Document r10KrkXwb8xvogXOwQ9YpqLv

ft E A ~ United States '('-1 Environmental Protectior Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT 6ENFORM-019-R8.2 (02/12/2020) Inspection Date(s): Media: Regulatory Program(s) October 7-8, 2025 RCRA Compliance Evaluation Inspection Hazardous Waste Generator Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Qarbon Aerospace Foundation Qarbon Aerospace Foundation 300 Austin Blvd Red Oak, Texas 75154 300 Austin Blvd Red Oak, Texas 75154 Ellis County Anais Askari Environmental Health and Safety (EHS) I Manager Anais.Askari@Qarbonaerospace.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110054868265 NA RCRA:TXR000081252 336411 - Aircraft Manufacturing Personnel participating in inspection: John Penland EPA Region 6 (ECDSR) Sandesh Thapa EPA Region 6 (ECDSR) Anais Askari Qarbon Aerospace Foundation (Qarbon) Edward Pounds Qarbon Senior Inspector Lead Inspector EHS Manager EHS Manager EPA Lead Inspector Signature/Date Supervisor Signature/Date SANDESH THAPA ~~!~!signed bySANDESH Date: 2025.12.22 14:25:08 -06'00' Sandesh Thapa - Lead Inspector DEBRA PANDAK ~~~~!:ignedbyDEBRA Date: 2025.12.22 14:31 :59 -06'00' Debra Pandak - RCRA Section Supervisor Date Date Qarbon Aerospace Foundation October 7-8, 2025 Section I - INTRODUCTION PURPOSE OF THE INSPECTION During the week of October 7, 2025, I, Sandesh Thapa, conducted an unannounced inspection of the Qarbon Aerospace Foundation (Qarbon) facility located at 300 Austin Blvd, Red Oak, Texas for compliance with the Resource Conservation and Recovery Act (RCRA). I was assisted on this inspection by Environmental Protection Agency (EPA) inspector John Penland. The inspection included a walkthrough of the facility's waste generation and management units, and a review of the facility records related to hazardous waste management. We concluded the inspection of the Qarbon facility on October 8, 2025, with a closing conference where we presented our observations. A summary of the areas of concern identified during the inspection is provided in Section III. This report serves as documentation of all onsite activities and observations during the inspection of the Qarbon facility. Photographs taken during the inspection to document onsite observations are included as Appendix 1. FACILITY DESCRIPTION Qarbon is a manufacturer of composite products for commercial and military aircraft. It uses automated lay-up systems to build complex composite shapes. The operations include manufacturing of composite fuselages, floor panels, doors, sponsons and wing assembly. The facility operates 24 hours a day, seven days a week, and employs five hundred personnel including contractors, customers and Qarbon's direct employees. Qarbon manages industrial, hazardous and non-hazardous wastes. Qarbon is currently notified as a Small Quantity Generator and was issued the EPA ID number TXR000081252. It is registered as a Large Quantity Handler of Universal Waste. The facility last submitted a biennial report in 2017. A general map of the plant is included in Appendix 2. Facility communications are included in Appendix 3. A copy of daily summary is included in Appendix 4. Section II - OBSERVATIONS October 7, 2025 We arrived at the Qarbon facility at approximately 9:40am Central Time and began the inspection with an opening conference. During this conference, we presented our credentials to Ms. Anais Askari and informed her that we were there to conduct an inspection of the facility under the authority of Section 3007 of RCRA. During this conference, we also discussed the purpose and scope of the inspection and that the facility has the right to assert a claim for Confidential Business Information for records and photos collected during this inspection. Following the opening conference, we had a tabletop discussion of the facility's process. This discussion was followed by a walkthrough of the facility's process and storage areas to identify activities that could generate hazardous waste and evaluate its subsequent management. Notably we observed the facility 2 Qarbon Aerospace Foundation October 7-8, 2025 manufacturing process. The process includes ply cutting, tape laying, composite and structure assembly, and painting and wing assembly. It uses isopropyl alcohol and methyl n-propyl ketone as solvents in their painting process. Tank Farm: On the east side of the main building, adjacent to the maintenance shop, I observed a Tank Farm with two above-ground storage tanks in secondary containment (Appendix 1, Photo 1). It contained an 8,500gallon tank of non-hazardous oily wastewater and an inactive Alodine rinse water tank. The oily wastewater tank is listed as unit 002 with a non-hazardous regulated status in the Notice of Registration (NOR). However, the tank's capacity is recorded as 10,000 gallons instead of the observed 8,500 gallons during the inspection. I noticed a spill of oily wastewater in the secondary containment as a result of overfill. The oily wastewater is generated from washing equipment and an X-ray process. In the same area, I observed an unknown riser within the secondary containment area (Appendix 1, Photo 2). Manifest Review: During the inspection, I observed a Cactus Environmental truck picked up a non-hazardous oily wastewater shipment. I reviewed the manifest being used for the pickup and it contained the EPA ID TX6170022770, which corresponds to a former Vought Integrated Programs Division JSF facility located at 9314 W Jefferson Blvd, Dallas, TX. However, it was noted that the location is currently operated as a Home Depot facility. Consequently, the manifest was corrected to reflect the Qarbon EPA ID TXR000081252. Central Accumulation Area (CAA): On the northeast side of the main building, I observed a covered CAA with both hazardous waste and universal waste (Appendix 1, Photo 3). There were 4 boxes and two bundles of universal waste lamps that were not labeled or marked clearly as required in the standards for universal waste handlers (See Section III - Preliminary Findings for additional regulatory citations). Painting Operation: There are two Satellite Accumulation Areas allocated for the painting operations. During my inspection, I observed a paint compactor on the northwest side of the main building. The paint waste from the painting operations was consolidated and processed at the paint compactor. Additionally, I saw a rolloff box connected to the paint compactor that contained paint waste but was missing universal waste labeling (Appendix 1, Photo 4). X-ray Operation: I then walked back inside the facility building to inspect the X-ray operation. I noticed that the wastewater from the used developer solution was drained to the sump and collected in a 275-gallon tote (Appendix 1, Photo 5). Upon my request, Qarbon submitted a wastewater determination result with silver at a Total Recoverable concentration of 0.0671 mg/L (Appendix 3). However, the analytical report states that the sample was received at the laboratory with insufficient preservation at a pH of >2, which does not meet the requirement of <2 under EPA Method 200.8. EPA has requested for a new test. 3 Qarbon Aerospace Foundation October 7-8, 2025 October 8, 2025 John Penland and I entered the facility at 9:30am Central Time. We reviewed our notes from October 7, 2025, with the facility representatives. We conducted our preliminary document review for the majority of the day. Records Review: I reviewed the weekly inspection reports of the CAA. Reports indicated that the weekly inspections for third and fourth week of November 2024 and fourth week of December 2024 were missing. The facility subsequently submitted their weekly inspection reports on October 16, 2025 (Appendix 3), but did not include the missing December inspection. Section III - PRELIMINARY FINDINGS The following is a list of potential areas of concern discussed with the facility representatives. See Appendix 4 for additional details of EPA's observations. The facility failed to conduct a weekly inspection of CAA during the fourth week of December 2024 (40 CFR 262.16(b)(2)(iv)). The facility failed to label or clearly mark four boxes and two bundles of universal waste lamps with one of the following phrases: "Universal Waste - Lamp(s)", or "Waste Lamp(s)", or "Used Lamp(s)" (40 CFR 273.34(e)). The facility failed to label or clearly mark the rolloff box connected to the paint compactor, which contained paint waste, with the words "Universal Waste - Paint and Paint-Related Wastes" (30 TAC 335.262(c)(2)(F)). o As a part of corrective action, Qarbon submitted a picture of the same rolloff box with a universal waste label identifying contents as Paint and Paint-Related Waste on October 9, 2025. Section IV - FOLLOW UP Actions taken by Qarbon to resolve any areas of concern were documented by Qarbon with photographs or other documentation and submitted to the EPA via the electronic secure online drive. Any information received from Qarbon after the inspection was also received via the secure online drive. These documents are accessible by the EPA Enforcement Officer, as applicable. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 5 photos taken 10/7/2025 Appendix 2 - Facility Diagram Appendix 3 - Facility Communication Appendix 4 - EPA Daily Summary E-mails 4 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Facility/Location: I City: Red Oak Filename: IMG_0102.jpeg Photographer: Sandesh Thapa Photo No. 1 Qarbon Aerospace Foundation County: I Ellis County I State: I TX I Direction: I W Photo Date: 10/07/2025 I Time: I 11:51:59 Witness Name: I John Penland Description: Overview of tank battery with oily wastewater tank. Latitude: N/A Longitude: N/A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Facility/Location: I City: Red Oak Filename: IMG_0103.jpeg Photographer: Sandesh Thapa Photo No. 2 Qarbon Aerospace Foundation County: I Ellis County I State: I TX I Direction: I W Photo Date: 10/07/2025 I Time: I 11:52:04 Witness Name: I John Penland r t WATER Description: Close view of unknown riser in secondary containment area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Facility/Location: I City: Red Oak Filename: IMG_0112.jpeg Photographer: Sandesh Thapa Photo No. 3 Qarbon Aerospace Foundation County: I Ellis County I State: I TX I Direction: I E Photo Date: 10/07/2025 I Time: I 12:09:39 Witness Name: I John Penland Description: Overview of CAA. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Facility/Location: I City: Red Oak Filename: IMG_0118.jpeg Photographer: Sandesh Thapa Photo No. 4 Qarbon Aerospace Foundation County: I Ellis County I State: I TX I Direction: I NW Photo Date: 10/07/2025 I Time: I 14:10:20 Witness Name: I John Penland Description: Rolloff box without universal waste label attached to paint compactor. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Facility/Location: I City: Red Oak Filename: IMG_0120.jpeg Photographer: Sandesh Thapa Photo No. 5 Qarbon Aerospace Foundation County: I Ellis County I State: I TX I Direction: I S Photo Date: 10/07/2025 I Time: I 13:57:06 Witness Name: I John Penland Description: Close view of tote used to collect wastewater from X-ray process. Appendix 2 Facility Diagram '0 t5 a, 0.. E 0 (.) 1: a, a. a, .C.l.) <( 'o .c.a,__,~ ~ .0.... Cl) Cl) ..... en ~ uc--au. en C: 0 :p '- a, 0 ... ti5 u a. ca 0. ~ E 0 Cl) (.) ...C: ca ll. Appendix 3 Facility Communication =:~eurofins II Environment Testing I ANALYTICAL REPORT PREPARED FOR Attn: Ms. Jody Walls A Storm Environmental PO BOX 10735 College Station, Texas 77842 Generated 10/30/2025 12:38:11 PM JOB DESCRIPTION QA-X JOB NUMBER 870-40968-1 Eurofins Dallas II Job Notes This report may not be reproduced except in full, and with written approval from the laboratory. The results relate only to the samples tested . For questions please contact the Project Manager at the e-mail address or telephone number listed on this page . Analytical test results meet all requirements of the associated regulatory program (i.e., NELAC {TNI), DoD, and ISO 17025) unless otherwise noted under the individual analysis. Authorization Authorized for release by Sylvia Garza, Project Manager Sylvia.Garza@et.eurofinsus.com (832)544-2004 Generated 10/30/202512:38:11 PM Eurofins Dallas is a laboratory within Eurofins Environment Testing South Central, LLC, a company within Eurofins Environment Testing Group of Companies Page 2 of 16 10/30/2025 Client: A Storm Environmental Laboratory Job ID: 870-40968-1 Project/Site: QA-X Table of Contents El Cover Page . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Definitions/Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Case Narrative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Client Sample Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 QC Sample Results ........................................ 7 QC Association Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Lab Chronicle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Certification Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1o Method Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Sample Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Chain of Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Receipt Checklists. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Page 3 of 16 Eurofins Dallas 10/30/2025  El Page 4 of 16 10/30/2025 Client: A Storm Environmental Project: QA-X Job ID: 870-40968-1 Case Narrative Job Narrative 870-40968-1 Job ID: 870-40968-1 Eurofins Dallas The analytical test results presented in this report meet all requirements of the associated regulatory program listed on the Accreditation/Certification Summary Page, unless otherwise noted. Data qualifiers and/or narrative comments are included to explain any exceptions, if applicable. Regulated compliance samples (e.g. SOWA, NPDES) must comply with associated agency requirements/permits . Matrix-specific batch QC (e.g ., MS, MSD, SD) may not be reported when insufficient sample volume is available or when sitespecific QC samples are not submitted. In such cases, a Laboratory Control Sample Duplicate (LCSD) may be analyzed to provide precision data for the batch. For samples analyzed using surrogate and/or isotope dilution analytes, any recoveries falling outside of established acceptance criteria are re-prepared and/or re-analyzed to confirm results, unless the deviation is due to sample dilution or otherwise explained in the case narrative. Receipt The sample was received on 10/22/2025 2:02 PM. Unless otherwise noted below, the sample arrived in good condition, and, where required, properly preserved and on ice. The temperature of the cooler at receipt time was 2.5C. Metals Method 200.8 - Total Recoverable: The reference method requires samples to be preserved to a pH of <2. The following sample was received with insufficient preservation at a pH of >2: QA-X (870-40968-1 ). The sample(s) were preserved to the appropriate pH in the laboratory. This does not meet regulatory requirements. Method 200.8 - Total Recoverable: The following sample was diluted due to the nature of the sample matrix: QA-X (870-40968-1 ). Elevated reporting limits (Rls) are provided . No additional analytical or quality issues were noted, other than those described above or in the Definitions/ Glossary page. II Page 5 of 16 Eurofins Dallas 10/30/2025  [- - - - - - - _ _ _ IJ Page 6 of 16 10/30/2025  - --------- ---- --- --- --- --- ---- - -- ---- -- -- m --------- ---- --- --- --- --- ---- - -- ---- -- -- --------- ---- --- --- - - - --- ---- - -- ---- -- -- Page 7 of 16 10/30/2025  II Page 8 of 16 10/30/2025  [- - - - - - -- -- - El Page 9 of 16 10/30/2025  m Page 10 of 16 10/30/2025  Page 11 of 16 10/30/2025  Page 12 of 16 10/30/2025 E Chain of Custody Environment Testing Houston. TX 1281) 240-4200. Dallas. TX 1214) 902-0300 Midland, TX (432) 704-5440, San Antonio, TX (210) 509-3334 EL Paso, TX (915) 585-3443, Lubbock, TX (806) 794-1296 Hobbs, NM (575) 392-7550, Carlsbad, NM (575) 988-3199 Little Rock, AR (501) 224-5060 Work Order No: _ _ _ _ _ _ __ Proiect Manaaer: Comoanv Name: Address: City, State ZIP: Phone: r ,~i..lvi~ Ct ....r.;i,. .. -- -- - ---- Bill to: (lfdlfferenl.) <'.1! r 1 ,.,- 1\..\r\ <t"\.I""' --~.v\~ Comoanv Name: (Jo ~ i I\)~ 1 '\ C..,,\ ,,,,..,. Sh'h- """...._ -.\.o. c J Address: Citv, State ZIP: Email: ~w '\.\\.> /'iJ -- -- . . - -- -- -9-h,"('m ....t\.v_ IA.Pk Page of - - - --- - -- WorK oraerCommen fii" ---- Program: UST/PST OPRPO Srownflelds O RRC O Superfund 0 State of Project: Reporting: Level II D Level Ill D PST/UST O TRRP 0 Deliverables: EDD 0 ADaPT 0 Other: Level NO Project Name: Project Number: ~A -~ @Routine 0 Rush Turn Around ...... Clod ANALYSIS REQUEST Preservative Codes None:NO DI Water: H2O Project Location: Sampler's Name: "5',.J \.. W-'-.\\ s Due Date: TAT starts the day received by - i:. PO#: ' u.,;;; 18U1 II l~IYQU UJ "T,UV,..111 SAMPLE RECEIPT T8113P Blank: Yes\NJ Wet Ice: ~ No E Samples Received Intact: Yes )No Thermometer ID: 7~ I! Cooler Custody Seals: Yes No (NIA Correction Factor: .,. J . I ~ Samole Custodv Seals: Total Containers: Yes No (NIA 'remoerature Readlna : '-""" Corrected Temperature: ' - . t1 '~K" ~--- Sample Identification Matrix Date Sampled Time Sampled Grab/ #of V) Depth Comp Cont . iO - '! ',,_, ~ A--- Y.. l\llti.-11,< QC, Cool: Cool HCL: HC H2S04: H2 MeOH:Me HNO3 NaOH: Na H3PO.: HP NaHSO4: NABIS Na,S2O3: NaSO3 Zn Acetate+NaOH: Zn NaOH+Ascorbic Acid: SAPC Sample Comments ~ \1\\\111y \11\\11\1 I I I Total 200.7 / 6010 200.8 / 6020: BRCRA 13PPM Texas 11 Al Sb As Ba Be B Cd Ca Cr Co Cu Fe Pb Mg Mn Mo NI K Se Ag Si02 Na Sr Tl Sn U V Zn Circle Method(s) and Metal(s) to be analvzed TCLP / SPLP 6010: SRCRA Sb As Ba Be Cd Cr Co Cu Pb Mn Mo Ni Se Ag Tl U Ha: 1631 /245.1 /7470 /7471 eotf. .: Signature of thlll docuJMnt and rellnqulahment of Hmpfea constltutea a valld purehaN order from client company to Eurollns Xenco, Ila llfflllalH and subcontractors. It aaalgna standard terms and conditions l Hrvice. Eurotlne xenco wttt be Hable only for the cost of Hmplal and ahaH not aaume any ruponslbfllly ror any loaaea or expenses Incurred by th cti.nt tr auch loaes .,. due to ctrcumw,ncea beyond tlHt control Eurofln Xenco, A minimum charae of $85.00 wlll be applied to each project and a chlll'll of $5 for each aample aubmlttad to Euroftns X1111co, but not analyzed. TheH terms wlll be enfoR:ed unteas pN1vtou.ly neaoll...d. Relinquished by: (Signature) IU ,~ 1( LN/'. I,._ J,,<-- I 7 - 3 5 V , RJPC9Jv~d gr: (Signature) VVVlY./J - t Pabj/Tlme 111 )}~ Relinquished by: (Signature) l:OL 4 6 Received by: (Signature) Date/Time Revi88d Dato: 08/25/2020 R>v, 2020,2 II) N 0 ~ 0 C") 0 ~ ---- Cl II Eurofins Dallas 9701 Harry Hines Blvd Dallas, TX 75220 Phone: 214-902-030D mma Client Information Client Contact: Shipping/Receiving (Sub Contract Lab\ company: Eurofins Environment Testing So_i.rt.h Centr Address: 4145 Greenbriar Dr City: Stafford ,state, Zip: TX, n4n Phone: 281-240-4200(Tel) Ema\l NIA Pro1ect Name: QA-X Site: ]AA sample l_dentification Client JD (Lab ID! QA-X (870-40968-1) el el r Sampler N/A Phone: NIA Chain of Custody Record \.ab PM: Garza, Sylvia EMa/1: Sylvia.Garza@et.eurofinsus.com l i i lCsnierTracJ<ing No[$): t-1/A - I S\a1e ol Or\gip: Texas A~ditatioris Required (See note): NEI.AP Texas Oue Date Requested: 10/28/2025 Anal~sis Reques~ TAT Requested (days): NIA PC#: NIA WO#: NIA Project#: 87002306 SSOW#'. ~ Sample Date ~ 10/22/25 12:00 Centr<i! -' !' '-.;,.: .:.i., z, e\!' 't : 'Jf ! :t:I Q -'~ :~ 0 ::E ~~ ,.. " i .~,, ,;,.' Sample Matrix ::;:,it := ,-. Type i5 i g' I I I I I I I I I I (C=comp, S11ofict, o-wucwci, !:! lcci,:,~ i ' "' G= rab BTTi""' AAlr}I ,:J ~ I I I I I I I , ( l J 'Pf~etic:ill>CQi:i~: G Water -x11---+-I-1-1-1-1-1 %1. fl 1 [ I r ~ 1-, i i ' ii ~:: eurofins COC No: I.C) N 0 \ ':! Environment festfn~ -0-- 870-9366.1 Page: Page 1 of 1 ,Job#: 870-40968-1 Preservation Coaes: trl 1 r11 rl \ _.:"!, ,,! ,, ~\I:~f: Other g ,J izf NIA :_!: 1 rl::I\' S~cial Instructions/Note: ' 6 1 e: ~ ii.. :i, ,J;, Note: Since labota.tory accreditations are subject to change. E\Jrcfins Environment Testing South Central, LLC places the ownership of method, analyte & adcrecfrta!Jon compliane$ t.1pot1 iour subcontract laboratories. :This sample shipment:is forwarded under chair,..of-cus1ody. It the laboratory does not currenijy maintain accreditation in the State of Origin isled above for analysisltesWmabix being analyzed, the samples mU$1 be shipped back to the Eurofin Environment Testing South.Central, U.C laboratory cr<>lheii:-sttut:'.ions will~ prcvide<I. Any changes to accreditation status should be t>rougltt to Euro~ns Envi=,ru,r,t Testng SQ\l\h Central. U.C attention 1mmed)ately. If all requested accreditatjon, are currentjto date, rett.Jm the signed Chain of Custody attesting to saip compliance to Eurofins Environment Testing South Central U.C. Possible Hazard Identification Unconfirmed Deliverable Requested: I, II Ill IV Other (specify) Primary Oellverable Rani<:.: 2 Sarnple Disposal ( A fee may be assessecl if sa',nples are retaine.d longer than 1 month) l:f=] f!etum To Cl{et1_t _ c:::JDisposal Bx_ Lab D Archive For_ _~_ Months Sp~cia\ instructions/QC Requlrements: \ Empty Kit Relinquijibe'!I by Relinquished Oy: Relinquished by: VVV\JJ) Rel,nquished oy: custody Seals Intact 1custody Seal No. ti Yes ti No Date/Time: Date: Company Datammf Q j 2 3 j Z C: .) - Oatemme: 1 VCompa.ny !) I') t; d Company .. f:.D..h- e"Trm arTh Time: 1 Received by: Received by, ;Recerted by: LD'Y -Y ,T - __ I - UC I ~ j -ut~ I ~\heel l)f Sh\l>men't . , r , - - - -' - - _I ,.O~ver,veu .failtT-21 2025 A. ;cooler Temperature(s)~ arlt!-6ther Remarks: r-- 1 -C \.l \\ Company Company Company \I n  Page 15 of 16 10/30/2025  Page 16 of 16 10/30/2025 QL\RBON ) AEROSPACE Hazardous Waste Accumulation Site Weekly Inspection Log Month/Year: {)etJ,1tn/J.er r{tQ:;-f' Mark answers (V)Yes or (N)No below s: s s s s N rn o::t 11'1 ~ """ ~ ~ ~ ~ QJ QJ QJ a, a, QJ a, QJ a, a, Location: Week 1 Date /;}./ J / ;LY Number of Containers in Area: 1/Jl) Are all drums and containers marked or labeled as hazardous waste (or "waste pending analysis")? Are all drums and containers marked with the risk associated with the waste? Are all containers (excluding satellite containers) marked with the accumulation start date? Are any drums near or exceeding the SQG 180 days timeframe? Are all drum labels visible and readable? Are all containers closed? Are all drums and containers in good condition? Are any drums leaking? Is there adequate aisle space and clearance between rows of containers? Containment Is the secondary containment free of cracks or o ther failures? Are sumps clean and free of contamination, spills, leaks, and standing water? Comments: Describe the actions taken to correct each deficiency noted above, and note date each action was taken. Ql\RBON AEROSPACE Hazardous Waste Accumulation Site Weekly Inspection Log Month/Year: t}__ilW~I" Jo ').A..-J Mark answers (Y)Yes or (N)No below Location: ~ N M ~ l.ll .:.:: .:.:: ~ ~ .:.:: Q) cu Q) Q) Q) Q) Q) Q) Q) Q) $ $ $ $ $ Weeki Week2 Week3 Week4 Weeks I I Number of Containers in Area: Are all drums and containers marked or labeled as hazardous waste (or "waste pending analysis")? Are all drums and containers marked with the risk associated with the waste? Are all containers (excluding satellite containers) marked with the accumulation start date? Are any drums near or exceeding the SQG 180 days timeframe? Are all drum labels visible and readable? Are all containers closed? Are all drums and containers in good condition? Are any drums leaking? Is there adequate aisle space and clearance between rows of containers? Containment Is the secondary containment free of cracks or other failures? Are sumps clean and free of contamination, spills, leaks, and standing water? Comments: Describe the actions taken to correct each deficiency noted above, and note date each action was taken. Appendix 4 EPA Daily Summary E-mails From: To: Cc: Subject: Date: Thapa, Sandesh "anais.askari@qarbonaerospace.com"; "edward.pounds@qarbonaerospace.com" Pandak, Debra; Penland, John Daily Summary for 2025 RCRA inspection of Qarbon Aerospace Foundation - Red Oak, TX - October 8, 2025 Wednesday, October 8, 2025 7:06:00 PM Hi All, Here is a summary from today's inspection. If there are any error or omissions, please let me know. Inspection Attendees: NAME TITLE Sandesh Lead Thapa Hazardous Waste Inspector John Senior Penland Hazardous Waste Inspector Anais Environmental Askari Health and Safety Manager REPRESENTING US EPA Region 6 US EPA Region 6 Qarbon PHONE 2146652265 2146659717 4698204589 EMAIL thapa.sandesh@epa.gov Penland.john@epa.gov anais.askari@qarbonaerospace.com Daily Summary Inspection Starts: 09:30am Recap of Daily summary from October 7, 2025. 0 5-gallon drum attached to paint gun washer unit is a solvent(product) which is used for cleaning. 0 Total of 5 manifests were used for oily waste with EPA ID TX6170022770 which corresponds to a former Vought Integrated Programs Division JSF facility. Opening meeting start- 09:45am Used Paint Filters: Used Paint filters are disposed as Universal waste. EPA has requested manifests related to used paint filters. Weekly Inspections: Weekly inspection of Central Accumulation Area (CAA) from third and fourth week of November 2024 and fourth week of December 2024 were missing. 40 C.F.R 262.16(b)(2)(IV). Emergency coordinator's contact number was not posted at the CAA. 40 C.F.R 262.16.(b)(9)(ii) Closing Conference: Identified Concerns: TCLP test required for X-ray wastewater. Awaiting test results. Weekly inspection of CAA from third and fourth week of November 2024 and fourth week of December 2024 were missing. 40 C.F.R 262.16(b)(2)(IV). Emergency coordinator's contact number was not posted at the CAA. 40 C.F.R 262.16.(b)(9)(ii)- Resolved 4 boxes of lamps and 2 bundles of lamps was observed without universal waste or waste lamps label, 40 C.F.R 273.34(e).- Resolved Roll-off container without universal waste label was observed at paint compactor. 30 TAC 335.262(c)(2)(F). Total of 5 manifests were used for oily waste with EPA ID TX6170022770 which corresponds to a former Vought Integrated Programs Division JSF facility. Areas for Additional Review: Review of Personal Training records. List of personnel for review. Anais Ankari Dale Cheek Ongoing request of compliance records, including 0 Arrangement with local authorities of contingency plan prior to the inspection start date. 40 C.F.R 262.16.(b)(8)(Vi) 0 Toxicity Characteristic Leaching Procedure (TCLP) for X-ray wastewater and Oily wastewater. 0 Facility maps and process diagrams. 0 Weekly inspection reports from recent year- including November and December 2024. Departed Facility at approximately 1:40 pm Regards, Sandesh Thapa Enforcement and Compliance Assurance Division U.S. EPA Region 6 Office: 214-665-2265