Document rxZn9q9vyBp6DRvwdmMYVbROE

Inspection Date(s): Facility or Site Name: Facility/Site Physical Location: (city, state, zip code) Mailing address (if different from above): Facility/Site Contacts: Website: RCRA ID Number: Latitude, Longitude: OPTIMAX SYSTEMS INC. INSPECTION REPORT 6 June 2024 Inspection Announced: No Optimax Systems Inc 6367 Dean Parkway, (585) 265-1020 Ontario, NY 14519-8939 Junel Chan Environmental, Health and Safety Specialist JChan@optimaxsi.com O: 585.265.1020 ext. 362 | C: 562.673.5649 www.optimaxsi.com NYR000112953 43.02277163324939, -77.09040063806268 Facility/Site Personnel Participating in Inspection: Junel Chan Environmental, Health and Safety Specialist Facilities Manager Inspector(s): Carl F. Plssl Additional Inspection Report Elements: US EPA, Enforcement Officer/Engineer Plossl.Carl@epa.gov (212) 637-4088 Photos, HW Contingency Plan, HW Personnel Training Records and Job Descriptions, Details on NYSP2I & Optimax Research Project, Manifest tracking spreadsheet Inspection Report Author: Carl F. Plssl Plossl, Carl Digitally signed by Plossl, Carl Date: 2024.08.15 15:18:39 -04'00' Team Leader Leonard Grossman LEONARD GROSSMAN Digitally signed by LEONARD GROSSMAN Date: 2024.08.15 15:41:23 -04'00' 1|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT SECTION I - INTRODUCTION Purpose of the Inspection Objective A Compliance Evaluation Inspection (CEI) was conducted to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management. Background This Optimax Systems (Optimax) facility was last been inspected for RCRA compliance by the state on 15 May 2018 and has had a notification history as a large quantity generator (LQG)(notifications on 24 Jan 2019) and as an LQG in Annual Reports from 2020-2024. A review of the facility's waste manifest records shows a consistent generator status of LQG (on a monthly basis). The facility was never inspected under the Clean Air Act or the Clean Water Act. The facility is not in an environmental justice area. 2|Page Opening Conference 6 June 2024. I, EPA Region 2 RCRA inspector Plssl, arrived at the main entrance to the Optimax Systems facility at ~10:15 am for an unannounced inspection of the precision optics manufacturing plant. I announced and identified myself at the reception area and was connected with Junel Chan Environmental, Health and Safety Specialist. Ms. Chan had worked at Optimax since 2017 and was familiar with the nature of federal and state compliance inspections but les so of those conducted pursuant to RCRA federal and state hazardous waste regulations. Ms. Chan and I discussed the facility past and current operations, waste management and disposal practices, and the nature of RCRA inspections. RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT We then began a walk through and inspection of the facility. Facility/Site Description https://www.optimaxsi.com/ From the Optimax Systems website: Precision Optics Fast & Accurate Optimax is a world-class manufacturer of precision optics. Our capabilities incorporate a wide range of manufacturing technologies from which we can engineer solutions that best fit your requirements. Fabrication capabilities range from conventional machinery to highly deterministic CNC machining. According to Mr. Chan: General o Optimax started operations at this site 1998. o Manufacturing operations are mainly precision optics grinding, polishing, and coating. o Optimax is the facility and property owner. o Facility employs 450-470 people in 3 shifts over 5 days. o Local emergency responders are the Ontario Fire Department. The town of Ontario conducts annual or biennial site walk throughs and inspections o Wastewater discharges are thru the sewer to the Ontario POTW. o No onsite tanks (technically incorrect, see walk thru). Hazardous Waste generation o Primarily: D004 ARSENIC D005 BARIUM D006 CADMIUM D007 CHROMIUM D008 LEAD D010 SELENIUM D011 SILVER Barium, lead, and other metal wastes from spent polishing compounds o Secondary (less common) wastes; D001 IGNITABLE D018 BENZENE D035 MEK D040 TCE F002 SPENT HALOGEN SOLVENT The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro- 1,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; ... F003 SPENT NON-HALO SOLVENT The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; ... o Unusual wastes (lab clean out): D003 REACTIVE P106 SODIUM CYANIDE Na(CN) P121 ZINC CYANIDE Zn(CN)2 3|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT o Other: Off-spec materials are lab packed Materials Lab shutdown waste chemicals were lab packed o HW accumulation locations Satellite accumulation areas (SAA) thru-out 90-day storage is in the Central Accumulation Area o Universal waste generation Fluorescent lamps and halogens Batteries Other regulated wastes o Used oil mainly from vacuum pumps and gear boxes o Floor drains go to settling tank. From there, discharge to sewer Facility is setting up a pump and centrifuge WWT system Waste dispositions o Manifests and LDR forms were provided o Online manifest records appeared complete Facility renotified in 2019, and is operating, as a large quantity generator. In 2023-2024 (June), the facility averaged some 4,062-lbs/month. 4|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT Optimax Inc Manifest Date Waste Qty Units 6/27/2024 190 Pounds 6/27/2024 59 Pounds 6/20/2024 3,630 Pounds 6/20/2024 95 Pounds 5/15/2024 1,815 Pounds 5/15/2024 255 Pounds 5/15/2024 225 Pounds 4/17/2024 1,510 Pounds 4/17/2024 60 Pounds 4/17/2024 30 Pounds 4/17/2024 220 Pounds 4/11/2024 2,225 Pounds 3/20/2024 95 Pounds 3/20/2024 1,925 Pounds 3/20/2024 55 Pounds 3/20/2024 25 Pounds 3/19/2024 9,685 Pounds 2/21/2024 4,125 Pounds 2/21/2024 150 Pounds 2/21/2024 400 Pounds 1/17/2024 100 Pounds 1/17/2024 2,445 Pounds 1/17/2024 75 Pounds 1/17/2024 165 Pounds 1/17/2024 330 Pounds 12/13/2023 510 Pounds 12/13/2023 1,885 Pounds 12/13/2023 715 Pounds 11/15/2023 3,555 Pounds 11/15/2023 165 Pounds 11/15/2023 20 Pounds 10/18/2023 3,435 Pounds 10/18/2023 140 Pounds 10/18/2023 945 Pounds 9/20/2023 3,295 Pounds 9/20/2023 330 Pounds 9/20/2023 40 Pounds 9/20/2023 290 Pounds 8/16/2023 85 Pounds 8/16/2023 3,742 Pounds 8/16/2023 75 Pounds 7/19/2023 2,190 Pounds 7/19/2023 250 Pounds 6/21/2023 95 Pounds 6/21/2023 4,605 Pounds 6/21/2023 120 Pounds 5/17/2023 2,685 Pounds 5/17/2023 60 Pounds 5/17/2023 50 Pounds 5/17/2023 255 Pounds 4/19/2023 3,425 Pounds 4/19/2023 75 Pounds 3/15/2023 15 Pounds 3/15/2023 3,330 Pounds 3/15/2023 185 Pounds 2/15/2023 220 Pounds 2/15/2023 3,160 Pounds 2/15/2023 105 Pounds 2/15/2023 30 Pounds 1/18/2023 2,550 Pounds 1/18/2023 420 Pounds 1/9/2023 1,000 Pounds 12/21/2022 90 Pounds Waste (kg) Waste Codes 86 D004 D005 D008 D010 27 D005 D006 D008 1,647 D004 D005 D008 D010 43 D005 D006 D008 823 D004 D005 D008 D010 116 D004 D008 D010 102 D005 D006 D008 685 D004 D005 D008 D010 27 D005 D006 D008 14 D008 100 D008 D018 1,009 D004 D008 D010 43 D001 F003 873 D004 D005 D008 D010 25 D005 D006 D008 11 D008 4,393 D004 D005 D006 D007 D008 D010 1,871 D004 D005 D008 D011 68 D005 D006 D008 181 D008 D018 45 D001 F003 1,109 D004 D005 D008 D011 34 D005 D006 D008 75 D008 150 D008 D018 231 D001 D008 855 D004 D005 D008 D011 324 D005 D006 D008 1,613 D004 D005 D008 D011 75 D005 D006 D008 9 D008 1,558 D004 D005 D008 D011 64 D005 D006 D008 429 D008 D018 1,495 D004 D005 D008 D011 150 D005 D006 D008 18 D008 132 D008 D018 39 D001 F003 1,697 D004 D005 D008 D011 34 D005 D006 D008 993 D004 D005 D008 D011 113 D005 D006 D008 43 D001 F003 2,089 D004 D005 D008 D011 54 D005 D006 D008 1,218 D004 D005 D008 D011 27 D005 D006 D008 23 D008 116 D008 D018 1,554 D004 D005 D008 D011 34 D005 D006 D008 7 D001 F002 1,510 D004 D005 D008 D011 84 D005 D006 D008 100 D001 D004 D005 D008 D011 F003 F005 1,433 D004 D005 D008 D011 48 D005 D006 D008 14 D008 1,157 D004 D005 D008 D011 191 D008 D018 454 D004 D005 D007 D008 41 D001 F003 TSDF ID OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 ILD980613913 KYD053348108 OHD000816629 ILD980613913 OHD000816629 OHD000816629 ILD980613913 PAD067098822 OHD000816629 OHD000816629 KYD053348108 ILD980613913 OHD000816629 OHD000816629 ILD980613913 KYD053348108 KYD053348108 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 KYD053348108 OHD000816629 OHD000816629 OHD000816629 KYD053348108 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 OHD000816629 KYD053348108 OHD000816629 OHD000816629 ARD069748192 OHD000816629 OHD000816629 ARD069748192 OHD000816629 OHD000816629 ARD069748192 OHD000816629 KYD053348108 PAD067098822 ARD069748192 Total Waste/ MTN* shipment Units lbs/month 009201715SKS 009201715SKS 009201870SKS 009201870SKS 3,974 lbs 3,360 lbs 009201815SKS 009201815SKS 009201815SKS 2,295 lbs 2,495 lbs 009201960SKS 009201960SKS 009201962SKS 009201959SKS 1,820 lbs 2,518 lbs 009201947SKS 2,535 lbs 3,507 lbs 009106784SKS 009106783SKS 009106783SKS 009106784SKS 019386062FLE 11,785 lbs 13,285 lbs 009106705SKS 009106705SKS 009106707SKS 4,675 lbs 4,066 lbs 009106850SKS 009106849SKS 009106849SKS 009106850SKS 009106852SKS 3,115 lbs 2,709 lbs 009106946SKS 009106945SKS 009106945SKS 3,110 lbs 3,381 lbs 008881185SKS 008881185SKS 008881185SKS 3,740 lbs 4,066 lbs 008881154SKS 008881154SKS 008881155SKS 4,520 lbs 4,913 lbs 008894074SKS 008894074SKS 008894074SKS 008894075SKS 3,955 lbs 3,439 lbs 008912644SKS 008912644SKS 008912644SKS 3,902 lbs 4,242 lbs 008912603SKS 008912603SKS 2,440 lbs 2,652 lbs 008893752SKS 008893752SKS 008893752SKS 4,820 lbs 4,232 lbs 008594394SKS 008594394SKS 008594394SKS 008594395SKS 3,050 lbs 3,316 lbs 008594346SKS 008594346SKS 3,500 lbs 3,044 lbs 008594480SKS 008594479SKS 008594479SKS 3,530 lbs 3,837 lbs 008594449SKS 008594448SKS 008594448SKS 008594449SKS 3,515 lbs 3,821 lbs 008284363SKS 008284364SKS 2,970 lbs 10,044 lbs 016455062FLE 1,000 lbs 1,602 lbs 008284311SKS LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG LQG 5|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT Additional records requested during inspection: o Recent waste manifests and associated LDR's for the past year (received copies during inspection) o Sample HW Inspection Log (see above)(received by email) o HW Contingency Plan (copy received during inspection - source of above facility map) o HW Personnel Training Records and Job Descriptions o Details on NYSP2I & Optimax Research Project o Other requests detailed in Post-Inspection Emails (Appendix 1) SECTION II - OBSERVATIONS The accompanying OPTIMAX SYSTEMS, INC Inspection Photo Album-June 2024.pptx document is the complete set of inspection observations made during the facility walkthrough with Ms Chan. 6|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT SECTION III - AREAS OF CONCERN Concerns (see OPTIMAX SYSTEMS, INC Inspection Photo Album-June 2024.pptx for additional details) Facility did not meet the 6 CRR-NY 372.2 Standards applicable to generators of hazardous waste, including: o Hazardous waste determination - 372.2(a)(2) Determination had not yet been made for waste sludge/paste observed in a centrifuge basket (Slide 7) and expired chemicals (Slide 60). o Accumulation Area Requirements - 372.2(a)(8)(i) o 90 Day Storage - 372.2(a)(8)(ii) and 373-3.9(b) All wastes in containers and tanks are shipped off-site to an authorized treatment, storage or disposal facility (TSDF) in 90 days or less - 372.2(a)(8)(ii). See Slide 31, for example 7|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT The date upon which each period of accumulation begins is clearly marked and visible for inspection on each container and tank - 372.2(a)(8)(ii), 373-1.1(d)(1)(iii)(c)(2), 3731.1(d)(1)(iv)(d). Numerous hazardous waste drums lacked accumulation start dates. All containers except those in use are closed - 373-3.9(d)(1). See Slide 26, for example Containers are marked with the words "Hazardous Waste" and with other words that identify the contents of the containers - 373-3.9(d)(3). The clarity of certain of the hazardous waste labels was lacking o Personnel Training - 373-3.2(g) a written job description for each position - 373-3.2(g)(4)(ii); a written description of the type and amount of both introductory and continuing training that will be given to each person related to hazardous waste management 373-3.2(g)(4)(iii); and records that document that the training or job experience required has been given to and completed by facility personnel - 373-3.2(g)(4)(iv). Also Facility personnel have taken part in an annual review of the initial training required 373-3.2(g)(3). The requirements of this section were not fully met. o Preparedness and Prevention - 373-3.3 Facility communications or alarm systems, fire protection equipment, and spill control equipment are tested and maintained as necessary to assure their proper operation in time of emergency - 373-3.3(d). As discussed, fire extinguisher inspections lacked consistency. o Contingency Plan - 373-3.4 Names, addresses and office and home phone numbers of all persons qualified to act as emergency coordinator; 373-3.4(c)(4). Plan lacked addresses and office phone numbers. Regarding the experimental tank and treatment system, the facility did not meet the o Assessment of Tank Systems or Components Installed after 7/14/86 - 373-3.10(c), o Secondary Containment Requirements - 373-3.10(d), o Annual Leak Test or Tank Integrity Examination - 373-3.10(d)(9), o General Operating Requirements - 373-3.10(e), o Inspections: - 373-3.10(f), or o Air Emission Standards requirements. Closing Conference Ms Chan and I reviewed my findings and we discussed any follow up. Ms Chan said that she would email me the requested documents shortly and would immediately begin work on the concerns we discussed (see Appendices). We agreed that we would correspond by email regarding any additional issues. INSPECTION PHOTOGRAPHS: See OPTIMAX SYSTEMS, INC Inspection Photo Album-June 2024.pptx FOLLOW UP EMAILS: See Appendix 1 8|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT PROVIDED RECORDS: See Attachments APPENDICES Appendix 1: Facility Emails re Requested Documents ATTACHMENTS: Attachment 1: OPTIMAX SYSTEMS, INC Inspection Photo Album-June 2024.pptx Attachment 2: RCRA Contingency Plan Attachment 2: TRI Report Attachment 3: Facility Manifests as Provided to EPA Attachment 4: Personnel Training Records 2023, 2024 Attachment 5: HW Trained Personnel: Names, Job Titles, Job Descriptions Attachment 6: NYSP2I & Optimax Research Project 9|Page RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT Appendix 1: Follow Up Email Chain From: Junel Chan <JChan@optimaxsi.com> Sent: Monday, June 10, 2024 1:01 PM To: Plossl, Carl <Plossl.Carl@epa.gov> Cc: Brad Hyman <BHyman@optimaxsi.com> Subject: Optimax Systems Inc. - NYR000112953- 06.06.24 Inspection Importance: High Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Hi Carl, I hope you had a safe trip back to Brooklyn and had a relaxing weekend! It was a pleasure meeting you last week. Attached are the documents you requested and below are corrective actions I've noted for us to cover. I will look into the regulations, but if you have any guidance regarding the labeling of containers for used acetone prior to being placed into the solvent distillation unit - should it be labeled with "hazardous waste"? Thank you for your time and feedback during the inspection last week. It's greatly appreciated and will aid us in improving our procedures. Please let me know if you require additional information or have questions/suggestions. 1. Documentation Requested a. Contingency Plan i. See attachment "Facility Contingency Reference Guide" b. Maintenance Personnel Names, copy of job description, and training records i. See attachment "Maintenance Personnel and Training.zip" ii. Corrective Action: Schedule site specific in-house training to maintenance personnel moving containers from satellite accumulation areas to 90-day storage. Schedule annual refresher. 1. Timeline: To be conducted the week of June 10th, but no later than June 28th c. Year-to-Date Weekly Inspection Record of Central Accumulation Area (CAA - 90-day storage) i. See attachment "2024 YTD - CAA HazWaste Inspection Checklist" ii. Corrective Action: Weekly inspection will be alternated between Junel Chan and Chris Masi on a monthly basis to ensure there is a fresh set of eyes. 1. Timeline: Alternate will start July 2024 iii. Corrective Action: Monthly inventory of containers in 90-day storage 1. Timeline: Week of June 10th iv. Corrective Action: On an quarterly basis, another employee who's role is not related to hazardous waste will accompany inspections to provide another set of eyes. 1. Timeline: Starting July 2024 d. NYS Pollution Prevention Institute Project Report i. See attachment "NYS2PI Supports Optimax with Reducing Costs and Hazards" ii. Let me know if you'd like the report for the partnership study we did with NYS Pollution Prevention in regards to antifouling coatings on membranes 10 | P a g e RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT iii. Corrective Action: Will purchase a covered tank and determine feasibility of recirculation without intermediary tank/container that's currently open 1. Timeline: By end of July 2024 e. Safety Data Sheet for UltraCool Coolant - from observed coolant change waste stored in 55-gal stored outside of CAA i. See attachment "LaPelSolutions UltraCool Coolant SDS" ii. Corrective Action: Move (2) 55-gal coolant waste barrels into CAA. Spoke with Maintenance Team Leader. This will be covered during training with the maintenance team. 1. Status: Completed f. Full TCLP result for waste sludge/paste observed in a centrifuge basket - PENDING i. Will provide once this analysis is complete ii. Request from inspection: Provide full TCLP analysis report from a representative sample of the waste sludge/paste contained in centrifuge baskets. iii. Corrective Action: Representative sampling to be conducted. Sample will be taken from area observed during inspection. 1. Timeline: Will have sampling done as soon as possible with environmental lab. Report will be sent as soon as possible. 2. Verbal Notice During Closing Conference a. Two barrels noted to be over 90 days i. Corrective Action: Remove wastes stored over 90-days 1. Timeline: By end of June 2024 ii. Corrective Action: Implementation of monthly inventory of 90-day storage 1. Timeline: Will start Week of June 17th b. Movement of container from SAA to CAA i. Corrective Action: Quantity of waste in barrel will be checked during weekly SAA inspections. If close to full, the barrel will be swapped out for the area during that time. 1. Timeline: To be implemented during SAA inspection the week of June 10, 2024 c. Labeling on containers in SAA i. Corrective Action: Modify labels used in satellite accumulation areas to indicate waste constituents and/or hazards and make written accumulation dates more legible 1. Timeline: By end of June 2024 3. Other Actions a. Fire extinguisher inspections i. Corrective Action: Monthly inspections has been transferred to a different employee. Inspections were conducted on 06-07-24. 1. Timeline: Completed b. Aerosol puncture barrel in chemical storage room i. Corrective Action: Implement easy visual of when filter was last changed 1. Timeline: By Week of July 1st 11 | P a g e RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT c. Solvent (acetone) container for collected used acetone i. Corrective Action: Purchase and implement funnel system with closed top for use when collecting used acetone 1. Timeline: By Week of June 24th Junel Chan Env., Health and Safety Specialist O: 585.265.1020 ext. 362 | C: 562.673.5649 6367 Dean Parkway, Ontario, NY 14519 www.optimaxsi.com 12 | P a g e RCRA Compliance Branch OPTIMAX SYSTEMS INC. INSPECTION REPORT 13 | P a g e