
5
WASTE
GENERATION HAZARDOUS
ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
WASTE
GENERATION MANAGEMENT
#
DETERMINATION RATE
3
Toxic Waste
Laboratory
D002 and various waste Less than 5-
Various sized
Clean Harbors Environmental
Chemicals
testing
codes (based on process gallons per year laboratory
Services, Inc. Plymouth
knowledge and
chemical
County, MA
knowledge of the
containers ranging (MAD039322250) in Polk
product)
up to 1 liter
County, IA to Clean Harbors
El Dorado LLC in El Dorado,
AR (ARD069748192) for
incineration
4
Lead/Perchloric Laboratory
D001, D008 (based on 5 pounds per
1 liter container Clean Harbors Environmental
Acid/Potassium testing
process knowledge and year
Services, Inc. Plymouth
Ferricyanide
knowledge of the
County, MA
product)
(MAD039322250) in Polk
County, IA to Clean Harbors
El Dorado LLC in El Dorado,
AR (ARD069748192) for
incineration
5
General Trash Facility
Nonhazardous (based on 5-yard container 5-yard container Shenandoah Sanitation in
operations
process knowledge and picked up three
Shenandoah, IA to Page
knowledge of the
times per week
County Landfill in Clarinda,
product)
IA for landfill
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4.4 Visual Inspection
Laboratory Operations:
LI conducts analytical analyses on various pharmaceutical products. Mr. Buhman stated the largest amount of raw material used to run analytical testing is water. In addition, various chemicals are used during analytical testing. Samples taken that are later used for testing are disposed as hazardous waste as waste chemicals. Mr. Buhman stated the largest amount of chemicals used are methanol and acetonitrile. Mr. Buhman stated all the hazardous wastes are accumulated in various containers in the lab and consolidated in the southern corner outside the QC lab (see Attachment 3, Photos 2-5). The facility accumulates toxic and corrosive wastes in separate blue containers in the same location. The containers are labeled "Hazardous Material Storage Cabinet" and "Toxic, or "Corrosive". There is one blue container for toxic and one container for corrosive wastes. The wastes are either expired chemicals or waste chemicals used during analytical testing. Mr. Buhman stated all the hazardous wastes are generated by running analytical tests on various pharmaceutical products. I did not observe any P listed wastes at the time of the inspection. Mr. Buhman explained when a toxic or corrosive waste is generated, chemists use process and product knowledge along with SDSs to determine how the respective waste should be managed. I observed expired toxic wastes during my visual inspection (see Attachment 3, Photo 4). Additionally, I observed expired corrosive wastes and did not note any concerns or issues with the management of either of these types of waste. All containers observed were closed, in good condition, and labeled with the words "Hazardous Waste" or a label indicating what type of waste is being stored within the container. The last hazardous waste shipment occurred on February 8, 2022. A total of 800 pounds of waste flammable liquid (primarily acetonitrile and methanol) was shipped off site. Mr. Buhman stated the facility ships off hazardous waste approximately once every 12-16 months. The manifest from the most recent shipment is provided in Attachment 8 as an example.
Universal Waste:
At the time of the inspection, LI was not generating or accumulating any universal wastes. Mr. Buhman stated the facility does not generate any battery waste but does generate spent lamps waste occasionally. During the visual inspection, I only observed green tipped florescent lamps. In addition, Mr. Buhman stated the maintenance team informed him they are beginning a transition to light emitting diode (LED) lighting. Mr. Buhman stated the green tipped lamps are thrown away in the general trash because they are nonhazardous. At the time of the inspection, I did not leave a finding for the management of spent lamps because they were green tipped. In order for a facility to manage lamps under the universal waste rule, they first must be hazardous and green tipped lamps do not appear to be a hazardous waste. Upon further EPA review, a finding may be added for failure to make an adequate waste determination and manage the lamps either as a hazardous waste or universal waste moving forward. At the conclusion of the inspection, Mr. Buhman stated he would research options to manage spent lamps under universal waste if required.
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Used Oil/Aerosol Cans/Wastewater:
Mr. Buhman stated the facility does not generate used oil, wastewater, or aerosol can wastes. I did not observe any used oil or aerosol cans being generated or accumulated during my visual inspection. Mr. Buhman explained the facility does not pour any chemicals down any laboratory sinks. Wastewater is not a generated waste stream on site.
I observed no issues or findings during this inspection. However, further EPA review may add findings.
Janosh
Digitally signed by Janosh Wolters
_W__o__lt_e__rs____07_:3_6_:2_1_-0_4_'0_0'__ Date: 2022.08.03
Janosh Wolters Energy Engineer Date: August 3, 2022
AMBER
Digitally signed by AMBER WHISNANT
_W__H__IS_N__A__N_T_____-0_5_'00_'___________ Date: 2022.08.09 18:15:35
Amber Whisnant
Section Chief
ECAD/CB/RCRA, EPA Region 7
Date: _________________
Attachments: 1. Facility Layout (1 page) 2. Lloyd Inc. Photolog (1 page) 3. Lloyd Inc. Photos (5 Photos/6 pages) 4. EPA Inspection Checklist (14 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Hazardous Waste Site Information Verification Report (1 page) 8. Manifest (1 page)
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