Document mmDEdwEaYRnYaEMKEqNDXxrjd

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: 08/25/2021 RCRA Hazardous Waste Weathermatic Weathermatic 3301 W. KINGSLEY RD Garland, TX 75041 P.O. Box 180205 Dallas, TX 75218-0205 Dallas 972-278-6131 Todd Grant Vice President of Operations FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: NA TXD007333255 NA 332919 Other Metal Valve and Pipe Fitting manufacturing -- Personnel participating in inspection: Debra Pandak EPA Region 6 Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date DEBRA PANDAK Digitally signed by DEBRA PANDAK DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=DEBRA PANDAK, 0.9.2342.19200300.100.1.1=68001003655850 Date: 2021.09.02 08:44:05 -05'00' Debra Pandak JEFFREY YURK Digitally signed by JEFFREY YURK DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=JEFFREY YURK, 0.9.2342.19200300.100.1.1=68001003652717 Date: 2021.08.30 08:31:44 -05'00' Jeff Yurk Date Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Custom Building Products Inc. Inspection Date 08/18/2021 PURPOSE OF THE INSPECTION I, Debra Pandak, EPA Region 6 inspector arrived at Weathermatic at 2:05 pm on 08/25/2021 for an unannounced inspection. I met with Todd Grant, Vice President of Operations for an opening conference. I presented my credentials and informed Mr. Grant that this was an EPA inspection to evaluate the facilities compliance with the Resource Conservation and Recovery Act (RCRA) regulations. The scope of the inspection is a Compliance Evaluation Inspection (CEI) and includes evaluation of the facility's hazardous waste management activities. FACILITY DESCRIPTION Weathermatic manufactures sprinkler systems and controllers. Weathermatic has been operational for 75 years. The facility registered as Very Small Quantity Generator (VSQG) in 2013, until 02/2019 when Weathermatic was registered as a Small Quantity Generator (SQG). In June 2019, they reverted to a VSQG. Section II - OBSERVATIONS EPA's review of RCRAinfo database show Weathermatic generates hazardous wastes from cleaning parts in the manufacturing process or service activities. Wastes include oil water emulsions, non-halogenated solvents, spent acids and caustics. One container storage area is used on-site. EPA's RCRAInfo database and Texas Commission on Environmental Quality (TCEQ) registration data show Weathermatic registered characteristic waste codes: D001, D002, D008, D018, D039, D040. TCEQ Annual Waste Summaries (AWS) were also reviewed for hazardous waste generation volumes. Based on waste generation in 2020, Weathermatic appears to have generated quantities of hazardous waste triggering Small Quantity Generator status requirements (greater than 100 kgs/month generation rate). A copy of the associated manifest was emailed to Mr. Grant following the inspection. Manifest Date: Manifest No. 10/30/2020 001078095 WAS Kgs reported 1,451 kg Section III - AREAS OF CONCERN I provided a Notice of Potential Violation and Opportunity to Confer (NOPVOC) letter to Mr. Grant. The NOPVOC identified the following concerns: 2 Custom Building Products Inc. Inspection Date 08/18/2021 Notification - Failure to notify the EPA or authorized state adequately describing the hazardous waste generating activity at the Facility pursuant to Section 3010(a) of RCRA, 42 U.S.C. 6930(a), and the regulation at 30 TAC 335.6. Hazardous Waste Determination - Failure to conduct a hazardous waste determination pursuant to 40 C.F.R. 262.11 and 30 TAC 335.62. EPA requested information specific to facility operations and hazardous waste management as part of the NOPVOC letter. Section IV - FOLLOW UP EPA extended Weathermatic the opportunity to advise the Agency via a conference call, or in writing, of any further information the EPA should consider with respect to the potential violations of the RCRA and the implementing regulations. Weathermatic has 14 days to notify EPA if interested in participating in an opportunity to confer with the Agency. 3