Document o9NVoNwxpn1Ep5g30xJn35XmX

Report Prepared by: Report Approved by: RCRA COMPLIANCE EVALUATION INSPECTION Lindeblad Piano Restoration LLC 158 West Clinton Street Dover, New Jersey NJR986659209 June 7, 2023 ROBERT Digitally signed by ROBERT MORRELL _M_O__R_R_E__L_L________D_ate_: _20_23_.0_7._13_1_4:4_2_:46_-_04_'0_0' Robert Morrell, Geologist Monitoring Operations Section Date: ________________ Digitally signed by PHILIP PHILIP COCUZZA COCUZZA _________________D_ate_: _20_23_.0_7._13_1_5:0_0_:01_-_04_'0_0' Philip Cocuzza, Supervisor Monitoring Operations Section Date: ________________ Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Page 2 of 9 Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Objective A RCRA Compliance Evaluation Inspection (CEI) was conducted at Lindeblad Piano Restoration LLC on June 7, 2023. The purpose of the inspection was to obtain information on the facility's hazardous waste management program. This information will be used to determine compliance with regulations pertaining to the Resource Conservation and Recovery Act (RCRA). Survey Participants Lindeblad Piano Restoration LLC Chad Tomlin, Director of Operations and Purchasing chad@lindebladpiano.com, 888-5874266 U.S. Environmental Protection Agency Robert Morrell, Geologist morrell.robert@epa.gov, 732-906-6804 Facility Description Lindeblad Piano Restoration is located at 158 West Clinton Street in Dover, New Jersey. The company started the piano restoration business in Brooklyn, New York, in 1920. The business moved to New Jersey in the 1950's and has been at the present location in Dover, New Jersey, for approximately 10 years. All piano restoration activities are conducted at a 25,000 square foot facility in Dover. There are 23 full time employees working eight hours per day, Monday through Friday. The restoration process involves rebuilding, refinishing, and tuning the piano to its original specifications. Lindeblad Piano Restoration restores approximately 300 pianos per year. Depending on the complexity of the job, the restoration process can take from 3 weeks to 6 months. After the initial consultation, the piano is picked up and delivered to the restoration studio. After the inspection and evaluation, a proposal is developed, and the restoration process begins. All the parts can be restored or replaced, including the soundboard, pinblock, harp, strings, dampers, pedals, keys, and cabinet. In the Finishing Department, the cabinet is restored by refinishing the original wood. A chemical stripper is used to remove the varnish. After sanding, a stain is applied by hand or paint is applied by spraying. A clear coat lacquer or polyurethane is then applied by spraying. In the Action Room, the piano is reassembled with the finished parts. The piano is tuned and prepared for delivery to the customer. After delivery, the piano is fine-tuned, and a final inspection is performed. Page 3 of 9 Lindeblad Piano Restoration LLC NJR986659209 Water and Wastewater Inspection Date: June 7, 2023 Water for the building is supplied by the City of Dover. There is no process water used in the piano restoration activities. Sanitary wastewater is discharged to the local POTW. Solid and Hazardous Waste Management Waste chemical stripper is generated during removal of the original varnish or paint in the Finishing Department. The waste stripper is placed in a 55-gallon drum in the Chemical Stripper Room. There are two spray booths in the Finishing Department. One spray booth is used for colored paints and varnishes. The other spray booth is used for clear coat lacquers. Waste paint thinner is generated during cleaning of the spray guns in the spray booths. The waste paint thinner is placed in a 55-gallon drum in the Chemical Stripper Room. Used rags are generated during refinishing operations. The used rags are placed in a 5-gallon metal container in the Chemical Stripper Room. The paint filters in the spray booths are replaced weekly. The spent filters are placed in a solid waste container. The facility generates approximately one 55-gallon drum of waste solvent per month and is a small quantity generator of hazardous waste. The drums are stored in the Chemical Stripper Room. A review of the hazardous waste manifests indicate that 3 or 4 drums of waste flammable liquids are shipped every quarter to Veolia Environmental in Flanders, New Jersey. The waste codes on the manifests are F003, F005, D001, and D035. Findings Lindeblad Piano Restoration is a small quantity generator of hazardous waste. On the day of the inspection, there were two 55-gallon drums of hazardous waste being stored in the Chemical Stripper Room. One drum was full with the cap on and no hazardous waste label. The other drum was half full with the cap off, a funnel on the opening, and no hazardous waste label. Containers holding hazardous waste must be kept closed during storage, except when adding or removing waste, as specified in 40 CFR Section 265.173(a). Containers must be marked clearly with the words "Hazardous Waste" and the accumulation start date, as specified in 40 CFR Section 262.34(a). The facility representative was informed of these requirements and both deficiencies were rectified within 48 hours (see attached photos provided by the facility representative). The hazardous waste codes on the manifests are representative of the waste paint thinner generated at the spray booths. However, the waste chemical stripper, containing approximately 85 percent methylene chloride, is also placed in the hazardous waste drums. Spent solvent waste containing more than 10 percent methylene chloride should have a hazardous waste code of F002 on the manifests and the hazardous waste labels. Page 4 of 9 Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Safety training, including hazardous materials, is provided to the employees twice per year. Full face respirators with cartridges are worn by employees during finishing operations. Attachments Photographs (#1 - #4) Hazardous Waste Manifest Page 5 of 9 Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Photo #1: View of the 5-gallon metal container where used rags are stored. Page 6 of 9 Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Photo #2: View of the two 55-gallon drums with no labels. One drum is open with a funnel. Page 7 of 9 Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Photo #3: Sent by the facility representative showing hazardous waste label on full drum. Page 8 of 9 Lindeblad Piano Restoration LLC NJR986659209 Inspection Date: June 7, 2023 Photo #4: Sent by the facility representative showing closed funnel and hazardous waste label. Page 9 of 9