Document oeQ1V0LJZOyErQ0XJrz6jxezg
REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION
At
Wellman Dynamics 1746 Commerce Road
Creston, IA 50801 (641) 782-0283
EPA ID Number: IAD065218737
On
December 15, 2021
By
Eastern Research Group, Inc.
For
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/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U.S. Environmental Protection Agency (EPA) Region 7, Eastern Research Group, Inc. (ERG) conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at Wellman Dynamics (WD) in Creston, Iowa on December 15, 2021. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. Throughout the CEI, data and information were collected to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI.
2.0 PARTICIPANTS
Wellman Dynamics: Matt Thelen, Environmental Engineer
EPA Representative, ERG: Janosh Wolters, Energy Engineer
3.0 INSPECTION PRECEDURES
Due to the COVID-19 pandemic, I contacted the facility via telephone and spoke with Mr. Thelen on December 6, 2022 at approximately 13:00. We discussed facility specific safety protocols to ensure the safety of all personnel involved during the inspection and I informed him when I would arrive at the facility to perform the inspection. After arriving announced at WD at approximately 07:40, I performed a drive-by of the facility and took a photograph before beginning the inspection and did not note any areas of concern. I then entered the main entrance and signed into the visitor's log. Mr. Thelen then led me to his office to begin the opening conference at approximately 07:45.
I initiated the opening conference with Mr. Thelen present as the WD representative. I presented him with my inspector credentials and business card, as well as the business card of the EPA Task Order Contracting Officer Representative, Mr. Trevor Urban. I then presented a copy of RCRA Section 3007(a), which contains EPA's inspection authority. I explained my need to collect accurate information and presented them with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I then presented Mr. Thelen with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed WD's confidentiality rights. I informed Mr. Thelen that I would provide a Confidentiality Notice at the end of this inspection.
The inspection consisted of a discussion of facility operations, waste generation and waste management, a review of waste management records, and a visual inspection of the waste generation and management areas. Mr. Thelen provided a facility layout (see Attachment 1) and explained facility operations and locations of hazardous waste generation and management.
During the visual inspection of the facility, Mr. Thelen guided me throughout the facility in order to conduct thorough evaluations of the facility's areas generating, accumulating hazardous waste, and all manufacturing and process areas. The facility also handles universal waste in a designated on-site area, which was also visually inspected. I conducted an in-depth visual inspection of the hazardous waste accumulation containers, used oil storage areas, the universal waste area on site, and all manufacturing areas.
Seven photographs were collected as inspection documentation and are shown in Attachments 2 and 3. Information collected during the inspection is documented on the EPA Inspection Checklist (see Attachment 4). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.01D), unless noted differently. At the conclusion of the inspection, I provided Mr. Thelen with a Confidentiality Notice and Receipt for Documents and Samples which he signed as acknowledgement of receipt (see Attachments 5 and 6, respectively). No confidentiality claims were made by WD.
The following inspection documents and compliance assistance handouts were left with WD:
RCRA Section 3007(a) Title 18 U.S. Code, Sections 1001 and 1002 Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by
2
EPA in Connection with Inspections Confidentiality Notice (Facility copy) Receipt of Documents and Samples (Facility copy) Security Awareness Commercial Motor Vehicle Transportation Security Planning EPA E-Manifest Fact Sheet U.S. EPA Small Business Resources U.S. EPA Publication, Managing Your Hazardous Waste U.S. EPA Publication, Managing Used Oil-Advice for Small Businesses PowerPoint Presentation, 2013 Solvent Wipes Final Rule Pollution Engineering Article, 10 Common Questions for Waste Generators Iowa Department of Natural Resources (IDNR) Waste Exchange Folder and P2 Brochures IDNR Management of Fluorescent Lamps for Businesses Information Sheets IDNR Aerosol Can Disposal for Businesses Information Sheet University of Northern Iowa Waste Reduction Center Information Card Solvent-Contaminated Wipes Final Rule Summary Chart
4.0 FINDINGS AND OBSERVATIONS
Facility Information and Operations
WD began operating in 1965 and currently employs approximately 325 people. The facility operates a stagged eight-hour, three shift operation, Monday through Friday. The facility has a footprint of approximately 293,000 square feet. WD's operations consist of manufacturing magnesium and aluminum sand castings. The major raw materials used are sand, magnesium, and aluminum. The major manufacturing or processing operations that generate waste streams include manufacturing magnesium and aluminum sand castings. The following waste streams are produced: hydrofluoric acid tank sludge, ignitable liquids, scrubber solution, spent flux, solvent wipes, wastewater, wastewater treatment sludge, foundry composite, scrap iron, scrap magnesium, scrap aluminum, scrap copper, quench solution, used oil, used oil filters, universal waste, and general trash.
4.2 RCRA Status
According to the Hazardous Waste Site Info Verification Report for Inspector (see Attachment 7), WD notified as a federal large quantity generator (LQG) of D001, D002, D003, D005, D007, F003, and F005 hazardous wastes. I asked Mr. Thelen to review the Hazardous Waste Site Info Verification Report for Inspector, which I provided prior to records review and visual inspection of the waste generation areas. Mr. Thelen stated the facility has not been operating as a LQG for three years. Mr. Thelen stated the facility has been generating less than 220 pounds of hazardous waste for approximately two years. Mr. Thelen stated he has left the facility as a LQG out of a best management practice. After reviewing the records and walking through the facility, I determined that the facility is operating as a very small quantity generator (VSQG) of D001, D002, and D005 hazardous wastes, a generator of used oil, and a small quantity handler (SQH) of universal waste. WD generated approximately 1,530 pounds in 2020, and approximately 600
3
pounds of hazardous waste in 2021. WD was previously inspected by an EPA contractor on March 22, 2016. The inspection led to a notice of preliminary findings (NOPFs). One finding was left for a failure to have adequate aisle space at the hazardous waste accumulation area. I did not observe any issues or findings during my inspection.
4.3 Facility Waste Streams and Management A Waste Stream and Waste Handling Table for WD is presented below. The table describes waste streams generated, generation process/rates, hazardous waste determinations, and onsite/off-site management. The rest of this page left blank intentionally.
4
WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT
#
RATE
1
Hydrofluoric Cleaning the etch D002 (based on process 800 pounds
55-gallon
Clean Harbors Environmental
Acid Tank
line acid bath
knowledge and
generated in
containers or 275- Services, Inc. Plymouth
Sludge (Waste tanks (one-time knowledge of the
2019 and has not gallon containers County, MA
Profile
occurrences)
product)
been generated at the time of clean (MAD039322250) to Clean
included in
since then
out
Harbors Deer Trail LLC in
Attachment 8)
Deer Trail, CO
(COD991300484) for
treatment and landfill
2
Ignitable
Residual from D001 (based on process One 55-gallon 55-gallon container Clean Harbors Environmental
Liquids (Waste empty containers knowledge and
container in 2021
Services, Inc. Plymouth
Profile
from casting
knowledge of the
County, MA
included in
production
product)
(MAD039322250) to Clean
Attachment 9) binders and
Harbors El Dorado LLC in El
aerosol can
Dorado, AR (ARD069748192)
residuals
for incineration
3
Scrubber
Cleanout of
D002 (based on process 0 pounds in 2021 275-gallon
Clean Harbors Environmental
Solution
scrubber
knowledge and
but has
container
Services, Inc. Plymouth
(Waste Profile
knowledge of the
historically
County, MA
included in
product)
generated this
(MAD039322250) to Clean
Attachment 10)
waste stream
Harbors El Dorado LLC in El
Dorado, AR (ARD069748192)
treatment and landfill
4
Spent Flux
Off-spec material D005 (based on process Has not yet
55-gallon container Clean Harbors Environmental
used in melting knowledge and
generated this
Services, Inc. Plymouth
operations or
knowledge of the
waste stream for
County, MA
spilled flux
product)
over five years
(MAD039322250) to Clean
and would be
Harbors El Dorado LLC in El
less than one 55-
Dorado, AR (ARD069748192)
gallon when
for incineration
generated
5
WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION GENERATION MANAGEMENT
#
RATE
5
Solvent Wipes Wiping excess Excluded per 40 CFR
One 40-gallon Five-gallon
Jim's Sanitation in Creston, IA
solvent off
261.4(b)(18) - (based on plastic bag every containers and
to Metro Park East Landfill in
casting
process knowledge and two weeks
consolidated into Des Moines, IA for landfill
knowledge of the
one 40-gallon
product)
plastic bag which
is added to general
trash
During the CEI, I determined based on how this type of waste is generated, it is nonhazardous. See Section 4.4 of this report for more
information.
7
Scrubber
Cleanout of
Nonhazardous (based on 2,400 pounds per 275-gallon
Clean Harbors Environmental
Solution
scrubber
process knowledge and year
containers
Services, Inc. Plymouth
(Waste Profile
knowledge of the
County, MA
included in
product)
(MAD039322250) to Clean
Attachment 11)
Harbors El Dorado LLC in El
Dorado, AR (ARD069748192)
for treatment
8
Wastewater
Rinsing castings Nonhazardous (based on 2,500 gallons per Treated in
Discharged to sanitary sewer,
process knowledge and week
wastewater
City of Creston, Publicly
knowledge of the
treatment plant
Owned Treatment Works
product)
(WWTP)
(POTW) for treatment (POTW
Agreement included in
Attachment 12)
9
Wastewater
Filter press from Nonhazardous (based on 500 pounds per 20-yard container Jim's Sanitation in Creston, IA
Treatment
WWTP pH
process knowledge and month
to Metro Park East Landfill in
Sludge
adjustment
knowledge of the
Des Moines, IA for landfill
pretreatment
product)
6
WASTE STREAM # 10 Foundry Composite (Sands and Dusts)
11 Scrap Iron
GENERATION PROCESS
Facility operations
HAZARDOUS WASTE DETERMINATION
Nonhazardous (based on process knowledge and knowledge of the product)
ESTIMATED GENERATION RATE 13,000 tons per year
ON-SITE MANAGEMENT
On-site landfill
OFF-SITE MANAGEMENT
H&H Commercial Services in Union County, IA to Metro Park East Landfill in Des Moines, IA for use as alternative daily cover
Facility operations
Nonhazardous (based on process knowledge and knowledge of the product)
10 tons per month
40-yard container
Clayton Auto Salvage in Greenfield, Iowa for recycling
12 Scrap
Facility
Magnesium, operations
Aluminum and
Copper
Nonhazardous (based on process knowledge and knowledge of the product)
20,000 tons per month
Gaylord boxes and 55-gallon containers
Shapiro Metal Recycling in St. Louis, MO for recycling
13 Quench
Heat treat
Solution
operations
(Waste Profile
included in
Attachment 13)
Nonhazardous (based on process knowledge and knowledge of the product)
2,500 gallons every four months
275-gallon containers
Safety-Kleen in Des Moines, IA (IAD981718000) for treatment
7
WASTE STREAM # 14 Used Oil
GENERATION PROCESS
Facility maintenance
HAZARDOUS WASTE DETERMINATION
Excluded (managed as used oil per 40 CFR 279)
ESTIMATED GENERATION RATE 1,000 gallons per year
ON-SITE MANAGEMENT
55-gallon container to 480gallon container
OFF-SITE MANAGEMENT
Safety-Kleen Systems Inc. in Des Moines, IA (IAD981718000) for recycling (Invoice included in Attachment 14)
15 Used Oil Filters
Facility maintenance
16 Universal
Facility
Waste Lamps maintenance
17 Universal Waste Batteries
Facility maintenance
18 General Trash Facility operations
Excluded (based on management and process knowledge) recycled as scrap metal
Two used oil filters per month
Hot drained and punctured and then added to scrap metal containers
Clayton Auto Salvage in Greenfield, Iowa for recycling
Excluded (managed as universal waste per 40 CFR 273)
Excluded (managed as universal waste per 40 CFR 273)
Nonhazardous (based on process knowledge and knowledge of the product)
Four 4-foot containers per year
One 5-gallon container per year
Two 2-yard containers picked up weekly. One 20-yard container picked up monthly
4-foot containers
5-gallon container
2-yard and 20-yard containers
A-TEC Recycling in Des Moines, IA (IA0000109827) for recycling ((Bill of Lading (BOL) included in Attachment 15)) A-TEC Recycling in Des Moines, IA (IA0000109827) for recycling (BOL included in Attachment 15)
Jim's Sanitation in Creston, IA to Metro Park East Landfill in Des Moines, IA for landfill (Invoice included in Attachment 16)
8
4.4 Visual Inspection
Foundry Operations:
WD manufactures magnesium and aluminum castings for a variety of industries. WD uses a combination of hydrofluoric waste tanks during the casting process. Cleanout operations take place based on production and would not occur more than once per year. This waste has not been generated in 2021 and Mr. Thelen stated he does not anticipate cleaning the tanks in the near future. Mr. Thelen explained the facility has been slowing operations over the past three years. When this waste is generated, it is shipped off-site on a hazardous waste manifest. The waste profile is provided in Attachment 7. In addition, the facility generates quench waste as a part of the casting process. This waste is nonhazardous and shipped off-site using the waste profile provided in Attachment 13. Mr. Thelen stated scrubber waste is also generated when the scrubber is cleaned out. Mr. Thelen explained a continuously monitoring gauge monitors the pH inside the scrubber and the facility attempts to clean out the scrubber when the pH is greater than 4. If this is achieved, the waste can be managed as a nonhazardous waste and is shipped off-site with the waste profile provided in Attachment 11. If the facility is unable to clean out the scrubber and the pH reaches a level below 4, the facility manages the waste as a D002 hazardous waste. The hazardous scrubber waste is shipped off site using the waste profile provided in Attachment 10.
Mr. Thelen stated the facility attempts to use all purchased binding product for financial reasons. If any residual from empty binding containers is left over, the facility manages this waste as a D001 hazardous waste. Mr. Thelen stated the facility also manages one aerosol can puncture unit on site and all residuals are managed under the same waste profile as the excess binding material. The waste profile for ignitable waste on site is provided in Attachment 9. During the visual inspection, I observed one 55-gallon container of aerosol can residuals and one 55-gallon container of ignitable waste (see Attachment 3, Photo 2 and 3).
Solvent Contaminated Wipes:
Mr. Thelen stated the facility generates solvent contaminated rags on site. The rags are generated from wiping excess solvent off castings during inspections with isopropyl alcohol, acetone, and methanol. The facility uses five-gallon red containers to accumulate all solvent contaminated rags (see Attachment 3, Photo 7). The containers are labeled with "Excluded Solvent Contaminated Wipes" and consolidated before being added to the general trash waste stream. Mr. Thelen explained the facility manages the wipes under the solvent contaminated wipes sent for disposal per 40 CFR 261.4(b)(18). Mr. Thelen explained wipes are not accumulated for more than 180 days, do not contain free liquids when placed inside the container, and all wipes are managed off-site by Jim's Sanitation in Creston, Iowa to Metro Park East Landfill in Des Moines, Iowa for landfill. An invoice for general trash being shipped off site is provided in Attachment 16. During records review, Mr. Thelen provided me with the facilities SOP for management for these wipes as shown in Attachment 17. In addition, the facility uses a tracking system outlined in the management practice form provided in Attachment 18. All five-gallon containers accumulating solvent contaminated rags were closed, labeled "Excluded Solvent Contaminated Wipes", and in good condition. I determined the facility is in compliance with the
9
exclusions set forth in 40 CFR 261.4(b)(18). During further review, I determined this waste to be nonhazardous. Based on the use of an isopropyl alcohol, acetone, and methanol solvent solution mixture and that no free liquids are present on the rags when initially placed inside the 5-gallon container, the rags would not be a F003 listed or D001 characteristic hazardous waste. The facility appears to be overclassifying this waste stream as a conservative measure.
Landfill:
WD has an on-site landfill which is located on the eastern portion of the facility. Mr. Thelen stated the landfill is used to store the facility foundry composite waste. This waste is comprised of different sands and dusts. Mr. Thelen stated the waste is hauled off-site by H&H Commercial Services in Union County, Iowa to Metro Park East Landfill in Des Moines, Iowa for use as alternative daily cover.
POTW:
The facility sends rinse wastewater through the facility's on-site WWTP for pH adjustment. After pretreatment, WD has an agreement with the City of Creston POTW and discharges wastewater via the sanitary sewer. Mr. Thelen explained WD is approved for this discharge as shown in the POTW agreement provided in Attachment 12.
Universal Waste:
WD manages a small amount of universal waste on site. I observed one 4-foot container accumulating universal waste lamps (see Attachment 3, Photo 6). Mr. Theler stated the facility had just shipped universal waste lamps and batteries off site last week. Mr. Thelen stated the facility has A-TEC Recycling pick up both universal waste batteries and universal waste lamps together. The container was located in the maintenance storage area and was replaced just before the visual inspection of this area. At the time of the inspection, I did not observe any universal waste batteries accumulating on site. Mr. Thelen stated the facility shipped off one 5-gallon container last week. The container I observed was labeled as "Universal Waste Lamps", closed, in good condition, and dated with the start accumulation date. The container was labeled with an accumulation start date of "12/15/2021". Examples of a BOL used to ship waste batteries and waste lamps off site is provided in Attachment 15. I did not note any issues or findings at the universal waste accumulation area.
Used Oil:
I visually observed the facility's 480-gallon used oil tank storage located north of the facility's on-site landfill. I observed one 55-gallon container of used oil in the maintenance area. The containers were closed, labeled "Used Oil", and in good condition. An invoice associated with a used oil shipment is provided in Attachment 14. I did not note any issues or findings at the used oil storage area.
10
Contingency Plan and Manifests:
During records review, Mr. Thelen explained that out of a best management practice, he created a contingency plan with a quick reference guide for the facility and has submitted both to all applicable response agencies. Although not a regulatory requirement for a VSQG, I reviewed the plan during the inspection. The contingency plan and quick reference guide are provided in Attachment 19.
In addition, as discussed in this report, the facility uses hazardous waste manifests to ship wastes off site. The most recent hazardous waste manifest generated and corresponding LDR form is provided in Attachment 20 as an example. Lastly, Mr. Thelen stated he attends a RCRA hazardous waste refresher and trains on-site employees with basic hazardous waste management practices. Mr. Thelen also stated he understood if the facility were to become a LQG of hazardous waste, all emergency coordinators would need to attend hazardous waste refresher training. Mr. Thelen's training certificate is provided in Attachment 21.
I observed no issues or findings during this inspection. However, further EPA review may add findings.
Janosh
Digitally signed by Janosh Wolters
_W__o__lt_e_r_s________-0_5_'0_0'___________ Date: 2022.02.03 16:43:32
Janosh Wolters Energy Engineer Date: February 3, 2022
AMBER
Digitally signed by AMBER WHISNANT
_W__H__I_S_N__A_N__T____-0_6_'0_0'___________ Date: 2022.02.07 22:38:25
Amber Whisnant
Section Chief
ECAD/CB/RCRA, EPA Region 7
Date: _________________
Attachments: 1. Facility Layout (1 page) 2. Wellman Dynamics Photolog (1 page) 3. Wellman Dynamics Photos (7 Photos/8 pages) 4. EPA Inspection Checklist (21 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Hazardous Waste Site Information Verification Report (1 page) 8. Hydrofluoric Acid Sludge Waste Profile (4 pages) 9. Ignitable Waste Profile (5 pages) 10. Hazardous Scrubber Solution Waste Profile (5 pages) 11. Nonhazardous Scrubber Solution Waste (5 pages)
11
12. POTW Agreement (4 pages) 13. Quench Waste Profile (4 pages) 14. Used Oil Invoice (1 page) 15. Universal Waste BOL (1 page) 16. Jim's Sanitation Invoice (1 page) 17. Solvent Excluded Contaminated Wipes SOP (1 page) 18. PM Excluded Solvent Contaminated Wipes Rule (1 page) 19. Contingency Plan (11 pages) 20. Manifests (2 pages) 21. Training Records (2 pages)
12