Document rxNg5e5J2DeYpbpe4Yzy0VBX7

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At AMAZON.COM SERVICES LLC - MKC6 6925 Riverview Avenue Kansas City, Kansas 66102 (855) 556-5214 Installation Phone Number Mailing Address: P.O. Box 80842 Attn: NA ENV TEAM Seattle, Washington 98108 (206) 413-4526 Site Contact Phone Number EPA ID Number: KSR191708275 On July 20 and 21, 2021 By U.S. ENVIRONMENTAL PROTECTION AGENCY Region VII Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division (ECAD), I performed a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at the Amazon.com Services LLC - MKC6 (Amazon MKC6) facility in Kansas City, Kansas. The inspection was conducted on July 20 and 21, 2021. The CEI was conducted under the authority of RCRA Section 3007(a), as amended. During the inspection, I collected the information and data necessary to determine compliance with the applicable regulatory and statutory requirements. This report and attachments present the results of the CEI. Based on the information obtained during the inspection, I inspected Amazon MKC6 as a large quantity generator (LQG) of known hazardous waste (HW), small quantity handler of universal waste (SQHUW) lamps and batteries, and a used oil generator. According to the U.S. Environmental Protection Agency (EPA) RCRAInfo database, the facility had not been inspected by the EPA or the Kansas Department of Health and Environment (KDHE). 2.0 PARTICIPANTS Amazon MKC6: Trevor Nichols, Workplace, Health, and Safety Site Safety Manager (about four months in position and three years with the company) Corey Jackson, Regional Environmental Manager - a floating position (about four months in position and with the company) Todd Smyly, Sr. Site Safety Manager (12 days in position and with the company) Joshua Lingenfelser, Assistant General Manager (since November 2020 in position and four years with the company) Casey Patton, Workplace, Health, and Safety Specialist (about one year and two months in position and three and half years with the company) Robert Kelly, Process Assistant (about two and half years in position and four and half years with the company) - Inbound Dock Area Jayne Peterman, Process Assistant (about five years in position and 15 years with the company) - Vendor Return Area Mike McOsker, Hazardous Waste Coordinator (about one year and three months in position and four years with the company) - HW Cage Area Eric Brook, Maintenance Manager (about one year in position and with the company) - Amazon Contractor, Daifuku Elite Line Services (ELS) Joe Wolf, Base Building Manager (about one and half years in position and with the company) - Amazon Contractor, ELS Scott Blau, Network PO for C5 (first started working with customer returns in January 2021 and about four years with the company) Elisha Sigei, IT Support Associate (about one year with the company and in position) David Wills, Dock Process Assistant (about one year in position and three years with the company) - Preparation Area Susan Rodgers, Planner/Scheduler (since November 2017 with ELS) - Maintenance Office Robert Stuteville, CMMS Admin (about four years in position with ELS) - Maintenance Parts Cage Amanda Payne, Site Safety Manager (by phone for closing conference only) Jamar Lewis, Sr. Regional WHS Manager (by phone for closing conference only) EPA: Dedriel Gardner, Environmental Engineer (Lead Inspector) Mark Holcomb, Civil Investigator (NOWCC/SEE) 3.0 INSPECTION PROCEDURES On July 19, 2021, I attempted to contact Ms. Waid (RCRAInfo contact) at (206) 413-4526 to announce the inspection. I was able to reach her at about 11:00 A.M. CT. I introduce myself and announced the RCRA inspection. I informed her that I planned to conduct a RCRA inspection at Amazon MKC6 the next day and asked about their COVID policy requirements. She stated that she was in Washington state and she would have the manager at the Kansas City, Kansas, facility call me to let me know their specific COVID procedures. At about 1:00 P.M. CT, I received a call from Mr. Nichols. I introduced myself and the purpose and procedures of the RCRA inspection. He let me know their COVID related procedures. He stated that they require masks that cover nose and mouth, they do temperature screenings, and require six feet of social distancing. I asked if they had a place for us to conduct the opening conference and he stated yes. Mr. Nichols stated that he along with Mr. Smyly will be the facility representatives during the inspection. I asked if they were operating as a LQG and he stated yes. I asked that he have the LQG records available for review and any HW determination documents and facility layouts. Also, I informed him that I would have Mr. Holcomb along with me for training purposes and that we would be there the following day at about 9:00 A.M. CT. Mr. 2 Nichols stated that worked for him and that we were to go to the security gate and ask for him as he will be expecting us. On July 20, 2021, at about 8:45 A.M. CT, prior to beginning the inspection, I conducted a visual reconnaissance of the facility searching for areas of concern observable from the adjacent roadways. I identified no environmental issues or concerns during this preliminary examination. I arrived at the facility's security entrance at about 9:00 A.M. CT. I introduced myself to the security guard and asked for Mr. Nichols. Mr. Holcomb and I met Mr. Nichols in the front lobby area and he escorted us to a conference room near the lobby. There we met Messrs. Smyly, Jackson, Lingenfelser, and Patton. I introduced myself and presented my EPA credentials. I explained the purpose and procedures of the inspection. Also, Mr. Holcomb introduced himself. I explained that Mr. Holcomb was being trained and would be observing during the inspection. I presented them with a copy of RCRA Section 3007(a), which provides 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 made them aware of their confidentiality rights and informed them that a Confidentiality Notice would be provided at the end of the inspection to make a confidentiality claim if they so desired. The RCRA inspection consisted of a discussion of facility operations, waste generation, and waste management; a visual inspection of active waste generation and management areas; and a review of waste management records. During the inspection, Messrs. Nichols, Smyly, and Jackson were present throughout the inspection. Mr. Lingenfelser was present for most of the opening conference and the exit conference. Mr. Patton was present for the opening conference, most of the visual inspection, and most of the records review. During the visual inspection, I met other employees in their respective areas. These additional employees were introduced by Mr. Nichols to answer my questions or escort me through their respective areas. I conducted a visual inspection, of the following: x On July 20, 2021 o First Floor - Inbound Products Awaiting Determination (PAD) Area, Inbound Dock Area, Outside Trash Compactor Area, Vendor Returns Area, HW Cage Area, and Maintenance Cage (aka, Cut Cage) o Third Floor - PAD Area and Floor Maintenance Area x On July 21, 2021 o First Floor - IT Department Cage, HW Cage, and Preparations Area near Inbound Dock o Third Floor - Daifuku Elite Line Services (ELS) Maintenance Office and ELS Parts Cage See Attachments 1A and 1B for the facility layouts and aerial location. Document Photocopies and Photographs were collected as inspection documentation (Attachments 1 through 20 and Photos 1-14). The photo log is included as Attachment 2. Information collected during the inspection is documented on the Entry/Exit checklist and KDHE HW compliance checklists (Attachment 3A and 3B). I reviewed documents including the 3 following: Safety Data Sheets (SDS); damaged goods related databases; emergency plans; shipping documents; waste profiles; weekly container inspections; facility layouts; and manifests/land disposal restriction (LDR) notices. On July 21, 2021, at the conclusion of the inspection, I held a closing conference. Participants included Messrs. Holcomb, Nichols, Jackson, Smyly, Lingenfelser, Lewis, and Ms. Payne. Prior to Mr. Lingenfelser arriving and Ms. Payne and Mr. Lewis being connected by conference call, I provided Mr. Jackson with a Receipt for Documents (Attachment 4) and a Confidentiality Notice (Attachment 5) which he signed as acknowledgement of receipt. No confidential business information (CBI) claims were made. This was verified on August 4, 2021, when Amazon MKC6 submitted their NOPF response that stated information was confidential for which I again asked if any confidential business information was claimed, and the answer was no. After Mr. Lingenfelser arrived and Ms. Payne and Mr. Lewis were connected, I summarized my findings and recommendations and provided Mr. Jackson with a Notice of Preliminary Findings (NOPF), which he signed to acknowledge receipt (Attachment 6). I provided inspection and compliance assistance documents during the inspection and two afterwards (see Attachment 7A for July 24, 2021 email) that included the following: x RCRA Section 3007(a) x Title 18 U.S. Code, Sections 1001 and 1002 x Confidentiality Notice (Top page of the completed carbonless transfer set) x Notice Regarding Proprietary/Confidential Business Information Submitted To Or Collected By EPA In Connection With Inspections Receipt for Documents and Samples x Notice of Preliminary Findings with Instructions for Responding on back of form (Top page of the completed carbonless transfer set) x Homeland Security Anti-Terrorism Standards (EPA Handout) x Environmental Compliance Assistance Centers (EPA Handout) x EPA R7 - Emergency Response Program Superfund x U.S. EPA Small Business Resources (EPA Handout) (emailed July 24, 2021) x A Method for Determining the Compatibility of Hazardous Waste, EPA-600/2-80-076, April 1980 (emailed July 24, 2021) I did not provide any additional KDHE documents as Mr. Nichols and Mr. Jackson stated that they were familiar with the KDHE's website. I followed the inspection procedures detailed in the RCRA CEI Standard Operating Procedure (SOP) 2321.1, unless noted otherwise. Any authorized Federal regulatory citations noted in this report are as adopted by reference in the authorized Kansas regulations. On July 30, 2021, I contacted Mr. Nichols by phone and email with additional questions and clarifications for which he responded (see Attachment 7B for emails and Amazon's response). I spoke with Mr. Smyly on August 4, 2021, to discuss the additional information emailed to EPA and afterwards I added two additional findings as stated in Attachment 7B. 4 4.0 FINDINGS AND OBSERVATIONS 4.1. General Information/ Facility Operations Amazon MKC6 is a part of Amazon.Com Services LLC (Amazon). Their headquarters (HQ) is in Seattle, Washington. Amazon MKC6 is a fulfillment center (FC) and as such distributes many types of household goods including dry non-perishable groceries and over the counter and prescription drugs. In the contingency plan (Attachment 8), this facility is described as follows: "North American Fulfillment Center {FC) MKC6 is located at 6925 Riverview Avenue, Kansas City, KS 66102. MKC6 consists of approximately 855,000 square feet of warehouse space and is a large AR sortable FC shipping products with a maximum dimension of up to 18 inches. Examples of products shipped include: baby products, books, consumer electronics, DVDs, kitchen items, toys, etc. The FC is also classified as an Amazon.com hazardous materials building, which stock and ship products that fall into DOT hazardous material classifications. These products are classified as ORM-D and include: perfumes, paint related materials, household cleaners, etc." Amazon MKC6 opened this approximately 860,000 square feet facility in August 2017. They lease the facility from CBR Property Management. The site contains one main four story building (see Attachments 1A and 1B for facility layout and aerial photo with surrounding information). The distribution process includes the following steps: 1) Goods are ordered and received inbound on trailer trucks from numerous vendors and other Amazon facilities including from Chicago, Illinois, St Louis, Missouri, and Cedar Rapids, Iowa. The goods received are products selected by Amazon HQ that have been identified as high demand type based on analysis. They primarily only receive goods that fit into an 18inch-wide x 22-inch-long x 10.5-inch-high tote (see Photo 1). 2) Goods are unloaded, separated, and stocked in the appropriate warehouse areas on robotic shelves to be available when ordered. 3) When an order comes in, the goods are manually removed and placed on conveyors in totes for packaging and offsite shipment. 4) Orders are packaged and labeled (laser printers are used to print labels). 5) Pallets are loaded onto trailers and shipped via Amazon, FedEx, USPS to other Amazon facilities (none are sent directly to end use customers). Currently, Amazon MKC6 is handling about 300,000 units per day and during peak seasons it may be up to 700,000 units per day where a unit is an item or package. About 50 percent of the inventory is owned by vendors and not Amazon. Amazon MKC6 may conduct a very small amount of repackaging to include relabeling and putting a container inside another bag if they have had problems with it breaking in the past. This is done in the Preparation Area and only about 0.25 percent of the volume handled is repackaged in this manner. Amazon MKC6 has a total of about 3000 to 4000 employees. The facility is operated 24 hours, seven days a week. Amazon MKC6 has a Workplace Health and Safety (WHS) group that 5 handles safety and environmental compliance. It includes five HW Coordinators that work in the HW Cage Area, five WHS Specialists, and three in leadership including Mr. Nichols for a total of 13. Also, Amazon has a regional and corporate safety and environmental group to assist Amazon MKC6 with safety and environmental compliance. Mr. Nichols stated that they have quarterly audits that mainly focus on hazardous waste compliance. 4.2. RCRA Status At the time, I determined that Amazon MKC6 was a LQG of known HW based on the amounts of HW manifested off-site. According to Mr. Nichols, Amazon MKC6 shipped the following amounts of HW: 35,347.81 pounds year to date (YTD) in 2021 and 76,705.31 pounds in 2020 (Attachment 7Bi). Also, I determined them to be a used oil generator and SQHUW lamps and batteries. The actual waste stream breakdown of these totals is included in the biennial reports and e-manifests reports in the RCRAInfo database. According to the EPA RCRAInfo database, Amazon MKC6 initially notified as a small quantity generator on August 6, 2017. They updated their notification on November 13, 2017, and annually since then as an LQG. Their latest Notification of Hazardous Waste Activity was received on March 1, 2021 (certified on February 24, 2021), and fees submitted (see Attachment 7Biii). They notified as a LQG of D001, D002, D003, D005, D006, D007, D008, D009, D011, D016, D018, D027, D035, P075, U002, U072, U154, and U279 HW. I provided Mr. Jackson the RCRAInfo HW Site Info Verification Report (Attachment 9) and asked if any of the information has changed. He noted that Natalie Waid was the Environmental Program Manager as shown on Attachment 9. 4.3. Wastes Management and Waste Streams Wastes Management: Amazon MKC6 manages primarily all waste (including HW, non-HW, universal waste, and used oil) through the Product Awaiting Determination (PAD) Areas. They have three PAD Areas, two on the first floor and one on third floor. At the PAD Areas, the wastes are sorted into categories prior to being taken to the Hazardous Waste Accumulation Area (HWAA). The HWAA is where the HW determinations are made as explained in waste stream #1 and where the HW Cage is located. The HW Cage is where wastes destined for offsite shipment are stored. It consists of an indoor chain link fenced area with containment pallets (see Attachment 1A for facility layout and Photos 4 through 7). A HW Coordinator sorts the waste in the PAD Area and then takes it to the HWAA. There are five HW Coordinators (aka, Waste Processors) and they are trained to handle spills and make HW determinations. At the time there were no satellite accumulation areas being managed onsite. The total amount of time from when the HW Coordinator takes a material from a PAD Area to the HWAA, sorts it, makes a HW determination on it if applicable, and places it into a HW container is less than a day. According to Mr. Nichols, he stated the following (see Attachment 7Bi for email): "Waste must be transferred from the Product Awaiting Determination Area at least once per day, or more frequently based on volume, to the Hazardous Waste Accumulation Area by the HW Coordinators. No waste can be placed in or outside the Hazardous Waste Accumulation Area without WHS approval as it must be processed immediately upon receipt. All waste brought from the PAD Site to the HWAA is processed and placed into HW containers during the HW Coordinators shift time, at maximum approx. 10hrs." 6 Clean Harbors collects the wastes every Monday. The waste management process is discussed in more detail below in waste stream #1. Waste Streams Generated Onsite: I asked for the current HW Cage inventory at the time and received Attachment 10. However, this appears to be a partial inventory of all the waste in the HW Cage since I observed drums of universal wastes but did not see them included in Attachment 10. In the contingency plan (Attachment 8), wastes generated onsite is described as follows: "Amazon does not manufacture any products and does not generate hazardous waste from any manufacturing processes. The hazardous wastes that are generated at this FC primarily consist of products from warehouse inventory that cannot be sold due to damage, recalls, or cannot be donated to local charities. The majority of wastes were at one point consumer commodities. Examples of these products include perfumes, paintrelated materials, household cleaners, butane lighters, and aerosol products. There are also wastes from building and equipment maintenance, but are generated in very limited quantities." Clean Harbors developed waste profiles for potential wastes that may be generated onsite. They are included as Attachment 11. As waste is generated, the HW Coordinators make the HW determinations based on these pre-determined Clean Harbors' waste profiles and SDS according to Mr. Nichols and Mr. Jackson. Some of the profiles were made for Amazon (see Attachment 11 for those including AMZ in the name). I asked if they have conducted any analyses on any waste and Mr. Nichols and Mr. Jackson stated no. All the determinations were based on knowledge and no testing according to Mr. Jackson and Mr. Nichols. They stated that the HW Coordinator is trained to make the HW determinations based on knowledge of where the Clean Harbors profiles state they fit and review of the SDS. It should be noted that the Attachment 11 waste profiles state they are confidential; however, they were not claimed on the Confidentiality Notice (Attachment 5). I asked Mr. Jackson if they were confidential as they were labeled, and he stated that no they were not confidential. Based on this apparent process that all waste would fit into one of these pre-determined profiles, after further review of the Clean Harbors waste profiles I had the following questions/comments: 1. Attachment 11, page 6, shows Bulk Fuel as D001/D018 HW. However, Attachment 11, page 23, shows various petroleum-based products and solvents from cleanup/spills as non-HW. During the inspection, Mr. Nichols and Mr. Jackson stated that the HW determinations were based on knowledge and that no testing was done. Therefore, I asked for the knowledge used to make these non-HW determinations (e.g., did the non-HW determination take into account benzene and the variability of the amount of chemicals that could be present in each cleanup/spill). According to the July 30, 2021, email response in Attachment 7Bi, the following was stated: a. A trained WHS Associate will identify the proper waste profile category for waste products by using the Clean Harbors Waste Profile Matrix, Waste Profile Selection Guide, Hazardous Waste Determination Flowchart (informative) and Classification and Profiling Flowchart (informative), Gensuite Waste Tracker and other available tools. However, this does not appear to exactly explain the knowledge used to determine that a petroleum-based products and solvents spill/clean up waste generated that could vary 7 would not fail applicable TCLP limits every time (e.g., D018 benzene). EPA may follow up further on this issue to verify adequate HW determinations are being made as required by 40 CFR 262.11. (Possible EPA Follow up #1) 2. As stated above in Section 4.2, Amazon MKC6 notified as a LQG of D001, D002, D003, D005, D006, D007, D008, D009, D011, D016, D018, D027, D035, P075, U002, U072, U154, and U279. However, according to the Clean Harbors' waste profiles, they also have identified other potential waste codes in Attachment 11 including U160 (page 6), U240 (page 7), U080 (page 11), P105 (page 11), D010 (page 11), D024 (page 11), U089 (page 11), U188 (page 11), U205 (page 11), U236 (page 11), and U248 (page 11). I asked why not notify for these codes also. According to the email response in Attachment 7Bi, the following was stated: a. "Site has shipped CH-AMZ-FlmPt: 01-Jan-2020 - 30-Jul-2021 i. Waste Profile Code: CH-AMZ-FlmPt Federal Waste Code: D001, D016, U240 b. Quantity Shipped: 8365.00 lbs c. Site has not shipped: U160, U080, P105, D010, D024, U089, U188, U205, U236, U248." Updating HW Notification with Waste Code (NOPF #3 Added on August 4, 2021) - According to KSR 28-31-4(c), each person shall update the information associated with that person's EPA identification number if there is a change in the information. The person shall submit these changes to the department on KDHE form 8700- 12 or another form approved by the secretary, no more than 60 days after the change occurs. Based on the above information, Amazon MKC6 must notify for the U240 waste code. Also, I suggested that they notify for all potential waste codes Clean Harbor identified so they do not have to remember to update their notification within 60 days each time a potential waste code they have not notified for is used. 3. It was stated during the Opening Conference that Amazon MKC6 has no wastewater treatment system onsite. However, I observed a profile for "OWS Waste" - "Non DOT Regulated Material (Wastewater)" (see Attachment 11, page 23). I did not determine prior to completing this report if OWS is an acronym for oil water separator for which used oil and wastewater are generated. EPA may follow up further on this issue to verify if wastewater is being treated onsite and if a HW determination has been made on any related waste streams as required by 40 CFR 262.11. (Possible EPA Follow up #2) Red bag biohazardous waste is collected by Stericycle for disposal. No facility painting is conducted onsite other than touch up painting on the wall. Mr. Nichols stated that they use tape on the floors instead of paint. Customer Returns Received Onsite: Customer returns are received onsite and managed as discussed below in waste stream #1. 8 Materials that are Not to be Handled Onsite: I was provided information regarding the types of materials that are not to be handled at Amazon MKC6. They include those noted on the recycle sheet provided by Ms. Petterman and two presentation slides titled Exceptions and Hazmat and Escalations provided by Mr. Nichols (Attachment 12). They include broken glass, leaking substances, aerosols and gas cylinders, weapons, paint cans, hazmat/ORM-D, flammables, liquids/gels, motor oil, etc. However, I observed some of these materials being shipped offsite as wastes and waste profiles including them (e.g., aerosols, corrosives, flammable liquids, etc.). Therefore, I asked when they are allowed to be handled at this site and end up in the waste streams. According to the email response in Attachment 7Bi, the following was stated: "These exceptions/hazmat items are only handled onsite when these items are damaged during transit to the facility. Any other hazmat items that are sent to the facility are transshipped to MEM2 for processing." I asked Mr. Smyly what is MEM2 and he stated probably a higher level hazardous material Amazon facility. I did not follow up further on how these items end up onsite and the type of processing MEM2 conducts. (Possible EPA Follow up #3) Contractor Services/Wastes: Amazon MKC6 uses contractors in the following areas and any waste generated is to be handled by them unless noted otherwise. x Maintenance onsite is handled by ELS. They have a Maintenance Cage (aka Cut Shop) on the first floor and other stations where no actual maintenance occurs throughout the four floors. Maintenance waste generated is handled by Amazon MKC6's through the HWAA. x Powered Industrial Trucks (PIT), e.g., forklifts, are serviced by Raymond (Kansas City area). x Groundskeeping is serviced by Brightview Landscaping (Kansas City area). x Pest control is serviced by Orkin (Kansas City area). x Amazon MKC6's Transportation Operations group handles the tractors and trailers. The tractors and trailers are either owned or rented by Amazon MKC6. All maintenance on the tractors and trailers is conducted by TA (Travel Centers of America) mechanics. TA comes onsite to do only emergency type maintenance. All other maintenance is done offsite at their facility. x Only mobile fueling is done onsite in a designated area by Jacobus Energy (Milwaukee, Wisconsin). Mr. Nichols stated that they have a spill kit in the area, but there is no collection system or wash down being conducted in the area. Mr. Jackson stated that they do have a storm water permit for this Amazon MKC6 site. x Cardboard recycling is handled by ABM (Kansas City area) for recycling. Waste Streams Reviewed/Discussed: The specific waste streams reviewed/discussed during the inspection are as follows: 9 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT 1 Off- The off-spec goods consist The salvageable off-spec The generation rates of the The salvageable and non- The salvageable Specification of any general merchandise goods are product. salvageable and non- salvageable off-spec goods are sold or (Off-spec) that become damaged salvageable goods vary. They goods are segregated and donated as discussed Goods during handling. Also, they include customer returns as discussed below. The non-salvageable offspec goods are either a HW, non-HW, universal waste, or non-hazardous oil/used oil depending on the type of goods that are off-spec and how they are handled. Clean Harbor's waste profiles of potential wastes are included as Attachment 11. See the HW depend on the type and amount of goods damaged. The amount of damaged goods that were salvaged was not obtained. The amount of non-salvageable goods manifested off-site may be obtained from the latest 2019 biennial report and the emanifests located in the RCRAInfo database (also see Section 4.2 above). managed as discussed below. below. The non-salvageable goods are collected by Clean Harbors for various treatment/disposal as discussed below. determination discussion below for additional details. At the time, I observed the drums shown in the partial inventory included as Attachment 10 (see Photos 4, 5, and 7). Off-Spec Goods Onsite Management Process/HW Determination Discussion - The salvageable and non-salvageable off-spec goods are managed as follows: 1. An off-spec good is observed and retrieved by an employee who places it into a tote. A Problem Solver evaluates it and decides if it should be taken to a PAD Area. If the decision is yes, then the Problem Solver takes it to the designated PAD Area for that location. 2. If a spill occurs, then a HW Coordinator is contacted online. The HW Coordinator cleans the spill using absorbent (or whatever is necessary), collects the waste in a container, and takes it to the HWAA to be sorted according to step #4 below. 3. At the PAD Area, the HW Coordinators sort the off-spec goods into totes as cleaners, oils/lubricants, non-regulated, electrical, pesticides/weed killers, other items, batteries, medical supplies, light bulbs, cosmetics/perfumes, and aerosols/paints (see Photo 1). The totes are collected by the HW Coordinator twice per day (once during day shift and once during night shift) and are taken to the HWAA to be sorted according to step #4 below (see Photo 14). 4. At the HWAA, off-spec goods are sorted into salvageable (i.e., resale), donation, or non-salvageable categories. For those off-spec goods owned by the vendor and not Amazon, the vendor makes this decision. The vendor is contacted electronically by Amazon MKC6's Operations group to determine their decision. a. If the off-spec goods are salvageable, then they are taken to the Inbound Put Back Area to be returned to stock for resale. b. If the off-spec goods are donated, then they are taken to the Donations Area located outside the HW Cage. Donations are made to various organizations including the Kansas City Police Department, Harvesters Food Bank, KC Pet Resource, or Operation Breakthrough. 10 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT c. If the off-spec goods are non-salvageable, then a HW determination is made by the HW Coordinator. They are then placed inside the HW Cage into the appropriate accumulation container. Accumulation container categories include HW, non-HW (including non-regulated excluded/exempted waste), used oil, and universal waste (see Photos 4, 5, and 14). Also, the waste is logged into a drum inventory log known as the Waste Tracker database (see Attachment 10 for a partial current inventory). i. Amazon uses Clean Harbors pre-established waste profiles (Attachment 11) to assist them in making the HW determinations. Also, Mr. Nichols stated that they use the SDS as necessary. d. The waste remains in the HW Cage until it is shipped offsite by Clean Harbors. They collect a shipment every Monday (see shipping log in Attachment 13 and 13A for sample LDR notices). The shipments depending on waste type are treated/disposed as stated on the biennial reports to include fuel blending-H061, energy recovery-H050, storage and transfer - H141, and treat/stabilize prior to landfilling- H132. Amazon MKC6 as a Co-generator (i.e., Disposing of the Vendor's HW) - The vendors pay Amazon MKC6 for storage of their goods and for Amazon to sell their goods through the Amazon company. Amazon does not own the vendors' products onsite. Once the goods become off-spec and the vendor decides to waste it, then Amazon handles the vendors' off-spec goods the same as their own (i.e., through step #4 above). They are included in the same containers as Amazon MKC6's waste to be collected by Clean Harbors. I asked if Amazon gets paid for handling the vendors' HW and Mr. Lingenfelser stated that he did not know what the arrangements were for Amazon disposing of the vendors' HW. The vendors do not lease space, just pay for storage for Amazon to sell their products according to Mr. Lingenfelser. Based on this, it appears that Amazon MKC6 and the vendors would be co-generators of the HW for which Amazon is taking responsibility. Customer Returns - Due to a backlog in the Amazon system, this Amazon MKC6 started processing customer returns in January 2021. During the inspection, Mr. Blau estimated that they process about 10,000 units per day (however, this was later clarified to them processing a total of about 700,000 units to date). The customer returns were not coming directly from the end use customers, but from other Amazon Sorting Centers for processing. The reasons for the returns vary including expired products. I asked Mr. Smyly what the Amazon Sorting Centers do. He stated that they scan a box and based on the material in it, sends it to the best closest geographical Amazon location that can handle that material. Amazon MKC6 is a medium level type hazardous material facility. Therefore, if it is a higher level type hazardous material, then it is sent to a higher level Amazon facility. Since the returns were not coming directly from the customers, to verify no known HW is being received onsite for processing (for which a RCRA permit would be required), I asked about the customer return process which was explained as follows according to Mr. Blau: 1. Customer Returns Management Process a. Mr. Blau stated that all the returns are presorted at the Amazon Sorting Centers prior to arriving at Amazon MKC6. They are not to send any of the do not recycle items listed on the recycle sheet provided to me by Ms. Petterman (Attachment 12, page 1). However, if any are sent to Amazon MKC6 by some error, they should be caught once they arrive onsite based on the customer returns process used. b. The returns arrive onsite at the Inbound Dock Area for sorting. c. The returns are scanned/logged into a T-Rex database that asks various questions about the goods such as why it was returned, condition, etc. Mr. Blau stated that based on the answers, the T-Rex database tells the employee where to place the return. The sorting options include saleable or unsaleable (i.e., destroy, liquidation, hazardous material, or donation). At the time, I observed in the Inbound Dock Area pallets labeled "Destroy" and "Liquidation". They included three labeled "Destroy" (dated 7/8/21, 7/9/21, and 7/12/21) and five labeled Liquidation" (dated 7/9/21, 7/13/21, 7/14/21 (two), and 7/19/21) (Photos 2 and 3). 11 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT d. If the return is flagged as a hazardous material (that should not have been sent onsite), then that information is shared through other computer algorithms (e.g., pandash and werc computer software) to decide on whether it is going for destruction or to the PAD Area. If it is going for destruction, then it is sent to the Vendor Return Area to be processed as explained below. If it is going to the PAD Area, then it is handled with the other off-spec goods as stated above. The returns sent to the PAD Area are only the returns that arrive onsite damaged. They would have been damaged during transit. Known damaged customer returns are not to be sent to Amazon MKC6 for processing or disposing. e. If the return is determined to be liquidated, recycled, or destroyed, then it is sent to the Vendor Return Area (where Ms. Petterman was located) and handled as discussed below in #3. 2. Customer Returns Prescription Drugs - I asked Mr. Nichols if they handle prescription drugs. According to the email response in Attachment 7Bi, the following was stated: "Do they handle prescription drugs? Yes a. Prescription drugs from customer returns. b. profile name: CH-AMZ-TOX-X c. Proper Shipping Name: UN2811, WASTE TOXIC SOLIDS, ORGANIC, N.O.S. (2,4-D, SILVER), 6.1, PGII, ERG(154) Note: CH might change to: UN2810, WASTE TOXIC LIQUIDS, ORGANIC, N.O.S, (2,4-D, SILVER), 6.1, PG II UN3249, WASTE MEDICINE, SOLID, TOXIC, N.O.S., 6.1, PG III d. Federal Waste Codes: D006 D008 D011 D016 D027 D035" Since the above response stated that pharmaceutical drugs were generated from customer returns and the pharmaceutical waste profile included the herbicide 2,4-D, I asked Mr. Smyly how much prescription drugs they shipped offsite in 2020 and 2021 and if the CH-AMZ-TOX-X waste profile included only prescription drugs. According to the email response in Attachments 7Bii and 7Biv, CH-AMZ-PhrmaH is the correct waste code for pharmaceuticals, and they have not shipped any off-site in 2020 or 2021. Kansas has not adopted the HW pharmaceutical rule, therefore, I discussed with Mr. Smyly that receiving known HW (including HW pharmaceuticals that cannot be recycled) for processing from one of their sorters would require a RCRA permit. 3. Customer Returns Sent to Vendor Returns to be Processed - As stated above in #1d and #1e, customer returns that are determined to be liquidated, recycled, or destroyed are sent to the Vendor Returns Area to be processed. Ms. Petterman stated that the Vendor Return Area onsite is a Reverse Logistic Area for vendors. The vendor returns consist of only those goods located at Amazon MKC6 that the vendor asks to be removed from Amazon's system. The vendor returns process is as follows according to Ms. Petterman and Mr. Blau: a. The vendor returns are pulled from storage and taken to the Vendor Returns Area for processing. They are not to include any of the items listed on the do not recycle sheet provided by Ms. Petterman (Attachment 12, page 1) as they should go to the PAD Area. However, some may be sent to the Vendor Returns Area by some error. b. If they are determined to be a hazardous material, then they go to the PAD Area where they are handled as off-spec goods discussed above. c. If they are determined to be liquidated, recycled, or destroyed then they are handled as follows: i. Ms. Petterman stated the returns are either packed and put on hold (i.e., staged until a certain amount is accumulated, but not held for long periods of time according to Mr. Blau), bulk packed, or packed in a spool (i.e., in a container with a barcode). 12 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT ii. Then a determination is made to either handle them one of five ways to include: (1) return to the vendor; (2) liquidate by a third party; (3) donate; (4) recycle by a third party vendor (e.g., the goods may be broken down into parts and certain parts are recycled such as plastic according to Mr. Blau); (4) destroy (would include hazardous materials if they make it this far); or (5) if a gift card, dispose in the general trash. It should be noted that for the above customer returns that are sent to this Vendor Returns Area for processing, the decision would be the same as what T-Rex had already decided earlier when it arrived onsite according to Mr. Blau. iii. If liquidated or recycled, they are sent to Genco (see Attachment 12, page 1 for recycling sheet). iv. If destroyed, Mr. Blau stated that the items are logged into a database tracking system, then they are sent to the appropriate PAD Area to be handled as off-spec goods discussed above. Normally goods to be destroyed are hazardous materials that do not make it through the process this far, but if they do, then they are handle as noted. 4. I asked how many customer returns arrived onsite that were shipped offsite as HW or UW since January 2021. Mr. Nichols stated 0.007 percent of 700,000 units (about 49 units) (see Attachment 7Bi for email). I did not follow up further on any specifics regarding these HW and UW customer returns. (Possible EPA Follow up #4) Storing Incompatibles without Separation (NOPF #1) - According to 40 CFR 265.177(c), HW containers that are incompatible with other waste or materials must be separated by means of a dike, berm, wall, or other means. According to 40 CFR Part 265, Appendix V, caustics and acids are incompatible and the potential consequences are heat generation and violent reaction. The containers of waste inside the HW Cage are placed on containment pallets (see Photos 4, 5, and 7). At the time, I observed on the same containment pallet two drums of caustic waste dated July 18, 2021 (#4323 - D002) and July 16, 2021 (#4316 - D002) and one drum of acidic waste dated July 13, 2021 (#4305 - D002) (see Attachment 10 for drum log and Photos 4 and 6 through 13). Regarding the regulatory separation requirement, it should be noted that the drums are lined with a plastic bag provided by Clean Harbors and all waste from spill cleanup is placed in the container including any broken containers. Therefore, the plastic holding any un-containerized liquids inside the drums would not appear to meet the separation regulatory requirements because the damaged container that is also inside the plastic bag could puncture the bag. Mr. McOsker stated that they did not have a process to separate corrosives into acids and bases, only separate all corrosives together, and this is the way they have always handled them. It should be noted that the weekly container inspection log does not note a problem with incompatibles as the latest (July 14, 2021) shown in Attachment 14. On July 24, 2021, I emailed Mr. Nichols a copy of the compliance assistance book, A Method for Determining the Compatibility of Hazardous Waste, EPA-600/2-80-076, April 1980. Verification of the Non-HW Determination in the Non-HW Acid Accumulation Drum Discussion - To verify some non-HW determinations I asked for the SDS of three randomly selected acids accumulated in the acid non-HW waste drum (Attachment 10, page 5). They included the Rescue One Step Disinfectant Cleaner & Deodorizer wipes that contained hydrogen peroxide (pH 2.0 to 2.5), Clorox Bath Wand (pH 2.1 - 2.97), and Naturevibe Botanicals Citric Acid. I received Attachments 15 and 16 for the wipes and wand, but not the citric acid (I did not pursue the citric acid SDS further since it appeared to be a 100 percent solid and Mr. Smyly stated they were having problems getting a copy from the manufacturer). According to 40 CFR 261.22(a)(1), a waste is corrosive if it is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, as determined by a pH meter using Method 9040C, or it is a liquid and corrode steel at a rate greater than 0.250 inch per year at a test temperature of 130 F as determined by Method 1110A. According to the SDS, the wipes pH ranges from 2.0 to 2.5 and the wand pH ranges from 2.1 - 2.97, although it is not clear what method they used to analyze the pH for these two goods (i.e., the goods have an aqueous phase where the pH is measurable, or a different method was used where water was added). As discussed at the 13 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT beginning of this Section 4.3, no testing is done on the waste as it is all based on knowledge. I did not follow up further on verifying the non-HW determination for the wipes that notes a pH of 2.0 to 2.5 prior to completing this report. (Possible EPA Follow up #5). Possibly Storing Incompatibles in Same HW Acid Accumulation Drum Discussion - According to 40 CFR 265.177(a), incompatibles must not be placed in the same container. After the inspection, I further reviewed the waste accumulated in the HW acid drum (Attachment 10, page 13). I obtained from the internet the SDS for three wastes including Clorox Co. Pine Sol Lemon Fresh Cleaner, Natural Chemistry Pool Perfect + Phosfree, and CLR Pro Calcium, Lime and Rust Stain Remover (Attachments 17 through 19). According to the CLR SDS, it has a pH of 2.05 to 2.3 and is incompatible with strong oxidizing agents, metals (except stainless steel and chrome), bleach, acids, and bases. According to the Pool Perfect SDS, it has a pH of 2.1 to 2.3 and is incompatible with strong oxidizing agents and alkaline materials. According to the Pin-Sol SDS, it has a pH of 10 to 11 (caustic) and no known incompatibles. According to 40 CFR Part 265, Appendix V, caustics and acids are incompatible and the potential consequences are heat generation and violent reaction. I did not follow up further on this potential incompatible issue prior to completing this report including all acids that were accumulated in that drum. (Possible EPA Follow up #6) 2 Spent Rags and Absorbent ELS is contracted by Amazon MKC6 to work onsite maintaining all their equipment. Cloth rags and absorbent are used during the general maintenance. They would be contaminated with oil. Also, the rags may be used with various cleaners, although the main cleaner is Simple Green. The spent rags and absorbents are handled with the off-spec goods (waste stream #1). Clean Harbor's waste profiles of potential wastes are included as Attachment 11 (see waste profile CHAMZ-NonReg, Attachment 11, page 18 as an example). The total amount of spent rags and absorbent shipped offsite is included in the applicable generation rates of the off-spec goods (waste stream #1). Mr. Brook and Mr. Wolf estimated that the spent maintenance rags are generated at about 500 rags per month. The spent rags and absorbents are collected in containers and taken to the PAD Area/HWAA to be handled with the offspec goods (waste stream #1). Ms. Rodgers stated that they only discussed sending spent cloth rags for laundry, however, it was never done. The spent rags and absorbents are handled with the offspec goods (waste stream #1). Absorbent pads are used onsite for spill cleanup. Chemicals Used with Rags - Mr. Brook stated that cloth towels may also be used with brake cleaner during maintenance. I asked for the SDS and received Attachment 20 for Brakleen Brake Parts Cleaner. However, Ms. Rodgers was not aware of the brake cleaner and stated that they only use the chemicals in their Parts Cage. I looked in the third floor Parts Cage flammable cabinet and did not see any brake cleaners. Mr. Stuteville was only aware of the chemicals in the cabinet being used and not the brake cleaner. It should be noted that any waste generated from using the Brakleen Brake Parts Cleaner would be a F005 HW based on the cleaner containing greater than 10 percent toluene before use. I did not see any Clean Harbors waste profiles noted as F005 hazardous waste. I discussed with Mr. Nichols on July 30, 2021, that if they determine that they are using, or start using, this brake cleaner that contains 10 to 20 percent toluene, to be aware that there are no F005 waste codes on the Clean Harbors potential waste profiles. 14 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT 3 Spent Personal Protective Equipment (PPE) PPE is worn by workers throughout the facility and by the HWAA/HW Cage workers including when handling spills. The contaminated PPE is handled separately from the non-contaminated PPE. PPE includes gloves and aprons. The contaminated PPE is handled with the off-spec goods (waste stream #1). The non-contaminated PPE is determined to be non-HW based on knowledge. The amount of spent PPE shipped offsite is included in the applicable generation rates of the off-spec goods (waste stream #1). The non-contaminated PPE generation rate was not obtained. The spent contaminated PPE is collected in containers and taken to the PAD Area/HWAA to be handled with the offspec goods (waste stream #1). The non-contaminated PPE is collected with the general trash (waste stream #8). The spent contaminated PPE is handled with the offspec goods (waste stream #1). The noncontaminated PPE is disposed with the general trash (waste stream #8). 4 Wastewater The following process (aka., Mud related wastewaters are Trap Waste) generated onsite: See discussion below. 1. Wastewater from washing totes with only water in a wash bay. If any spill occurs in the tote, it is cleaned by the HW Coordinators prior to being sent to the wash bay. The amount of wastewater generated was 475 gallons in 2020 and 1000 gallons to date in 2021 according to Mr. Nichols. Amazon has two wash bay areas that each have their own blind collection pit according to Mr. Nichols. They are pumped out about once or twice per year and taken to the Johnson County Landfill. The wastewater is taken to the Johnson County Landfill for stabilizing and then landfilling according to Mr. Jackson. 2. Wastewater from floor sweeper units that are used to clean the warehouse floors, except for any chemical spills. Mr. Nichols was only aware of water being used in the sweepers. Maintaining Test Results and/or Using an KDHE Certified Lab (NOPF #4 Added on August 4, 2021) - According to 40 CFR 262.40(c), test results for documentation of waste determination must be kept for three years. According to KAR-28-31-262(c)(2), if waste was tested the analysis must be conducted by a lab certified by KDHE. During the inspection it was stated that the wastewater from the two collection pits was non-HW and that it would be noted as mud trap waste on the Clean Harbor's waste profile list. However, I was not able to locate it. Therefore, after the inspection I asked Mr. Nichols if a HW determination had been made on it. According to the email response in Attachment 7Bi, the following was stated: 15 # WASTE NAME GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ONSITE MANAGEMENT OFFSITE MANAGEMENT "Reddi Services plumbing and air conditioning pumps out the collection pits. Reddi Services performs PH balance testing prior to emptying mud trap. However, the manifest does not state the PH testing findings." Therefore, I asked Mr. Smyly on August 9, 2021, how they were using the test results, i.e., as tests results or knowledge to make their HW determination. If used as a test, then they are required to use a KDHE certified lab according to KAR-28-31-262(c)(2). If used as knowledge, then they are required to keep the results for three years according to 40 CFR 262.40(c). Mr. Smyly was not sure. Therefore, I added on August 4, 2021, as NOPF #4, either KAR-28-31262(c)(2) or 40 CFR 262.40(c) depending on how they were using the test results (see Attachment 7B for email). It should be noted that the test results must be kept for three years whether they are being used to make the determination or as knowledge. 5 Spent Lamps Spent lamps are changed The spent lamps are The spent lamps shipped The spent lamps are The spent lamps are during building handled as universal offsite are included in the collected in containers handled with the off- maintenance. Mr. Nichols waste (see the Clean applicable generation rates of and taken to the PAD spec goods (waste stated that they do not have Harbors waste profiles in the off-spec goods (waste Area/HWAA to be stream #1). an issue with broken lamps. Attachment 11). stream #1). handled with the off-spec goods (waste stream #1). 6 Spent Batteries Various types of spent batteries are generated onsite from equipment. The different types include leadacid, nickel-cadmium, lithium, and alkaline. The spent batteries are handled as universal waste (see the Clean Harbors waste profiles in Attachment 11). The spent batteries shipped offsite are included in the applicable generation rates of the off-spec goods (waste stream #1). The spent batteries are collected in containers and taken to the PAD Area/HWAA to be handled with the off-spec goods (waste stream #1). The spent batteries are handled with the off-spec goods (waste stream #1). 7 Used Oil 8 General Trash Used oil is generated by onsite equipment maintenance to include gear box changes and from sorters. No used oil filters are generated. Also, there are no goods refrigeration units onsite according to Mr. Nichols. Refuse, paper, etc. The used oil is managed as used oil (see the Clean Harbors waste profiles in Attachment 11). The general trash is determined to be nonhazardous based on knowledge. Generate about 6 quarts of used oil every 26 weeks. The two approximately 20cubic yard dumpsters are collected about once week. The used oil is collected in containers and taken to the PAD Area/HWAA to be handled with the offspec goods (waste stream #1). The used oil is handled with the offspec goods (waste stream #1). The general trash is collected in two trash compacters connected to 20-cubic yard dumpsters. Republic collects the general trash about once a week and disposes of it in a sanitary landfill. 16 4.6. Other RCRA Issues COVID Affects - Amazon MKC6 was not affected by COVID other than since January 2021 they started processing a backlog of customer returns onsite, as discussed in waste stream #1, and they are transferring their past in-person awareness type training (includes some HW related training) to an online format. Contingency Plan Comments - I was provided with the contingency plan that also references an Emergency Action Plan (Attachment 8) and noted the following: x No Evacuation Plan (NOPF #2) - According to 40 CFR 265.52(f), the contingency plan must include an evacuation plan for facility personnel where there is a possibility that evacuation could be necessary. This plan must describe signal(s) to be used to begin evacuation, evacuation routes, and alternate evacuation routes (in cases where the primary routes could be blocked by releases of hazardous waste or fires). The plan did not include the evacuation routes, alternate routes, or a description of the signal. x Emergency Coordinators - The plan contains a list of emergency coordinators (EC). Mr. Nichols stated that he does not know if all the EC listed in the plan are located within a short time (i.e., about 30 minutes). However, he stated that at all times there is at least one EC located onsite to respond to an emergency, as required by 40 CFR 265.55. x Emergency Equipment - The plan included the emergency equipment and its locations, a description, and some capabilities. I discussed with the facility representatives to provide more information on all the emergency equipment capabilities. Aisle Space - I discussed with the facility representatives, including Mr. McOsker, to make sure they maintain adequate aisle space, as required by 40 CFR 265.35, for all the HW containers in the HW Cage. I observed a jack pallet stored in-between two pallets against the fence. However, these pallets contained UW and not HW. Training - Amazon appeared to have a training program in place as required by 265.16. However, all of the class names in the training matrix did not match up with the actual class names of documented required training, although the class content appeared to match. Also, job titles did not exactly match titles on job descriptions. Therefore, I discussed making sure all the names of training classes, job descriptions/titles being used matches the training matrix. Security's Involvement with HW Related Emergency Procedures - On July 19, 2021, when I initially tried to contact Ms. Waid at about 10:45 A.M. CT, and did not reach her, I called the Amazon MKC6 facility directly at a number I obtained from their website (855-556-5214). After no answer, it transferred me to Security. I introduced myself including my name and that I was with US EPA and asked for Natalie Waid. The employee did not know her. I asked if they had an environmental division or group and he said they did not have such a group. I asked for the manager in charge, and he stated that he was not there right now. Since Amazon MKC6 had notified as a LQG and sometimes Security is involved in HW related emergency response procedures, I asked the Security person that if there was a waste related emergency right now who would they contact and he stated "Lost Prevention". I asked for their 17 number and he stated that he could give me the Employee Resources number and maybe they could give me the Lost Prevention number. He gave me 888-892-7180 for Employee Resources. I phoned the number and it was a recording related to human resources and employee related topics that asked the person to press a number for the topic you wanted. Therefore, I hung up. During the inspection, I asked Messrs. Nichols, Jackson, Smyly, and Patton about the facility's emergency response procedures and asked if Security was to be contacted during a HW related emergency. I was informed that Security would be contacted during an emergency but only to contact local authorities (i.e., call 911). I informed them of what happened during my call and the security person not stating the procedures they would follow and not mentioning an EC at all. However, since the initial call in a HW related emergency would go to the EC and not Security, I only informed them of what happened during my call. 5.0 SUMMARY OF FINDINGS I inspected Amazon MKC6 as a LQG of known hazardous waste, used oil generator, and SQHUW lamps and batteries. The following apparent findings/issues were noted as discussed above: x NOPF #1 - Storing Incompatibles without Separation - According to 40 CFR 265.177(c), HW containers that are incompatible with other waste or materials must be separated by means of a dike, berm, wall, or other means. x NOPF #2 - No Evacuation Plan - According to 40 CFR 265.52(f), the contingency plan must include an evacuation plan for facility personnel where there is a possibility that evacuation could be necessary. This plan must describe signal(s) to be used to begin evacuation, evacuation routes, and alternate evacuation routes (in cases where the primary routes could be blocked by releases of hazardous waste or fires). x NOPF #3 Added on August 4, 2021 - Updating HW Notification with Waste Code U240 - According to KSR 28-31-4(c), each person shall update the information associated with that person's EPA identification number if there is a change in the information. The person shall submit these changes to the department on KDHE form 8700- 12 or another form approved by the secretary, no more than 60 days after the change occurs. x NOPF #4 Added on August 4, 2021 - Maintaining Test Results or Using an KDHE Certified Lab - According to 40 CFR 262.40(c), test results for documentation of waste determination must be kept for three years. According to KAR-28-31-262(c)(2), if waste was tested the analysis must be conducted by a lab certified by KDHE. Possible EPA Follow up x #1 - Verify adequate HW determinations are being made on the petroleum-based products and solvents spill/clean up waste. x #2 - Verify if any wastewater is being treated onsite that generates waste streams and a HW determination has been made on them as applicable. x #3 - How exception hazmat items end up onsite and must be sent to MEM2 for processing and what type of process MEM2 conducts. x #4 - Customer returns details that were shipped offsite as HW or UW. 18 x #5 - Verifying the non-HW determination for the wipes that notes a pH range of 2.0 to 2.5. x #6 - Potential incompatibles stored in the same HW acid drum. Other than the items specifically noted in this report, I observed no additional issues or potential findings. However, further EPA review may change or add to my findings. Gardner, Dedriel Date: 2021.08.19 14:14:31 -05'00' Digitally signed by Gardner, Dedriel _________________________________________________ Dedriel L. Gardner Environmental Engineer Date: Digitally signed by CANDACE CANDACE BEDNAR BEDNAR Date: 2021.09.02 12:37:37 -05'00' _________________________________________________ Amber Whisnant RCRA Section Chief, ECAD/CB Date: Attachments 1. Facility Layouts A. Facility Layout (includes the evacuation routes added during the inspection) (4 pages) B. Aerial Photo (1 page) 2. Photo Log (7 pages, 14 Photographs) 3. Checklists A. Entry/Exit Checklist (2 pages) B. KDHE HW Compliance Checklist (17 pages) 4. Receipt for Documents (1 page) 5. Confidentiality Notice (1 page) 6. NOPF (2 pages) 7. Additional Information After the Inspection A. July 24, 2021 Email - EPA Email with Two Additional Compliance Assistance Documents (1 page) B. August 2021 Emails with Attachments - RE Amazon RCRA Inspection Questions Clarifications and Additional NOPFs (3 pages) i. July 30, 2021 Attachment Response to Questions/Clarifications (3 pages) ii. August 9, 2021 Attachment Response to Questions/Clarifications (2 pages) iii. August 9, 2021 Attachment 2020 Annual Hazardous Waste Invoice (4 pages) iv. August 9, 2021 Attachment Pharma Waste Report (1 page) v. August 9, 2021 Attachment Mud Trap special waste KDHE authorization (3 pages) 8. April 19, 2021 Contingency Plan and June 17, 2021 Emergency Action Plan (123 pages) 9. RCRAInfo Hazardous Waste Site Info Verification Report (1 page) 10. Partial Current HW Cage Inventory (17 pages) 19 ATTACHMENT 6, Page 1 of 2