Document mmLVoQmpmrJ0ydNKBjovLZZBJ

US Environmental Protection Agency - Region 2 Caribbean Environmental Protection Division Response and Remediation Branch Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection Facility Name: EPA ID Number: Date of Inspection: Generator Status in Record: Generator Status at the time of inspection: RCRA Permitted: Basis for Inspection: Corrective Action: Project ID Alco High Tech Plastic, Inc. PRR000027003 March 27, 2024 LQG LQG No Core Program No CEPD-RCRA-23-0441 Facility Physical Location: State Road 159, km 13.5, Zona Industrial Cibuco, Corozal, Puerto Rico 00783 (Municipality, PR, zip code) Geographical Coordinates: 1820'22.85" N, 6619'14.87" W Facility Owner: Mr. Gilberto Nieves, President/CEO (787) 692-0297 gilbertonieves@alcohtgroup.com Mailing address: State Road 159, km 13.5, Zona Industrial Cibuco, Corozal, Puerto Rico 00783 Facility Operator: Ms. Waleska Canting, Compliance Manager (939) 599-8532 waleskacanting@alcohtgroup.com Mailing address: State Road 159, km 13.5, Zona Industrial Cibuco, Corozal, Puerto Rico 00783 NAICS: 326100 - Plastics Packaging Film and Sheet (Including Laminated) Manufacturing SIC: 2220 - Manufacture of Plastic Products Area: 6.5 acres of land property Number Employees: 100 Personnel participating in inspection: Eduardo R. Gonzalez, P.E. EPA Region 2-CEPD Enforcement Officer (787) 977-5839 gonzalez.eduardo@epa.gov Status: Final Record Schedule: 1044(c) Multi-media Checklist: ATTACHMENT # N/A Referral: No EPA Lead Inspector Signature/Date X May 24, 2024 Supervisor Signature/Date DAVID CUEVAS- Digitally signed by DAVID CUEVAS-MIRANDA X MIRANDA Date: 2024.05.24 10:39:06 -04'00' Da vid N . Cueva s M ira nd a , Ph.D. 1 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 1 INTRODUCTION On August 11, 2023, a Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection (the "Inspection") was conducted at Alco High Tech Plastic, Inc. (the "Facility" or "Alco High Tech"), pursuant to Section 3007 of RCRA. The Facility is located on State Road 159, km 13.5, Zona Industrial Cibuco, Corozal, Puerto Rico 00783. As part of the Inspection, an opening meeting, walkthrough, documents review and closing meeting were conducted to evaluate Facility's compliance with the requirements that govern hazardous waste generators, universal waste handlers and used oil generators as per RCRA. Alco High Tech is designated in the RCRAInfo1 database as a Large Quantity Generator (LQG). According to RCRAInfo database, Alco High Tech has never been inspected by EPA. On June 16, 2021, the Facility submitted to EPA a "Notification of RCRA Subtitle C Activities (EPA Form 8700-12)" to notify hazardous waste activities as Large Quantity Generator for spent solvents such as ignitable (D001), corrosives (D002), and nonhalogenated solvents (F003), respectively. 2 OPENING MEETING An opening meeting was held between Ms. Waleska Canting, Compliance Manager from Alco High Tech and me. I identified myself as EPA RCRA Enforcement Officer and told the Facility representative that the purpose of my visit was to conduct a RCRA Inspection at the Facility to evaluate its hazardous waste management practices and compliance. I discussed the objectives of my Inspection, and the requirements under RCRA for a Large Quantity Generator (LQG). I asked Ms. Canting to provide me for review Alco High Tech's manifests (last three years), and land disposal records regarding the handling, transportation, and final disposal of hazardous waste generated, and stored at the Facility. I also asked for review the waste analysis plan, weekly inspection records, personnel training requirements, biennial report, waste minimization plan, closure plan, contingency and emergency and preparedness plan, SPCC (Used Oil), and RCRA air emission requirements under 40 CFR 265 Subparts AA, BB & CC compliance reports. Ms. Canting stated that Alco High Tech did not have any knowledge on how to comply with Subparts AA, BB & CC of RCRA requirements, including the areas that might apply as the hazardous waste containers storage area. She specified that containers holding volatile organic wastes were provided by Safety Kleen Environ System as their main carrier of hazardous wastes and other wastes generated at the Facility. I stated that containers holding spent volatile organic waste must comply with the Department of Transportation (DOT) (49 CFR 178 - Specifications for Packagings) requirements in which covers and containers are manufactured tested and sealed in accordance with the, and the United Nations (UN) Performance Oriented Packaging Standards. Based on a review of electronic manifests, it was estimated that approximately over 2,200 pounds of hazardous waste are generated at the Facility. I was told by Ms. Canting that there are one central hazardous waste containers storage area and various hazardous waste satellite accumulation areas 1 RCRA Info and ECHO, EPA's Enforcement Compliance and History Online System Status: Final 2 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 (SAA) for the management of hazardous wastes in the areas of manufacturing of plastic packaging, printing and diluting inks, and cleaning of plastic processes. 2.1 FACILITY PHYSICAL DESCRIPTION AND OPERATION Alco High Tech is an industrial Facility engaged in the manufacturing of flexible, custom, and suitable plastic packagings. The Facility began operations in 1995 in Corozal, Puerto Rico and employs approximately 100 full time employees rotating two shifts from Mondays to Fridays depending on the production demands from 6:00 am to 11:00 pm. Alco High Tech is classified as a light manufacturing industry primarily engaged in the manufacturing, assembly, conversion, and extrusion of plastics packaging for medical devices, pharmaceutical consumers, food packages, industrial packaging, heavy construction bags, commercial packaging, product labels, and a variety of custom and flexible packaging. As part of its manufacturing activities, solid and hazardous wastes are generated. The Facility consists of two (2) large two-story buildings, and five (5) separate freestanding smaller structures, housing the Maintenance Shop, the Mechanical Building (compressors' room), solvents storage, used oil storage and equipment shed. The plant size covers approximately 87,000 sq. ft. in a 6.5 acres of land property in Corozal. Alco High Tech specializes in the manufacturing of flexible and industrial plastic packaging to suit the needs of all customers. Main process steps employed at the Facility during the manufacturing process include: 1) Extrusion of LDPE (low density Polyethylene); 2) Package Pigmentation; 3) Package Film Printing; 4) Film Lamination; and 5) Film Conversion within others. Products manufactured primarily include Bags, labels for packaging, Film and Bags for food packaging food, drugs, and food bottles, etc. Manufacturing activities at Alco High Tech take place using physical processes only. In order to support Facility's manufacturing processes several chemical solvents are used in the manufacturing of flexible and printing of plastic packaging, equipment cleaning, equipment lubrication and glue removal cleaning processes. Most of these materials are stored in a warehouse located on premises. 2.1 PHYSICAL SETTING The site is located at approximately 286 feet above mean sea level. Figure 1 presents the site location on a portion of the US Geological Service (USGS) Topographical Map. Figure 2 presents an aerial photograph of the site. The closest superficial water body is the Rio Corozal located approximately 1.75 miles to the southwest of the site (see ATTACHMENT I). 2.2 SOLID AND HAZARDOUS WASTE GENERATION Typically, solid waste is generated from the manufacturing of plastics packaging, extrusion, conversion, and assembly of a variety of plastic products, discarded raw materials, impacted rags with solvents, cleaning processes and office paperwork. Their solid waste is disposed of in a municipal landfill with Con Waste. According to Facility's record, Alco High Tech is a RCRA Large Quantity Generator of hazardous waste. Hazardous waste generation mostly from the press' s operations and cleaning, and includes the use of solvents like alcohols, acids/ caustics, aerosols, among others. The solvents represent the main Status: Final 3 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 generation of hazardous waste, as well as rags laden with these solvents generated during cleaning and maintenance activities. Waste is accumulated at the Facility's 90-Day Hazardous Waste Accumulation Area for a period not exceeding 90 days and is shipped to an approved, offsite hazardous waste management facilities. Based on a review of the 2023 Hazardous Waste Biennial Report, the Facility generates hazardous wastes including: waste flammable liquids (n-propyl acetate, n-propanol) (D001), waste flammable liquid, toxic (tetrachloroethylene, naphtha) (D001, D018, D039, F002), and waste solids containing flammable liquid (methyl ethyl ketone) (D035, F005, D001). Most of them were flammable spent solvents. All the hazardous waste are disposed of with Safety Kleen Environ System and according to waste quantities, the Facility is classified as a Large Quantity Generator (LQG). Based on a review of the 2023 Hazardous Waste Biennial Report and the RCRA Contingency Plan (Appendix D) the following hazardous wastestreams were identified and depicted in table below. Waste Stream Flammable spent ink with solvent Solids containing ink/solvents Solids containing solvents Rechargeable Lithium batteries Fluorescent lamps Lead acid batteries non-spillable Aerosols can Status: Final Description Flammable liquid from printing and cleaning equipment Rags with alcohols Rags with ethyl acetate Rechargeable batteries used at the site Lamp replacement from facilities Batteries used in the site Lubricants, penetrants, and paints Hazard (EPA waste code) Flammable (D001) Flammable (D001) Flammable (D001) Flammable (D001), Reactive (D003) Universal Wastes Toxic (D009) Universal Wastes Corrosive (D002, D008) Universal Wastes Flammable (D001) Reactive (D003) Universal Wastes 4 Point of Generation Soma Press Approximate Maximum Quantity per Month 3,000 pounds Presses Lamination Facilities 300 pounds 40 pounds 20 pounds Facilities 25 pounds Manufacturing, Warehouse & Truck Fleet Manufacturing, Warehouse & Maintenance 60 pounds 10 pounds CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 Other solid wastes generated at the Facility included discarded plastic residuals and cardboards, imprinted plastics that cannot be recycled, debris from plant maintenance and cleaning activities, paint wastes from painting activities, packaging materials, paper and other waste from Administrative Offices, high and low density polyethlene for recycling of low-quality products or for sale by other plastic companies, and other disposal of sanitation, maintenance, and housekeeping products. 3 FACILITY WALKTHROUGH Ms. Canting accompanied me during the Facility walkthrough. During the facility walkthrough the manufacturing areas where Satellite Accumulation Areas (SAA) were located, supporting units such as Universal Waste storage area, and Used Oil shed, and the 90-Day Hazardous Waste Accumulation Area (HWAA) were inspected as described below. The observations for each area are described below. Refer to Appendix 1 for pictures taken during the inspection. 3.1 PLASTIC EXTRUSION AREA - PLANT NO. 1 Ms. Canting escorted me to initially inspect the Plastic Extrusion area in which a high-volume manufacturing process was ongoing where raw plastic (pellets) is melted and formed into a continuous plastic layer. This process starts by feeding plastic material (pellets) from a hopper into the barrel of the extruder. The material is gradually melted by the mechanical energy generated by turning screws and by heaters arranged along the barrel (see Pictures 1 and 2). Most of the waste generated in this area are plastic residues or discarded plastic layers along with some cardboard boxes. Observations at this area rendered no concerns regarding the generation or management of hazardous wastes. 3.2 PLASTIC EXTRUSION PRINTING AREA (SOMA) - PLANT NO. 1 I proceeded to inspect the Plastic Extrusion Printing (SOMA) area where plastic pellets are forced through a heated nozzle, melting the material, and depositing it on a print surface roll. At the time of the Inspection, I observed one satellite area (SSA) containing one (1) 55-gallon black steel drum with impacted rags contaminated with spent liquid solvent waste of a mixture of propanol and ink, labeled as "Hazardous Waste," and "Paos Sucios con Solventes," and was not identified with its hazard communication pictogram as "Flammable Solids" (see Picture 3). I also observed a second satellite area (SSA) containing one (1) 55-gallon black steel drum with spent liquid solvent waste containing a mixture of propanol mix 80/20 and ink waste, labeled as "Hazardous Waste," and "Propanol Mix 80/20 Con Tinta," and was not identified with its hazard communication pictogram as "Flammable Liquids" (see Picture 4). According to Ms. Canting, the mixture of propanol mix 80/20 and ink waste is generated from ink changes and cleaning of the machine after printing campaigns. There was a third SSA with a washing machine for the cleaning of printing anilox rollers. As explained by Ms. Canting, anilox rollers are part of a printing ink unit and used ink storage medium to provide a Status: Final 5 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 defined amount of ink during the printing process. The SSA contained one (1) 300-gallon stainless steel tank used for cleaning anilox rollers which generates spent solvents characterized as corrosive-oxidizer, and human irritant. The SSA was not labeled with the words, "Hazardous Waste," nor identified with its hazard communication pictogram as "Corrosive Liquids" (see Picture 5). I explained to Ms. Canting that pursuant to 40 CFR 262.15(a)(5), a generator must mark or label its container with the words "Hazardous Waste," and must include an indication of the hazards of the content such as ignitable, corrosive, reactive, or toxic, a hazard communication consistent with the Department of Transportation requirements at 49 CFR Part 172 Subpart E (labeling) or Subpart F (placarding), a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704. As observed by EPA Inspector, all containers were filled with spent solvents, and/or rags impacted with spent solvents which were not clearly labeled, coded, or identified with its hazard communication pictograms. 3.3 INK WAREHOUSE (WIP) AREA - PLANT NO. 1 I proceeded to inspect the Ink Warehouse area where all new ink products are stored in 5-gallon pails (i.e., Cyan, Magenta, Yellow and Black) for immediate use in plastic printing machines (see Picture 6). Observations at this area rendered no concerns regarding the generation or management of hazardous wastes. 3.4 ALCOHOL WAREHOUSE AREA - BACKYARD SHED I proceeded to inspect the Alcohol Warehouse area where all Propanol Mix 80/20 solvent products (i.e., UN 1993 - Flammable Liquids) are stored in two (2) 275-gallon totes for future use in plastic printing machines (see Picture 7). At this area, I observed a part-washer machine that was used to clean anilox and/or plaster rollers until the new SAA Washing Machine unit was installed nearby the plastic printing machines. According to Ms. Canting, this part-washer has been discontinued and emptied over a year ago and is not currently in use (see Picture 8). In addition, I observed one (1) -cut 55-gallon blue plastic drum "open" with impacted rags contaminated with spent liquid solvent waste of a mixture of propanol and ink, not labeled as "Hazardous Waste," nor identified with its hazard communication pictogram as "Flammable Solids" (see Picture 9). I explained to Ms. Canting that pursuant to 40 CFR 262.15(a)(4) a container holding hazardous waste must be closed at all times during accumulation, except when adding, removing, or consolidating waste. Also, I reiterated that pursuant to 40 CFR 262.15(a)(5), a generator must mark or label its container with the words "Hazardous Waste," and must include an indication of the hazards of the content such as ignitable, corrosive, reactive, or toxic or a a hazard communication pictogram, Status: Final 6 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 3.5 SOLVENTS & INK WAREHOUSE STORAGE AREA - BACKYARD SHED I proceeded to inspect the Solvents & Ink Warehouse Storage area in which all new solvent and ink products are stored in 55-gallon drums and 5-gallon pails for future use in the manufacturing of flexible plastic packagings and plastic printing machines. The area is a 20' X 40' open metal shed warehouse with reinforced concrete floor and protected with cyclone fence. It has an estimated storage capacity of over 500 5-gallon containers and drums. As observed, the base floor was free of cracks or gaps, and it was designed to contain leaks and spills in a collection sump. The room is well vented and provided with ambient controlled temperature in the area. Observations at this area rendered no concerns regarding the generation or management of hazardous wastes. 3.6 DIESEL TANKS AREA - BACKYARD I proceeded to inspect the Diesel Tanks area located in the backyard of the Facility. This area consists of an outdoor 3,000-gallon steel double tank and one 1,000-gallon steel tank provided with a zinc roof both storing diesel to supply the energy demand of the manufacturing of flexible plastic packaging. According to Facility record, Alco High Tech has developed and implemented several environmental release prevention, control, and countermeasure plans, which included: An Oil Release Prevention, Control & Countermeasures (SPCC) Plan (40 CFR 112.7); and, Best Management Practices (BMP) plans to prevent releases of oil, hazardous wastes, and hazardous materials to stormwater. Observations at this area rendered no concerns regarding the generation or management of hazardous wastes. 3.7 90-DAY HAZARDOUS WASTE ACCUMULATION AREA (HWAA) I proceeded to inspect the 90-day Hazardous Waste Accumulation area (HWAA) in which all hazardous waste collected from all manufacturing processes and satellite accumulation areas (SSAs) are transferred and stored at this area. Also, all hazardous waste generated from plastic printing machines, as well as any discarded or damaged products are transferred to this area before final disposition with Safety Kleen Environ System. The area is in an annex building where an area on the 1st floor has been habilitated and secured with cyclone fence to store hazardous wastes. It is an enclosed area with reinforced concrete floor and contain a drainage system that flows toward stormwater collection system. It has an estimated storage capacity of 50 55-gallon drums. As observed, the base floor was free of cracks or gaps, and it was designed to contain leaks and spills in a collection sump. The area has a sign posted reading "Hazardous Waste Storage Area - Unauthorized Persons Keep Out." The room is well vented and provided with ambient controlled temperature in the area. Inside the 90-day Hazardous Waste Accumulation area, I observed the following: i. Three (3) 55-gallon blue plastic drums containing aqueous wastes generated from the cleaning activities of the cooling system of the SOMA Printing Machine. All drums' contents were Status: Final 7 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 characterized as non-hazardous and were clearly labeled with the words, "Non-Hazardous Waste," (see Picture 10). ii. Two (2) 55-gallon drums, one steel black and the other plastic white, containing rags impacted with glue and spent acetone and methyl ethyl ketone generated from cleaning activities of the plastic lamination process. Both drums were clearly labeled with the words, "Hazardous Waste," and dated on March 7, 2024, and March 11, 2024, respectively, coded as "D035" (MEK -methyl ethyl ketone), and one of them (steel black) identified with its hazard communication pictograms as, "Flammable." The 55-gallon white plastic drum did not have its hazard communication pictograms (see Picture 11). iii. Seven (7) 55-gallon blue plastic drums containing spent liquid solvent waste made up of a mixture of propanol mix 80/20 and ink waste and coded as "D001" (Ignitable). All drums were clearly labeled with the words, "Hazardous Waste," and dated on February 13, 2024, February 15, 2024, February 20, 2024, February 28, 2024, March 7, 2024, and two March 11, 2024, respectively. Also, all drums were identified with its hazard communication pictograms as, "Flammable Liquids" (Picture 12). iv. Two (2) 55-gallon drums, one steel black and the other plastic white, containing unknown water paints identified with its hazard communication pictograms as, "Flammable Liquids," without proper hazardous waste determination or characterized, "Hazardous Waste," or "Non-Hazardous Waste." Both drums appeared to be abandoned and were covered with dust. I asked Ms. Canting about the origin of theses drums for which she replied that no one knew about from where or when these drums were placed in this storage area for hazardous wastes (see Picture 13). As observed by the EPA Inspector, most of the drums and containers were clearly labeled with the words, "Hazardous Waste," were dated with its accumulation start dates from the date of generation and identified with its hazard communication pictograms as required by RCRA requirements. Additionally, all the drums and containers holding hazardous waste were closed and in good conditions. No leaks were observed on the floor. The 90-day Hazardous Waste Accumulation area at Alco High Tech was equipped with fire alarms, emergency system and security system. However, the emergency telephone located inside of the HWAA was out of service, and I recommended that it must be repaired promptly. 3.8 PLASTIC LAMINATION AREA - PLANT NO. 2 I proceeded to inspect the Plastic Lamination area where two or more layers of material are put together to create multi-layered plastic sheet. Laminating improves the physical properties of a plastic sheet, such as the impact strength, stability, and sound insulation. As part of the plastic lamination, glue is applied to plastic layers to put them together. At the time of the Inspection, I observed two satellite areas (SSAs) containing each one (1) 55-gallon black steel drum with impacted rags contaminated with glue and spent ethyl acetate, labeled as "Hazardous Waste," and "Paos Sucios con Pega y Acetato," and was not identified with its hazard communication pictogram as "Flammable Solids" (see Picture 14). Status: Final 8 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 I reiterated that pursuant to 40 CFR 262.15(a)(5), a generator must mark or label its container with the words "Hazardous Waste," and must include an indication of the hazards of the content such as ignitable, corrosive, reactive, or toxic or a hazard communication pictogram, 3.9 UNIVERSAL WASTE STORAGE AREA - BACKYARD SHED I proceeded to inspect the Universal Waste Storage area in which stores spent fluorescent-lamps, ballasts, and other lamps for the lighting maintenance of the Facility and open areas. The area is a 20' X 20' open metal shed warehouse with reinforced concrete floor and protected with cyclone fence and doors. As observed, the base floor was free of cracks or gaps, and it was designed to contain leaks and spills in a collection sump. The room is well vented and provided with ambient controlled temperature in the area. Inside the Universal Waste Storage area, I observed the following: i. Five (5) square cardboard boxes (1'x1'x 4') packing over forty (40) 4-foot spent fluorescent lamps, some open and not labeled with the words, "Universal Waste," or dated with their accumulation start dates (see Pictures No. 15 and No.16). I stated that pursuant to 40 CFR 273.14(e), each lamp or a container or package in which lamps are contained must be labeled or marked clearly with the words, "Universal Waste-Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." I also stated that pursuant to 40 CFR 273.13(d)(1), a small quantity handler of universal waste 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. 3.10 USED OIL STORAGE AREA - FRONT YARD SHED I proceeded to inspect the Used Oil Storage area where used oil generated from service and maintenance of truck fleet are stored. The area is a 10' X 10' enclosed metal shed warehouse with reinforced concrete floor and protected with cyclone fence. As observed, the base floor was free of cracks or gaps, and it was designed to contain leaks and spills in a collection sump. The room is well vented and provided with ambient controlled temperature in the area. According to Ms. Canting, light mechanic repairs and preventive maintenance to truck fleet is performed at this Facility. Oil and filter changes are part of the truck's preventive maintenance program. Used oil is placed in 55-gallon drums and 5-gallon containers and stored in this Used Oil Storage area. Used Oil impacted materials are disposed of as domestic garbage. No hazardous waste determination has been made on the used oil impacted materials before disposal of and/or mixed with their solid waste. Used oil filters are not punctured and/or crushed, nor hot drained between 24 - 48 hours before been disposed of with the local used oil collector company. At the time of the Inspection, Ms. Canting indicated that Used Oil is collected ad disposed of with Jesus Oil Recycling. Inside the Used Oil Storage area, I observed the following: Status: Final 9 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 i. One (1) 55-gallon blue steel drums with impacted rags with used oil not marked with the words, "Used Oil" (see Picture No. 17). ii. One (1) 55-gallon blue steel drums with impacted used oil filters not marked with the words, "Used Oil" (see Picture No. 18). iii. Five (5) 55-gallon blue/white plastic drums with used oil not marked with the words, "Used Oil" (see Picture No. 19). iv. Seven (7) 5-gallon orange/gray plastic containers with used oil not marked with the words, "Used Oil" (see Picture No. 20). v. Two (2) 5-gallon orang plastic containers "Open" with used oil not marked with the words, "Used Oil" (see Picture No. 20). vi. One (1) 5-gallon yellow plastic containers with spent coolant without a proper hazardous waste determination or characterized, "Hazardous Waste," or "Non-Hazardous Waste" (see Picture No. 19). 4 DOCUMENTS REVIEW The following documents were reviewed as required by the RCRA Program after the walkthrough inspection: 4.1 WASTE ANALYSIS A Full RCRA analysis was provided on a Detailed Profile Report attached to each Manifest prepared by Safety Kleen Environ System containing all Toxic Characteristic Leaching Procedure (Test Method SW 1311) tests, and other analytical methods or knowledge of the waste. All wastestreams generated by the Facility were identified, tested, codified, and disposed of as required by the land disposal restrictions (LDRs). The Waste Analysis Plan appeared to be in compliance. 4.2 MANIFEST RECORDS AND LAND DISPOSAL RESTRICTION FORMS (LDR) Manifests and associated LDRs for all incoming and outgoing shipments for the last three years were reviewed in hard copies and in an electronic format. Most of the hazardous waste are disposed of by Safety Kleen Environ System and/or Clean Harbour to a destination in Bartow, Florida, USA. One of the most recent shipments manifested the disposal of 7,280 lbs (> 1000kg) on February 7, 2024. All appeared to be properly maintained and in compliance. 4.3 PERSONNEL TRAINING RECORDS The Facility provided a Record of Training for the personnel associated with the management of hazardous waste. The Record of Training detailed the kind of training, date, and completion status provided by an outside contractor, Ramon Cardona Environmental Consulting, dated on January 12, 2024. It appeared to be properly maintained and in compliance. Status: Final 10 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 4.4 WEEKLY LOG RECORDS All weekly logs records for daily and weekly SSAs and hazardous waste container storage areas were not available for review. According to Ms. Canting no weekly inspections are conducted at the Facility, therefore it was found not to be in compliance. 4.5 JOB TITLE & DESCRIPTION RECORDS Pursuant to 40 CFR 262.17(a)(7)(iv), large quantity generators must provide for review a job title for each position at the Facility related to hazardous waste management, and the name of the employee filling each job. In addition, it must provide a written job description for each position including the requisite skill, education, or other qualifications, and duties of Facility personnel assigned to each position. Information provided appeared to be properly maintained and in compliance. 4.6 AIR EMISSIONS STANDARD RECORDS Pursuant to 40 CFR 262.17(a)(1)(i) referring to 40 CFR Part 265 Subpart AA, BB, and CC - All Facility record for accumulation of hazardous waste in container related to the RCRA air emission requirements were requested. According to Ms. Canting, Alco High Tech does not have any knowledge that the Facility was required to comply with 40 CFR Part 265 Subparts CC of RCRA requirements for the managment and control of air emissions of hazardous waste stored in containers. All associated information regarding RCRA Subpart CC Air Emissions Standard controls air emissions for containers was found not to be to compliance. 4.7 CONTINGENCY AND EMERGENCY PREPAREDNESS PLAN There was a RCRA Hazardous Waste Contingency Plan, dated April 2023, which outlines the procedures and activities required for the prevention of, and response to, hazardous waste releases at the Facility located in Corozal. In general, the plan provided contingency and emergency preparedness procedures in case of an emergency incident. The plan also provided a list of names and telephones in case of an emergency and proper procedures in a case of an emergency. As observed the RCRA Contingency Plan was ready accessible, and so the plan was also posted and accessible to all employees and provided to emergency agencies. (i.e., Fire Department, Hospitals, Police Department, and Civil Defense). Additionally, the Facility was equipped with alarm systems, sprinkler systems, telephones, certified extinguishers nearby areas where hazardous wastes were stored in the Facility. A "RCRA Contingency Plan Quick Reference Guide RCRA" was also provided for review. All appeared to be properly maintained and in compliance. 4.8 BIENNIAL REPORT The Hazardous Waste Report for 2023 was submitted electronically on February 28, 2024, in RCRA Info Site. The Biennial Report described all the wastestreams generated and managed by the Facility including waste flammable liquids (n-propyl acetate, n-propanol) (D001), waste Status: Final 11 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 flammable liquid, toxic (tetrachloroethylene, naphtha) (D001, D018, D039, F002), and waste solids containing flammable liquid (methyl ethyl ketone) (D035, F005, D001). It appeared to be properly documented and in compliance. 4.9 WASTE MINIMIZATION Pursuant to 40 CFR 262.27, large quantity generator must have a program in place to reduce the volume and toxicity of waste generated to the degree it is economically practicable for the method of treatment, storage, or disposal currently available which minimizes the present and future threat to human health and the environment. The Facility did not have a Waste Minimization Plan (WMP) at Alco High Tech Corozal, and therefore, it was found not to be in compliance. 5 CLOSING MEETING After completion of the walkthrough and document review, I met with Ms. Waleska Canting, Compliance Manager from Alco High Tech to conduct a closing meeting. I indicated that the purpose of the closing meeting is to inform the Facility's representatives about the RCRA observations. I indicated to Ms. Canting that I wanted to discuss some EPA's observations before I can reach a full compliance determination of the RCRA program. Based on EPA Inspection findings, I discussed the following topics that needed Facility consideration: i. EPA Inspector identified some solid waste stored at the Facility without a proper hazardous waste determination or characterized, as "Hazardous Waste," or "Non-Hazardous Waste." ii. At the 90-day Hazardous Waste Accumulation area as part of the emergency preparedness system it was found that emergency telephone located inside of the HWAA was out of service and needed to be repaired promptly. iii. EPA Inspector found various drums and containers located in the HWAA and SAAs that must be marked or labeled with the words "Hazardous Waste," and must include an indication of the hazards of the content such as ignitable, corrosive, reactive, or toxic or a hazard communication pictogram. iv. It is required to conduct weekly inspections that include the inspection of drums and container holding hazardous waste and verify if they are properly closed, and in good working conditions and document each inspection in a notebook and take corrective measures if anything is out of order or insecure. v. Facility is required to comply with the air emissions requirements under RCRA for the managment and control of air emissions of hazardous waste stored in drums and containers. vi. Facility must develop a Waste Minimization Plan to reduce the volume and toxicity of waste generated to the degree it is economically practicable for the method of treatment, storage, or disposal currently available which minimizes the present and future threat to human health and the environment. vii. EPA Inspector identified some cardboard boxes with spent fluorescent lamps that were not labeled with the with the words, "Universal Waste-Lamp(s)," and prevent them from brokage. Status: Final 12 CEPD-RCRA-23-0441 Resource Conservation and Recovery Act Alco High Tech Plastic, Inc. PRR000027003 viii. EPA Inspector identified some drums and containers with Used Oil that were not properly labelled with the words, "Used Oils," some were open, and needed to comply with used oil filter requirements. 6 COMPLIANCE ASSISTANCE The EPA inspector discussed with Alco High Tech Plastic's representative the specific RCRA program regulations that apply to the Facility, and how to stay in compliance in case they decide to minimize or recover waste streams and implement waste minimization/pollution prevention procedures as required by RCRA. 7 CONCLUSION & FOLLOW-UP ACTIONS Based on EPA's observations of the Inspection of regulated areas and completion of a document review session, EPA has determined that the hazardous waste management program at Alco High Tech Plastic was not satisfactory as required by the RCRA program, and potential violations on applicable hazardous waste regulations were found. Therefore, I communicated to Ms. Canting that any further enforcement action regarding potential violations were tentative and are pending administrative review by EPA. 8 ATTACHMENTS I. Figure 1- Facility Location Map and Figure -2 Aerial Photograph II. Photolog and Camera Roll (include all pictures taken during the inspection) Status: Final 13 CEPD-RCRA-23-0441 Title: Figure 1: Alco High Tech Plastics, Corozal, Puerto Rico EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Title: Figure 2: Alco High Tech Plastics, Corozal, Puerto Rico - Aerial Photo EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Picture 1 - ALCO HIGH TECH PLASTICS - At the Plastic Picture 2 - ALCO HIGH TECH PLASTICS - At the Plastic Extrusion area, a high-volume manufacturing process is under- Extrusion area, the material is gradually melted by the mechani- taken where raw plastic (pellets) is melted and formed into a con- cal energy generated by turning screws and by heaters arranged tinuous plastic layer. along the barrel of the extruder. Picture 3 - ALCO HIGH TECH PLASTICS - At the Plastic Extrusion area (SOMA), there was a SSA with (1) 55-gallon black drum with impacted rags with spent liquid solvent waste containing a mixture of propanol and ink, labeled as "Hazardous Waste," and not identified with its hazard communication pictogram as "Flammable Solids." Picture 4 - ALCO HIGH TECH PLASTICS - At the Plastic Extrusion area (SOMA), there was a second SSA with one (1) 55 -gallon black drum with with spent liquid solvent waste containing a mixture of propanol and ink, labeled as "Hazardous Waste," and not identified with its hazard communication pictogram as "Flammable Liquids." Title: Pictures taken by: Alco High Tech Plastics, Corozal , Puerto Rico EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Eduardo Gonzalez March 27, 2024 Picture 5 - ALCO HIGH TECH PLASTICS - At the Plastic Extrusion area (SOMA), there was a third SSA with one (1) 300gallon stainless steel tank used to clean anilox rollers not labeled with the words, "Hazardous Waste," nor identified with its hazard communication pictogram as "Corrosive Liquids." Picture 6 - ALCO HIGH TECH PLASTICS - At the Ink Warehouse area EPA Inspector observed that all new ink products are stored in 5-gallon pails (i.e., Cyan, Magenta, Yellow and Black) for immediate use in plastic printing machines. Picture 7 - ALCO HIGH TECH PLASTICS - At the the Alcohol Warehouse area, it was observed that all Propanol Mix 80/20 solvent products (i.e., UN 1993 - Flammable Liquids) are stored in two (2) 275-gallon totes for future use in plastic printing machines. Picture 8 - ALCO HIGH TECH PLASTICS-- At the Alcohol Warehouse, I observed a part-washer machine that was used to clean anilox and/or plaster rollers until the new SAA Washing Machine unit was installed nearby the plastic printing machines. This part-washer has been discontinued and emptied over a year ago and is not currently in use. Title: Pictures taken by: Alco High Tech Plastics, Corozal , Puerto Rico EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Eduardo Gonzalez March 27, 2024 Picture 9 - ALCO HIGH TECH PLASTICS - At the Alcohol Warehouse, I observed one (1) -cut 55-gallon blue plastic drum "open" with impacted rags contaminated with spent liquid solvent waste of a mixture of propanol and ink, not labeled as "Hazardous Waste," nor identified with its hazard communication pictogram as "Flammable Solids." Picture 10 - ALCO HIGH TECH PLASTICS - At the 90-day Hazardous Waste Accumulation area, I observed three (3) 55gallon blue plastic drums containing aqueous wastes generated from the cleaning activities of the cooling system of the SOMA Printing Machine, all clearly labeled with the words, "NonHazardous Waste." Picture 11 - ALCO HIGH TECH PLASTICS - At the 90-day Hazardous Waste Accumulation area, I observed two (2) 55gallon drums containing rags impacted with glue and spent acetone, clearly labeled with the words, "Hazardous Waste," and dated on March 7, 2024, and March 11, 2024, respectively. Picture 12 - ALCO HIGH TECH PLASTICS- At the 90-day Hazardous Waste Accumulation area, I observed seven (7) 55gallon blue plastic drums containing with spent liquid solvent waste containing a mixture of propanol mix 80/20 and ink waste and coded as "D001" (Ignitable). All drums were clearly labeled with the words, "Hazardous Waste," and dated Feb-Mar 2024. Title: Pictures taken by: Alco High Tech Plastics, Corozal , Puerto Rico EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Eduardo Gonzalez March 27, 2024 Picture 13- ALCO HIGH TECH PLASTICS-- At the 90-day Hazardous Waste Accumulation area, I observed two (2) 55gallon drums, one steel black and the other plastic white, containing unknown water paints identified with its hazard communication pictograms as, "Flammable Liquids," without proper hazardous waste determination as "Hazardous Waste." Picture 14 - ALCO HIGH TECH PLASTICS- At the Plastic Lamination one (1) 55-gallon black steel drum with impacted rags contaminated with glue and spent ethyl acetate, labeled as "Hazardous Waste," and "Paos Sucios con Pega y Acetato," and was not identified with its hazard communication pictogram as "Flammable Solids" Picture 15-ALCO HIGH TECH PLASTICS- At the Universal Waste Storage area, I observed five (5) square cardboard boxes (1'x1'x 4') packing over forty (40) 4-foot spent fluorescent lamps, some open and not labeled with the words, "Universal Waste." Picture 16 - ALCO HIGH TECH PLASTICS- At the Universal Waste Storage area, I oalso bserved five (5) square cardboard boxes (1'x1'x 4') packing over forty (40) 4-foot spent fluorescent lamps, not ldated with their accumulation start dates. Title: Alco High Tech Plastics, Corozal , Puerto Rico EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Pictures taken by: Eduardo Gonzalez March 27, 2024 Picture 17- ALCO HIGH TECH PLASTICS-- At the Used Picture 18 - ALCO HIGH TECH PLASTICS- At the Used Oil Oil Storage area, I observed one (1) 55-gallon blue steel drums Storage area, I observed one (1) 55-gallon blue steel drums with with impacted rags with used oil not marked with the words, impacted used oil filters not marked with the words, "Used Oil." "Used Oil." Picture 19-ALCO HIGH TECH PLASTICS- At the Used Oil Storage area, I observed five (5) 55-gallon blue/white plastic drums with used oil not marked with the words, "Used Oil." Picture 20 - ALCO HIGH TECH PLASTICS- At the Oil Storage area, I observed seven (7) 5-gallon orange/gray plastic containers with used oil not marked with the words, "Used Oil" Title: Alco High Tech Plastics, Corozal , Puerto Rico EPA ID: Project: PRR000027003 CEPD-RCRA-23-0441 Pictures taken by: Eduardo Gonzalez March 27, 2024