Document gxXNX8Q7vmGg9zrVpkRNRky3

RCRA Inspection Report 1) Inspector and Author of Report Paula A. Whiting Environmental Engineer (706) 355-8625 whiting.paula@epa.gov U.S. Environmental Protection Agency, Region 4 61 Forsyth Street, S.W. Atlanta, GA 30303 2) Facility Information Arch Wood Protection Inc. 1579 Kopper Road Conley, Georgia 30288 Clayton County EPA ID: GAD000821934 NAICS: 325320 - Pesticide and Other Agricultural Chemical Manufacturing 3) Responsible Official Dan Kersting Director of Global Operations Arch Wood Protection Inc. 1579 Kopper Road Conley, Georgia 30288 dan.kersting@arxada.com 4) Inspection Participants Dan Kersting Jeff McEachern William Maitland Brett Blackwelder Scarlett Kastner Paula Whiting Arch Wood Protection Inc. Arch Wood Protection Inc. Arch Wood Protection Inc. GAEPD GAEPD US EPA Region 4 Atlanta 5) Date and Time of Inspection March 18, 2024, at 9:10 a.m. EDT EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 1 of 23 6) Applicable Regulations1 Resource Conservation and Recovery Act (RCRA) Sections 3002, 3005 and 3007 (42 U.S.C. 6922, 6925 and 6927), and the regulations promulgated pursuant thereto at 40 Code of Federal Regulations (C.F.R.) Parts 260-270, 273 and 279. Chapter 391-3-11 of the Georgia Hazardous Waste Management Act, adopts and incorporates by reference 40 CFR Parts 260 - 266, 268, 270, 273 & 279. The Georgia Hazardous Waste Management Act, O.C.G.A. 12-8-60, et seq. as amended (Act), Chapter 391-3-11 of the Georgia Rules for Hazardous Waste Management (Rules), and those portions of 40 CFR Parts 260-270, 273, and 279 that are adopted into the Rules by reference. RCRA Permit No. HW-029(T&D)-3 was issued by GAEPD for treatment, corrective action, and post closure of hazardous waste at the site. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)], a large quantity generator (LQG) may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 12-8-66 of the GHWMA, Ga. Code Ann. 12-8-66 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)] (hereinafter referred to as the "LQG Permit Exemption"). Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.15(a)], a generator may accumulate as much as 55 gallons of non-acute hazardous waste and/or either one quart of liquid acute hazardous waste at or near the 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 12-8-66 of the GHWMA, Ga. Code Ann. 12-8-66 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the satellite accumulation area conditions listed in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.15(a)] (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to Ga. Comp. R. and Regs. 391-3-11-.18 [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, or lamps, calculated collectively) at any time. 7) Purpose of Inspection The purpose of the inspection was to conduct an unannounced RCRA compliance evaluation inspection (CEI) to determine the compliance of Arch Wood Protection Inc., EPA ID Number: 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. EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 2 of 23 GAD000821934 with the applicable regulations and RCRA Permit No. HW-029(T&D)-3. This was an EPA lead inspection. 8) Facility Description Arch Wood Protection Inc. (Arch Wood) in Conley, Georgia, develops and manufactures several lines of wood preservatives for indoor and outdoor residential, commercial, and industrial use to help increase the durability and resistance of wood products. The use of wood treatment chemicals in residential and commercial applications include decks, retaining walls, fences, and structural members. Treated lumber in industrial applications are used in utility, highway, marine, and heavy construction projects. The following chemicals are manufactured at the facility: Wolmanac CCA (Copper Chromated Arsenate), Chemonite ACZA (Ammoniacal Copper Zinc Arsenate), Wolman Copper Azole/CAC, Wolmanized Erawood, and Liquid Borate. The facility is divided into three manufacturing areas, including the Arsenic Acid Plant, the Copper Oxide Plant, and the Mix Plant. In the Acid Plant, Arch Wood produces arsenic acid for use as an intermediate material in the production of Wolmanac CCA and Chemonite. Arsenic acid is produced by reacting arsenic trioxide, nitric acid, and potassium iodide (as a catalyst). Routine hazardous wastes generated in the Acid Plant consists of filter cakes from product filtering in the Oberlin Filter (a liquid/solid separation filter) and arsenic contaminated debris. The term "contaminated debris" used in the report includes contaminated personal protection equipment, spill cleanup materials, and other contaminated items. In the Copper Oxide Plant, Arch Wood manufactures Chemonite ACZA, liquid borate and Wolman Copper Azole/CA-C. The copper oxide intermediate product is produced from copper metal, ammonia, sulfuric acid, and oxygen. Chemonite ACZA is produced by reacting copper oxide, zinc oxide, ammonia, carbon dioxide and arsenic acid. Liquid borate is produced by dissolving boric acid in water and monoethanolamine. Wolman Copper Azole/CA-C is produced by dissolving recycled copper metal in monoethanolamine and water. The Copper Oxide Plant routinely generates hazardous waste contaminated debris. In the Mix Plant, Arch Wood combines chromic acid, copper oxide, arsenic acid, and process water in CCA mix tanks. Routine hazardous wastes generated in the Mix Plant consist of filter cakes from CCA filtering operations and hazardous waste contaminated debris. The Tech Center houses six of the laboratories for analysis of various wood treatment products. Arch Wood owns the property for the Tech Center and Production Facility, as well as the land between the two facilities. The Tech Center and Production Facility appeared to be within one contiguous property. Arch Wood operates both locations under same EPA ID number. Arch Wood recycles production wastewaters back into the process where it was generated. Hazardous wastes generated by Arch Wood include contaminated debris, filter cake, liquid EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 3 of 23 waste from the Acid and Mix Plants, spent solvents in the laboratory, ignitable waste material from laboratories in lab packs, over packs, and debris samples. Other materials generated by Arch Wood which are regulated under RCRA include used oil and universal waste. The facility also includes maintenance shops, a tank farm, materials warehouses, and laboratories. Two laboratories are located within the manufacturing areas and six laboratories are located at the Technical Center (Tech Center). Raw materials used in the production process include arsenic trioxide, metallic copper, chromic acid, oxygen, ammonia, and sulfuric acid. Arch Wood encompasses approximately 34 acres with 17 acres in production and operates 24 hours per day, 7 days per week in three shifts. Arch Wood employs approximately 180 full time employees with 85 employees in production and 40 employees handling hazardous waste. Arch Wood has RCRA Hazardous Waste Permit # HW-029(T&DS)-3. The permit, renewed on November 17, 2016, is for the following activities: Treatment of filter cakes (D004/D007) in a sludge dryer ("J-Mate Sludge Dryer"). The JMate Dryer is operated to reduce the overall volumes of hazardous waste generated and to recover arsenic acid, which is reclaimed back into the production process; Post-closure care of Regulated Units No. 2 and No. 3; and Corrective action for contaminated soil and groundwater. The most recent Hazardous Waste Generator Notification (EPA Form 8700-12), dated February 25, 2020, characterized the facility as a large quantity generator (LQG) of hazardous waste. Waste codes from the EPA Form 8700-12 include D001, D002, D003, D004, D006, D007, D010, F003, P010, P012, U003, U051, U154. The facility notified as a small quantity handler of universal waste and a used oil generator. 9) Previous Inspection History This facility was last inspected on April 13, 2022, by Georgia Environmental Protection Department. Deficiencies were noted. 10) Findings On March 18, 2024, EPA inspector Paula Whiting, accompanied by Georgia Environmental Protection Department (GAEPD) inspectors Brett Blackwelder and Scarlett Kastner arrived at Arch Wood Protection Inc. at approximately 9:10 a.m. EDT. Mr. Dan Kersting, Director of Global Operations, Mr. Jeff McEachern, EHS Manager, and Mr. William Maitland, Environmental Engineer, received the inspectors. The inspectors introduced themselves, showed their credentials to Mr. Kersting, and explained the purpose of the visit. The inspectors described the anticipated use of a digital camera during the inspection and provided a request for records. The EPA inspector explained 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 EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 4 of 23 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 the EPA. The company did not assert a business confidentiality claim. Mr. Kersting, Mr. McEachern, and Mr. Maitland 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 facility representatives led the inspectors on a tour of the facility operations. Below is a description of the observations made during the inspection. 11) Inspection Observations 11.1 Rework Area The tour began at tote storage area near the entrance of the facility. Mr. Maitland explained that during the weekend he consolidated 40 275-gallon totes into a railcar for shipment to a sister facility in Washington state. The empty totes were stockpiled in the Rework Area for reuse. The inspectors observed totes filled with liquid (Pictures 1-2). Mr. Kersting explained that the totes contained washwater that would be reused in the process and that Mr. Maitland was tasked with reducing the volume of totes. Some of the totes had written markings on the side to identify the contents or the area where the tote was generated. Mr. Kersting explained that the facility was a zero-discharge plant and all the wastewater from the processes would eventually be reused at the plant. 11.2 Maintenance The Maintenance Shop had two satellite accumulation containers (Pictures 3-4). At the time of the inspection, the maintenance staff had emptied the contents of the two yellow wheeled trash cans into an open metal bin. The bin was then moved to another area. The inspectors observed that the trash cans were closed and labeled. The first container was labeled Universal Waste Aerosol Cans and the second container was labeled Hazardous Waste. The universal waste was stored in the loft of the Maintenance Shop. The inspectors observed three 4-foot boxes of universal waste lamps. Two boxes were not closed or dated, and one box was not labeled. Two 5-gallon containers of universal waste batteries that were closed, labeled, and dated. Mr. Maitland closed, labeled, and dated the boxes during the inspection. Pursuant Ga. Comp. R. and Regs. 391-3-11-.18 [40 C.F.R. 273.13(d)], a SQHUW must manage universal waste lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.18 [40 C.F.R. 273.14(e)], a SQHUW must label or mark each lamp or container of lamps clearly with one of the following phrases: "Universal Waste-Lamp(s)," or "Waste Lamp(s)," or "Used Lamps." EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 5 of 23 Pursuant to Ga. Comp. R. and Regs. 391-3-11-.18 [40 C.F.R. 273.15(a) and (c)], a SQHUW may accumulate universal waste no longer than one year and must to be able to demonstrate the length of time that the universal waste has accumulated from the date that it became a waste or was received. 11.3 Copper Plant The Copper Plant is used to manufacture Chemonite ACZA, liquid borate, Wolman Copper Azole/CA-C, and copper oxide. The inspectors observed numerous 275-gallon containers staged outside the Copper Plant (Pictures 8-9). Mr. Kersting explained that the materials were generated within the Copper Plant and accumulated in the containers for reuse in copper production. The inspectors entered the Copper Plant and observed the following: Five 275-gallon containers of copper carbonate to be reworked (Pictures 10-11). The tops of the containers were cut off. At the time of the inspection, some of the containers of copper carbonate appeared to have discarded debris mixed with copper carbonate; and Supersacks of copper oxide (Picture 12). Mr. Kersting explained this is raw material used in the copper production. The inspectors noted that the raw material was being wasted on the floor and stated that to Mr. Kersting. 11.4 Copper Oxide Plant Outside the Copper Plant was a small rework area for the Copper Oxide Plant that was adjacent to the Copper Plant (Picture 13). Several 275-gallon containers of rework material were observed in this area. Inside the Copper Oxide Plant, the inspectors observed the following: One satellite accumulation area (SAA) container for personal protection equipment that had recently been emptied. The container was closed and labeled; and Two 5-gallon containers of unknown blue material (Picture 14). When asked, Mr. Kersting and Mr. McEachern stated they were not sure what the material was and why it was left there, but they would have the contents identified. The inspectors stated a hazardous waste determination was required. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Code Ann. 12-8-62(20) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11]. A 275-gallon container of reactor cleanout (Pictures 15-16). When asked, Mr. Kersting and Mr. McEachern did not know if the reactor cleanout was hazardous. The inspectors stated a hazardous waste determination was required. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11], a person who generates a solid waste, as defined in Ga. Code Ann. 12-8-62(20) [40 C.F.R. 261.2], must make an accurate determination as to whether that waste is a hazardous waste in order to EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 6 of 23 ensure wastes are properly managed according to applicable RCRA regulations articulated in Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.11]. The sump area flooded with blue water from the Copper Oxide operations (Picture 17). The water contained 1% ammonia. Mr. Kersting explained the entire area was a secondary containment and the water would be reused in the process; and The floor inside the Copper Oxide Plant secondary containment area had built up residue from the process (Picture 18). Currently the process was undergoing maintenance and regular housekeeping had not been maintained. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(6)], which incorporates Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.251], and is a condition of the LQG Permit Exemption, a generator is required to maintain and operate its facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. Two vacuums used to remove excess material inside the secondary containment area (Picture 19). However, the vacuums were not working at the time of the inspection; and A large plastic bag of spent filter bags from the copper metal ammonia process that was installed in 2022 (Picture 20). The process sat idle for 18 months, but recently operated on March 16th and 17th, thus generating the spent filter bags. Mr. Kersting and Mr. McEachern did not know if the spent filters were hazardous. The inspectors stated a hazardous waste determination was required. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(6)], which incorporates Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.251], and is a condition of the LQG Permit Exemption, a generator is required to maintain and operate its facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. 11.5 Main Rework Container Storage The inspectors observed numerous 275-gallon containers stored near the Copper Plant and the Copper Oxide Plant (Picture 8). The inspectors inquired about the status of the material in the containers and Mr. Kersting stated the materials in the containers were generated from various production processes within the facility and were accumulated in the 275-gallon containers for reuse in the facility's production. The inspectors also asked about the length of time the containers had been stored in this area and others, and Mr. Kersting stated that he, Mr. McEachern, and Mr. Maitland were recently employed at the facility, and tasked to clean up the issues caused by the previous management and staff. The gentlemen were aware that some of the 275-gallon containers had been stored on site for longer than a year. The inspectors requested the container inventory, the contents of each container, the length of time and number of containers on site. EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 7 of 23 11.6 Micro Copper Plant Building Mr. McEachern explained no hazardous waste was generated in the Micro Copper Plant Building, and because the proprietary process pictures could not be taken in this area. However, the inspectors did observe the following: Poor housekeeping throughout the building; Broken supersacks and spilled material all over the floor, the machinery, and the piping; Trash thrown into the rework containers that are filled with rework material; and Visible tracks from the front loaders tracking material out of the plant. The inspectors expressed concern that the raw materials and the rework materials were not being stored to prevent release to the environment. 11.7 Mix Plant The Mix Plant had four SAA containers for personal protective equipment staged throughout the two-floor building (Pictures 21-22). The containers were observed closed and labeled. Downstairs, in the Mix Plant, was a three-sided bin that was labeled as an SAA (Pictures 23-24). Inside the bin, were several trash bags of spent personal protective equipment and had a net tarp covering the top. The bin was covered, labeled, but not dated. The inspectors explained that the bin was over 55-gallons and was not an SAA but a central accumulation area (CAA) and should have a start accumulation date. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(5)(i)], which is a condition of the LQG Permit Exemption, a generator must mark or label its containers with the following: the words "Hazardous Waste"; an indication of the hazards of the contents; and the date upon which each period of accumulation begins clearly visible for inspection on each container. The inspectors continued walking through the Mix Plant and noticed the product storage area contained finished product and material to be reworked. In addition, the inspectors observed the downstairs floor drain was filled with overflowed process material. Mr. McEachern assured the inspectors that the material would be placed back into the Mix Plant process. 11.8 90-Day Hazardous Waste Roll-Off Outside the Mix Plant was a 20-cubic yard roll-off of hazardous waste (Pictures 25-28). At the time of the inspection, the roll-off was leaking hazardous waste onto the ground. Water was observed on the tarp covering the roll-off, and Mr. Kersting released the rainwater to the ground. However, Mr. Kersting nor Mr. McEachern could determine the cause of the leak. Absorbent was applied to the release during the inspection. The roll-off was observed closed, labeled, and dated February 1, 2024. A trash roll-off was observed in this area (Picture 29). No hazardous waste was observed inside the roll-off. EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 8 of 23 Outside the doors of the Mix Plant was a rework area with numerous 275-gallon containers (Picture 30). Mr. Kersting explained that containers would be reused in the Mix Plant process and were being stored in the secondary containment area. However, the inspectors observed that several containers were outside the secondary containment area and expressed concern that if a forklift and any other heavy machinery pierced and/or damaged one or more totes that the rework material would be released into the storm drains. 11.9 Quality Control Lab An SAA was observed near the door to the lab. The container had discarded personal protective equipment and rags. The container was closed and labeled. As the inspectors were informed earlier by Mr. Kersting, materials tested from the processes were returned to the processes and not discarded as hazardous waste. 11.10 Truck Loading The truck loading area contained an 18,000-gallon railcar being loaded with ammonia rework material to be sent to the Washington facility for reuse (Picture 31). An SAA for personal protective equipment and discarded rags was observed closed and labeled. 11.11 3-Sided Warehouse The inspectors observed one small yellow three-sided bin and two large gray 3-sided bins. The middle gray bin contained bags of discarded personal protective equipment collected from around the facility that morning. The bin was not closed, not labeled, and no start accumulation date. The inspectors explained that by moving the hazardous waste from the SAA containers into this bin, a CAA was created. Mr. Maitland immediately had the bin labeled and dated. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(5)(i)], which is a condition of the LQG Permit Exemption, a generator must mark or label its containers with the following: the words "Hazardous Waste"; an indication of the hazards of the contents; and the date upon which each period of accumulation begins clearly visible for inspection on each container. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(1)(iv)], which is a condition of the LQG Permit Exemption, (A) a container holding hazardous waste must always be closed during accumulation, except when it is necessary to add or remove waste; and (B) A container holding hazardous waste must not be opened, handled, or stored in a manner that may rupture the container or cause it to leak. Further inside the three-sided warehouse was a used oil storage area (Pictures 34-35). The inspectors observed obsolete equipment to be discarded with used hydraulic oil inside the secondary containment, two 55-gallon used oil containers with funnels sitting on secondary containment filled with used oil, and a release of used oil on the ground beside the secondary containment. The inspectors stated that the secondary containments were not storage and required to be cleaned out and empty in the event of a release. The used oil released to the ground needed to cleaned up with absorbent to prevent further released to the environment. EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 9 of 23 Pursuant to Ga. Comp. R. and Regs. 391-3-11-.17(1) [40 C.F.R. 279.22(c)(1)], containers and aboveground tanks used to store used oil at generator facilities must be labeled or marked clearly with the words "Used Oil." Pursuant to Ga. Comp. R. and Regs. 391-3-11-.17(1) [40 C.F.R. 279.22(d)], upon detection of a release of used oil to the environment, the facility must clean up and manage properly the released used oil and other materials. An SAA was observed near a workstation and beside a spill kit. The SAA was closed and labeled. 11.12 Arsenic Acid Plant The inspectors were informed that the Arsenic Acid Plant stopped operations in the first quarter of 2023. Mr. Kersting stated that the desire is to shut down the Arsenic Acid Plant permanently. The plant used to manufacture the acid needed for production, but currently purchase the acid from Tetra Tech and First Environmental. An SAA container was inside the plant and was observed closed and labeled. 11.13 Tech Center The inspectors toured the Tech Center with Mr. Charles Walker. The inspectors observed the following: The Tech Center had several small SAA containers located throughout the lab (Pictures 3640). The containers were observed closed and labeled; The CAA located in the Pilot Plant, was a gaylord container with a plastic liner (Pictures 4142). The container held discarded personal protective equipment and debris, and was observed closed, labeled, and dated March 5, 2024; The universal waste storage was a shelving unit with a one-gallon container of spent batteries that was closed, labeled, and dated (Picture 43); A yellow metal flammable storage cabinet held with a 30-gallon container of hazardous waste flammable liquid (Pictures 44-45). The container was an SAA that was closed and labeled; and The outside shed contained a yellow flammable metal cabinet which was the lab pack CAA. Inside was a 55-gallon container labeled Waste Liquid Flammable that was closed (Picture 46-47). A four-foot container of universal waste lamps was observed closed, labeled, and dated January 3, 2024 (Pictures 48-49). 12) Records Review The inspectors requested the training records, the contingency plan, the weekly inspection records, the waste minimization plan, the Post Closure Care Permit, the rework container inventory, the 2022-2023 hazardous, non-hazardous, and used oil manifests. The generator status notification (EPA Form 8700-12) was last updated February 25, 2020. EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 10 of 23 The inspectors requested the training records for the employees handling hazardous waste. Forty-three employees received 8-hour HAZWOPER training via Red Vector computer-based training starting December 18, 2023, until March 2024. Thirteen employees received facility specific Hazardous Waste, RCRA and Stormwater Training on November 9, 2023, from William Maitland. Mr. Maitland received the computer based RCRA Hazardous Waste Refresher Webinar from Lion Technology on December 12, 2023. Job titles and descriptions were provided and reviewed. At the time of the inspection, Mr. Jeff McEachern's training records were currently unavailable due to his recent transfer to the facility. Mr. McEachern was going to contact the Arxada human resources staff in California to get copies of his records. Mr. Dan Kersting was not current on his external 8-hour HAZWOPER refresher. The inspectors stated that if Mr. Kersting was going to continue actively working in and around the production areas (i.e., Arsenic Acid Plant) that he was required to update his 8-hour HAZWOPER refresher training. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(7)], which is a condition of the LQG Permit Exemption, (iii) Facility personnel must take part in an annual review of the initial training required by this section. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(7)], which is a condition of the LQG Permit Exemption, (iv) the generator must maintain training records that include, among others: the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; a written job description for each position; a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position; and records documenting that the training required has been given to and completed by Facility personnel. On May 10, 2024, Mr. McEachern emailed the inspectors the training records for the thirteen employees which included the 2022-2024 training. However, Mr. McEachern still did not provide his training records for three years as requested. The inspectors requested the Contingency Response Plan for review. The plan included an emergency contact list, an evacuation map, a fire extinguisher inspection list, a list of emergency response equipment, and the Quick Reference Guide. However, the documentation (i.e., green return receipt cards, emails) that copies of the current contingency plan were provided to the local emergency response agencies (i.e., fire, police, hospital) were not available. Pursuant to Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.17(a)(6)], which incorporates Ga. Comp. R. and Regs. 391-3-11-.08(1) [40 C.F.R. 262.256], and is a condition of the LQG Permit Exemption, a generator must: (a) attempt to make arrangements with the local authorities identified, as appropriate for the type of waste handled at the Facility and the potential need for the services of these authorities, and (b) maintain records EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 11 of 23 documenting the arrangements made. The weekly inspection records for the three CAAs were requested and received. The Annual Waste Minimization Plan dated February 29, 2024, was reviewed. The Post Closure Care Permit for Regulated Units 2 (SWMU 2 - Mix Plant) and 3 (SWMU 3 - Tank Farm) was reviewed. Mr. Maitland provided his spreadsheet on the Rework Container Inventory. At the time of the inspection, the facility had 2,376 275-gallon containers on site that contained rework material for reuse. Mr. Maitland had spent the previous weekend consolidating 40 275-gallon containers into the 18,000-gallon ammonia railcar for shipment to the Washington facility. The inspectors stated that though the inventory was reduced, the number of containers on site was still significant and the inventory needs to be reduced by 75% in a year. Otherwise, the inventory would be considered speculative accumulation and thus illegal storage. Hazardous and non-hazardous manifests were reviewed for 2022-2023. Hazardous wastes were shipped to MKC (EPA ID GAD000616387) in Doraville, GA, Chemical Waste Management (EPA ID ALD070513767) in Emelle, AL, Michigan Disposal Treatment Plant (EPA ID MID000724831) in Belleville, MI, and US Ecology Idaho Inc. (EPA ID IDD073114654) in Grand View, ID. The nonhazardous waste was shipped to Republic Pine Ridge Landfill in Griffin, GA. The land disposal restriction forms were reviewed. 13) Summary The inspectors conducted the exit meeting with Mr. Kersting, Mr. McEachern, and Mr. Maitland. During this meeting, the EPA and GAEPD presented the preliminary results of the inspection. Arch Wood Protection Inc. was inspected as a LQG of hazardous waste. On April 18, 2024, Mr. McEachern emailed to the inspectors the corrective responses taken by Arch Wood that included: 1. Summary table that lists the number of findings with recommendations and status updates; 2. Leak investigation report that stems from drip release coming from the 25-yard roll off bin#25320; 3. Tote Reduction Plan. The spread sheet found therein with contents thereof tracks tote usage and will be submit monthly via email to you; 4. Tote Management Protocol; and 5. PDF copies of the missing Designated Facility to Generator manifests. 14) List of Attachments Attachment A - Photo Log: Arch Wood Protection, Inc. EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 12 of 23 15) Signed Digitally signed by PAULA PAULA WHITING WHITING Date: 2024.05.17 10:51:24 -04'00' Paula A. Whiting Environmental Engineer 16) Concurrence Digitally signed by ALAN ALAN NEWMAN NEWMAN Date: 2024.05.18 11:52:28 -04'00' Alan R. Newman Acting Chief RCRA Enforcement Section EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 13 of 23 ATTACHMENT A ARCH WOOD PROTECTION INC. CONLEY, GEORGIA COMPLIANCE EVALUATION INSPECTION PHOTOGRAPHS February 12, 2024 Photos taken by Paula A. Whiting Camera Type: Olympus Tough Serial Number: SC7374 EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 14 of 23 Picture 1 - Rework Area with empty totes Picture 4 - Maintenance SAA roll-off cart Picture 2 - Rework Area Picture 5 - Maintenance universal waste storage Picture 3 - Maintenance SAA roll-off cart EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 15 of 23 Picture 6 - Maintenance universal waste lamps Picture 9 - Copper Plant Rework Area Picture 7 - Maintenance universal waste batteries Picture 10 - Copper Plant tote of copper carbonate to rework Picture 8 - Copper Plant and Rework Container Storage EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Picture 11 - Copper Plant tote of copper carbonate to rework Page 16 of 23 Picture 12 - Copper Plant supersack of copper oxide Picture 15 - Copper Oxide Plant reaction cleanout tote Picture 13 - Copper Oxide Plant totes to be reworked Picture 16 - Copper Oxide Plant reaction cleanout tote Picture 14 - Copper Oxide Plant containers of unknown material Picture 17 - Copper Oxide Plant sump area EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 17 of 23 Picture 18 - Copper Oxide Plant ground residue Picture 21 - Mix Plant SAA Picture 19 - Copper Oxide Plant vacuums Picture 22 - Mix Plant SAA label Picture 20 - Copper Oxide Plant bag of spent filter bags EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Picture 23 - Mix Plant CAA bin Page 18 of 23 Picture 24 - Mix Plant CAA bin Picture 27 -90-Day HW Roll-off Picture 25 - 90-Day HW Roll-off with leak Picture 28 -90-Day HW Roll-off Picture 26 -90-Day HW Roll-off label EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Picture 29 - Garbage Roll-off Page 19 of 23 Picture 30 - Mix Plant Rework Area Picture 33 - Three-Sided Warehouse CAA Picture 31 - Truck Loading Area Picture 34 - Three-Sided Warehouse used hydraulic oil Picture 32 - Three-Sided Warehouse CAA EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Picture 35 - Three-Sided Warehouse used oil storage Page 20 of 23 Picture 36 - Tech Center Lab SAA Picture 38 - Tech Center Lab SAA Picture 37 - Tech Center Lab SAA EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Picture 39 - Tech Center Lab SAA Picture 40 - Tech Center Lab SAA Page 21 of 23 Picture 41 - Tech Center Pilot Plant CAA Picture 44 - Tech Center Pilot Plant flammable cabinet SAA Picture 42 - Tech Center Pilot Plant CAA Picture 45 - Tech Center Pilot Plant flammable cabinet SAA Picture 43 - Tech Center Pilot Plant UW Storage EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 22 of 23 Picture 46 - Tech Center Outside Shed Lab Pack CAA Picture 49 - Tech Center Outside Shed UW Storage Picture 47 - Tech Center Outside Shed Lab Pack CAA Picture 48 - Tech Center Outside Shed UW Storage EPA-RCRA CEI Report Arch Wood Protection Inc. EPA ID: GAD000821934 March 18, 2024 LSASD Project ID: 24-0070 Page 23 of 23