Document wdyoOQXDazOyBOE2xDBKvdj3

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At John Deere Ottumwa Works 928 E Vine St. Ottumwa, IA 52501 (641) 683-2257 EPA ID Number: IAD005291182 On December 14, 2021 By Eastern Research Group, Inc. For U.S ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division 1.0 INTRODUCTION At the request of the Enforcement and Compliance Assurance Division/Chemical Branch/RCRA Section (ECAD/CB/RCRA) of the U.S. Environmental Protection Agency (EPA) Region 7, Eastern Research Group, Inc. (ERG) conducted a Resource Conservation and Recovery Act (RCRA) compliance evaluation inspection (CEI) at John Deere Ottumwa Works (JDOW) in Ottumwa, Iowa on December 14, 2021. The CEI was conducted under the authority of Section 3007(a) of RCRA, as amended. Throughout the CEI, data and information were collected to determine compliance with the applicable regulatory and statutory requirements. The inspection report and attachments present the results of the CEI. 2.0 PARTICIPANTS John Deere Ottumwa Works: Allison Miller, Environmental Manager Tyler Carter, Environmental Engineer EPA Representative, ERG: Janosh Wolters, Energy Engineer 3.0 INSPECTION PRECEDURES Due to the COVID-19 pandemic, I contacted the facility via telephone and spoke with Ms. Miller on December 9, 2022 at approximately 16:00. We discussed facility specific safety protocols to ensure the safety of all personnel involved during the inspection and discussed the best time to arrive on-site. Due to the size of the facility and ensure I had enough time to thoroughly inspect the facility, as well as align with facility personnel, we planned to begin the inspection at approximately 06:30. After arriving announced at JDOW at approximately 06:25, I performed a drive-by of the facility and took a photograph before beginning the inspection and did not note any areas of concern. I then entered the main entrance and signed into the visitor's log. Ms. Miller and Mr. Carter then led me to a conference room with to begin the opening conference at approximately 06:40. I initiated the opening conference with Ms. Miller and Mr. Carter present as the JDOW representatives. I presented them with my inspector credentials and business card, as well as the business card of the EPA Task Order Contracting Officer Representative, Mr. Trevor Urban. I then presented a copy of RCRA Section 3007(a), which contains EPA's 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 then presented Ms. Miller and Mr. Carter with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed JDOW's confidentiality rights. I informed Ms. Miller and Mr. Carter that I would provide a Confidentiality Notice at the end of this inspection. The inspection consisted of a discussion of facility operations, waste generation and waste management, a review of waste management records, and a visual inspection of the waste generation and management areas. Mr. Carter provided a facility layout (see Attachment 1) and explained facility operations and locations of hazardous waste generation and management. During the visual inspection of the facility, Ms. Miller and Mr. Carter guided me throughout the facility in order to conduct thorough evaluations of the facility's satellite accumulation areas (SAAs) and central accumulation area (CAA). At the time of the inspection, the facility was operating 49 SAAs and one CAA. The facility also handles universal waste throughout the facility before consolidating universal waste in the CAA. All universal waste storage areas were visually inspected. JDOW uses two parts washers on site. All parts washers utilize the same nonhazardous cleaning solution. I conducted an in-depth visual inspection of the SAAs, the CAA, the universal waste storage areas, used oil storage area, and all manufacturing areas. Seven photographs were collected as inspection documentation and are shown in Attachments 2 and 3. Information collected during the inspection is documented on the EPA Inspection Checklist (see Attachment 4). I followed the inspection procedures discussed in the RCRA CEI Standard Operating Procedure (No. 2321.01D), unless noted differently. At the conclusion of the inspection, I provided Ms. Miller with a Confidentiality Notice, and Receipt for Documents and Samples, which she signed as acknowledgement of receipt (see Attachments 5 and 6 respectively). No confidentiality claims were made by JDOW. 2 The following inspection documents and compliance assistance handouts were left with JDOW: RCRA Section 3007(a) Title 18 U.S. Code, Sections 1001 and 1002 Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections Confidentiality Notice (Facility copy) Receipt of Documents and Samples (Facility copy) Security Awareness Commercial Motor Vehicle Transportation Security Planning EPA E-Manifest Fact Sheet U.S. EPA Small Business Resources U.S. EPA Publication, Managing Your Hazardous Waste U.S. EPA Publication, Managing Used Oil-Advice for Small Businesses PowerPoint Presentation, 2013 Solvent Wipes Final Rule Pollution Engineering Article, 10 Common Questions for Waste Generators Iowa Department of Natural Resources (IDNR) Waste Exchange Folder and P2 Brochures IDNR Management of Fluorescent Lamps for Businesses Information Sheets IDNR Aerosol Can Disposal for Businesses Information Sheet University of Northern Iowa Waste Reduction Center Information Card Solvent-Contaminated Wipes Final Rule Summary Chart 4.0 FINDINGS AND OBSERVATIONS Facility Information and Operations JDOW began operating in 1911 and currently employs approximately 800 people. The facility operates on a 24/6 schedule with 8-hour shifts, split amongst three shift teams. The facility has a footprint of approximately 120 acres. JDOW's operations consist of manufacturing large agricultural equipment. The major raw materials used are steel, weld wire, paints, and solvents. The major manufacturing or processing operation that generates waste streams include manufacturing agricultural equipment. The following waste streams are produced: waste paint related material, paint flush, solvent and paint rags, still bottoms, waste paint dip and plastic, aerosol cans, orphan chemicals, adhesive and thinner, dip tank waste, nital etchant, waste batteries, waste pharmaceuticals, parts washer solution, laser dust, coolants, pre-wash wastewater, paint booth filters, oily debris and sorbents, scrap metal and grinder solids, wastewater, used oil, used oil filters, universal wastes, and general trash. 4.2 RCRA Status According to the Hazardous Waste Site Info Verification Report for Inspector (see Attachment 7), JDOW notified as a federal large quantity generator (LQG) of D001, D002, D003, D007, D008, D018, D035, F003, F005, U002, U159, and U220 hazardous wastes. I asked Mr. Carter 3 and Ms. Miller to review the Hazardous Waste Site Info Verification Report for Inspector, which I provided prior to records review and visual inspection of the waste generation areas. Ms. Miller requested I update the facility contact and some waste codes may no longer apply. After reviewing the records and walking through the facility, I determined that the facility is operating as a LQG of D001, D002, D008, D035, and F003 hazardous wastes, a generator of used oil, and a small quantity handler (SQH) of universal waste. JDOW generates more than 1,000 kilograms of hazardous waste monthly based on a review of facility records, a visual inspection of process and waste management areas, and interviewing personnel. JDOW was previously inspected by an EPA contractor on May 2, 2016. The inspection did not lead to a notice of preliminary findings (NOPFs). 4.3 Facility Waste Streams and Management A Waste Stream and Waste Handling Table for JDOW is presented below. The table describes waste streams generated, generation process/rates, hazardous waste determinations, and onsite/off-site management. The rest of this page left blank intentionally. 4 WASTE STREAM # GENERATION PROCESS HAZARDOUS WASTE DETERMINATION ESTIMATED GENERATION RATE ON-SITE OFF-SITE MANAGEMENT MANAGEMENT 1 Paint Obsolete / Paint brushes, D001 (based on process 800 pounds per 55-gallon Veolia ES Technical Off-spec Waste rollers, excess knowledge and month containers in SAAs Solutions (NID080631369) to Paint (Waste left-over paint knowledge of the Veolia ES Technical Paint Related product) Solutions in Menomonee Material) Falls, WI (WID003964148) (Waste Profile for fuel blending included in Attachment 8) 2 Paint Flush Flushing paint D001, D035 (based on 4,700 pounds per 55-gallon Veolia ES Technical (Waste Profile lines process knowledge and month containers in SAAs Solutions (NID080631369) to included in knowledge of the Veolia ES Technical Attachment 9) product) Solutions in Menomonee Falls, WI (WID003964148) for fuel blending 3 Hazardous Wiping excess D001 (based on process 200 pounds per 55-gallon Veolia ES Technical Solvent and solvent knowledge and month containers in SAAs Solutions (NID080631369) to Paint Rags knowledge of the Veolia ES Technical (Waste Profile product) Solutions in Menomonee included in Falls, WI (WID003964148) Attachment 10) for fuel blending 4 Reclaimed Paint Reclaiming paint Hazardous secondary Under 1 ton in 55-gallon Flush (HSM gun flush material (HSM) - 2021. If still is containers Notification excluded per operating, 34 tons included in 261.4(a)(23)(i)(A) per year Attachment 11) (based on process knowledge and knowledge of the product) NA - reclaimed on site 5 WASTE GENERATION HAZARDOUS ESTIMATED ON-SITE OFF-SITE STREAM PROCESS WASTE GENERATION MANAGEMENT MANAGEMENT # DETERMINATION RATE 5 Still Bottoms Distillation unit D001, D035 (based on 300 pounds per 55-gallon Veolia ES Technical (Waste Profile process knowledge and year for the 1 ton container in SAA Solutions (NID080631369) to included in knowledge of the of reclaimed #40 Veolia ES Technical Attachment 12) product) solvent in 2021 Solutions in Menomonee Falls, WI (WID003964148) for incineration 7 Waste Paint Dip Dipping products D001 (based on process 1,400 pounds per 55-gallon Veolia ES Technical and Plastic into product knowledge and month containers in SAAs Solutions (NID080631369) to (Waste Profile paint tank and knowledge of the Veolia ES Technical included in excess drippage product) Solutions in Menomonee Attachment 13) is accumulated Falls, WI (WID003964148) on plastic sheets for incineration 8 Aerosol Waste Spent aerosol D001 (based on process 65 pounds per 55-gallon Veolia ES Technical Cans (Waste cans knowledge and month containers in SAAs Solutions (NID080631369) to Profile included knowledge of the Veolia ES Technical in Attachment product) Solutions in Menomonee 14) Falls, WI (WID003964148) for fuel blending 9 Orphan Expired or Chemicals unwanted (Waste Profile chemicals included in Attachment 15) Hazardous LabPak (waste codes change with each shipment) (based on process knowledge and knowledge of the product) 32 pounds per month LabPak in CAA Veolia ES Technical Solutions (NID080631369) to Veolia ES Technical Solutions in Menomonee Falls, WI (WID003964148) for incineration 6 WASTE GENERATION HAZARDOUS ESTIMATED ON-SITE OFF-SITE STREAM PROCESS WASTE GENERATION MANAGEMENT MANAGEMENT # DETERMINATION RATE 10 Adhesive and Reaction D001, D035 (based on 100 pounds per 55-gallon Veolia ES Technical Thinner (Waste injection process knowledge and year containers in SAA Solutions (NID080631369) to Profile included molding knowledge of the #20 Veolia ES Technical in Attachment process used product) Solutions in Menomonee 16) adhesive Falls, WI (WID003964148) for incineration 11 Dip Tank Cleanout of paint D001 (based on process 1,500 pounds per 55-gallon Veolia ES Technical Cleanout Waste dip tank once per knowledge and year containers moved Solutions (NID080631369) to (Waste Profile year knowledge of the to CAA Veolia ES Technical included in product) immediately Solutions in Menomonee Attachment 17) during cleanout Falls, WI (WID003964148) operations for incineration 12 Nital Etchant QC for welding D002 (based on process Less than one 5-gallon container Veolia ES Technical knowledge and gallon per year in SAA #22 Solutions (NID080631369) to knowledge of the Veolia ES Technical product) Solutions in Port Washington, WI (WID988566543) for incineration 13 Waste Batteries Broken lead acid D002, D008 (based on 800 pounds per 55-gallon Veolia ES Technical (Broken lead batteries process knowledge and year containers in CAA Solutions (NID080631369) to acid batteries) knowledge of the Veolia ES Technical product) Solutions in Port Washington, WI (WID988566543) for recycling 7 WASTE GENERATION HAZARDOUS ESTIMATED ON-SITE OFF-SITE STREAM PROCESS WASTE GENERATION MANAGEMENT MANAGEMENT # DETERMINATION RATE 14 Waste Waste PHARMS (based on 10 pounds in 2020 5-gallon container Veolia ES Technical Pharmaceuticals pharmaceutical process knowledge and (Manifest Solutions (NID080631369) to (Waste Profile waste knowledge of the included in Veolia ES Technical included in product) Attachment 19) Solutions in Port Washington, Attachment 18) WI (WID988566543) for incineration 15 Parts Washer Cleaning small Nonhazardous (based on 150 pounds per In parts washer Veolia ES Technical Solution (Safety tools process knowledge and year Solutions (NID080631369) to Data Sheet knowledge of the Veolia ES Technical (SDS) included product) Solutions in Menomonee in Attachment Falls, WI (WID003964148) 20) for recycling 16 Laser Dust Dust from metal Nonhazardous (based on 1,400 pounds per 55-gallon Alter Metal Recycling in cutting process knowledge and month containers Ottumwa, IA for recycling knowledge of the product) 17 Machining Machine coolant Nonhazardous (based on 5,000 gallons per One 8,600-gallon Transported to John Deere Coolants (SDS waste process knowledge and year tank in Building P Waterloo Works in Waterloo, included in knowledge of the IA via Sully Transportation Attachment 21) product) for wastewater treatment prior to permitted discharge to City of Waterloo Publicly Owned Treatment Works (POTW) 18 Pre-Wash Iron phosphate Nonhazardous (based on 18,600 gallons per Two 18,000-gallon Transported to John Deere Wastewater and zirconium process knowledge and year tanks in Building P Waterloo Works in Waterloo, (SDSs included pretreatment knowledge of the IA via Sully Transportation in Attachment solutions product) for wastewater treatment prior 22) to permitted discharge to City of Waterloo POTW 8 WASTE STREAM # 19 Paint Booth Filters GENERATION PROCESS Exchanging paint booth filters HAZARDOUS WASTE DETERMINATION Nonhazardous (based on process knowledge and knowledge of the product) ESTIMATED GENERATION RATE One ton per month ON-SITE OFF-SITE MANAGEMENT MANAGEMENT One 30-yard container, 40-yard compactor Midwest Sanitation in Oskaloosa, IA to City of Ottumwa Landfill in Ottumwa, IA for landfill 20 Oily Clean up Debris/Sorbents operations Nonhazardous (based on process knowledge and knowledge of the product) 680 pounds per month 55-gallon containers 21 Scrap Metal and Facility Nonhazardous (based on Four 40-yard 40-yard and 10- Grinder Solids operations process knowledge and containers and 12 yard containers knowledge of the 10-yard product) containers picked up two to three times per week 22 Wastewater Parts rinsed with Nonhazardous (based on Unknown - not Discharged to only water process knowledge and tracked sanitary sewer knowledge of the product) Veolia ES Technical Solutions (NID080631369) to Veolia ES Technical Solutions in Menomonee Falls, WI (WID003964148) for fuel blending Alter Metal Recycling in Ottumwa, IA for recycling Discharged to sanitary sewer for to the POTW of City of Ottumwa (POTW Permit included in Attachment 23) 23 Used Oil Facility (Invoice maintenance included in Attachment 24) Excluded (managed as used oil per 40 CFR 279) 4,700 gallons per year 55-gallon and 10,000-gallon used oil tank Safety-Kleen Systems Inc. in Des Moines, IA (IAD981718000) for recycling 9 WASTE GENERATION HAZARDOUS ESTIMATED ON-SITE OFF-SITE STREAM PROCESS WASTE GENERATION MANAGEMENT MANAGEMENT # DETERMINATION RATE 24 Used Oil Filters Punctured and Excluded (not a solid Unknown - not 40-yard and 10- Alter Metal Recycling in oil hot drained waste as managed) and tracked yard containers Ottumwa, IA for recycling into used oil recycled as scrap metal container and used oil filter added to scrap metal containers 25 Universal Waste Facility Excluded (managed as 220 pounds per 4-foot containers Veolia ES Technical Lamps maintenance universal waste per 40 month to eight-foot Solutions (NID080631369) to CFR 273) containers Veolia ES Technical Solutions in Port Washington, WI (WID988566543) for recycling (Manifest included in Attachment 25) 26 Universal Waste Facility Excluded (managed as 420 pounds per 5-gallon containers Veolia ES Technical Batteries maintenance universal waste per 40 year Solutions (NID080631369) to CFR 273) Veolia ES Technical Solutions in Port Washington, WI (WID988566543) for recycling (Manifest included in Attachment 25) 27 General Trash Facility Nonhazardous (based on Approximately 20 to 40-yard Midwest Sanitation in operations process knowledge and 440,000 pounds containers on site Oskaloosa, IA to City of knowledge of the per year Ottumwa Landfill in product) Ottumwa, IA Remainder of Page Intentionally Left Blank 10 Less-Than-90-Day Hazardous Waste Accumulation Area JDOW has one Less-Than-90-Day CAA on site, which is located in a separate small structure as labeled on the facility layout (see Attachment 1). I visually inspected the CAA and observed one 55-gallon of obsolete / off-spec waste paint, one 55-gallon container of paint flush waste, and 55gallon container which held aerosol cans and paint pens. All three containers were managed as hazardous wastes (see Attachment 3, Photo 6). In addition, I observed a red flammable cabinet placed inside the facility's CAA. The flammable cabinet is used to store orphan chemicals. At the time of the inspection, the cabinet was empty (see Attachment 3, Photo 7). All hazardous waste containers were closed, in good condition, labeled as "Hazardous Waste", and labeled with an indication of the nature of the hazard. The earliest accumulation start date on a hazardous waste container in the CAA was December 9, 2021. December 9, 2021 is within 90 days from the time of the inspection. I also observed two 55-gallon containers of laser dust nonhazardous waste. Lastly, I observed two 30-gallon containers of universal waste batteries, three 4-foot, and two 8-foot universal waste lamp containers. All universal waste containers were closed, in good condition, and labeled as "Universal Waste Batteries" or "Universal Waste Lamps". The earliest accumulation start date observed on a universal waste container was on one of the 30-gallon containers and was "08/10/2021". I observed adequate aisle space to allow for container inspections and access in the event of a spill. The floor of the container was sloped towards a non-draining sump that could be pumped out in the event of a spill. I observed a fire extinguisher, spill control equipment, and related safety equipment within the CAA. Operators handling hazardous waste are trained to use their two-way radio system in case of emergencies. In addition, a phone was placed directly outside the CAA that could be used to communicate in case of an emergency. In addition, a sign was posted next to the phone outside of the CAA which listed the phone numbers of emergency coordinators and emergency response agencies. I asked Mr. Carter if the facility inspected the CAA. Mr. Carter stated the facility inspected the CAA at least weekly and had weekly inspection logs. During records review, Mr. Carter provided inspection logs for the CAA. I reviewed the logs and determined the facility was adequately performing weekly inspections of the CAA. An example of a CAA log is provided in Attachment 26. During records review, I asked Mr. Carter if the facility has closed a CAA since the last inspection occurred. Mr. Carter and Ms. Miller discussed and stated one CAA was closed. Mr. Carter explained a notice was placed in the facility's operating records and provided me with the document shown in Attachment 27. The document outlines the regulatory requirement in 40 CFR 262.17(a)(8)(i)(A) and shows the facility had a document tracking when the CAA moved and where the previous CAA was located. I determined JDOW was in compliance with the requirements set forth int 40 CFR 262.17(a)(8)(i)(A). I did not note any issues or findings at the CAA during the inspection. Satellite Accumulation Areas I observed 49 satellite areas during the visual inspection. The table below shows the SAA name or location, waste type, volume of waste observed, and container type. 11 SAA # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 SAA Name or Location Waste Type Building C-5 Tryout Booth Paint Obsolete / Offspec Building C-5 South Wall Paint Obsolete / Offspec Building M-7 MOCO Rework Solvent / Paint Rags Building M-7 Brake Press Aerosols & Paint Pens Building C-4 RB Rework Paint Obsolete / Offspec Building C-4 RB Rework Aerosols & Paint Pens Building C-9 Rework Paint Booth Building C-9 Rework Paint Booth Outside Area Building C-9 Rework Paint Booth Outside Area Building C-9 Paint Kitchen Building C-4 Touchup Booth Building C-4 Touchup Booth Building C-4 Primer Paint Booth Building C-12 Primer Booth Building C-12 Topcoat Booth Building C-12 Topcoat Booth Building C-13 Paint Kitchen Building C-8 South Wall Paint Obsolete / Offspec Aerosols & Paint Pens Solvent / Paint Rags Paint Flush Aerosols & Paint Pens Paint Obsolete / Offspec Paint Flush Solvent / Paint Rags Solvent / Paint Rags Paint Flush Paint Flush Aerosols & Paint Pens Building C-8 Docks Area Building C3(S) RIM Area Building R D14 Office Paint Obsolete / Offspec Adhesive Thinner Waste Aerosols & Paint Pens Volume of Waste 10 gallons 5 gallons 35 gallons 35 gallons 10 gallons 5 gallons 5 gallons 15 gallons 5 gallons 20 gallons 5 gallons 5 gallons 40 gallons 45 gallons 15 gallons 40 gallons 40 gallons 5 gallons 5 gallons 45 gallons 10 gallons Container Type 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 12 22 Building R D14 Lab Nital Etchant Less than one 5-gallon bucket millimeter of material 23 Building R Maintenance Paint Obsolete / Off- 1 gallon 55-gallon drum Paint Booth spec 24 Building R Maintenance Solvent / Paint Rags 5 gallons 55-gallon drum Paint Booth 25 Building R Maintenance Paint Flush 30 gallons 55-gallon drum Paint Booth 26 Building D-8 Maintenance Paint Obsolete / Off- 20 gallons 55-gallon drum Powerhouse spec 27 Building D-8 Maintenance Aerosols & Paint Pens 1 gallon 55-gallon drum Powerhouse 28 Building L-2 Aerosols & Paint Pens 35 gallons 55-gallon drum Experimental Building 29 Building M-8 Overhead Solvent / Paint Rags 1 gallon 55-gallon drum Doors 30 Building M-2 Column E- Solvent / Paint Rags 5 gallons 55-gallon drum 17 31 Building N-3 Column B- Paint Obsolete / Off- 10 gallons 55-gallon drum 16 spec 32 Building A-4 Maintenance Aerosols & Paint Pens 2 gallons 55-gallon drum Office 33 Building N-6 LSB Aerosols & Paint Pens 25 gallons 55-gallon drum 34 Building N-6 Column D- Paint Obsolete / Off- 39 spec 35 Building M-1 Column C-8 Paint Obsolete / Off- spec 36 Building E-3 Paint Paint Flush Kitchen 37 Building E-3 Paint Booth Solvent / Paint Rags 5 gallons 5 gallons 1 gallon 25 gallons 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 38 Building E-3 Paint Booth Paint Obsolete / Off- spec 39 Building E-3 Spray Paint Paint Flush Booth 40 Building W-3 Paint Still Bottoms Storage Building 41 Building W-3 Paint Paint Flush Storage Building 42 Building W-3 Paint Solvent / Paint Rags Storage Building 0 gallons 25 gallons 10 gallons 20 gallons 5 gallons 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 13 43 Building W-3 Paint Dock Aerosols & Paint Pens 20 gallons 44 Building E-4 Paint Dock Solvent / Paint Rags 5 gallons 45 Building E-3 Paint Drip Paint Dip Plastic/Paper 40 gallons Tank 46 Building C 1500 Ton Aerosols & Paint Pens 5 gallons Press 47 Building C-6 Column B9 Paint Obsolete / Off- 1 gallon spec 48 Building C-6 Column J15 Solvent / Paint Rags 15 gallons 49 Health Care Facility Hazardous Waste Pharmaceuticals 0 gallons 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 5-gallon bucket All hazardous waste accumulation containers observed in the SAAs were in good condition, closed, labeled with the indication of the nature of the hazard, and labeled with the words "Hazardous Waste". During the visual inspection of the SAAs, I asked Ms. Miller how aerosol cans were managed. Ms. Miller stated the facility uses aerosol cans for touch up paint operations and when the aerosol can is RCRA empty, the entire aerosol can is discarded and managed as a hazardous waste. I reviewed the management of the SAAs, and no issues or findings were noted. Painting Operations and Distillation Unit During the visual inspection, I observed large paint booths throughout the facility and a distillation unit located in Building W-3. Mr. Carter stated the facility's distillation unit has not been operational for most of 2021. At the time of the inspection, the distillation unit was not operating, and I observed only one 55-gallon container holding paint flush material awaiting reclamation. Mr. Carter explained that when the distillation is operational, it is used to reclaim the facility's paint flush waste from flushing paint lines. The container was labeled "Paint Flush Awaiting Reclamation" and had an accumulation start date of December 14, 2021. Mr. Carter explained the facility anticipates the distillation unit to be operational in the near future and this 55-gallon container of paint flush would be reclaimed. I was unable to photograph the distillation unit or 55-gallon container of HSM because all electronics were required to be left outside of the room as a fire prevention measure. Mr. Carter explained the facility uses methyl n-amyl ketone (MAK) to flush automated paint lines on site. The MAK is hard piped via a 55-gallon container and is connected to automated paint lines. The SDS for MAK is provided in Attachment 28. Mr. Carter explained if paint flush was not distilled, it is managed as a hazardous waste. During records review, I observed a manifest showing the paint flush was sent off-site as a D001, D035, F003, and F005 hazardous waste. Mr. Carter explained this must have been a legacy issue and 14 that the waste is managed as a D001 and D035 waste per the waste profile in Attachment 9. I asked Mr. Carter why the waste profile stated a DOT description of xylene and toluene, and he was not sure because these are not included in the waste stream. Mr. Carter explained the facility keeps the D035 waste code attached to the waste stream because some paints could contain MEK but reiterated that the facility only flushes paint lines with MAK. I observed one 55-gallon container in SAA #40 holding still bottoms waste. The waste profile for the still bottoms waste is provided in Attachment 12. I asked Mr. Carter why the F003 and F005 were applied to this waste stream. Mr. Carter stated he was not sure because the still bottoms are only generated from the reclamation of MAK. Mr. Carter stated he would update the waste profile. Mr. Carter explained when operational, the facility used engineering judgement based on amount of reclaimed solvent and the efficiency rating of the distillation unit that at least 75 percent of the HSM is reclaimed. Mr. Carter explained the facility reclaims 55-gallons of HSM each batch. The installation manual for the distillation unit is provided in Attachment 29. I asked Mr. Carter if the facility notified EPA of their HSM activity. Mr. Carter stated the facility initially notified EPA of their hazardous waste activity on February 23, 2012. During records review, Mr. Carter provided EPA Form 8700-12 for the original notification and the most recent renotification of the facility HSM activities from 2019. The HSM renotification is provided in Attachment 11. During the visual inspection, I observed paint flush being accumulated in 55-gallon drums as described above and the facility was managing all drums in manufacturing areas as hazardous waste. The 55-gallon containers were managed as SAA containers. As stated in Section 4.5 of this report, all SAA containers were in good condition, closed, labeled with the indication of the nature of the hazard, and labeled with the words "Hazardous Waste". After conversations with Mr. Carter, Ms. Miller, completed the full compliance checklist for HSM reclaimed on site in Attachment 4, and reviewing documents provided in records review, I determined the facility was in compliance with 261.4(a)(23)(i)(A). During the visual inspection of the facility's paint booths, I observed multiple 55-gallon containers accumulating aerosol cans and paint pens, solvent and paint rags, and obsolete and off-spec waste paint. The generating processes for these wastes are as described in Table 1 of this report. I asked Ms. Miller and Mr. Carter if all aerosol cans are managed as hazardous waste. Ms. Miller stated it was easier from a management perspective to manage all aerosol cans as a hazardous waste and that she was aware of their ability to manage this type of waste as universal waste if desired. Ms. Miller then explained she was also aware of the multiple exclusions for managing solvent contaminated wipes. Ms. Miller stated the facility preferred to manage the waste as a hazardous waste. I asked Ms. Miller what types of solvents are used on-site. Ms. Miller stated MAK is the only solvent used in painting operations, but the facility maintenance team use a Startex cleaning solution to clean small tools and manufactured parts. Spent rags from this process would be considered hazardous waste. The SDS for Startex is provided in Attachment 30. Ms. Miller explained the maintenance team wipes excess solution off tools or manufactured parts and generated hazardous waste rags. Ms. Miller stated when the rags are 15 placed into the 55-gallon containers, there is a potential that rags contain free liquids. Therefore, the facility manages them as a hazardous waste. I reviewed the hazardous waste rags waste profile at the time of the inspection. The waste profile for the hazardous waste rags is provided in Attachment 10. I asked Ms. Miller why this waste stream is classified as a F003 listed hazardous waste. Ms. Miller stated the facility was overclassifying the waste stream out of an abundance of caution. Based on how this waste is generated, it appears this waste stream can be managed as a only a D001 characteristic hazardous waste. I also observed a paint dip tank which is used to dip large, manufactured parts into and allows paint to adhere to the manufactured parts. The manufactured parts are on a hanging conveyor system and excess paint is dripped onto plastic floor covering. The facility manages this plastic covering as a hazardous waste. The waste profile for this waste is provided in Attachment 13. In addition, Mr. Carter explained the dip tank is cleaned out once per year. The cleanout generates a hazardous waste as shown in the dip tank cleanout waste profile provided in Attachment 17. I asked Ms. Miller how the facility manages paint booth filters waste. Ms. Miller stated paint booth filters do not contain free liquids when replaced and are added to general trash containers. Ms. Miller estimated one ton of paint booth filters are generated monthly. I reviewed the management of paint booths and manufacturing areas no issues or findings were noted. Healthcare Facility During the visual inspection, I observed a small healthcare facility as labeled on the facility layout (see Attachment 1). The facility managed SAA #49 in this building. Mr. Carter explained the facility rarely generates hazardous waste pharmaceuticals (HWP). Mr. Carter stated the most recent generation of any pharmaceutical waste occurred in 2020. During records review, Mr. Carter provided the most recent manifest generated from a shipment of 10 pounds of HWP. The manifest is provided in Attachment 19. The waste profile for this waste is provided in Attachment 18. This waste was a nonhazardous waste but a pharmaceutical waste. Ms. Miller stated if the facility generated HWP, they would manage HWP waste as a non-creditable HWP. The facility-maintained manifests and land disposable restriction (LDR) forms for HWP dating back three years. During records review, Ms. Miller provided me the training PowerPoint that all employees in the HCF receive. I reviewed the training program and determined the training ensured all personnel would be thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies. At the time of the inspection, the facility's container observed in SAA #49 was empty and the facility was not accumulating any HWP. Based on conversations with Mr. Carter, Ms. Miller, and records reviewed, I determined the facility was in compliance with 40 CFR 266.502 and no issues or findings were noted. 16 Parts Washers The facility operates two parts washers, one located in Building L-2 and one in the LSB weld area as labeled on the facility layout (see Attachment 1). The facility uses a nonhazardous parts washer solution. The parts washers are used to clean small tools in both these areas. Ms. Miller explained parts washers are serviced by the facility maintenance team and spent parts washer solution is accumulated in 55-gallon containers and managed as nonhazardous waste. The SDS for the parts washer solution used on-site is provided in Attachment 20. Ms. Miller stated the facility does not comingle wastes in parts washers to ensure the spent solution is nonhazardous. I did not note any issues or findings with any of the parts washers. Nital Etchant and Adhesive Thinner Waste During the visual inspection, I observed one 55-gallon container in SAA #20 of adhesive thinner waste and one 5-gallon container in SAA #22 of nital etchant waste. These two waste streams were the least actively generated amounts of hazardous waste streams observed on site. Ms. Miller explained the adhesive thinner is applied to one specific part to allow for better adhesion during final assembly. Approximately 100 pounds of this waste stream is generated each year. The waste profile is provided in Attachment 16. The nital etchant is generated due to a nondestructive test used to determine if overheating has occurred on a part due to machining, grinding, or welding. Ms. Miller stated the facility generates less than one gallon of this waste when conducting quality assurance tests on welded parts. Prewash Wastewater and Machining Coolant The facility uses multiple prewash solutions during cleaning operations of manufacturing equipment before painting operations take place. All solutions used are nonhazardous and prewash wastewater is accumulated in totes and transported to two 18,000-gallon tanks located in Building D-8 as labeled on the facility layout (see Attachment 1). Ms. Miller stated these prewashes are sent to John Deere Waterloo Works (JDWW) in Waterloo, IA via Sully Transportation for wastewater treatment prior to permitted discharge to City of Waterloo POTW. Ms. Miller stated this prewash wastewater is comingled with the facility machine coolant waste. The coolants are also nonhazardous waste and the SDS for the machine coolant used on site is provided in Attachment 21. The SDS shows the coolant has approximately 3% of a trade secret ingredient. Ms. Miller stated the nonhazardous waste determination was made with confirmation that the trade secret ingredient is nonhazardous. The prewash solution SDSs are provided in Attachment 22. Ms. Miller stated these waste streams are managed separately from the facility's industrial wastewater which is comprised of 100 percent rinse water. This water is managed under the facility's industrial wastewater discharge agreement with the City of Ottumwa (see Attachment 23). I asked Ms. Miller why these wastes are managed separately. Ms. Miller stated the prewash solutions and coolant wastes need pretreatment prior to discharge and that JDOW does not have a wastewater treatment plant. Therefore, JDOW ships this waste stream to JDWW. Ms. Miller explained the rinse water does not contain any solutions or coolants and therefore 17 does not require pretreatment prior to discharge and is managed under JDOW's industrial wastewater discharge agreement with the City of Ottumwa. I did not observe or note any issues with management practices regarding prewash wastewater, machine coolant, or rinse wastewater during the visual inspection. Universal Waste Accumulation Area JDOW manages universal waste in various locations throughout the facility. Universal wastes are consolidated prior to shipments off site in the CAA. Universal Waste lamps and batteries were observed in CAA as discussed in Section 4.4 of this report. I observed two 30-gallon containers of universal waste batteries, three 4-foot, and two 8-foot universal waste lamp containers. All universal waste containers were closed, in good condition, and labeled as "Universal Waste Batteries" or "Universal Waste Lamps". The earliest accumulation start date observed on a universal waste container was on one of the 30-gallon containers and was "08/10/2021". I also observed universal waste batteries containers located in Building R outside of the D14 lab (see Attachment 3, Photo 4). Both containers were closed, in good condition, and labeled as "Universal Waste Batteries". The containers were labeled with an accumulation start date of "08/10/2021." An example of a manifest used to ship universal waste off site is provided in Attachment 25. I reviewed the management of all universal waste storage areas throughout the facility and no issues or findings were noted. Used Oil JDOW generates and manages used oil throughout manufacturing areas on site. The facility manages used oil in 55-gallon containers and consolidates used oil in the facility's 10,000 gallon used oil tank (see Attachment 3, Photo 5). Ms. Miller explained 55-gallon containers are brought to the used oil tank and are pumped directly from the container into the used oil tank. SafetyKleen Systems Inc. services the used oil tank as needed by draining the used oil tank into a vacuum truck. The containers and tank were closed, labeled "Used Oil", and in good condition. I did not note any issues or findings at the used oil storage area. Other Regulatory Requirements Preparedness, Prevention, and Emergency Requirements - Safety and emergency equipment were present and in satisfactory condition in areas throughout the facility, including the hazardous waste container CAA (as noted in Section 4.4 of this report). Appropriate arrangements and coordination were made with necessary State and local emergency agencies. I reviewed the preparedness, prevention, and emergency requirements and no issues or findings were noted. Contingency Planning Requirements - The contingency plan (see Attachment 31) was on file 18 electronically and was reviewed while on site. The contingency plan included emergency evacuation routes, emergency response procedures, emergency coordinators and contact information, and a list of emergency response equipment. The quick reference guide was included within the contingency plan. The facility had submitted the guide and contingency plan to local emergency response agencies including the local police department, fire department, and hospital. Upon review of the guide, I observed a list and description of hazardous waste with estimated maximum amounts of each waste on site at one time. The guide summarized evacuation and emergency response procedures as well. The guide included a map showing where hazardous waste is generated and accumulated on site, and another map showing the facility in relation to surrounding businesses, schools, and residential areas. Lastly, the guide included references to water supply and fire response equipment locations, identification of on-site notification systems or alarms, and the name and telephone number for the emergency contact for the area. I reviewed the entire RCRA contingency plan, and no findings were noted. Personnel Training Requirements - Personnel are to be trained to perform hazardous waste duties, and new employees are to be trained within six months of start. The training, at a minimum, must be designed to ensure personnel at JDOW are able to manage hazardous waste relevant to the positions in which they are employed and respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including: 1. Procedures for using, inspecting, repairing, and replacing facility emergency equipment 2. Communications and alarm systems 3. Response to fires or explosions Upon reviewing the hazardous waste training employees of JDOW receive, I determined the training to be sufficient. Ms. Miller stated annual refresher trainings are tracked in an excel sheet matrix and organized by facility teams. Ms. Miller showed me this excel spreadsheet and observed a column that flagged all personnel that manage hazardous wastes in their respective teams to ensure all employees are trained annually. In addition, refresher training is held by Ms. Miller or Mr. Carter each quarter for new hires, inter team transfers, or employees who would otherwise have expired training the following quarter. I reviewed all employees who manage hazardous waste and emergency coordinators to ensure all personnel receive an annual hazardous waste refresher training. I determined all emergency coordinators and employees who require annual refresher training were up to date on their trainings. Ms. Miller also provided completed quizzes for all applicable employees which were reviewed during records review. Ms. Miller and Mr. Carter's most recent training certificates are provided in Attachment 32 as examples. I reviewed the personnel training requirements, and no other findings were noted. Manifest and Land Disposal Restriction (LDR) Requirements - JDOW maintained records of manifests on site at the time of inspection dating back three years. JDOW generated approximately 207 manifests over the last three years. I reviewed a representative sample of approximately 100 from the last three years. A manifest and corresponding LDR form are 19 provided in Attachment 33 as an example. I reviewed all other manifest and LDR requirements and no issues or findings were noted. I observed no issues or findings during this inspection. However, further EPA review may add findings. Janosh Digitally signed by Janosh Wolters W___o_l_t_e_r_s________-0_5_'0_0'___________ Date: 2022.02.03 16:27:44 Janosh Wolters Energy Engineer Date: February 3, 2022 AMBER Digitally signed by AMBER WHISNANT _W__H__I_S_N__A_N__T____-0_6_'0_0_' __________ Date: 2022.02.07 22:29:46 Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 Date: _________________ Attachments: 1. Facility Layout (1 page) 2. John Deere Ottumwa Works Photolog (1 page) 3. John Deere Ottumwa Works Photos (7 photos/8 pages) 4. EPA Inspection Checklist (56 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Hazardous Waste Site Info Verification Report for Inspector (1 page) 8. Paint Obsolete and Off spec Waste Profile (3 pages) 9. Paint Flush Waste Profile (3 pages) 10. Solvent and Paint Rags Waste Profile (3 pages) 11. HSM Notification (7 pages) 12. Still Bottoms Waste Profile (3 pages) 13. Paint Dip Plastic Waste Profile (3 pages) 14. Aerosol Cans and Paint Pens Waste Profile (3 pages) 15. Orphan Chemicals LabPak Waste Profile (3 pages) 16. Adhesive Thinner Waste Profile (2 pages) 17. Dip Tank Waste Profile (3 pages) 18. Hazardous Pharmaceuticals Waste Profile (3 pages) 19. Hazardous Pharmaceuticals Waste Profile Manifest (1 page) 20. Parts Washer SDS (10 pages) 21. Coolant SDS (5 pages) 22. Water Pretreatment Solutions SDSs (24 pages) 23. POTW Discharge Agreement (16 pages) 20 24. Used Oil Invoice (1 page) 25. Universal Waste Manifest (1 page) 26. CAA Log (2 pages) 27. CAA Closure Notice (3 pages) 28. MAK SDS (12 pages) 29. Distillation Unit Manual (42 pages) 30. Startex SDS (13 pages) 31. Contingency Plan (34 pages) 32. Training Records (2 pages) 33. Manifest & LDR Form (2 pages) 21