Document vd303OJEodxaD85xV6yM3k5R

Inspection Entry Date/Time Inspection Exit Date/Time Weather Regulatory Program Type of Inspection EPA Region 10 Enforcement Division INSPECTION REPORT 09/07/2022 10:35 AM (PT) Announced: No 09/07/2022 01:15 PM (PT) Access: Granted Sunny, dry, 80s RCRA CEI - Compliance Evaluation Inspection Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Size of Facility Length of Facility at Location Geographic Coordinates Collins Aerospace Goodrich Corporation Carbon Products WAH000006940 11135 W Westbow Blvd Spokane, WA 99224 Spokane LQG 336413 - Other Aircraft Parts and Auxiliary Equipment Manufacturing Carbon manufacturing brake disks 27 acres manufacturing, plus 140,000 sq ft support areas Since 1998 47.583604, -117.568511 Permit Number (If Applicable) Not Applicable Lead Inspector: Katie Bradshaw Peer Review: Matt Quarterman Supervisor Review: Jen Sullivan KATRINA BRADSHAW Date: 2022.09.23 09:30:16 -07'00' Digitally signed by KATRINA BRADSHAW EPA Region 10 bradshaw.katrina@epa.gov (206) 553-6318 MATTHEW QUARTERMAN Date: 2022.09.23 09:47:43 -07'00' Digitally signed by MATTHEW QUARTERMAN EPA Region 10 Jennifer A Sullivan Date: 2022.09.23 10:05:04 -07'00' Digitally signed by Jennifer A Sullivan EPA Region 10 Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI - Compliance Evaluation Inspection EPA Region 10 Lead Inspector, Katie Bradshaw, arrived at the Goodrich Corporation Carbon Products Facility (the "Site" or "Facility"), located at 11135 W Westbow Blvd, Spokane, WA 99224, at 10:35 AM (PT) on 09/07/2022 for an unannounced RCRA inspection. EPA Region 10 Lead Inspector presented credentials to and informed Craig Meredith, Safety Manager, that this was an EPA Region 10 inspection to determine compliance with the Resource Conservation and Recovery Act (RCRA). This inspection was conducted pursuant to Washington's federally authorized RCRA regulations found at Washington Administrative Code (WAC) 173-303. The facility was inspected to ensure compliance with standards for hazardous waste generators, universal waste management, and used oil management. The inspection was conducted as part of a Core Program requirement for FY 2022. This report is based on information supplied by Goodrich Corporation Carbon Products Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its Headquarters, but not limited to: direct observations made by the EPA Region 10 inspector, photographs taken by EPA Region 10 inspector, physical evidence collected by the EPA Region 10 inspector, measurements or samples taken by EPA Region 10 inspector, verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector by the facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Email Lead Inspector Safety Manager Environmental Compliance Manager Katie Bradshaw (206) 553-6318 Craig Meredith Chris Matuszak (509) 744-6038 bradshaw.katrina@epa.gov Craig.Meredith@collins.com Chris.Matuszak@collins.com Opening Conf. Yes Yes Yes Closing Conf. Yes Yes Yes Opening Conference I, EPA Lead Inspector Katie Bradshaw arrived at the Goodrich Corporation Carbon Products at 10:35 AM (PT) on 09/07/2022 for an inspection. I presented my credentials to and informed Craig Meredith that this was an EPA RCRA inspection. The table above presents all the inspection participants in opening and closing conferences. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. Specifically, I inspected the following areas of the facility listed below: Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. 2 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 Facility/Site Information What type of generator facility verified as? Large Quantity Generator, verified by Chris Matuszak, along with observations during inspection, and review of manifests What type of LQG generator facility notified? Safety Training Yes Provided to Inspector(s)? Operating Hours 24 hours a day, 365 days a year Weather Conditions Sunny, warm, dry Number of employees 223 Process Description Carbon manufacturing of brake disks is accomplished by the following processes: Textile processing Single Step Carbonization (SSC) Chemical Vapor Deposition (CVD) Feature Machining Finishing Building(s) Building/Area/Sub-area Admin Furnace Deck Main Level 1,2,3 Basement Phase 1,2,3 Machine Shop Finishing SAA Main Level Haz Waste Cage SSC Basement Textile Process Description single step carbonization 90-day area, three oil tanks transfer to a single storage tank, satellite accumulation areas Area Of Concern No No Yes No No No Yes No No Yes No 3 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 SECTION II - OBSERVATIONS Building: SSC/Basement Observation #: KB1-OB-003 Person Interviewed: Date: 09/07/2022 Contains AOC: Yes Title: Contains CBI: No While inspecting the single step carbonization process in the basement, I observed four 55-gallon drum container, each labeled as hazardous waste. All four containers were closed and had accumulation start dates and hazard indicators. Two of the containers in this area had labels listing the waste as D003 reactive waste but had toxic hazard indicators. One container was labeled as, "SSC Carbon Tar PPE, Rags, Absorbent, & Ammonia," the other was labeled "SSC Acid Filters." Photo(s) 1. IMG-202209071129432943190550.jpg 2. IMG-202209071130193019158098.jpg 3. IMG-202209071130323032179667.jpg Building: Furnace Deck/SAA Observation #: KB1-OB-004 Person Interviewed: Date: 09/07/2022 Contains AOC: Yes Title: Contains CBI: No While inspecting the satellite accumulation area on the furnace deck, I observed two 55-gallon drum containers. Both were closed and labeled as hazardous waste. On each label were D003 reactive waste codes. The hazard indicators listed health hazard and environmental hazard. One container was labeled as, "FD Lid Scrapings," the other was labeled as, "FD Vertical Heat Exchanger Cleanout Condensers, Demister Pads." Photo(s) 1. IMG-202209071137213721168984.jpg 2. IMG-202209071137293729175814.jpg Building: Machine Shop/SAA Observation #: KB1-OB-005 Person Interviewed: Date: 09/07/2022 Contains AOC: Yes Title: Contains CBI: No While also inspecting the Machine Shop, I observed one 55-gallon drum container. The container had a funnel lid that was open. I was told this container was used oil. During the inspection a facility representative closed the funnel and attached a label to the container with the words "Used Oil." Photo(s) 1. IMG-20220907120454454189177.jpg 2. IMG-2022090712050858202209.jpg 3. IMG-20220907120536536160128.jpg 4 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 SECTION III - RECORDS REVIEW Record: Manifests Ref #: KB1-RR-001 Reviewed By: Katie Bradshaw AOC: No Reviewed Date: 09/07/2022 I reviewed all manifests from calendar years 2021 and 2022. Record: Inspections Ref #: KB1-RR-002 Reviewed By: Katie Bradshaw AOC: No Reviewed Date: 09/07/2022 I reviewed weekly central accumulation area inspections for calendar year 2022. This facility conducts inspections of each central accumulation twice weekly. Record: Personnel Training Ref #: KB1-RR-003 Reviewed By: Katie Bradshaw AOC: No Reviewed Date: 09/22/2022 I reviewed the training records for the following employees: Craig Meredith (2021) and Chris Matuszak (2022). SECTION IV - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Machine Shop KB1-OB-005 Area: SAA Sub-area: One container of used oil not closed, Citations: WAC 173-303 not labeled as "Used Oil." Building: SSC KB1-OB-003 Area: Basement Sub-area: Waste codes were for D018 and D003. Hazard indicators were for health hazard and environmental hazard. Citations: WAC 173-303 Building: Furnace Deck KB1-OB-004 Waste codes indicated reactive waste; hazard indicators were for toxic waste. Area: Main Level Citations: WAC 173-303 Sub-area: SAA 5 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 One additional area of concern is the hazardous waste tank in the basement level of the SSC area. This tank designates as Extremely Hazardous Waste and receives oil from the three oil tanks which are part of the oilwater separator process. I asked Chris Matuszak if the tank was subject to Subpart CC requirements, and he replied that he was not sure. SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference During the closing conference, I reviewed the areas of concern cited above with Chris Matuszak and Craig Meredith. I requested the following: Documentation of the corrected hazard indicator labels A copy of the contingency plan The waste profiles for the Waste Scrubber Oil Most recent analytical results for the Waste Scrubber Oil Waste profile for the Contaminated Rags Waste Profile for the SSC Waste Liquids I explained that I was not making a compliance determination on site, and that any follow up would likely come from a compliance officer once I finished the report. I thanked them for their time and cooperation and departed the facility at 1:15 PM. Follow Up I observed Chris Matuszak close the funnel and label the used oil container in the Machine Shop SAA. Communication Log I received an email from Chris Matuszak with the following records: Contingency Plan Waste Profiles of the Scrubber Oil and mis-labeled containers Waste Scrubber Oil Analytical Results Photographs of Updated Waste Labels with Hazard Indicators SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 6 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 APPENDIX 1: PHOTO LOG Label with "Toxic" indicator and D003 code 09/07/2022 11:37 AM Furnace Deck SAA IMG-202209071137213721168984.jpg Photographer: Katie Bradshaw No CBI No PII Label with "Toxic" indicator and D003 code 09/07/2022 11:37 AM Furnace Deck SAA IMG-202209071137293729175814.jpg Photographer: Katie Bradshaw No CBI No PII 7 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 Open funnel on used oil container; no label 09/07/2022 12:04 PM Machine Shop/SAA IMG-20220907120454454189177.jpg Photographer: Katie Bradshaw No CBI No PII Chris M. closed funnel on used oil container 09/07/2022 12:05 PM Machine Shop/SAA IMG-2022090712050858202209.jpg Photographer: Katie Bradshaw No CBI No PII 8 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 Chris M. placed "Used Oil" label on container 09/07/2022 12:05 PM Machine Shop/SAA IMG-20220907120536536160128.jpg Photographer: Katie Bradshaw No CBI No PII Label with "Toxic" indicator and D003 code 09/07/2022 11:29 AM SSC/Basement IMG-202209071129432943190550.jpg Photographer: Katie Bradshaw No CBI No PII 9 of 10 Goodrich Corporation Carbon Products Inspection Date: 09/07/2022 Label with "Toxic" indicator and D003 code 09/07/2022 11:30 AM SSC/Basement IMG-202209071130193019158098.jpg Photographer: Katie Bradshaw No CBI No PII Backup view of labels with "Toxic" indicator 09/07/2022 11:30 AM SSC/Basement IMG-202209071130323032179667.jpg Photographer: Katie Bradshaw No CBI No PII 10 of 10