Document pp11nJKM568pzvg4BKGKqb6da

RCRA Compliance Branch INSPECTION REPORT Inspection Date(s): Facility or Site Name: Facility/Site Physical Location: (City, state, zip code) Mailing address (if different from above): Facility/Site Contact: 4/25/2024 RSM Electron Power Inc 219 W Industry Ct Deer Park, NY 11729 Pedro Reyes Pedro.Reyes@rsm.com Inspection Announced: No Lead Technician RCRA ID Number: Inspector: Areeba Khan Supervisor: Derval Thomas NYD052786001 AREEBA KHAN Digitally signed by AREEBA KHAN Date: 2024.07.02 08:25:17 -04'00' DERVAL THOMAS Digitally signed by DERVAL THOMAS Date: 2024.07.01 18:33:06 -04'00' SECTION I - INTRODUCTION Purpose of the Inspection Objective The purpose of the inspection was to perform a Resource Conservation and Recovery Act (RCRA) comprehensive evaluation inspection (CEI) at this facility. The inspection was conducted by EPA RCRA inspector Areeba Khan. Opening Conference EPA Region 2 RCRA inspector Areeba Khan arrived at RSM Electron Power on April 25, 2024, for an unannounced inspection. I was greeted by the security guard in the back entrance. The security guard called Pedro Reyes, the Lead Technician to the back entrance. I presented my 1 credentials to Mr. Reyes and informed him that this was an EPA inspection to determine the facility's compliance with RCRA regulations. The scope of the inspection was to conduct a compliance evaluation inspection (CEI). Facility/Site Description RSM Electron Power is a manufacturer located in Deer Park, New York. RSM Electron Power currently conducts its business as Sensitron Semiconductor. The company manufactures aerospace and electronic components. The facility generates hazardous waste and universal waste (fluorescent bulbs). The fluorescent bulbs are changed out by Triumvirate and are taken for disposal. The hazardous wastes generated by the facility are different types of acid waste and solvent waste. The facility uses Premiere Recycling Solutions as its Transporter and every month ships out one to two drums. There is one main central storage area and two satellite accumulation areas. After review of the manifest information and statements made by Mr. Reyes, the facility was determined to be a Small Quantity Generator (SQG) of hazardous waste at the time of the inspection. The facility operates 24 hours a day from Monday through Friday, and it employs about 75 to 100 people. SECTION II - OBSERVATIONS Wafer Fabricators Mr. Reyes stated this is the wafer fabricators area. In this area they use small dyes to get the desired etching for its products. The hazardous waste generated in this area are spent products and expired chemicals. At the time of the inspection the following was observed: 1. Ignitable cabinet (Shown in figures 1 and 2) Inside the Cabinet i. Two 1 gallon satellite accumulation container of acetone and proponal (hazardous waste) that were labeled and closed. 2 (Figure 1: Showing chemicals inside of the ignitable cabinet) On top of the Cabinet i. One 1 gallon satellite accumulation container of acetone and proponal (hazardous waste) that was labeled and closed. ii. Three 1 gallon satellite accumulation container of xylene (hazardous waste) that was labeled and closed. 3 (Figure 2: Showing chemicals on top of the ignitable cabinet) 2. Acids Cabinet (Shown in Figures 3 and 4) One 1 gallon satellite accumulation container of sulfur peroxide (hazardous waste) that was labeled and closed. Three 1 gallon satellite accumulation container of nitric acid and acetic acid (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation container of amonium hydroxide and hydrogen peroxide (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation container of sulfuric acid and hydrogen peroxide (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation container of acetic acid (hazardous waste) that was labeled and closed. Four 1 liter satellite accumulation container of nitric acid (hazardous waste) that was labeled and closed. 4  Two 1 gallon satellite accumulation container of hydrogen phosphorus (hazardous waste) that was labeled and closed. Three 1 gallon satellite accumulation container of hydrogen peroxide (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation container of sulfuric acid (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation container of hydrofluoric acid (hazardous waste) that was labeled and closed. (Figure 3: Showing chemicals inside the acids cabinet) 5 (Figure 4: Showing chemicals on top of the acids cabinet) Chemical Lab: Mr. Reyes then showed me the chemical lab. The facility representative stated the chemical lab is where the facility does metal etching. There was a total of thirty five one gallon satellite accumulation containers of hazardous waste located all in one area underneath a hood as shown in figure 5, 6, 7 and 8. At the time of the inspection the following was observed: Five 1 gallon satellite accumulation containers of proponal (hazardous waste) that was labeled and closed. Eleven 1 gallon satellite accumulation containers of ultrabrite- organic cleaning solution (hazardous waste) that was labeled and closed. Three 1 gallon satellite accumulation containers of ethyl alchol (hazardous waste) that was labeled and closed. 6  Three 1 gallon satellite accumulation containers of potassium cyanide (hazardous waste) that was labeled and closed. Three 1 gallon satellite accumulation containers of sulfuric acid (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation containers of NaOH (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation containers of nitric acid, hydrofluoric acid, acetic acid, and sodium hydroxide (hazardous waste) that was labeled and closed. Two 1 gallon satellite accumulation containers of glutonic acid flux (hazardous waste) that was labeled and closed. Four 1 gallon satellite accumulation containers of proponal zyglo (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation containers of proponal ultra brite (hazardous waste) that was labeled and closed. One 1 gallon satellite accumulation containers of proponal petroleum distillate (hazardous waste) that was labeled and closed. 7 (Figure 5: Showing Chemicals located in the Chemical Lab Area) (Figure 6: Showing Chemicals located in the Chemical Lab Area) 8 (Figure 7: Showing Chemicals located in the Chemical Lab Area) (Figure 8: Showing Chemicals located in the Chemical Lab Area) Central Storage Area: Mr. Reyes then showed me the central storage area. Mr. Reyes stated there is a wastewater treatment plant that is checked by Suffolk County and samples are sent to York Labs. One 30 gallon drum of ultra brite (hazardous waste) that was labeled, closed, and not dated. One 30 gallon drum of TI Etch (sulfuric peroxide) that was labeled, closed, and not dated. One 5 gallon container of acetic acid and nitric acid (hazardous waste) that was closed but was not labeled and did not have a date. One 30 gallon drum of SI Etch (sulfuric acid) that was labeled, closed, and not dated. 9  One 1 gallon drum of hazardous waste (nitric acid, sulfuric acid, and peroxide) that was closed but was not labeled and did not have a date. One 55 gallon drum of solvent waste (hazardous waste) that was open, not labeled and was not dated. One 55 gallon drum of acid waste (hazardous waste) that was closed but was not labeled and did not have a date. Two 1 gallon containers of phosphorous acid (hazardous waste) that was closed but was not labeled and did not have a date. (Figure 9: Showing hazardous waste located in the Central Storage Area with no date) 10 (Figure 10: Showing hazardous waste located in the Central Storage Area with no date and some with no labels) 11 (Figure 11: Showing hazardous waste located in the Central Storage Area with that are open and not labeled with the words hazardous waste or have a date) 12 (Figure 12: Showing corrosion of the piping system above) 13 (Figure 13: Showing an open container and funnel into the other side of the drum) 14 (Figure 14: Showing hazardous waste located inside the secondary containers with no label and date) Records Review Basic Plan The facility representative stated they had a basic plan. Manifests and Land Disposal Restrictions There were no return manifest copies on site, however the manifest were uploaded to rcrainfo and are available to view. Personnel Training At the time of the inspection, the facility representative states there was personnel training done. 15  Arrangement with Local Authority At the time of the inspection, there was no arrangements made with the local authorities. SECTION III - AREAS OF CONCERN Regulatory Concerns 1. Pursuant to 6 NYCRR 373-3.9(d)(1), management of containers. (1) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste. At the time of the inspection, there was one 55 gallon hazardous waste (solvent waste) drum located in the central storage area that was open. 2. Pursuant to 6 NYCRR 373-3.9(d)(3): Each container is marked with the words "Hazardous Waste" and with other words to identify the contents. a. At the time of the inspection, there was one 55 gallon hazardous waste (solvent waste) drum located in the central storage area that was not labeled with the words hazardous waste. b. At the time of the inspection, there was one 5 gallon container of hazardous waste (acetic acid and nitric acid) drum located in the central storage area that was not labeled. c. At the time of the inspection, there was one 1 gallon drum of hazardous waste (nitric acid, sulfuric acid, and peroxide) drum located in the central storage area that was not labeled. d. At the time of the inspection, there was one 55 gallon hazardous waste (acid waste) drum located in the central storage area that was not labeled with the words hazardous waste. e. At the time of the inspection, there were two 1 gallon drum of hazardous waste (phosphorous acid) drum located in the central storage area that was not labeled. 3. Pursuant to 6 NYCRR 372.2(a)(8)(ii), The date upon which each period of accumulation begins is clearly marked and visible for inspection on each container. 16 a. At the time of the inspection, there was one 55 gallon hazardous waste (solvent waste) drum located in the central storage area that was not dated. b. At the time of the inspection, there was one 5 gallon container of hazardous waste (acetic acid and nitric acid) drum located in the central storage area that was not dated. c. At the time of the inspection, there was one 1 gallon drum of hazardous waste (nitric acid, sulfuric acid, and peroxide) drum located in the central storage area that was not dated. d. At the time of the inspection, there was one 55 gallon hazardous waste (acid waste) drum located in the central storage area that was not dated. e. At the time of the inspection, there were two 1 gallon drum of hazardous waste (phosphorous acid) drum located in the central storage area that was not dated. f. At the time of the inspection, there was one 30 gallon hazardous waste (ultra brite) drum located in the central storage area that was not dated. g. At the time of the inspection, there was one 30 gallon hazardous waste (sulfuric peroxide) drum located in the central storage area that was not dated. h. At the time of the inspection, there was one 30 gallon hazardous waste (sulfuric acid) drum located in the central storage area that was not dated. 4. Pursuant to 6 NYCRR 373-3.9(g)(1) and (2), Incompatible wastes, or incompatible wastes and materials, are not placed in the same container, or in an unwashed container that previously held an incompatible waste or material unless the placement is conducted to prevent the following: a. At the time of the inspection, there were incompatible wastes and materials placed near each other in the wafer fabricator area. The following acids were observed in the acid's cabinet and on top of the cabinet as shown in Figures 3 and 4: i. One 1 gallon satellite accumulation container of sulfur peroxide (hazardous waste). ii. Three 1 gallon satellite accumulation container of nitric acid and acetic acid (hazardous waste). iii. One 1 gallon satellite accumulation container of amonium hydroxide and hydrogen peroxide (hazardous waste). 17 iv. One 1 gallon satellite accumulation container of sulfuric acid and hydrogen peroxide (hazardous waste). v. One 1 gallon satellite accumulation container of acetic acid (hazardous waste). vi. Four 1 liter satellite accumulation container of nitric acid (hazardous waste). vii. Two 1 gallon satellite accumulation container of hydrogen phosphorus (hazardous waste). viii. Three 1 gallon satellite accumulation container of hydrogen peroxide (hazardous waste). ix. One 1 gallon satellite accumulation container of sulfuric acid (hazardous waste). x. One 1 gallon satellite accumulation container of hydrofluoric acid (hazardous waste). b. At the time of the inspection, there were incompatible wastes and materials placed near each other in the chemical lab area. The following acids were observed underneath the hood as shown in Figure 5, 6, 7 and 8: i. Five 1 gallon satellite accumulation containers of proponal (hazardous waste). ii. Eleven 1 gallon satellite accumulation containers of ultrabrite- organic cleaning solution (hazardous waste). iii. Three 1 gallon satellite accumulation containers of ethyl alchol (hazardous waste). iv. Three 1 gallon satellite accumulation containers of potassium cyanide (hazardous waste). v. Three 1 gallon satellite accumulation containers of sulfuric acid (hazardous waste). vi. One 1 gallon satellite accumulation containers of NaOH (hazardous waste). vii. One 1 gallon satellite accumulation containers of nitric acid, hydrofluoric acid, acetic acid, and sodium hydroxide (hazardous waste). 18 viii. Two 1 gallon satellite accumulation containers of glutonic acid flux (hazardous waste). ix. Four 1 gallon satellite accumulation containers of proponal zyglo (hazardous waste). x. One 1 gallon satellite accumulation containers of proponal ultra brite (hazardous waste). xi. One 1 gallon satellite accumulation containers of proponal petroleum distillate (hazardous waste). c. At the time of the inspection, there was One 1 gallon drum of hazardous waste (nitric acid, sulfuric acid, and peroxide) that were incompatible wastes placed in the same container in the central storage area. 5. Pursuant to 6 NYCRR 373-3.3(g)(1)(i), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (i) arrangements to familiarize police, fire departments and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to and roads inside the facility, and possible evacuation routes. At the time of the inspection, the facility had not made arrangements with the local police department and fire department about the type of waste handled at the owner or operator's facility and the potential need for the services. 6. Pursuant to 6 NYCRR 373-3.3(g)(1)(iv), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (iv) arrangements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility. At the time of the inspection, the facility had not made arrangements to familiarize local hospitals with the properties of hazardous waste handled at the 19 facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility. General Concerns At the time of the inspection there was no general concern. Closing Conference The closing conference was conducted by EPA inspector Areeba Khan and the facility representative Pedro Reyes. Inspector Khan explained to Mr. Reyes the areas of concerns. He stated that he will follow up and tend to the areas of concern immediately. 20