Document gbv0aKdDOog3g37zvo22ojrQ3

RCRA Inspection Report 1) Inspector and Author of Report Laurie Benton DiGaetano Environmental Engineer RCRA Enforcement Section Phone: 404-562-8948 benton-digaetano.laurie@epa.gov U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch 61 Forsyth Street, S.W. Atlanta, Georgia 30303 2) Facility Information University of South Alabama 307 University Boulevard North Mobile, Alabama 36688 EPA ID# ALD079474037 3) Responsible Officials William L. Guess Director Safety and Environmental Compliance wguess@southalabama.edu 4) Inspection Participants William Guess, U. of South Alabama F. Anne Foster, U. of South Alabama Savannah Wallace, U. of South Alabama Laurie Benton DiGaetano, USEPA Lee Gunter, ADEM Rahne Hicks, ADEM Cheyan Wilson, ADEM 5) Date of Inspection December 6, 2023 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 Alabama Hazardous Waste Management and Minimization Act of 1978, Ala. Code 22-30-1 et seq., and rules 335-14-1 to 335-14-17 (2016 and 2018) of the Alabama Department of Environmental Management (ADEM) Administrative Code (ADEM Admin. Code); and Hazardous Waste Facility Permit ALD079474037. 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 ADEM Admin. Code r. 335 14-1-.02-(1)(a)111. [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 ADEM Admin. Code r. 335-14-1-.02(1)(a)157. [40 C.F.R. 273.9], a large quantity handler of universal waste (LQHUW) is a universal waste handler who accumulates 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. Pursuant to ADEM Admin. Code r. 335-14-3-.01(5)(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 Section 22-30-12(b) of the Alabama Hazardous Wastes Management and Minimization Act (AHWMMA), Ala. Code 22-30-12(b) [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with ADEM Admin. Code r. 335-14-3-.01(6)(b) or 335-14-3.01(7)(a) [40 C.F.R. 262.16(b) or 262.17(a)], except as required in ADEM Admin. Code r. 33514-3-.01(5)(a)7. and 8. [40 C.F.R. 262.15(a)(7) and (8)], provided that the generator complies with the satellite accumulation area conditions listed in ADEM Admin. Code r. 335-14-3.01(5)(a) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to ADEM Admin. Code r. 335-14-3-.01(7) [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 Section 22-30-12(b) of the AHWMMA, Ala. Code 22-30-12(b) [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in ADEM Admin. Code r. 335-14-3-.01(7) [40 C.F.R. 262.17] (hereinafter referred to as the "LQG Permit Exemption"). 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine the University of South Alabama's compliance with the conditions of its RCRA Hazardous Waste Facility Permit (ALD079474037), the applicable requirements of RCRA and the corresponding Alabama regulations. This was an EPA lead inspection. 8) Facility Description The University: The University of South Alabama (USA or University) is a public, doctoral-level university operating under the NAICS Code 611310 for Colleges, Universities, and Professional Schools. The University was founded in 1963, and the main campus covers approximately 1,224 acres in Mobile, Alabama. The USA consists of ten colleges and includes one of Alabama's two state- EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 2 of 13 supported medical schools. It has an enrollment of about 14,000 students and a workforce of approximately 5,500 members of faculty and staff. The Alabama Department of Environmental Management (ADEM) issued a hazardous waste operating permit to the USA for hazardous waste container storage and treatment at the University Treatment, Storage, and Disposal Building (TSD Building). The TSD Building consists of a single-story structure on the University campus in which the USA is permitted to store up to 12,000 gallons of liquid and solid wastes. The USA is also permitted to treat up to 300 gallons of waste per day in a neutralization tank at the TSD Building. The current hazardous waste operating permit became effective on January 24, 2020, and shall remain in effect until January 23, 2030, unless it is revoked and reissued, or it is terminated. In addition to the hazardous waste management activities in the TSD Building, the USA is also a large quantity generator (LQG) and a transporter of hazardous waste. In the 2021 biennial report, dated February 21, 2022, the USA also notified as a large quantity handler of universal waste (LQHUW) (batteries and lamps), as a used oil transporter, and as a recycler of hazardous waste that stores prior to recycling. The biennial report also indicated that the USA is operating under 40 CFR 266 Subpart P for the management of hazardous waste pharmaceuticals. Hazardous Waste Generation and Transport: The University's research laboratories, teaching laboratories, healthcare operations, maintenance activities, and facility operations all generate hazardous wastes which may be transported from on-campus and off-campus areas to the University's permitted storage area. The USA operates teaching and research laboratories distributed through approximately 112 buildings and ten colleges, including all areas of engineering, biomedical, genetic, medical, and agricultural and natural science research studies. Each laboratory is a potential point of generation for hazardous waste. In addition, the USA provides instruction in all areas of liberal and performing arts studies, and some of those areas may also perform activities that generate hazardous waste. Finally, the USA's support services such as maintenance, grounds, motor pool and athletics also have the potential to house one or more points of generation for hazardous waste. The types of waste generated onsite include ignitable, corrosive, reactive and/or toxic waste generated in the teaching and research laboratories and waste oils, antifreeze, oil contaminated debris, outdated fertilizer, pesticides, herbicides, etc. generated during normal maintenance and landscaping activities. Laboratory generated wastes include expired chemicals as well as wastes generated from non-clinical laboratory tests, which are based on the type of individual research or classroom work and vary depending on the classes being offered during a given semester. Waste containers can be as small as a 50 ml glass bottle or as large as a 55gallon metal drum. Wastes in most teaching and research laboratories are managed using a collection of bottles, with multiple sizes ranging up to a 5-gallon poly carboy. The USA does not have a centralized campus wide procurement office to coordinate or control chemical purchases ordered by and received at the USA campuses. Instead, each department is EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 3 of 13 responsible for its own ordering process. In the event that an investigator/staff member determines that the use, contamination, or expiration of a given chemical has caused it to no longer be usable in their area, that person is responsible for contacting the Safety and Environmental Compliance (SEC) Department for a waste chemical pick-up. The SEC Department receives information on the type and quantity of waste that is ready to be picked up and three SEC Department employees transport all university generated wastes to the TSD Building. Hazardous waste is picked up from the USA's hospital once every week, and from all other SAAs upon request. Based on information provided by the person responsible for generating a container of waste, SEC Department personnel determine and assess the chemical and physical properties of the waste to determine the proper treatment, storage, and disposal methods. The USA's in-house manifest system generates a computerized records for each waste container and this record is used to create an in-house laminated manifest card (with individual tracking number), which is affixed to the container for on-site identification and tracking of the material. Wastes that are generated at non-contiguous USA locations are transported to the TSD Building using a DOT Uniform Hazardous Waste Manifest, and an in-house laminated manifest card from the same USA in-house manifest system is affixed to each container when it arrives at the TSD Building. The computerized log provides information such as the specifically assigned manifest number; the name or general description, volume, EPA number, source location, DOT designation for the waste; the date the waste is picked up; and other information deemed necessary for proper managment. The USA also enters a process code to indicate the desired treatment method on these records. Hazardous Waste Storage: The TSD Building is the only area on the USA main campus where hazardous wastes are stored outside of an SAA. The building, a single-story structure that was built in 1986, is enclosed within a chain-link fence that is eight-feet tall and topped with barbed wire. Only SEC Department personnel have access into the fenced area and inside the building. The floor of the TSD Building is constructed of poured concrete and it slopes down to several floor drains that connect to an underfloor storage tank through a locked-off piping system. In addition, the concrete flooring system is sealed with a chemical resistant, two-part epoxy paint coating that is applied approximately 18-36 inches up the walls. Most containers in the TSD Building are stored in one of five individual storage bays: (1) caustic storage; (2) flammable liquid barrel storage; (3) high hazard storage; (4) chlorinated solvent storage; and (5) acid storage, but containers of highly toxic material, oxidizers, and stable organic peroxides are stored on a dedicated wooden shelving unit located next to the bays. The storage bays are separated by concrete walls and each bay is equipped with a shelving system above an obstructed pit used to capture any spilled or leaked material. Spilled or leaked material can either be recovered directly from the pit or it can be drained into the underfloor storage tank. EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 4 of 13 The TSD Building receives and manages numerous different hazardous waste profiles, and most waste arrives in containers that hold less than or equal to 5-gallons or 25-pounds of material. When vehicles transporting containers of waste arrive at the TSD Building, they are parked in the delivery area in front of the roll-up door. From there, SEC Department personnel off-load the containers directly into the building. Containers greater than 5-gallons are stored in the flammable liquid barrel storage area, and containers less than 5-gallons are staged on a set of wooden shelves according to waste classification. An in-house laminated manifest card is affixed to each container within the TSD Building, and containers less than 5-gallons are then transferred from the wooden shelves to the designated storage bay. Containers greater than 5gallons are stored in the barrel storage area near the roll-up door. Wastes that have been accepted at the TSD Building may continue to be stored in their incoming containers, such as the original manufacturer's container (glass, plastic, and metal) or a high-density polyethylene carboy (two-and-a-half or five-gallon capacity), until it is ready for shipment off-site. Other wastes or waste containers may be consolidated into a thirty-gallon high density polyethylene drum (both open and closed head), into a DOT-approved 55-gallon metal drum (both open and closed head), or into a fiberboard, lined drum (various sizes). For example, compatible ignitable solvents are bulked together into 55-gallon drums for off-site vendor fuel blending. Under standard practices, barrels are stored single file in the designated bulking portion of the barrel storage area with enough aisle space for routine inspection of the containers. Once a barrel is filled, it is moved to the designated holding portion of the barrel storage area until it is shipped offsite for disposal. The bulking portion of the barrel storage area has been specifically designed to capture both spills and fumes that may be generated by the bulking process. Spilled or leaked material is captured in one of two 10-inch deep retaining pits beneath a fiberglasscoated grating used to support the 55-gallon drums. Material that is captured in the pits can either be pumped directly into another drum or it can be released into the underfloor holding tank before it is pumped into another drum. Fumes that may occur during the bulking process are controlled by a single pass exhaust vent, which runs along the entire length of the bulking portion of the barrel storage area. Hazardous Waste Neutralization and Disposition: Neutralization of non-hazardous, non-EPA listed materials (salts, sugars, amino acids) and EPA hazardous (D002) listed materials (acids, bases, non-silver-containing photochemical solutions) is performed within the 250-gallon neutralization vessel in the TSD Building. The USA only uses this procedure to neutralize outdated or unwanted laboratory chemicals that do not contain any contaminants. The process may not be used to neutralize any waste that is a combination of corrosive material and other chemicals. Once materials have been neutralized, personnel check the pH before opening the release valve to discharge the effluent to the USA Sanitary Sewer System which then ultimately discharges to the City of Mobile Sanitary Sewer System. The USA SEC Department also handles the arrangements for ultimate disposal of all other hazardous and nonhazardous chemical waste materials. Disposal methods are selected based EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 5 of 13 on the waste characteristics, and barrel wastes are shipped off-site once every quarter. The USA prepares lab pack shipments twice a year and evaluates the quoted price, available disposal options and company reputation/referrals before selecting the desired vendor for managing the lab pack shipment. Stericycle disposes of all USA pharmaceutical waste. Hazardous Waste Identification: According to the 2021 Biennial Report, which was dated February 21, 2022, the USA generated the following hazardous wastes on the Main Campus during 2021: Waste Description & Number Spent non-halogenated solvents from research and teaching laboratories Ignitable waste from research and teaching laboratories F003 D001 Corrosive waste from D002 research and teaching labs Lead-acid batteries from normal university operations Alkaline batteries from normal university operations Speat halogenated solvents from research and teaching laboratories Spent halogenated solvents from research and teaching laboratories Ignitable waste from normal maintenance activities Lithium batteries from normal university operations Nickel metal hydride batteries from normal university operations D002 D008 D002 F002 F001 D001 D002 D002 Volume (pounds) 24,479 5,026 3,250 2,210 2,040 1,439 942 750 434 350 Waste Description & Number Chloroform waste from research and teaching laboratories Mercury waste from research and teaching laboratories Barium waste from research and teaching laboratories D022 D009 D005 Formic acid from research and teaching laboratories U123 Resorcinol from research and teaching laboratories Spent non-halogenated solvents from research and teaching laboratories Potassium cyanide from research and teaching laboratories Sodium cyanide from research and teaching laboratories Reactive waste from research laboratories Sodium azide from research and teaching laboratories U201 F005 P098 P106 D003 P105 Volume (pounds) 13 10 5 1.7 1.4 1.1 1.1 1.1 0.3 0.3 EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 6 of 13 Silver waste from research 1,2-dichloroethane from and teaching laboratories D011 125 research and teaching D028 0.2 laboratories Arsenic waste from Hydrazine from research research and teaching D004 113 and teaching laboratories U133 0.2 laboratories Ni-cad batteries from normal university operations D002 D006 Selenium waste from 75 research and teaching D010 0.1 laboratories Cadmium waste from Benzene waste from research and teaching D006 55 research and teaching D018 0.1 laboratories laboratories Lead waste from research and teaching laboratories D008 Cyanides (soluble cyanide 29 salts) NOS from research P030 0.1 and teaching laboratories Chromium waste from research and teaching laboratories D007 Ethylene glycol 21 monomethyl ether from U359 0.1 research and teaching laboratories According to the 2021 Biennial Report, the following hazardous wastes were accepted at the USA's TSD Building from non-contiguous USA property during 2021: Waste Description & Number Waste non-halogenated solvents from USA - University Hospital Waste spent nonhalogenated solvents from USA - Mitchell Cancer Institute Lead acid batteries from USA - University Hospital Alkaline batteries from USA - University Hospital F003 F003 D002 D008 D002 Corrosive waste from USA - University Hospital D002 Ignitable waste from USA - Mitchell Cancer Institute Lithium batteries from USA - University Hospital D001 D002 Volume (pounds) 21,050 Waste Description & Number Spent halogenated solvents from USA - Mitchell Cancer Institute 4,484 Ignitable waste from USA - Springhill Annex Campus 1,820 1,513 1,497 461 364 Lead waste from USA - University Hospital Corrosive waste from USA - Children & Women Hospital Spent non-halogenated solvents from USA - Children & Women Hospital Mercury waste from USA - Children & Women Hospital Resorcinol waste from USA - University Hospital F002 D001 D008 D002 F003 D009 U201 Volume (pounds) 50 41.3 29 26 10 4 1.1 EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 7 of 13 Spent halogenated Chromium waste from USA - solvents from USA - F001 274 University Hospital D007 0.9 Mitchell Cancer Institute Alkaline batteries from Ignitable waste received USA - Springhill Annex D002 164 from USA Children & D001 0.3 Campus Women Hospital Corrosive waste from USA D002 102 Arsenic waste from USA - D004 0.3 - Mitchell Cancer Institute University Hospital Alkaline batteries from USA - Mitchell Cancer Institute D002 97 Reactive waste from USA - D003 0.2 Mitchell Cancer Institute Nickel-cadmium batteries from USA - University Hospital D002 D006 97 Silver waste from USA - D011 0.2 University Hospital Ignitable waste from USA - D001 University Hospital 97 1,2-dichloroethane from D028 0.2 USA - University Hospital 9) Previous Inspection History The ADEM and the EPA typically conduct a RCRA CEI at the subject facility every fiscal year. The most recent CEI was conducted by the EPA and the ADEM on March 29, 2023. Violations of hazardous waste container labeling requirements were noted during the RCRA CEI. 10) Opening Conference On December 6, 2023, EPA inspector Laurie Benton DiGaetano, accompanied by ADEM inspectors Lee Gunter, Rahne Hicks, and Cheyan Wilson, arrived at the USA at approximately 11:20 a.m. Anne Foster, Assistant Director Safety and Environmental Compliance, immediately received the inspectors, and they were soon joined by William Guess, Director of Safety and Environmental Compliance. The inspectors displayed their credentials and explained the purpose of the visit. The inspectors described the anticipated use of equipment (digital camera) during the inspection and provided a request for records. Note that 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 discussed the University's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA, but the University did not assert a business confidentiality claim. EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 8 of 13 The inspection participants discussed health and safety protocols and required personal protective equipment before they began a tour of the University operations. 11) Inspection Observations The TSD Building: The tour of the University began at the TSD Building, which is permitted to store hazardous waste that is generated on the University's main campus and that is generated by the University on non-contiguous properties and to neutralize corrosive hazardous waste that do not contain any contaminants. The TSD Building is a single-story cinderblock structure inside a chain-linked fence. The building is equipped with a security system that is monitored by the USA Police Department and includes four security cameras outside of the building and an audible security alarm. The building is also equipped with portable fire extinguishers and fire hoses, and warning signs are posted on all four sides of the fence. The inspectors observed "no smoking" and "danger, chemical storage" signs in this area, a safety shower and eyewash station on the outside of the building, and an emergency telephone at the workstation in the building's office. The inspectors observed waste containers on the wooden shelves at the incoming waste processing area in the TSD Building (Photos 1 and 2). Each container was labeled with waste identification information provided by the person(s) generating the waste. Containers of hazardous waste were labeled with the words "hazardous waste" and with an indication of the hazards of their contents. The inspectors also observed one 55-gallon drum labeled used oil; one 10-gallon container labeled universal waste NiCad batteries; one 25-gallon container labeled universal waste alkaline batteries; one 30-gallon container labeled universal waste nickel metal batteries; one 30-gallon container labeled universal waste lithium batteries; one 5-gallon container labeled universal waste odd group of dead batteries; and one -gallon container labeled universal waste zinc batteries near the roll-up door and the flammable liquid barrel storage area (Photo 3). The inspectors observed a total of two 55-gallon drums of waste flammable liquid (xylene, toluene) in the flammable liquid bulking and barrel storage area (Photo 4). Each of these containers was labeled D001, F003, F005 hazardous waste and identified with DOT placards to indicate the contents are a flammable liquid and are toxic. The inspectors also observed one 55-gallon drum labeled nonregulated waste; one 30-gallon drum labeled hazardous waste flammable liquid (formaldehyde, methanol); one 30-gallon drum labeled toxic and corrosive hazardous waste containing ferrous ammonium sulfate, sulfuric acid, phosphoric acid, potassium permanganate and water; and two 30-gallon drums labeled toxic, flammable, and corrosive hazardous waste in the flammable liquid barrel storage and bulking area (Photo 4). EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 9 of 13 Finally, the inspectors observed the 250-gallon neutralization tank, which was empty at the time of the inspection. According to the neutralization records, the tank was last used on November 2, 2023. Maintenance Division UW Storage: The USA manages universal waste in a caged area within the Maintenance Division. The inspectors observed the following cardboard containers for accumulating spent lamps as universal waste lamps: three 4-foot cylinders; one 2-foot square box; eleven 4-foot boxes; and one 8-foot box. The inspectors also observed the following containers for accumulating spent batteries as universal waste: one 25-gallon container for spent lithium batteries, one 30-gallon container for spent alkaline batteries; and one 30-gallon container for spent nickel-cadmium batteries. All of the boxes and containers were marked with an accumulation start date, and each cardboard box was labeled universal waste lamps and each battery container was labeled universal waste batteries. Two boxes of universal waste lamps were open: one 2-foot square box and 8-foot box. Facility personnel closed the boxes during the inspection. Pursuant to ADEM Admin. Code r. 335-14-11-.02(4)(a) [40 C.F.R. 273.13(d)(1)], a SQHUW must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. In addition to the containers of universal waste, the inspectors also observed four small leadacid batteries on a pallet near the universal waste battery containers (Photo 5). None of these batteries were labeled as universal waste. Pursuant to ADEM Admin. Code r. 335-14-11-.02(5)(a) [40 C.F.R. 273.14(a)], a SQHUW must label or mark each Universal Waste battery or container or tank in which the batteries are contained clearly with one of the following phrases: "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." Two containers of universal waste lamps were marked with an accumulation start date that was over one year old: one 4-foor cylinder was marked with an accumulation start date of April 12, 2022, and another was marked with an accumulation start date of December 1, 2022. None of the four loose universal waste lead-acid batteries were marked with an accumulation start date. Facility personnel explained that neither the lamps nor the batteries could have been accumulated for over one year, because this area had been completely cleared out during a recent universal waste shipment event. During the closing conference, personnel provided records to show that the most recent shipment of universal waste was initiated from the facility on November 13, 2023. Science Laboratory Building SAAs: The USA manages one SAA in the Science Laboratory Building for accumulating hazardous waste that may be generated in the 201 Chemistry Stockroom, the 202 Solvent Room, and the EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 10 of 13 220 Chemistry Laboratory. Hazardous wastes are routinely collected in hazardous waste containers as they are generated at individual workstations in the teaching laboratories. The contents of the workstation containers are then consolidated into a 2-liter bottle, which is kept in the laboratory for daily use. At the end of every week, the contents of the 2-liter bottle are transferred into a carboy for management in the Solvent Room. At the end of each semester, personnel perform a waste cleanout event to ensure all hazardous waste has been removed from the chemistry laboratories. Hazardous wastes are also generated whenever chemicals in the stockroom become expired or unwanted. The inspectors also observed the Solvent Room, which contained two flammable cabinets (Photo 6) and a mobile cart for holding carboys of hazardous waste (Photo 7). The inspectors observed six 5-gallon car-boy containers on the mobile cart, twelve 2-liter bottles in the first cabinet, and five large glass bottles, six small glass bottles and one plastic jar in the second cabinet. Each container was closed, labeled with the words "hazardous waste," and marked with an indication of the hazards of its contents. The inspectors also reviewed the inventory log for the current academic semester, which was scheduled to close before the end of the month. According to the inspectors' observations and the inventory log, the Science Laboratory Building has accumulated approximately 20-gallons of hazardous waste over the course of this semester. Landscaping / Grounds Maintenance Area SAAs: The USA manages one SAA in the Landscaping / Grounds Maintenance Area for managing used aerosol cans and another for managing the contents of punctured aerosol cans. The inspectors observed one 55-gallon drum in each SAA (Photo 8). Each drum was labeled as hazardous waste and marked with an indication that its contents are flammable. The USA also accumulates used oil and oil contaminated materials in the Landscaping / Grounds Maintenance Area. The inspectors observed a secondary containment pallet holding one 55gallon drum of used oil, which was labeled with the words "used oil" (Photo 9). Transportation Department SAA: The USA manages one SAA at the Transportation Department for managing hazardous waste paint related material that is generated by puncturing used aerosol cans. The inspectors observed one 55-gallon drum in this SAA. The drum was located along the wall, and it was equipped with a can puncture device. The drum was labeled as D001 hazardous waste paint related material. The USA also accumulates used oil and oil contaminated materials at the Transportation Department. The inspectors observed one 200-gallon tank containing used oil, one 55-gallon drum containing used oil filters, and one 55-gallon drum containing oil contaminated rags in this area. The tank was labeled with the words "used oil". EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 11 of 13 Marine Environmental Contaminants Laboratory SAA: The USA manages one SAA for managing hazardous waste that is generated in the Marine Environmental Contaminants Laboratory. The inspectors observed three containers of hazardous waste in this SAA. One container was labeled hazardous waste sulfuric acid, another was labeled hazardous waste HNO3, and the third was labeled hazardous waste HCl. Contingency Plan: 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 February 2023. The plan describes actions facility personnel must take to prevent or respond to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility; it describes arrangements agreed to with the local police department, fire department, and local hospital; and it includes the name and telephone number of the individual identified as the emergency coordinator, and of the individuals identified as alternate emergency coordinators. The plan includes a list of emergency equipment and the location of that equipment at the facility, and that list includes fire extinguishing systems, spill control equipment, communications and alarm systems, and decontamination equipment. Finally, the plan includes a brief evacuation plan, which describes signal(s) to be used to begin evacuation and potential evacuation routes for personnel. The USA also has a quick reference guide, which identifies the potential SAAs and they type and volume of hazardous waste in each area; a diagram of the TSD Building showing where hazardous wastes are treated and stored and routes for accessing these wastes; a street map of the facility in relation to surrounding businesses, schools and residential areas; the locations of water supply; and the name of the emergency coordinator(s) and emergency telephone number(s). Training Records: Facility job descriptions for the Assistant Director of Safety and Environmental Compliance, the Director of Safety and Environmental Compliance, an Industrial Hygiene Specialist, a Safety and Environmental Specialist, a Safety Specialist/Fire Marshal, and a Safety and Environmental Compliance Training Specialist describe the requisite skill, education, or other qualifications, and duties of facility personnel assigned to that position. Waste Manifest Records: Hazardous waste manifest records show that lab pack shipments are sent to several different designated facilities twice each year, and barrel shipments are sent to Tradebe (TND000772186) every quarter. Inspection Records: The inspectors reviewed the USA's available records of weekly inspections of the hazardous waste permitted storage area since the date of the last CEI. The inspection log includes the date and time of the inspection, the name of the person conducting the inspection, and comments EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 12 of 13 related to the observations. Immediately following treatment, treated waste is released from the neutralization tank through the USA sanitary sewer system and ultimately to the City of Mobile's sanitary sewer system. The tank is not used to store hazardous waste. Therefore, no daily inspections of the tank are recorded. 12) Closing Conference The inspectors conducted the exit meeting with William Guess, Anne Foster, and Savannah Wallace. During this meeting, the inspectors stated their preliminary conclusions of the inspection. 13) List of Attachments Attachment 1 - Photo Log: 9 Photos taken on: December 6, 2023 Photos taken by: Laurie Benton DiGaetano Photos taken with: Panasonic DMC TS-5 Digital Camera EPA Property Tag: S09533 14) Signed Digitally signed by LAURIE LAURIE DIGAETANO DIGAETANO Date: 2024.01.25 10:19:08 -05'00' Laurie Benton DiGaetano Environmental Engineer Concurrence ARACELI CHAVEZ Araceli B. Chavez RCRA Enforcement Section Digitally signed by ARACELI CHAVEZ Date: 2024.01.25 10:26:31 -05'00' EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Page 13 of 13 Attachment 1 - Photo Log Nine Photos taken on: December 6, 2023 Photos taken by: Laurie Benton DiGaetano Photos taken with: Panasonic DMC TS-5 EPA Property Tag: S09533 Photo 1: Waste containers on the wooden shelves at the incoming waste processing area in the TSD Building. Photo 2: Waste containers on the wooden shelves at the incoming waste processing area in the TSD Building. EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Photo 3: Containers of universal waste batteries near the roll-up door and the flammable liquid barrel storage area in the TSD Building. Attachment 1 Page 2 of 4 Photo 4: Two 55-gallon drums of waste flammable liquid (xylene, toluene); one 55-gallon drum labeled nonregulated waste; and one 30-gallon drum labeled hazardous waste flammable liquid (formaldehyde, methanol) in the flammable liquid bulking and barrel storage area in the TSD Building. One 30-gallon drum labeled toxic and corrosive hazardous waste containing ferrous ammonium sulfate, sulfuric acid, phosphoric acid, potassium permanganate and water; and two 30-gallon drums labeled toxic, flammable, and corrosive hazardous waste on the floor in the flammable liquid barrel storage and bulking area. Photo 5: Four small lead-acid batteries on a pallet near the universal waste battery containers in the Universal Waste storage area of the Maintenance Division. EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Photo 6: One of two flammable cabinets holding twelve 2-liter bottles of hazardous waste in the Solvent Room. Attachment 1 Page 3 of 4 Photo 7: Mobile cart holding six 5-gallon car-boy containers of hazardous waste in the Solvent Room. Photo 8: SAA in the Landscaping / Grounds Maintenance Area for managing used aerosol cans and another for managing the contents of punctured aerosol cans. EPA-RCRA CEI Report University of South Alabama EPA ID# ALD079474037 December 6, 2023 Photo 9: Secondary containment pallet holding one 55-gallon drum of used oil, which was labeled with the words "used oil," in the Landscaping / Grounds Maintenance Area. Attachment 1 Page 4 of 4