Document j0o9RGvb8pazEVzmQR6zOk2N

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At JJ CUSTOMS AUTOBODY 3012 420th Street Sioux Center, Iowa 51250 (712) 722-4088 EPA ID Number: IAR000006684 On March 19, 2024 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division (ECAD), I conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at JJ Customs Autobody, located in Sioux Center, Iowa, on March 19, 2024. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. During the inspection, I collected the information and data necessary to determine compliance with the applicable regulatory and statutory requirements. This inspection report and attachments present the results of the CEI. 2.0 PARTICIPANTS JJ Customs Autobody: Joel De Weerd, Owner (1 year with company) EPA: Mark Holcomb, Civil Investigator/Inspector (SEE) 3.0 INSPECTION PROCEDURES On March 19, 2024, I arrived unannounced at the facility's main entrance at about 1330 hours. Initially, I conducted a visual reconnaissance of the facility searching for areas of concern observable from the adjacent public roadways and parking lots. I identified no environmental issues or concerns during this preliminary examination. I entered the facility through the main entrance and stopped at the front office area. I introduced myself and asked for the Facility Manager. I was introduced to Mr. Joel De Weerd, and he escorted me to his office. Mr. De Weerd stated that he is the primary RCRA contact for the facility, and he had been with the company for about one year. Mr. De Weerd told me the only items of personal protective equipment required for our visual inspection at this facility was eye protection in limited areas. At the opening conference, I presented my EPA ID and credentials to Mr. De Weerd. I next explained the purpose and procedures of the inspection. I then presented Mr. De Weerd with a copy of RCRA Section 3007(a), which provides inspection authority. I explained my need to collect accurate information and presented him with a copy of Title 18 U.S. Code, Sections 1001 and 1002. He was made aware of his confidentiality rights, and I informed him that a Confidentiality Notice would be provided at the end of the inspection to make a confidentiality claim if he so desired. Mr. De Weerd acted as the official facility representative during the inspection. The CEI consisted of a discussion of facility operations, waste generation, and waste management; a visual inspection of active waste generation and management areas; and a review of waste management records and documents. I conducted a visual inspection of the following areas: Shop Mix Room Outside North Lot Air Compressor Room Paint Booth See Attachment #1 for the aerial/map views. Document photocopies and photographs were collected as inspection documentation (see Attachments #1-11 and Photos 1-10). The photo log is included as Attachment #2. Information collected during the inspection is documented on an Entry/Exit checklist, the hazardous waste compliance checklists, and in a notebook. I reviewed documents including the following: Safety Data Sheets (SDS), bills of lading, and invoices. I followed the inspection procedures detailed in the RCRA CEI Standard Operating Procedure 2321.01E, unless noted otherwise. At the conclusion of the inspection, I provided Mr. De Weerd with a Receipt for Documents (see Attachment #3), Confidentiality Notice (see Attachment #4), and a Notice of Preliminary Findings (NOPF) (see Attachment #6), which he signed as acknowledgement of receipt. No claim of confidential business information was made by Mr. De Weerd. I provided inspection and compliance assistance documents to Mr. De Weerd during the inspection, some as paper versions and some in electronic PDF via email post-inspection, that included the following: x RCRA Section 3007(a) (EPA Handout) x Title 18 U.S. Code, Sections 1001 and 1002 (EPA Handout) x Confidentiality Notice (Top page of the completed carbonless transfer set) x Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA In Connection with Inspections (EPA Handout) x Receipt for Documents and Samples (Top page of the completed carbonless transfer set) x Instructions for Responding to a NOPF (EPA Handout) x U.S. EPA Small Business Resource Information Sheet (EPA Handout) x Solvent-Contaminated Wipes Final Rule Chart (EPA Handout) 2 x Recycling Electronics (Iowa Department of Natural Resources - IDNR Handout) x Lead-Based Paint Activities (IDNR Handout) x Excluded Solvent-Contaminated Wipe Rule (IDNR Handout) x Battery Recycling/Disposal (IDNR Handout) x Management of Fluorescent Lamps for Businesses (IDNR Handout) x Incompatible Chemicals (IDNR Handout) x Universal Wastes Including Aerosol Cans (IDNR Handout) x TCLP Waste Determination Testing (IDNR Handout) x Industry Sector Notebooks (EPA Handout) x Environmental Compliance Assistance Centers (EPA Handout) x e-Manifest Fact Sheet (EPA Handout) x RCRA Online A Quick Reference Guide (EPA Handout) x Requirements for Used Oil Management Standards (EPA Handout) x Emergency Response Program (EPA Handout) x Commercial Motor Vehicle Transportation System Security & Safety (EPA Handout) x Security Awareness (EPA Handout) x Chemical Facility Anti-Terrorism Standards (Homeland Security Handout) x Iowa Life/Changing Iowa Department of Economic Development - Iowa Environmental Guide for Business (IDNR Handout) x How to Register for RCRAInfo Industry Application for Iowa Facilities (IDNR Handout) 4.0 FINDINGS AND OBSERVATIONS 4.1 Facility Information and Operations JJ Customs Autobody is a commercial autobody repair shop. Mr. De Weerd stated that he had recently purchased the shop from the previous owner and opened his new business on January 1, 2023. He stated that he had worked three years for the previous owner. The previous shop, at this same location, was named Countryside Body Shop. The facility is privately owned by Joel & Allison De Weerd. The business has been open for over 40 years including as Countryside and one year as JJ Customs Autobody. The facility is about 6,000 square feet and operates Monday-Friday 0800-1700 hours, with five employees (this includes two employees for a colocated business called Countryside Signs that he also owns, which makes and applies custom graphic signage to vehicles). Mr. De Weerd estimates they work on about 400 vehicles per year. Mr. De Weerd stated that he was not aware of any previous RCRA inspections at the facility and there had been no spills or activation of their emergency action plan. See Attachment #1 for the facility aerial map views. 4.2 RCRA Status JJ Customs Autobody had not been previously inspected for RCRA compliance. According to RCRAInfo, the facility had most recently notified as a Very Small Quantity Generator (VSQG) on August 16, 1994, as Countryside Body Shop. I verified the facility address and the site contact information with Mr. De Weerd and updated the EPA RCRA Notification Acknowledgement Verification Report to indicate the primary contact's name and phone 3 number, and new business name (see Attachment #5). At the time of this inspection, I determined JJ Customs Autobody to be a VSQG of hazardous waste with less than 100 kg, or 220 lbs, of non-acute hazardous waste generated per month, and generator of used oil. 4.3 Facility Waste Streams and Management Mr. De Weerd stated that the following waste streams are managed by JJ Customs Autobody: Waste Paint and Related Materials - JJ Customs Autobody generates about five gallons (35-40 pounds) of waste paint and solvents per month from vehicle painting operations. This waste had been determined to be D001, F003, and F005 hazardous waste based on process and product knowledge. Mr. De Weerd stated that the paints used are typically latex water-based, but they also use enamel (he estimates about 80% latex water based and 20% enamel) (see Attachment #7 for an example paint SDS and see Attachment 8 for enamel clear coat). The facility uses a paint thinner to clean paint guns (and Attachment #9 for thinner SDS). Mr. De Weerd stated that the facility had not filled their 55-gallon waste paint drum since they opened about 14 months ago and have not had to ship any waste paint yet. During the visual inspection, I observed a 55gallon poly drum of waste paint and solvent, that was about full (see Photos 3-5). Accumulation started when the new business started last January 1, 2023 (about 14 months ago). I did not observe any obvious drum damage or leaks. In the area just outside the Mix Room, I observed a solvent still (see Photo 6). Mr. De Weerd stated that he does not use the still and it has not been used since the previous owner. Soiled Cloth Rags - JJ Customs Autobody generates about 100 soiled cloth rags per month. Mr. De Weerd stated that the facility uses white cloth rags and yellow cloth rags. He stated that the rental white shop rags may get oily and are commercially laundered by A&M Services monthly (see Attachment #11 for shop rags invoice). He also stated that the yellow microfiber cloth rags are used for detailing and buffing cars, and not used with solvents. The yellow rags are laundered in their in-house washer & dryer. During the visual observation, I observed two cloth bags for rags (see Photo 2). The brown bag was for rental white shop rags that are commercially laundered and contained only one mildly soiled rag that appeared dry (no solvents); the left orange bag, was full of yellow microfiber cloth rags used for detailing and buffing cars and laundered in-house. Waste Paper Wipes - JJ Customs Autobody generates about 12 paper wipes per month. These are typically used to clean the paint guns. The dry waste paper wipes are considered nonhazardous waste based on product and process knowledge. Mr. De Weerd stated that the spent wipes are only lightly soiled with paint (mostly latex) and are dry with no free liquid when disposed of in the general trash. Used Oil - JJ Customs Autobody generates about 50 gallons per year of used oil. The used oil is generated from vehicle repairs and preventive oil changes. Mr. De Weerd stated that most of the used oil comes from employee oil changes on their own vehicles. Onsite, the used oil is transferred to a 55-gallon drum in the Air Compressor Room (see Photos 8). The 55-gallon poly drum was 7/8 full, unlabeled, and appeared to be in good condition with no obvious damage or leaks. I informed Mr. De Weerd that the drum of used oil must be labeled with the words "Used 4 Oil." During the visual inspection, Mr. De Weerd added the words "Used Oil" to the 55-gallon drum of used oil (see Photo 9) addressing this potential finding at the time of the inspection. Since this is the first drum of used oil since the business started, they have not had to dispose of the used oil yet. NOPF 1: Failure to label used oil container in the Air Compressor Room with the words "Used Oil" as required in 40 CFR 279.22(c)(1) Spent Used Oil Filters - JJ Customs Autobody generates about 10-15 spent used oil filters per month from oil changes. This waste had been determined to be non-hazardous based on product and process knowledge. Mr. De Weerd stated that that the spent used oil filters are punctured and hot drained for 24 hours and then disposed of in the general trash. The used oil is collected in a 55-gallon used oil storage drum. During the visual inspection, I observed two spent used oil filters draining on top of the used oil drain (see Photo 9 - left in photo). Both appear to be free of any used oil. Scrap Metal - JJ Customs Autobody generates about 2,000 pounds of scrap metal per year from vehicle repair operations. The scrap metal had been determined to be non-hazardous based product and process knowledge. The scrap metal is collected outside behind the shop (see Photo 7). Mr. De Weerd stated that to date they had not had to ship any scrap metal, but when they do he plans to use Post Metal Recycling (Rock Valley, Iowa). Waste Tires - JJ Customs Autobody generates about 30 waste tires per year from vehicle repair operations. This waste had been determined to be non-hazardous based product and process knowledge. The scrap metal is collected outside behind the shop (Outside North Lot). Mr. De Weerd stated that to date they have not had to ship any waste tires. Waste Air Bags - JJ Customs Autobody generates about two waste air bags per year from vehicle repair operations. These air bags had been deployed and determined to be non-hazardous based product and process knowledge. The facility has a core exchange with Billion Automotive (Sioux City, Iowa). I did not observe any waste air bags onsite. Spent Lead-Acid Batteries - JJ Customs Autobody generates about 20 spent lead-acid batteries per year from vehicle repair operations. The spent lead-acid batteries that are managed under Part 266, Subpart G. The facility has a core exchange with Arnold's Motor (Sioux Center, Iowa). I did not observe any spent batteries onsite. Spent Paint Booth Air Filters - JJ Customs Autobody generates about one paint booth air filter once every six months, based on usage. Mr. De Weerd stated that the facility had not replaced the air filters yet and no spent air filters had been generated. Mr. De Weerd stated that once removed, the dry spent paint air filters (non-hazardous waste based on product and process knowledge) would be disposed of in the general trash. General Trash - JJ Customs Autobody generates non-hazardous general trash from repairs, painting, and business office operations. The facility estimates it generates about 16-cubic-yards per month. The waste trash is picked up weekly by Brommer Sanitation (Sioux Center, Iowa) 5 (see Attachment #10 for invoice) and transported to the local landfill. During the visual inspection, I observed one 2 cubic-yard trash container, about full, in the Shop (see Photo 1). 4.4 Other Areas Reviewed Outside Facility Perimeter - I conducted a limited inspection of the outside perimeter of the facility and observed no hazardous waste storage tanks or containers except as noted above. See the aerial and map views in Attachment #1. 5.0 SUMMARY OF FINDINGS NOPF 1: Failure to label used oil container in the Air Compressor Room with the words "Used Oil" as required in 40 CFR 279.22(c)(1) Digitally signed by MARK MARK HOLCOMB HOLCOMB (Affiliate) (Affiliate) Date: 2024.05.10 _____________1_2:_26_:4_5 _-0_5'0_0'______________________ Mark Holcomb Civil Investigator, SEE EDWIN Digitally signed by EDWIN BUCKNER Date: 2024.05.13 _B_U__C_K_N__E_R____1_4:_46_:1_5 _-0_5'0_0'______________________ Amber Whisnant RCRA Section Chief, ECAD/Chemical Branch Attachments: 1) Facility Aerial Map Views (3 pages) 2) Photo Log (10 photos and 12 pages) 3) Receipt for Documents (1 page) 4) Confidentiality Notice (l page) 5) EPA RCRA Notification Acknowledgement/Verification Report (1 page) 6) NOPF (1 page) 7) SDS - Envirobase Paint (20 pages) 8) SDS - Velocity Clearcoat (19 pages) 9) SDS - Primer Thinner (17pages) 10) Invoice - Trash (1 page) 11) Invoice - A&M Commercial Cleaners (1 page) 6