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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 RESOURCE CONSERVATION AND RECOVERY ACT BASIC INFORMATION Facility Name: Sioux Manufacturing Corporation Facility Location: 1115 Dakotah Drive, Fort Totten, North Dakota 58335 RCRA ID: XHN068155423 Notification Status: SQG Facility Contact: Jim Anderson, Engineering Manager, 701-766-4211 ext. 2018, janderson@siouxmanufacturing.com Date of Inspection: June 9, 2022 Arrival Time: 9:30 a.m. Departure Time: 3:20 p.m. Lead Inspector: Annette Maxwell, U.S. EPA RCRA Inspector Other Attendees: 1. Kristin McNeill, RCRA Inspector, U.S. EPA 2. Lynnia Bustos, Environmental Technician, Spirit Lake EPA 3. Jim Anderson, Engineering Manager, Sioux Manufacturing 4. Robby Mock, Facilities Manager, Sioux Manufacturing 5. Kyle Lafontaine, IT Technician, Sioux Manufacturing 6. Daniel Nestell, Materials Supervisor, Sioux Manufacturing Type and Purpose of Inspection: Compliance Evaluation Inspection Compliance with RCRA Subtitle C Facility Type: Composite armor manufacturing facility Facility located on Tribal land Applicable Regulations to Inspection: 40 CFR Parts 260-279 Inspection Type: Unannounced Inspection EPA Inspection OPENING CONFERENCE Credentials Presented CBI warning to facility provided The following information was obtained verbally during the inspection from Mr. Anderson and Mr. Mock unless otherwise noted. General Facility and Process Description: Sioux Manufacturing Corporation is a manufacturer of composite armor products. The facility is owned and operated by the Spirit Lake Nation and has been in operation since approximately 1973. The primary product currently manufactured at Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 the facility is kevlar liners for military vehicles and equipment. The facility has approximately 80 employees and operates one shift from 8:00 a.m. to 4:30 p.m., Monday through Friday. Operations at the facility include weaving, coating, cutting and molding. The facility is approximately 250,000 square feet in size. The facility layout is organized into Plants 1, 1A and 1B. See Attachment 1 - Site Map. The portion of the building that was formerly Plant 1C is no longer part of Sioux Manufacturing. Operations occurring by area at the facility include Plant 1 - molding, quality control, GunMounted Ballistic System (GMBS) operations, painting and sheeting (cutting); Plant 1A - water jets, CNC, remanufacturing, marking and touchup, coating, molding and presses; and Plant 1B - weaving, trim room, warehouse (shipping and receiving) and freezers. Hazardous waste generated at the site is stored in the chemical storage room located in Plant 1A. Mr. Mock stated that the facility's generator status at the time of the inspection was very small quantity generator, although generation rates depend on contracts and could change. Mr. Anderson stated that waste isopropyl alcohol (IPA) is generated at very low rates, approximately 100 gallons/year. The facility's notification status in EPA's RCRAInfo database at the time of the inspection was small quantity generator (SQG) based upon the most recent notification provided to EPA on 3/22/2010. Wastewater from waterjet operations is discharged to the sewer after routing through a sediment tank. The POTW is Sioux Utilities. The waterjet tanks are periodically pumped out by a waste hauler; the waste is primarily garnet with water. A previously used anodizing operation has been dismantled and removed. A roll-off trash dumpster is disposed to Sawyer landfill. The Sawyer landfill website states that this landfill is a non-hazardous industrial waste landfill operated by Clean Harbors, NDD000351270. This dumpster is referred to below as the "roll-off dumpster." The facility has been issued air pollution control PSD permit no. PSD-SLS-0001-05.00, which is available for viewing at https://www.epa.gov/caa-permitting/caa-permits-issued-epa-region-8. TOUR INFORMATION All photos collected during the inspection are included in Attachment 2 - Photograph Log. Areas of the facility toured: I toured the following areas with Mr. Anderson and Mr. Mock (below noted as "facility personnel" or by name) as well as Ms. McNeill and Ms. Bustos: x Plant 1 o GMBS operations Glue is removed by heating and scraping, with scraped glue disposed to McDaniels landfill near Minot. The facility website states that this landfill Page 2 of 6 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 is operated by Waste Management and accepts non-hazardous industrial solid waste. o Paint booth Spray gun cleaner used in this area is Safety Kleen's Ultra Kleen Spray Equipment Solution. Facility personnel stated that a hazardous waste determination had not been performed for the paint booth filters. o Satellite accumulation area A flammable cabinet labeled "Hazardous Waste" contained a 55-gallon drum equipped with a spring-loaded lidded funnel that held hazardous waste and was labeled with the words "hazardous waste" and an indication of the hazard (flammable). See photos 1-2. o Used oil storage area Hydraulic oil and mineral (heat transfer) oil are stored here. Tri-B Oil picks up this used oil, and the next pickup was scheduled for July 2022. o QA laboratory No hazardous waste is generated in this lab. Tests include specific gravity, tensile testing and resin testing. Resin samples are returned to the process after testing. o Press area o Ablative scrap storage The facility personnel stated that this scrap is inert and will be disposed to the landfill in the roll-off dumpster. o Rags waste can Small red trash can containing waste rags used to wipe Loctite 700-NC Frekote. These rags are disposed into the roll-off dumpster. x East side of facility - scrap steel storage x Plant 1B o Shipping and receiving, finished products, raw materials, supplies o Cold storage area o Ovens for curing o Grit blasting Grit is used to aid in bonding per customer specifications; material being blasted is glass phenolic composite. Grit is reused and tested for contaminants. Spent grit is disposed in the roll-off dumpster. Grit is also collected in a dust collector, and grit accumulated here is also disposed to the roll-off dumpster. o Trim room Saws are used to cut bevels. A waste container is used to collect rags used to wipe paint pen markings using IPA. Dust collection system - dust is accumulated in cardboard barrels and disposed to the roll-off dumpster. o Bonding area Page 3 of 6 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 o Autoclave (curing) o R&D storage o Weaving Department o Former clean room (labeled above door "Process Dev Area") Flammables cabinet with one blue 55-gallon drum and one green 55gallon drum. Both drums had a layer of dust on top indicating that they may not have been used for some time. See photos 3-7 and 9. x The blue drum label was marked received Sep 11, 1998, "Shelf Life 24 months" and "Retest After 7-15-99". This drum was also marked as epoxy resin, CAS Number 025085-99-8. x The green drum was labeled "Curing Agent" and "Amines, liquid, corrosive, n.o.s. (Cycloaliphatic Amine)". This drum was marked received Feb 2 1998, "Shelf Life 36 mo's" and "Retest After 5-12000." Yellow flammables cabinet x Contained old chemicals, including at least one marked with a 1996 date. See photos 10-13. x Plant 1A o Ballistic lab, where simulated steel (not lead) projectiles are used to test products o Paint booth - chemical agent resistant paint o Water jets - drain following garnet settling leads to POTW o Garnet storage, 80-grit o Flammables cabinet IPA - 55-gallon drum, see photos 14 & 15. o Four cardboard drums with absorbant soaking through - Mr. Mock stated that he would take care of these drums that same afternoon. o Chemical Storage Room Contained inside secondary containment berm: x four empty drums x one drum of solvent - IPA dated 7/15/2021, labeled "hazardous waste" and "Flammable" x one SAA drum of aerosol cans, labeled "hazardous waste", contained only a small number of aerosol cans, had been accumulating since 2017 Other items in the room included chemical raw ingredients awaiting use o Mixing room Air from this room goes through the oxidizer air pollution control device Mixing tank 4 storage tanks Lines route to coating, then return to the same tank A floor drain leads to outside if the fire suppression system is deployed; the drain is open to outside and leads to a bermed area that is lined with rubber. See photo 17 of the outside area. Discoloration was observed outside in the immediate vicinity of the drain. o Coating line: ovens; resin coating added to kevlar Page 4 of 6 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 o Wedge Block Molding x Returned to Plant 1 o Main rags drum Facility personnel stated that it takes approximately two months to get full, at which point it goes into the roll off dumpster. o Maintenance Area Spent lead acid battery storage - facility personnel stated that batteries are taken to a recycler, usually Gerdau, who pays for them. o Spent lamps - spent mercury-containing lamps were stored on the first and second floors. See photos 18-20. Mr. Mock stated that the lamps had been accumulating for probably three years, and that they were planning to buy a bulb crusher. Mr. Mock estimated that each container held approximately 300 lamps. I observed a total of 22 containers of lamps in the upstairs storage area, three of which were 8' long lamps; only ten of the 22 containers were closed at the time of the inspection. I observed an additional five containers of lamps in the first-floor maintenance area, none of which were closed. Additionally, none of the 27 containers holding lamps were labeled with the hazardous waste labeling criteria of 40 CFR Part 262, including wording and accumulation start date requirements, or, alternatively, the universal waste labeling criteria of 40 CFR Part 273. Records Review: During the inspection I was provided a copy of the following, which are included in Attachment 3 - Records Provided During the Inspection: x hazardous waste manifest 007453957SKS for waste paint related material shipped on 3/10/2021 o Waste shipped on March 10, 2021, on this manifest consisted of two drums of waste paint related material. Hazardous waste codes on the manifest were: F003 spent solvents F005 spent solvents D001 ignitability characteristic D005 toxicity characteristic for barium D006 toxicity characteristic for cadmium D007 toxicity characteristic for chromium o In addition to the above, the accompanying LDR paperwork further included: D035 toxicity characteristic for MEK D008 toxicity characteristic for lead x a Safety Kleen receipt dated 3/10/2021 for the above-described manifest x a safety data sheet for Henkel Loctite Frekote 770-NC. This SDS indicates that when disposed, this material is a D001 ignitable hazardous waste; rags containing this material may carry this code if sufficient levels of the liquid are present in the waste container ("free liquids"), in which case the entire waste would be D001 ignitable hazardous waste. Following the inspection, a copy of manifest 007453957SKS was acquired from the RCRAInfo e-Manifest database and includes the designated facility signature (Attachment 4 - TSDF-Signed Manifest 007453957SKS). Page 5 of 6 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Inspection Logbook No.: 2021-0021 Pages: 1-19 and 2021-0024 Pages 3-29 CLOSING CONFERENCE During the closing conference with Mr. Anderson and Mr. Mock, I discussed that a hazardous waste determination should be performed for the paint booth filters, that chemicals in the clean room that are no longer of use and are waste should be cleaned out, and that the hazardous waste lamps should be disposed. I also stated that I would provide information on universal waste and episodic generation requirements. INSPECTION FOLLOW-UP Follow-up is needed in order to address the following: 1. Hazardous waste determinations 2. Generator category determination 3. Plant 1A compromised containers 4. Plant 1A drum in flammable cabinet 5. Mixing room fire suppression system overflow containment area 6. Spent lamps 7. Expired chemicals Details regarding requested follow-up will be included in correspondence to the facility, as appropriate. SIGNATURES ANNETTE MAXWELL Date: 2022.12.19 16:29:38 -07'00' Digitally signed by ANNETTE MAXWELL Lead Inspector: ________________________________________________ Annette Maxwell, RCRA Inspector Pearson, Janice Date: 2023.01.03 14:20:14 -07'00' Digitally signed by Pearson, Janice Supervisor: ___________________________________________________ Janice A. Pearson, Manager RCRA & OPA Enforcement Branch Enforcement and Compliance Assurance Division APPENDIX LIST - Attachment 1 - Site Map - Attachment 2 - Photograph Log - Attachment 3 - Records Provided During the Inspection - Attachment 4 - TSDF-Signed Manifest 007453957SKS Page 6 of 6 Attachment 1 - Site Map Sioux Manufacturing Corporation, 1115 Dakotah Drive, Fort Totten, North Dakota Attachment 1 - Site Map Sioux Manufacturing Corporation Liquid nitrogen Chemical storage room Mixing room fire suppression overflow area Former building 1C, no longer part of SMC Plant 1A Plant 1B Fire suppression water storage Scrap metal Groundskeeping building Plant 1 Offices Attachment 2 - Photograph Log Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 ATTACHMENT 1: PHOTO LOG Photo 1, 20220609_105718.JPG, 6/9/2022 10:57 a.m., taken by Annette Maxwell. Photo of a 55-gallon SAA drum of hazardous waste. Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 2, 20220609_105727.JPG, 6/9/2022 10:57 a.m., taken by Annette Maxwell. Photo of the same flammable cabinet shown in Photo 1 with the doors closed. The cabinet is labeled with the words "hazardous waste". Page 2 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 3, PXL_20220609_170621715.MP.JPG, 6/9/2022 12:06 p.m., taken by Kristin McNeill. Photo of drums in a flammable cabinet in the former clean room. The blue drum label is marked received Sep 11, 1998, "Shelf Life 24 months" and "Retest After 7-15-99". Page 3 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 4, PXL_20220609_170636994.JPG, 6/9/2022 12:06 p.m., taken by Kristin McNeill. Close-up of the label on the blue drum shown in Photo 3 indicating that it held an epoxy resin. Page 4 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 5, PXL_20220609_170639280.JPG, 6/9/2022 12:06 p.m., taken by Kristin McNeill. Close-up of the label on the blue drum shown in Photos 3 and 4. Label states CAS Number 025085-99-8. Page 5 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 6, PXL_20220609_170648809.JPG, 6/9/2022 12:06 p.m., taken by Kristin McNeill. Close-up of the label on the green drum shown in Photo 3 indicating that it held a curing agent. DOT shipping label information states, "Amines, liquid, corrosive, n.o.s. (Cycloaliphatic Amine)" and includes a corrosive placard. Page 6 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 7, PXL_20220609_170703808.JPG, 6/9/2022 12:07 p.m., taken by Kristin McNeill. Photo of the opposite side of the green drum shown in Photos 3 and 6. Labels are marked received Feb 2 1998, "Shelf Life 36 mo's" and "Retest After 5-1-2000." Page 7 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 8, PXL_20220609_170733282.JPG, 6/9/2022 12:07 p.m., taken by Kristin McNeill. Photo of paint on a table in the former clean room. Dates on the two smaller, silver containers state, "MFG. Date 12/20" and "MFG. Date 7/18." The labels indicate that the containers held coating epoxy and state, "Shelf life: 1 year." Page 8 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 9, PXL_20220609_170753619.JPG, 6/9/2022 12:07 p.m., taken by Kristin McNeill. Photo of flammable cabinet shown in Photos 3-7 with the cabinet doors closed. Page 9 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 10, PXL_20220609_171101038.JPG, 6/9/2022 12:11 p.m., taken by Kristin McNeill. Photo of another flammable cabinet in the former clean room. The cabinet housed a number of chemicals that appeared to be old and possibly no longer usable, some marked with dates indicating receipt in the 1990's. Page 10 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 11, PXL_20220609_171112945.JPG, 6/9/2022 12:11 p.m., taken by Kristin McNeill. Close-up of the top shelf of the cabinet shown in Photo 10. Page 11 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 12, PXL_20220609_171117161.JPG, 6/9/2022 12:11 p.m., taken by Kristin McNeill. Close-up of the middle shelf shown in Photo 10. Page 12 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 13, PXL_20220609_171203159.JPG, 6/9/2022 12:12 p.m., taken by Kristin McNeill. Photo of the flammable cabinet shown in photos 10-12 with the cabinet doors closed. Page 13 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 14, 20220609_123227.JPG, 6/9/2022 12:32 p.m., taken by Annette Maxwell. Photo of flammables cabinet containing 55-gallon drum of IPA located in Plant 1A. Page 14 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 15, 20220609_123241.JPG, 6/9/2022 12:32 p.m., taken by Annette Maxwell. Photo of flammables cabinet shown in Photo 14. Page 15 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 16, 20220609_124423.JPG, 6/9/2022 12:44 p.m., taken by Annette Maxwell. Photo of bermed area within chemical storage room. Photo 17, 20220609_125833.JPG, 6/9/2022 12:58 p.m., taken by Annette Maxwell. Photo of bermed catch area leading from the mixing room. Page 16 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 18, 20220609_131707.JPG, 6/9/2022 1:17 p.m., taken by Annette Maxwell. Photo of spent mercury-containing lamps stored on the first floor. Page 17 of 18 Facility Name: Sioux Manufacturing Corporation Facility Location: Fort Totten, North Dakota Date of Inspection: June 9, 2022 Photo 19, 20220609_132013.JPG, 6/9/2022 1:20 p.m., taken by Annette Maxwell. Photo of spent mercury-containing lamps stored on the second floor. Photo 20, 20220609_132018.JPG, 6/9/2022 1:20 p.m., taken by Annette Maxwell. Photo of spent mercury-containing lamps stored on the second floor near those shown in Photo 19. Page 18 of 18 Attachment 3 Records Provided During the Inspection Attachment 4 TSDF-Signed Manifest 007453957SKS