Document eB8kxGEeeZ8v5kvX0eQyw98G

RCRA Inspection Report 1) Inspector and Author of Report Laurie Benton DiGaetano Environmental Engineer Phone: 404-562-8948 benton-digaetano.laurie@epa.gov 2) Facility Information Safety Kleen - St. Pauls 934 North 5th Street St. Pauls, North Carolina 28384 3) Responsible Officials Damon Brown Branch General Manager damon.brown@safety-kleen.com 4) Inspection Participants Damon Brown, Safety-Kleen Todd Blake, Safety-Kleen Donald Jones, Safety-Kleen Laurie Benton DiGaetano, USEPA 5) Date of Inspection June 13, 2024, at 10:30 AM U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch RCRA Enforcement Section 61 Forsyth Street, S.W. Atlanta, Georgia 30303 EPA ID#: NCD980846935 NAICS #: 532490 - Other Commercial and Industrial Machinery and Equipment Rental and Leasing Bobby Nelms, NCDEQ Mark Burnette, NCDEQ Kim Caulk, NCDEQ Taylor Fant, NCDEQ 6) Applicable Regulations1 Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927), and 40 Code of Federal Regulation (C.F.R.) Parts 260 - 270, 273, 278, & 279; The North Carolina Solid Waste Management Law, N.C.G.S. 130A-17 to-28 and 130A290to -310.22, and North Carolina Hazardous Waste Management Rules, 15A NCAC 13A .0101 to .0119; and Hazardous Waste Permit NCD980846935. 1 As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions will be to the authorized State program. However, for ease of reference, the federal citations will follow in brackets. Pursuant to 15A NCAC 13A .0102(b) [40 C.F.R. 260.10], a large quantity generator of hazardous waste (LQG) is a generator who generates greater than or equal to 1,000 kilograms (2,200 pounds) of non-acute hazardous waste in a calendar month. Pursuant to 15A NCAC 13A .0119(a) [40 C.F.R. 273.9], a small quantity handler of universal waste (SQHUW) is a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. Pursuant to 15A NCAC 13A .0107(a) [40 C.F.R. 262.17], an LQG may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Sections 130A-294(c) and (g) of the NCSWML, N.C.G.S. 130A-294(c) to (g) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in 15A NCAC 13A .0107(a) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to 15A NCAC 13A .0107(a) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or without having interim status, as required by Sections 130A-294(c) and (g) of the NCSWML, N.C.G.S. 130A-294(c) to (g) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with 15A NCAC 13A .0107(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in 15A NCAC 13A .0107(a) [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in 15A NCAC 13A .0107(a) [40 C.F.R. 262.15] (hereinafter referred to as the "SAA Permit Exemption"). 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine Safety Kleen St Paul compliance with the conditions of its RCRA Hazardous Waste Facility Operating Permit (Permit Number NCD980846935), the applicable requirements of RCRA and the corresponding North Carolina regulations. This was an EPA lead inspection. 8) Facility Description Company Description: Safety-Kleen Systems, Inc. (SK), a subsidiary of Clean Harbors Inc., is an international serviceoriented company whose customers are primarily engaged in after-market automotive repair, industrial maintenance, manufacturing, and dry-cleaning. The company has been operating since 1968, and offers solvent distribution, collection, and reclamation services. Through SK's waste recovery service, a customer can lease material from SK and use it in machines that are either provided by SK or owned by the customer. Customers use SK parts-cleaner solvents, known as parts washer solvent and immersion cleaners, to clean oil, grease, and dirt from metal parts. SK collects used parts cleaning solvents for recycling and subsequent reuse and replaces EPA-RCRA CEI Report June 13, 2024 Page 2 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 the collected material with clean solvents. SK also collects used materials from the dry-cleaning industry and paint waste/used lacquer thinners from a variety of customers. SK has operated for over forty years, and currently services several hundred thousand customers throughout North America. According to the Waste Analysis Plan, SK's customers are typically very small quantity generators (VSQGs) and small quantity generators (SQGs) of hazardous waste and nearly 80% are in the automotive after-market business. SK reports that customers typically generate only one type of hazardous waste, and that those wastes are well known and relatively homogeneous. SK has a company-wide Annual Recharacterization Process to evaluate the homogeneity of each waste stream and determine its associated pervasive TCLP-based hazardous waste codes. According to SK, historical operating and analytical records indicate that the characteristics of customers' waste streams do not significantly change from year to year. Waste Descriptions: SK may receive various waste streams, including used solvents, dry cleaner wastes, paint wastes, photographic processing wastes, used immersion cleaner, used oil, and, on occasion, household hazardous waste at this facility. The primary function of the facility, however, is to serve as an intermediate storage center for used solvents. SK receives used solvents from customer facilities and transfers those used solvents from this location to a centralized SK recycling facility. SK also receives clean solvents that have been reclaimed at a centralized SK recycling facility and distributes those clean solvents from this location to customer facilities. Additional business activities related to the leasing and servicing of SK parts cleaning equipment are also conducted at this location. According to the Waste Analysis Plan, used parts washer solvents received and managed on-site are generated by SK customers in parts degreasing/cleaning machines that may be "sink-on-adrum" units or larger, vat-like devices. Although SK typically provides these parts degreasing/ cleaning machines to customers, the company also provides a solvent and solvent reclamation service for customer-owned parts degreasing/cleaning machines. The majority of SK parts washer solvent is a petroleum distillate solvent, and aqueous based solvents are also utilized to a lesser extent. SK has determined that its used parts washer solvent consists primarily of solvent and/or water, solids (i.e., metal bearing residue), oil, and grease, and that it is regulated as a hazardous waste exhibiting the hazardous waste characteristics associated with the following EPA hazardous waste codes: D001, D004-D011, D018, D019, D021-D030, and D032D043. SK's spent immersion cleaner is a hazardous waste solvent generated by off-site customers when oil, grease, and other solids become entrained in the solvent during its use to remove varnish and gum from such things as carburetors, transmissions, and other metal parts. SK describes the waste as a single phased heavy aromatic naphtha-based formulation that is basically unchanged from its product state, but that exceeds the TCLP criteria due primarily to heavy metals and organic contamination that is typical of that found in auto repair shops. Organic contamination may include benzene from gasoline, perchloroethylene and trichloroethylene from specialty cleaning solvents, and methyl ethyl ketone from paint EPA-RCRA CEI Report June 13, 2024 Page 3 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 thinners. SK has determined that its spent immersion cleaner is regulated as a hazardous waste exhibiting the toxicity characteristics associated with the following EPA hazardous waste codes: D004-D011, D018, D019, D021-D030, and D032-D043. Spent dry-cleaning materials generated off-site by contracted SK customers include cartridge filters, powder residue, still residue and still condensate. According to the Waste Analysis Plan, these wastes contain various concentrations of tetrachloroethylene, mineral spirits (petroleum naphtha), trichlorotrifluoroethane, and other used products. Dry-cleaning cartridges are constructed of steel, paper, clay and/or carbon, and spent dry-cleaning cartridge filters include these construction materials as well as retained dry-cleaning solvent, oil, grease, and undissolved elements (such as lint and soil). Although the spent cartridges range from dry to wet, SK has determined that the solvent retained in a spent cartridge generally amounts to less than 50% of the total cartridge by weight. Some SK dry-cleaner customers use a mixture of powdered materials instead of a cartridge filter to clean used dry-cleaner solvent. These powdered materials generally consist of diatomaceous earth and carbon, and the spent powder residues include the filter medium as well as retained solvent, lint, soil, oil, and grease. SK has determined that the solvent retained in this filter medium typically comprises between 40 and 50% of the spent powder residue by weight. After filtering undissolved elements from spent dry-cleaning solvents, SK dry cleaner customers distill the spent solvents to remove dissolved materials. These dissolved materials, or still residues, are in liquid or solid form and consist primarily of detergent, oil, grease, vinyl acetate (a sizing compound), water, and solvent. In some instances, dry cleaner customers also separate water from the still residues. In these cases, solvent contaminated separator water, or still condensate, is collected in a container that is separate from the container for the remaining still residues, or still bottoms. According to the Waste Analysis Plan, SK has determined that spent dry-cleaning material wastes are regulated as a listed hazardous waste carrying the EPA waste code F002, and as a hazardous waste exhibiting the characteristics associated with the following EPA hazardous waste codes: D001, D004-D011, D018, D019, D021-D030, and D032-D043. SK's paint waste/used lacquer thinner reclamation program primarily services automobile body repair shops, and paint waste/spent lacquer thinner is generated through various painting operations at customers' locations. According to the Waste Analysis Plan, paint waste and used lacquer thinner is ignitable; it is toxic due to the concentration, before use, of non-halogenated solvents including toluene, xylene, and methyl ethyl ketone; it is toxic due to its concentrations, after use, of trichloroethylene and methyl ethyl ketone; and it may also be toxic due to its concentrations, after use, of heavy metals and/or other TCLP volatile and semi-volatile organic constituents. SK has determined that paint waste/used lacquer thinner is regulated as a listed hazardous waste with the EPA hazardous waste codes F003 and F005, and as a hazardous waste exhibiting the characteristics associated with the following EPA hazardous waste codes: D001, D004-D011, D018, D019, D021-D030, and D032-D043. Facility Description: The Safety-Kleen Service Center, which has been in operation since March 1985, occupies approximately 5.7 acres of land within Robeson County, North Carolina, in an area that the Town of St. Pauls has zoned for industrial development. The property is owned by Nancy R. Hall EPA-RCRA CEI Report June 13, 2024 Page 4 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 and Lynda D. Hall, and the facility is operated by SK using a single shift five days per week, Monday through Friday. The company has twelve employees, including five box-truck drivers, two vac-truck drivers, and one oil-truck driver, who are assigned to work at this location. Facility operations include the accumulation and storage of various waste streams, including used solvents, dry cleaner wastes, paint wastes, photographic processing wastes, and used immersion cleaner. On February 6, 2024, SK most recently notified as an LQG and a treater, storer, or disposer of hazardous waste that receives hazardous waste from off-site at this location. The subject facility is permitted to receive and store hazardous wastes under the RCRA Hazardous Waste Management Permit Number NCD980846935 R3 (the RCRA Permit), which sets forth the conditions for SK to store hazardous waste in containers within two permitted container storage areas (CSAs), in one permitted storage tank (Tank No. 2), and in two permitted tank-like Subpart X units (drum washer/dumpster units). The Facility also operates as a transfer facility, as defined by 15A NCAC 13A.0118 [40 C.F.R. Part 263], holding hazardous wastes in containers for a period of ten days or less during the normal course of transportation. SK generates drum washer sediment from washing/cleaning drums containing used parts washer solvent, waste solvent dumpster sludge, tank bottom sediment, personal protective clothing, spill debris, and sampling debris at the subject facility. The drum washer sediment consists of soils, oils, grease, water, small amounts of solvent, and some metal parts. According to the Waste Analysis Plan, characterization of branch facility generated wastes is based on SK's knowledge of the waste stream and confirmed through annual waste recharacterization. The drum washer sediment and the tank bottom sediment are derived from the used parts washer solvent, and SK has determined that they are hazardous according to the Toxic Characteristic Leaching Procedure (TCLP) because of heavy metals and other organic TCLP based waste codes. The facility-generated wastes may also exhibit the characteristic of ignitability. SK accumulates facility-generated hazardous waste in two satellite accumulation areas (SAAs) and transfers full containers from each SAA to one of the existing permitted CSAs. Containers of facilitygenerated hazardous waste are stored in the permitted CSA for less than 90 days, and the CSAs are subject to the inspection procedures set forth in the RCRA Permit. 9) Previous Inspection History NCDEQ routinely conducts RCRA Focused Compliance Inspections at the subject facility as part of the Resident Inspector program and conducts a full RCRA Compliance Evaluation Inspection at least once each year. The NCDEQ most recently conducted a RCRA CEI at the subject facility on August 23, 2023, and the EPA and NCDEQ most recently conducted a joint RCRA CEI at the subject facility on June 6, 2019. No apparent violations of RCRA's requirements were reported during either of these CEIs. 10) Opening Conference On June 13, 2024, EPA inspector Laurie Benton DiGaetano, accompanied by NCDEQ inspectors Mark Burnette and Bobby Nelms and by NCDEQ permit writers Kim Caulk and Taylor Fant, arrived at Safety-Kleen Systems - St. Pauls at approximately 10:30 AM. Damon Brown, Branch General Manager, immediately received the inspectors. The inspectors introduced themselves, EPA-RCRA CEI Report June 13, 2024 Page 5 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 showed their credentials to Damon Brown, and explained the purpose of the visit. Todd Blake, Senior Environmental Compliance Manager, joined Damon Brown, the inspectors, and the permit writers via telephone for the opening conference. The inspectors described the anticipated use of equipment (digital camera) during the inspection and provided a request for records. The Small Business Regulatory Enforcement Fairness Act's classification of a "small business" is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. A copy of the EPA's information sheet for small businesses can be found at https://www.epa.gov/sites/production/files/2017-06/documents/smallbusinessinfo.pdf. The EPA inspector also discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. The company did not assert a business confidentiality claim. Damon Brown and Todd Blake provided an overview of the facility's history and current operations during the opening conference. The inspection participants also discussed health and safety protocols and required personal protective equipment before Damon Brown led the inspectors on a tour of the Facility operations. 11) Inspection Observations Warehouse SAA: SK St. Pauls manages one SAA in the Warehouse for managing hazardous waste retain samples that are generated when oil retain samples are purged. SK St. Pauls personnel explained that oil and vac truck samples are collected from each customer and retained on-site for ninety days. After ninety days, the oil retain samples are accumulated as hazardous waste in a SAA. The inspectors observed one 55-gallon container in this SAA (Photo 1). The container was labeled hazardous waste retain/oil samples and identified with a flammable liquid DOT hazard sticker. Permitted Container Storage Area 2150: Container Storage Area No. 1, the non-ignitable waste container storage area, is permitted to store up to 4,110 gallons of immersion cleaner wastes, aqueous parts washer solvent, photographic waste (as 10-day transfer only), perchloroethylene waste, new product, empty drums, and compatible 10-day transfer wastes. Facility personnel stated that the area is currently used for product storage. The inspectors observed twenty-nine 55-gallon containers of product materials in this area at the time of the inspection. Permitted Container Storage Area: Container Storage Area No. 2, the class 1B flammable container storage, is permitted to store up to 4,480 gallons of paint-related waste, compatible 10-day transfer waste, used parts washer solvent, drum washer sediment, and dry-cleaning waste. The inspectors observed only one waste container in this area during the inspection (Photo 2): one 30-gallon container labeled universal waste aerosols and identified with a flammable DOT hazard sticker. Facility EPA-RCRA CEI Report June 13, 2024 Page 6 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 personnel stated that the area did not contain any containers of hazardous waste, because the facility had a scheduled waste pick-up event earlier in the day. 10-day Transfer Area: In a covered area directly adjacent to Container Storage Area No. 2, SK St. Pauls manages another area, the "Flam Room Porch," as a less than 10-day containerized waste transfer area. Because the facility had a waste pick-up event earlier that day, no containers of hazardous waste were observed in this area at the time of the inspection. Return and Fill Station: The canopy covered Return and Fill Station, which is located directly across from the Warehouse along the southern most portion of the facility, consists of a sheet metal structure comprising a roof and three sides (Photo 3). The fourth side is open to allow for truck loading/unloading onto the elevated metal grating floor, which is supported over twelve sixinch deep galvanized metal containment pans on a concrete pad. The area contains two tanklike Subpart X drum washer/dumpster units, and one drum rinsing unit. Containers of used parts washer solvent are collected from customers and delivered to the offloading dock at the Return and Fill Station. The drums are opened manually, and the used solvent is poured into one of two drum washer/dumpster units. The drum washer/dumpster units are specifically designed to remove residuals from both the inside and the outside of empty used open-ended containers. The drum is placed between two rotary brushes in the unit, and the lid is closed. The brushes then rotate the drum as a recirculating pump lifts solvent from a collection reservoir and injects it inside the turning container. This process is designed to sufficiently clean the container, so that it can be used to transport clean solvent back for use at the customers location. In addition to cleaning drums, the unit serves as part of the transfer system for transferring the used solvent into the use parts washer solvent storage tank, Tank No. 2. A separate drum rinsing unit (i.e., drum spritzer) is also located in the Return and Fill Station. The drum spritzer may be used to provide a final rinse of SK's premium solvent to containers that are utilized for non-RCRA regulated parts cleaning waste. The residues from this process are handled as Facility generated waste. The drum spritzer is hard-piped directly to a drum washer/dumpster unit that gravity drains to the parts washer solvent storage tank, Tank No. 2, in order to minimize the possibility of emissions and minimize the chance of spills. SK manages one SAA for accumulating hazardous waste generated in and around the Return and Fill Station. The inspectors observed one 55-gallon container in this SAA (Photo 4). The container was closed, labeled hazardous waste branch debris, and marked with an indication that the contents are flammable and toxic. Tank Farm: The Tank Farm is located immediately northeast of the Return and Fill station. The Tank Farm consists of three storage tanks within a concrete containment structure (Photo 5): Tank No. 1 is EPA-RCRA CEI Report June 13, 2024 Page 7 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 a 10,000-gallon capacity horizontal steel aboveground tank used to store clean parts washer solvent; Tank No. 2 is a 15,000-gallon capacity RCRA regulated vertical steel aboveground storage tank used to store used parts washer solvent; and Tank No. 3 is a 15,000-gallon capacity vertical steel aboveground tank used to store used oil. Tank No. 2 may also be utilized on an asneeded basis to store stormwater that has collected within the Tank Farm or the Return and Fill Station. Ancillary Equipment and Emergency Preparedness: Tanker trucks delivering clean parts washer solvent or picking up used parts washer solvent or used oil park on a concrete paved secondary containment area located adjacent to the Tank Farm during loading or unloading activities. Lines used to transfer used parts washer solvent from the drum washer/dumpster units to Tank No. 2 and from Tank No. 2 to the tanker truck are painted brown. Lines used to transfer clean parts washer solvent from the tanker truck to Tank No. 1 and from Tank No.1 to the Return and Fill Station are painted green. The inspectors did not observe evidence of leaks from the waste transfer lines during the inspection. The Return and Fill and Tank Farm areas are equipped with fire extinguishers, spill kits, an automatic fire alarm that alerts the local fire department, an emergency eyewash station, and a push-button alarm. Employees working in this area carry cellular phones. 12) Records Review Contingency Plan and Quick Reference Guide (QRG): The quick reference guide, dated January 25, 2022, includes the types/names of hazardous waste in layman's terms and the associated hazard associated with each hazardous waste present at any one time; the estimated maximum amount of each hazardous waste that may be present at any one time; the identification of any hazardous wastes where exposure would require unique or special treatment by medical or hospital staff; a map of the facility showing where hazardous wastes are generated, accumulated and treated and routes for accessing these wastes; a street map of the facility in relation to surrounding businesses, schools and residential areas; the identification of on-site notification systems; and the name of the emergency coordinator(s) and emergency telephone number(s). A copy of the draft Contingency Plan to be included with the Permit Renewal Application (and its quick reference guide) was most recently submitted to the Big Marsh Fire Department, the Robeson County Sheriff's Department, the UNC Health Southeaster Regional Medical Center, the St. Pauls Police Department, and the Robeson County Manager on June 16, 2023. The actions that facility personnel should take in response to an emergency are described in the facility's Contingency Plan, which was last updated in October 2023. The plan describes actions facility personnel must take in response to fires, explosions, or any unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility. The plan describes arrangements agreed to with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals, or the Local Emergency Planning EPA-RCRA CEI Report June 13, 2024 Page 8 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 Committee. The plan includes the names and emergency telephone numbers for persons identified as emergency coordinators. The plan includes a list of emergency equipment at the facility. The list includes fire extinguishing systems, spill control equipment, communications and alarm systems, decontamination equipment, and personal protective equipment. The plan includes the location and a physical description of each item on the list, and a brief outline of its capabilities. The plan includes an evacuation plan for personnel. This plan describes signal(s) to be used to begin evacuation, evacuation routes, and alternate evacuation routes. Training Records: The inspectors reviewed facility job descriptions and employee names that were provided for the Branch General Manager, the Branch Secretary, the Lead Material Handler, the Material Handler, the Customer Service Representative, the Oil Sales and Service Representative, the Market Sales Specialist - Hunter, the Market Sales Specialist - Farmer, and the Senior Customer Service Representative. The inspectors also reviewed a record of hazardous waste training completed by twelve employees in calendar year 2024. Waste Manifest and Land Disposal Restriction (LDR) Records: The inspectors reviewed randomly selected hazardous waste manifest records and land disposal restriction forms for shipments of hazardous waste sent since the date of the most recent RCRA CEI. Inspection Records: The inspectors spot-checked SK's available electronic records of daily tank inspections and CSA inspections. The electronic records indicate that inspections appear to be conducted and recorded. Observed issues are flagged and corrections are tracked and recorded using a workticket system. Subpart BB and CC Air Emissions: The inspectors reviewed records of determination that the SK parts washer solvent storage tank farms are in heavy liquid service with an average vapor pressure at 20 C of 0.11 kPa. The inspectors reviewed records of the Subpart CC visual tank inspection, which was conducted on Tank No. 2 on February 5, 2024. 13) Closing Conference The inspectors conducted the exit meeting at 1:25 PM with Damon Brown and Todd Blake (via telephone). During this meeting, the inspectors stated their preliminary conclusions of the inspection. 14) List of Attachments Attachment 1 - Photo Log EPA-RCRA CEI Report June 13, 2024 Page 9 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 15) Signed Digitally signed by LAURIE LAURIE DIGAETANO DIGAETANO Date: 2024.08.02 08:59:45 -04'00' Laurie Benton DiGaetano Environmental Engineer 16) Concurrence ALAN NEWMAN Date: 2024.08.05 13:00:26 -04'00' Digitally signed by ALAN NEWMAN Alan R. Newman Acting Chief RCRA Enforcement Section EPA-RCRA CEI Report June 13, 2024 Page 10 of 10 Safety Kleen St Pauls EPA ID# NCD980846935 Attachment 1 - Photo Log Five Photos taken on: June 13, 2024 Photos taken by: Laurie Benton DiGaetano Photos taken with: Panasonic DMC TS-5 EPA Property Tag: S09533 Photo 1: One 55-gallon container for accumulating hazardous waste retain/oil samples in the Warehouse SAA. Photo 2: One 30-gallon container of universal waste aerosols in the Container Storage Area No. 2. Photo 3: Return and Fill Station. EPA-RCRA CEI Report June 13, 2024 Attachment 1 - Page 2 of 3 Safety Kleen St Pauls EPA ID# NCD980846935 Photo 4: One 55-gallon container for accumulating hazardous waste branch debris in the Return and Fill SAA. Photo 5: Three storage tanks at the Tank Farm. EPA-RCRA CEI Report June 13, 2024 Attachment 1 - Page 3 of 3 Safety Kleen St Pauls EPA ID# NCD980846935