Document pB6mnz8VNNYegxorQLNaEK4ya

RCRA Inspection Report 1) Inspector and Author of Report Daryl Himes RCRA Enforcement Section Chemical Safety and Land Enforcement Branch Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency (EPA), Region 4 61 Forsyth Street, S.W. Phone: 404-562-8614 Atlanta, Georgia 30303 Email: himes.daryl@epa.gov 2) Facility Information Safety-Kleen Systems, Inc. (SKS) 3536 Fite Road Millington, Tennessee 38053 EPA ID No.: TND000614321 3) Responsible Officials Jonathan Busby General Branch Manager Safety-Kleen Systems, Inc. jonathan.busby@safety-kleen.com 4) Inspection Participants Timothy Hill Curtis Shannon Jason Simpson Judy Low Jim Holt Brett Harris Daryl Himes SKS SKS TDEC TDEC TDEC TDEC EPA Region 4 5) Date and Time of Inspection October 26, 2022, 9:00 a.m. 6) Applicable Authority RCRA Sections 3005 and 3007; 40 Code of Federal Regulations (C.F.R.) Parts 260 - 266, 268, 270, 273, and 279 Tennessee Hazardous Waste Management Act of 1977, Tennessee Code Annotated (Tenn. Code Ann.) 68-212-101 et seq., and Chapter 040012-01 of the Rules and Regulations of the State of Tennessee (Tenn. Comp. R. & Regs.) TDEC Permit Number TNHW 141. As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions alleged herein will be to the authorized State program; however, for ease of reference, the federal citations will follow in brackets. 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine Safety-Kleen's compliance with the applicable requirements of RCRA and the corresponding TDEC regulations. This was an EPA lead inspection. 8) Previous Inspection History EPA's last inspection of the facility occurred on February 26, 2015. Permit and generator violations were observed during the inspection. TDEC has conducted annual RCRA CEIs at the subject facility during the past three years and found one violation during the most recent inspection on June 15, 2022, related to its quick reference guide. The violation was subsequently corrected. 9) Facility Description SKS operates treatment and storage facility permitted by the State of Tennessee and is a large quantity generator of hazardous waste. TDEC Permit TNHW-141 (permit) was issued on September 30, 2009 and is effective until September 30, 2019. In March of 2019, SKS submitted a permit renewal application to TDEC. TDEC is currently working on a permit renewal. In the interim, SKS continues to operate under their existing permit. The permit authorizes SKS to manage hazardous waste onsite in containers, in above ground storage tanks and in two Return and Fill stations (for solvents). The permit allows SKS to store hazardous waste for up to one year. The permitted capacity of the container storage area (CSA) is 17,690 gallons. The containment area capacity is 18,351 gallons. The CSA is covered by an open sided structure. The floor of the CSA is sealed to prevent infiltration of any spilled material into the concrete. SKS operates five above ground storage tanks in a tank farm. The tank farm includes four vertical 15,000-gallon tanks and one horizontal 10,000-gallon tank. Three of the vertical tanks store used oil and the fourth stores clean solvent. The horizontal tank stores spent solvent recovered from the Return and Fill units. SKS also operates a 10-day transfer facility at this location for off-site generated waste. SKS is authorized to store other wastes including universal waste, used oil, and non- EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 2 of 12 hazardous waste at the facility. SKS operates a 90-day or less hazardous waste container storage area on the permitted CSA. SKS provides cleaning solutions (solvents) to a variety of industries. SKS services part washer units by removing cleaning solutions, replenishing the units, and returning to the facility with the removed cleaning solutions to bulk them in a hazardous waste tank using the Return and Fill units at this facility. SKS employs 19 personnel at this location. The site occupies approximately 9.5 acres of which 5.5 acres are inside the fenced area. 10) Opening Conference On October 26, 2022, the EPA and TDEC inspectors listed above arrived at Safety-Kleen at approximately 9:00. Facility Representative Timothy Hill, District Manager, immediately received the inspectors. The inspectors introduced themselves, showed their credentials to Timothy Hill and explained the purpose of the visit. The inspectors described the anticipated use of equipment a digital camera during the inspection and provided a request for records. The facility representative did not assert a business confidentiality claim, pursuant to 40 C.F.R. 2.203, for information requested for review by EPA. The inspection participants also discussed health and safety protocols and required personal protective equipment before Timothy Hill led the inspectors on a tour of the Facility operations. Timothy Hill provided an overview of the facility's history and current operations during the opening conference. The company does not appear to meet the Small Business Regulatory Enforcement Fairness Act's classification of a "small business," which is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. Therefore, the EPA inspector did not provide a copy of the agency's information sheet for small businesses, which can be found at https://www.epa.gov/compliance/small-business-resources-information-sheet. 11) Findings During a walk-through inspection of the facility, the inspectors made observations in the following areas: Sample Return Area Samples of materials picked up from customers are maintained in a metal shed measuring approximately 10-feet by 8-feet (Photo 1). The inspection team observed the area where samples collected from customers are accumulated and maintained for 90 days before they are bulked and shipped offsite. EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 3 of 12 10-Day Transfer Area operated in Permitted Container Storage Area The inspection team observed 55-gallon, 30-gallon, 5-gallon, cubic yard fiber bag and 275-gallon totes in a part of the facility's permitted storage area that the facility is managing as a 10-day transfer area (Photo 2). The volume of waste managed in this area was within the permitted storage capacity for this area. Each container observed in this area was properly labeled, closed, and in good condition. Each container in this area had been stored for less than 10-days. 90-Day Accumulation Area operated in Permitted Container Storage Area The inspection team observed 55-gallon and 5-gallon containers of hazardous waste generated on-site in an area within the facility's permitted container storage area that the facility manages as a 90-day hazardous waste accumulation area. All containers in this area were properly labeled, closed and marked with accumulation start dates of less than 90-days. Boxes of universal waste batteries were also observed in this area. Each box was closed, labeled with appropriate universal waste language, and marked with an accumulation start date of less than one year. Return and Fill Stations The inspection team inspected two permitted Return and Fill stations located on the north end of the facility's container storage building. The two stations are used to receive spent solvent containers picked up from customers utilizing parts washing machines provided to their customers (Photos 3 and 4). Timothy Hill stated that Safety-Kleen only provides limited amounts of low flash solvents to customers that request it. Hazardous waste codes assigned to wastes returned to the facility in 30-gallon containers are primarily codes for solvents the customer may use at its facility or metals which are the result of customer processes. The dump and fill stations were idle at the time of the inspection. More than twenty 30-gallon containers of hazardous waste collected from the facility's customers were observed on the permitted loading dock area on both sides of the Return and Fill stations (Photos 3 and 4). One 55-gallon container was observed within a satellite accumulation area (SAA) in this location for accumulation of contaminated rags, personnel protective equipment and filters. This container was in good condition, closed, and labeled with the words "Hazardous Waste." Above Ground Storage Tank Farm SKS operates five tanks in the tank farm. Tank 2 was being used to store solvent product. Tanks 1, 4, and 5 are used to store used oil and were properly labeled with the words "Used Oil." SKS utilized Tank 3 to store spent solvent (Photo 5). Tank 3 was labeled with the words "Hazardous Waste.," the secondary containment for the tank was free of cracks and gaps and at the time of the inspection. EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 4 of 12 Truck Loading Area This area is used for loading outgoing solvent from the facility's hazardous waste storage tank. One 55-gallon container was observed within a SAA in this area for hazardous waste filters and PPE generated in this area (Photo 6). The container was closed and labeled with the words "Hazardous Waste" at the time of the inspection. Record Review The inspection team reviewed records at the facility including the contingency plan, hazardous waste reduction plan for on-site generated waste, annual RCRA training, hazardous waste manifests for shipments made during the last four months and inspection records for container storage and tank storage areas. 12) Closing Conference A closing conference with the inspection team and Timothy Hill of Safety-Kleen was conducted at the conclusion of the walkthrough inspection and record review. A review of the inspectors' observations and findings were discussed. 13) Signed Digitally signed by DARYL DARYL HIMES Date: 2022.12.09 13:29:04 HIMES -05'00' Daryl R. Himes Environmental Engineer 14) Concurrence ARACELI CHAVEZ Digitally signed by ARACELI CHAVEZ Date: 2022.12.09 14:05:39 -05'00' Araceli B. Chavez Chief RCRA Enforcement Section Date ________________________ Date EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 5 of 12 ATTACHMENT A Safety-Kleen Systems, Inc. Millington, Tennessee COMPLIANCE EVALUATION INSPECTION TND000614321 October 26, 2022 Photos taken by Daryl R. Himes Photos taken with Canon Power Shot Elph 360 HS EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 6 of 12 Photo 1 - Sample Return Area EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 7 of 12 Photo 2 - Container Storage Area used as 10-Day Transfer Area EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 8 of 12 Photo 3 - Northeast Return and Fill Station EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 9 of 12 Photo 4 - Northwest Return and Fill Station EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 10 of 12 Photo 5 - Hazardous Waste Storage Tank EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 11 of 12 Photo 6 - 55-gallon drum located in SAA in truck loading area EPA-RCRA CEI Report Safety-Kleen Systems, Inc. EPA ID# TND000614321 October 26, 2022 Page 12 of 12