Document oMQo1OMxJEowRy9EL32LjL7bo
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
ATLANTA FEDERAL CENTER 61 FORSYTH STREET SW
ATLANTA, GEORGIA 30303-8960
SENT VIA ELECTRONIC MAIL
Eddie E. Hook Facility Manager Safety-Kleen Systems, Inc. Lexington Distribution Center 128 Frontage Road Lexington, SC 29703 eddie.hook@safety-kleen.com
Dear Eddie E. Hook:
On January 24, 2023, the U.S. Environmental Protection Agency Region 4 Air Enforcement Branch conducted a partial compliance inspection of Safety-Kleen Systems, Inc., located in Lexington, South Carolina. We have enclosed the final report generated for this inspection (Enclosure).
If you have any questions, please contact me at (404) 562-9206, or by email at hughesfairley.rosalyn@epa.gov.
Sincerely,
Enclosures
ROSALYN
Digitally signed by ROSALYN HUGHES FAIRLEY
HUGHES FAIRLEY -04'00' Date: 2023.03.20 12:30:52 Rosalyn Hughes Fairley
Environmental Engineer
South Air Enforcement Section
ENCLOSURE INSPECTION REPORT
United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report
I. GENERAL INFORMATION
Facility Name: Safety-Kleen Systems, Inc.
Location (Address): 128 Frontage Road, Lexington, SC 29073
Inspection Date: January 24, 2023
Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation
PROGRAMMATIC ID: SC000156000039
PERMIT NUMBER: SOP-1560-0039
EPA Region 4 Investigator(s)/Inspector(s): 1. Rosalyn Hughes Fairley, Environmental Engineer 2. Sharron Porter, Environmental Engineer 3. Steve Rieck, Environmental Scientist
State/Local Investigator(s)/Inspector(s): 1. Reggie Watts, Environmental Engineer
Person(s) Contacted at Facility (Name and Title): 1. Eddie E. Hook, Facility Manager 2. Steve Hopkins, Operations Manager
Report Prepared by: Rosalyn Hughes Fairley
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 1 of 12
FACILITY INFORMATION A. Facility and Permit Information
Facility and Permit Information
1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.).
2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.).
3. Air permit issuance date.
4. Air permit expiration date.
Comments Off-site Waste Recycling Operations
SCDHEC SOP-1560-0039
January 1, 2020 No Expiration Date
5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor).
6. Major source pollutants (if applicable).
7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.).
8. Types of air emission points (e.g., tanks, process vents, boilers, etc.).
9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.).
Minor N/A State Implementation Plan
Tanks and process vents Flare
B. Process Description
Safety-Kleen Systems, Inc. operate a storage, recycling, and reclamation facility for a variety of used solvents. Waste solvents and other spent chemicals are received into the facility's storage tanks. The solvents and chemicals are processed for reuse and stored in the facility's storage tanks prior to shipment to customers.
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 2 of 12
II. INSPECTION ACTIVITIES
Activity
Opening Meeting 1. Date and time entered the
facility.
Yes No NA
Y
2. Credentials presented to
Y
facility personnel (include
name and title).
3. Conducted an opening
Y
meeting to explain the
purpose and objectives of the
inspection.
Comments
EPA Region 4 (R4) inspectors arrived at the facility on January 24, 2023, at approximately 9:00 am. All inspectors presented their credentials to Eddie L. Hook, Facility Manager
Inspectors held an opening meeting with Eddie Hook to discuss the purpose and objectives of the inspection. Steve Hopkins also joined the discussion.
4. Discussed safety issues.
Y
5. Discussed which records to N be reviewed.
6. Discussed the facility walk- Y through and the areas to be observed in the facility.
Inspectors discussed facility-specific safety and emergency procedures and appropriate protective equipment. The inspection team requested the following records: Number of tanks and the size Flare performance test Leak Detection and Repair Emissions Calculations
Inspectors were primarily interested in inspection of the tanks and the flare
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 3 of 12
Activity
7. Discussed facility policy regarding photographs or video (if applicable).
Yes No NA Y
8. Discussed the use of the
N/A
infrared camera, TVA, PID,
and any other equipment.
9. Discussed CBI.
Y
Comments
Region 4 inspectors indicated a digital camera and an Optical Gas Imaging camera would be used during the inspection. The team discussed facility policy regarding photography and videography. Inspectors indicated that copies of any videos or photographs taken at the facility would be sent to the company. A log of photographs and videos taken at the facility is included in this report. See Appendix A.
TVA/PID were not used during the inspection.
EPA inspectors indicated that any material claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations.
The draft report was sent to Safety-Kleen and Mr. Hook did identify any CBI information in the draft inspection report.
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 4 of 12
Activity
Yes
No
NA
Records Reviewed at the
Facility
10. The types of records
N
reviewed, and the time period
reviewed.
Facility Walk-Through
Observations
11. The process equipment
N/A
observed and the associated
operational rate observed
(e.g., Furnace 1 production
rate was 5 lbs/hr on 1/1/15, at
2:00 pm - permit requires
max rate at 6 lbs/hr).
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Comments
The inspection team reviewed the past 4 months of leak detection records during the inspection. The flare performance test report was not available during the inspection. The 2021 flare maintenance records for were reviewed during the inspection.
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 5 of 12
Activity
12. The type of process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch).
Yes No NA N/A
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
13. If process equipment or
N/A
parametric monitoring
equipment was not operating,
state the reason by facility
personnel why the equipment
was not operating.
Comments
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 6 of 12
Activity
14. The type of air pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.).
Yes No NA Y
(For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher).
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Comments
The distillation unit is equipped with a flare. The flame indicator on the distillation control panel was on, which indicated the pilot light was on and the flare was in operation. The unit is equipped with a flare alarm system to notify the facility when the flare is not operational. It, also, has a lock out system for flare safety.
Since the permit did not contain parametric monitoring, no parameters associated with the flare were recorded.
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 7 of 12
Activity
15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.).
Yes No NA N/A
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
16. If air pollution control
N/A
equipment was not operating,
state the reason by facility
personnel why the equipment
was not operating.
17. Capture and collection
N/A
system (enclosures and
hoods) observations, if
applicable (e.g., the
magnitude and duration of
emission escaping capture
from the hood).
Comments
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 8 of 12
Activity
Yes
No
NA
18. Ductwork transferring the Y
emissions to the air pollution
control device observations,
if applicable (e.g., the
magnitude and duration of
emission escaping from the
ductwork, holes or
deterioration in ductwork, no
deterioration observed, etc.).
Comments
The infrared camera was used to observe the flare. No emissions were observed from the ductwork.
19. Any existing unpermitted
N
emission points, new
unpermitted emission points,
or non-permitted
construction activities
observed. (if yes, describe in
the comments field).
20. Were any visible emissions N observed? (if yes, identify the location and equipment).
21. Was a Method 9 reading
N
performed? (if yes, identify
the location and equipment).
22. Was the cause of the visible N/A emissions investigated and the information documented?
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 9 of 12
Activity
Yes
No
NA
23. Was a Method 22 performed N
for visible emissions? (if yes,
identify the location and
equipment).
Comments
24. Identify the cause of the
N/A
visible emissions as
explained by facility
personnel, if applicable.
25. Was the infrared camera
Y
used? If so, attach the video
log (which includes the
equipment ID, and the date
and time the video was
recorded) and videos to this
report.
26. Was the TVA used? If so, N identify the equipment monitored and the results.
Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release.
An attachment may be used for a large amount of information.
The infrared camera videos and the video log are attached. The photos taken with the digital camera are attached and included on the video log.
EPA R4 inspectors did not use a TVA at the facility.
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 10 of 12
Activity
27. Was the PID used? If so, identify how the PID was used and the results.
Yes No NA N
Provide the date and time the information was recorded by the inspector.
An attachment may be used for a large amount of information.
Closing Meeting 28. Conducted a closing meeting. Y
29. Summarize any additional Y information needed, if applicable?
30. Accept a declaration of CBI, N/A
if applicable?
31. Discussed observations.
Y
32. Discussed next steps, if
Y
applicable?
Comments
EPA R4 inspectors did not use a PID at the facility.
EPA Region 4 inspectors conducted a closing meeting on January 24, 2023. The emissions calculations were not available at the facility during the inspection, but Mr. Hook agreed to send the information. The information was received on February 3, 2023.
Inspectors thanked facility personnel for their time and summarized inspection activities. The inspectors indicated that the flare performance test was not reviewed, and the report may be requested later. The facility agreed to send the latest emission calculations to EPA and as noted above were received. A final inspection report from EPA Region 4 will be sent to the company within a 70day timeframe.
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 11 of 12
Activity
Yes
No
NA
33. Date and time inspection
concluded.
Miscellaneous
34. Include any additional
N/A
observations, if applicable.
Comments
The inspection concluded on January 24, 2023, at approximately 11:30 a.m.
ROSALYN HUGHES Digitally signed by ROSALYN
HUGHES FAIRLEY
EPA Investigator/Inspector Signature: ___F_A_I_R_L_E_Y____________D_a_te_: 2_0_23_.0_3._20_1_2_:33_:3_5_-04'00'
EPA Supervisor Signature & Title: _T_O__D__D____________D_i_gi_ta_lly_s_ig_ne_d_b_y_TO_D_D____ GROENDYKE
GROENDYKE
Date: 2023.03.20 10:28:38 -04'00'
___________________________________
Date Report Finalized: March 20, 2023
Project Name: Safety-Kleen Systems, Inc. Lexington ICIS/Project No.: SC000156000039-2023
Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019
Page 12 of 12
APPENDICES AND ATTACHMENTS 1. Appendix A. Inspection Photograph log
Appendix A: Inspection Photograph Log
During the January 24, 2023, inspection, EPA Region 4 staff used an infrared camera and a digital camera at the facility. Below is a list and description of the videos and photographs taken during the inspection.
Table 1: Videos and photographs taken during the January 24, 2023, inspection
File Number
Media Description
MOV_1161
Tank Farm 2
MOV_1162
Tank Farm 2
MOV_1163
Tank Farm 1
MOV_1164
Tank Farm 3
MOV_1165
Flare
IMG_1366
Flare
IMG_1377
Flare