Document wgQyoN14zN8Ja4EXeyzevKqdQ
REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION
At
MAHLE Engine Components USA Inc. 60428 Marne Road Atlantic, IA 50022 (712) 250 - 3452
EPA ID Number: IAD096526108
On
June 8, 2022
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 MAHLE Engine Components USA Inc. (MAHLE) in Atlantic, Iowa on June 8, 2022. 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
MAHLE Engine Components USA Inc.: Jodi Allen, Safety, Health and Environment (SHE)/Human Resources Manager Cody Weaver, Plant Manager Clint Mathisen, Wastewater Treatment Specialist
EPA Representative, ERG: Joseph Watson, Senior Chemical Engineer
3.0 INSPECTION PRECEDURES
After arriving unannounced at MAHLE at approximately 08:35, I performed a drive-by visual inspection 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 I used the intercom in the lobby for assistance. I explained my reason for being on site is to conduct a RCRA CEI and asked to meet with the facility personnel who manage hazardous waste on site. Ms. Jodi Allen then greeted me at the facility entrance. I was instructed to watch the site safety video and she then led me to the wastewater treatment lab to begin the opening conference at approximately 09:15. I initiated the opening conference with Ms. Allen and Mr. Mathisen as the MAHLE representatives. I presented Ms. Allen and Mr. Mathisen 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 her with a copy of Title 18 U.S. Code, Sections 1001 and 1002. I then presented Ms. Allen with a copy of the Notice Regarding Proprietary/Confidential Business Information Submitted to or Collected by EPA in Connection with Inspections and reviewed MAHLE's confidentiality rights. I informed Ms. Allen 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. The Plant Manager, Mr. Weaver joined the inspection during the walkthrough. Ms. Allen provided a facility layout (see Attachment 1) and Ms. Allen, Mr. Mathisen, and Mr. Weaver explained facility operations and locations of hazardous waste generation and management.
During the visual inspection of the facility, Ms. Allen, Mr. Mathisen, and Mr. Weaver guided me throughout the facility in order to conduct thorough evaluations of the facility's satellite accumulation areas (SAAs) and central accumulation areas (CAAs). At the time of the inspection, the facility was operating 83 SAAs and two CAAs. The facility also handles universal waste in a designated area on site. The universal waste storage area was visually inspected. The two parts washers utilize an aqueous cleaning solution. I conducted an in-depth visual inspection of the SAAs, the CAAs, the universal waste storage areas, and all manufacturing areas.
Twelve 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 Mr. Weaver with a Confidentiality Notice, Receipt for Documents and Samples, and a Notice of Preliminary Findings (NOPF) which he signed as acknowledgement of receipt (see Attachments 5, 6, and 7 respectively). No confidentiality claims were made by MAHLE.
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The following inspection documents and compliance assistance handouts were left with MAHLE:
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) NOPF (Facility copy) Instructions for Responding to a NOPF 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
MAHLE began operating in 1978 and currently employs approximately 167 people. The facility operates on a five day, two 8-hour shift schedule with a third shift of two persons for preventive maintenance only. The facility has a footprint of approximately 25 acres. MAHLE operations consist of the manufacturing of engine bearings for heavy duty and industrial gasoline or diesel engines. Manufacturing processes include metal stamping, forming, and boring; electroplating (nickel, lead, aluminum, indium, tin, and copper); and protective coating and painting. The primary raw materials used are bi-metallic strips (steel with a variety of alloys), purchased from MAHLE's sister plants, plating solutions (nickel, lead, aluminum, indium, tin, and copper), and coatings. The major manufacturing or processing operations that generate waste streams include metal stamping, forming, and boring; electroplating (nickel, lead, aluminum, indium, tin, and copper); wastewater treatment plant, and protective coating and painting. The following waste streams are produced: wastewater treatment plant (WWTP) filter cake, waste tool room air filters, waste coatings, mixed waste residuals, aerosol can residuals, solvent/oily rags, parts washer solution, wastewater, scrap metal, waste oil/coolant, universal wastes, and general trash.
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4.2 RCRA Status According to the Notification Acknowledgement/Verification Report (see Attachment 8), MAHLE notified as a federal Large Quantity Generator (LQG) of D001, D007, D008, and F006 hazardous wastes. I asked Ms. Allen to review the Notification Acknowledgement/Verification Report, which I provided prior to records review and visual inspection of the waste generation areas. Ms. Allen requested I update the facility contact and confirmed the remaining information on the form was accurate to the best of her knowledge. After reviewing the records and walking through the facility, it appears the facility is operating as a federal LQG of D001, D007, D008, and F006 hazardous wastes, and a small quantity handler (SQH) of universal waste. MAHLE 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. MAHLE was previously inspected by an EPA contractor on March 10, 2017. The inspection led to a NOPF. The findings included a failure to keep SAA containers closed when not in use, a failure to label CAA containers with accumulation start dates, failure to maintain documentation of annual refresher hazardous waste training, and failure to mark a container of universal waste lamps with an accumulation start date. I observed a repeat finding regarding an open SAA container. MAHLE responded by correcting issues that led to the findings as shown through documentation provided by the facility and no enforcement actions were taken.
4.3 Facility Waste Streams and Management A Waste Stream and Waste Handling Table for MAHLE 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.
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WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION
GENERATION MANAGEMENT
#
RATE
1 Scrap Metal
Production
Nonhazardous (based on Approximately 55-gallon
TOTALL Metal Recycling, Inc.
Aluminum and
process knowledge and 40,000 pounds containers
of Granite City, IL
Scrap Metal Red
knowledge of the product) per month all
throughout
(ILD099670911) for recycling
Alloy
metals
facility,
(Invoice included in Attachment
occasionally a 1- 9)
yard box
2 Waste
Maintenance of D008 (based on process 1,500 pounds per 55-gallon
Tri State Motor Transit
Oil/Coolant
cutting,
knowledge and 2010
month
containers in
Company in Duenweg,
(Analytical Data grinding, and analytical results)
CAA
Missouri (MOD095038998) to
included in
fabricating
Tradebe Treatment and
Attachment 10) equipment
Recycling in East Chicago,
Indiana (IND000646943) for
disposal or energy recovery
3 Mixed Process Floor
D008 (based on process Approximately 5-gallon, 10-
Tradebe Transportation LLC
Waste/lead
sweepings, filter knowledge and 2011
7,000 pounds per gallon, 55-gallon, INR000125497 to Tradebe
contaminated
paper, plastic, analytical results)
month
and 1-yard
Treatment and Recycling in
waste (Waste
and rags,
containers
East Chicago, Indiana
Profile included contaminated
(IND000646943) for disposal
in Attachment equipment, and
11)
used PPE
4 Wastewater
Generated from Nonhazardous (based on 33,000 gallons Process tanks
Discharged to the City of
(Discharge
WWTP; a mix process knowledge and per day
Atlantic POTW
Agreement
of process
knowledge of the product) maximum
included in
plating
Attachment 12) wastewater and
groundwater
from the on-site
remediation
activities
5
WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION
GENERATION MANAGEMENT
#
RATE
5 Aerosol Cans
Aerosol can
D001 (based on product Less than one 55-gallon
Tri State Motor Transit
Residuals (Waste puncturing
and process knowledge) inch per year
container
Company in Duenweg,
Profile included
Missouri (MOD095038998) to
in Attachment
Tradebe Treatment and
13)
Recycling in East Chicago,
Indiana (IND000646943) for
disposal
6 Used Parts
Cleaning small D008 (based on product 50 gallons
In parts washer Heritage-Crystal Clean, LLC in
Washer Solvent tools in
and process knowledge) serviced every
Omaha, NE for recycling
(Aqueous)
maintenance
three months
(Invoice included in Attachment
14)
7 Filter Cake
WWTP on-site F006 (based on process 20 cubic yards 1-yard rollaway Heritage Transport LLC
(Analytical Data treatment of
knowledge)
per month
container to 20- (IND058484114) to Heritage
included in
plating
yard container Environmental Services in
Attachment 10) wastewater
Indianapolis, IN
(IND093219012) for disposal
8 Spent GAC
Groundwater treatment system
Nonhazardous (based on process knowledge) Combined with filter cake solids
Approximately 400 pounds every three years
20-yard container
Heritage Transport LLC (IND058484114) to Heritage Environmental Services in Indianapolis, IN (IND093219012) for disposal
6
WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION
GENERATION MANAGEMENT
#
RATE
9 Waste Degreaser Vapor degreaser D008 (based on process 25-gallons per 55-gallon
Tri State Motor Transit
(SDS included in
knowledge)
month
container
Company in Duenweg,
Attachment 15,
Missouri (MOD095038998) to
Waste Profile
Tradebe Treatment and
Included
Recycling in East Chicago,
Attachment 16)
Indiana (IND000646943) for
disposal
10 Used Tool Room From
(D007) based on product Two 55-gallon 55-gallon
Tri State Motor Transit
Filters
ventilation
and process
containers per container
Company in Duenweg,
(Analytical Data systems in the knowledge and 2011
month
Missouri (MOD095038998) to
included in
tool room
analytical results
Tradebe Treatment and
Attachment 10)
Recycling in East Chicago,
Indiana (IND000646943)
11 Cardboard/ Paper Generated from Nonhazardous (based on Approximately Standard Bales TOTALL Metal Recycling, Inc.
packing
process knowledge and 1,500 pounds per
of Granite City, IL
material
knowledge of the product) month
(ILD099670911) for recycling
(Invoice included in Attachment
9)
12 Universal Waste Facility
Lamps (Invoice maintenance
included in
Attachment 17)
13 Universal Waste Facility
Batteries
maintenance
(Invoice included
in Attachment
17)
Exempted (managed as universal waste per 40 CFR 273)
Exempted (managed as universal waste per 40 CFR 273)
Approximately 500 lamps per year
Three 5-gallon containers per year
4-foot container, 8-foot container
A-TEC Recycling, Inc. of Pleasant Hill, IA for recycling
5-gallon container A-TEC Recycling, Inc. of Pleasant Hill, IA for recycling
7
WASTE
GENERATION HAZARDOUS WASTE ESTIMATED ON-SITE
OFF-SITE MANAGEMENT
STREAM
PROCESS
DETERMINATION
GENERATION MANAGEMENT
#
RATE
14 Waste Coating Protective
D001 (based on product Approximately 55-gallon
Tri State Motor Transit
polyimide
and process knowledge) 55-gallons every container
Company in Duenweg,
coatings
six months
Missouri (MOD095038998) to
Tradebe Treatment and
Recycling in East Chicago,
Indiana (IND000646943) for
disposal
15 General Trash Facility
Nonhazardous (based on One 20-yard
20-yard container Hepler Curbside Recycling to
operations
process knowledge and container picked
Cass County Landfill in
knowledge of the product) up weekly
Atlantic, Iowa for landfill
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Less-Than-90-Day Hazardous Waste Accumulation Area
MAHLE has two Less-Than-90-Day CAAs on site, which are located in close proximity to the WWTP on the facility layout (see Attachment 1). I visually inspected CAA #1 located directly underneath the waste treatment lab in the WWTP. I observed 12 55-gallon containers waste coating and hazardous oil (see Photo 3, Attachment 3). All 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 container in CAA #1 was March 25, 2022. March 25, 2022 is within 90 days from the time of the inspection. There was also one nonhazardous 55-gallon drum of plating wastewater to be processed through the WWTP. A 20-yard WWTP filter cake roll-off container was located just outside the WWTP in CAA #1 (see Photo 5, Attachment 3). The roll-off container was numbered RO-8144. The container was closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard. The accumulation start date on the container was May 6, 2022. May 6, 2022 is within 90 days from the time of the inspection. A close-up photograph of the label on the 20-yard filter cake roll-off container is shown in Photo 4, Attachment 3.
I visually inspected CAA #2 located west of the WWTP and CAA #1. CAA #2 contained nine 1yard containers of mixed waste/lead-contaminated waste, one 1-yard container of used tool room air filters, and one black 55-gallon container of waste polymer (see Photos 6, 8 and 9, Attachment 3). The containers were closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard. A close-up view of a 1-yard mixed waste/leadcontaminated waste container in CAA #2 is shown in Photo 7, Attachment 3. The oldest accumulation start date on a container was April 23, 2022. April 23, 2022 is within 90 days from the time of the inspection.
I observed adequate aisle space to allow for container inspections and access 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. A sign was posted on the door of the CAA which listed the phone numbers of emergency coordinators and emergency response agencies along with a "No Smoking" sign. I asked Mr. Mathisen if the facility inspected the CAA. Mr. Mathisen stated the facility inspected the CAA at least weekly and had weekly inspection logs but there might be some gaps from when MAHLE was shut down due to COVID. During records review, Mr. Mathisen provided inspection logs for the CAA. I reviewed the logs and determined the facility did not inspect the CAA from 1/29/22 through 2/12/22; 9/17/21 through 10/1/21; 4/17/21 through 4/30/21; and 6/23/20 through 7/17/20. Examples of the CAA logs are provided in Attachment 18. Therefore, I left the following finding:
NOPF 1 - Failure to inspect CAAs weekly. [40 CFR 262.17(a)(1)(v)].
Satellite Accumulation Areas
I observed 83 SAAs during the visual inspection. The table below shows the SAA name or location, waste type, volume of waste observed, and container type.
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SAA # 1 2 3 4 5 6 7 8 9 10 11 12 13 14
SAA Name or Location
Waste Type
Waste Treatment Lab Mixed Process Waste
- Lead Contaminated
Plating Area 486
Waste Paint Related Material
Area 486, Near RAC Mixed Process Waste
Repair
- Lead Contaminated
Area 486, Near Nitric Mixed Process Waste
Scrubber
- Lead Contaminated
Area 486, Near Alloy Mixed Process Waste
Scrubber
- Lead Contaminated
Area 586, EQ No. Mixed Process Waste
9226
- Lead Contaminated
Area 487, Coordinator Mixed Process Waste
Desk
- Lead Contaminated
Area 487, Pack Table Mixed Process Waste - Lead Contaminated
Area 486, Nickel Mixed Process Waste
Recovery
- Lead Contaminated
Area 488, Tin Plater Mixed Process Waste - Lead Contaminated
Spent Vapor Degreaser
Spent Vapor Degreaser
Polymer Room Back Corner
Spent Polymer
Polymer Room Aisle Mixed Process Waste - Lead Contaminated
Polymer Room Aisle Spent Polymer
Volume of Waste
Two gallons Five gallons
Empty Five gallons
Empty One gallon One gallon Four gallons Less than three
inches 30 gallons 25 gallons Five gallons One gallon
Empty
Container Type 5-gallon container
30-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 5-gallon container 5-gallon container 5-gallon container 55-gallon drum 55-gallon drum 55-gallon drum 55-gallon drum 5-gallon container 55-gallon drum
15
Polymer Room Aisle Mixed Process Waste
Empty
- Lead Contaminated
5-gallon container
16 Area 551, Maintenance Mixed Process Waste 50 gallons - Lead Contaminated
55-gallon drum
17
Maintenance Desk Mixed Process Waste Two gallons 10-gallon container
Area
- Lead Contaminated
18
Area 421, EQ No. Mixed Process Waste Two gallons 5-gallon container
5240
- Lead Contaminated
10
19
Area 423
Mixed Process Waste Two gallons 5-gallon container
- Lead Contaminated
20
Area 422
Mixed Process Waste Two gallons 5-gallon container
- Lead Contaminated
21
Tool Room, by 125 Mixed Process Waste Two gallons 10-gallon container
Crane
- Lead Contaminated
22
Tool Room Tool Room - Chrome Three gallons 5-gallon container
Contaminated
23
Area 413
Mixed Process Waste
Empty
5-gallon container
- Lead Contaminated
24
Area 413 - Aisle Mixed Process Waste Three gallons 10-gallon container
- Lead Contaminated
25 Area 413 - Tool Room Mixed Process Waste One gallon 5-gallon container
Wall
- Lead Contaminated
26 Area 413 - Next to EQ Mixed Process Waste Three gallons 5-gallon container
No.1904
- Lead Contaminated
27 Area 413 - Next to EQ Mixed Process Waste 40 gallons
No.3664
- Lead Contaminated
55-gallon drum
28 Area 413 - Next to EQ Mixed Process Waste Two gallons 5-gallon container
No.6130
- Lead Contaminated
29
Area 411 - Across Mixed Process Waste Two gallons 5-gallon container
Cafeteria
- Lead Contaminated
30 Area 413 - Next to EQ Mixed Process Waste Two gallons 5-gallon container
No.5453
- Lead Contaminated
31
Area 413 - Next to Mixed Process Waste One gallon 5-gallon container
Cafeteria
- Lead Contaminated
32
Area 434 - EQ No. Mixed Process Waste 0.5 gallons 5-gallon container
5217
- Lead Contaminated
33
Area 434 - Behind Mixed Process Waste Two gallons 55-gallon drum
7307 Shave
- Lead Contaminated
34
Area 412 - EQ No. Mixed Process Waste Two gallons 5-gallon container
7405
- Lead Contaminated
35
Area 430 - EQ No. Mixed Process Waste Two gallons 5-gallon container
5455
- Lead Contaminated
36
Area 432 - EQ No. Mixed Process Waste Four gallons 5-gallon container
2317
- Lead Contaminated
37
Area 455 - EQ No. Mixed Process Waste Two gallons 5-gallon container
3106
- Lead Contaminated
11
38
Area 427 - EQ No. Mixed Process Waste Three gallons 5-gallon container
6207
- Lead Contaminated
39
Area 452
Mixed Process Waste Three gallons 7-gallon container
- Lead Contaminated
40
Area 453 - EQ No. Mixed Process Waste 4.5 gallons 5-gallon container
2111
- Lead Contaminated
41
Area 453 - EQ No. Mixed Process Waste Two gallons 5-gallon container
5217
- Lead Contaminated
42
Area 453 - EQ No. Mixed Process Waste Two gallons 5-gallon container
2206
- Lead Contaminated
43
Area 453 - EQ No. Mixed Process Waste Two gallons 5-gallon container
2206
- Lead Contaminated
44
Area 453 - EQ No. Mixed Process Waste Two gallons 5-gallon container
2508
- Lead Contaminated
45
Area 452 - EQ No. Mixed Process Waste One gallon 10-gallon container
2101
- Lead Contaminated
46
Area 455 - EQ No. Mixed Process Waste One gallon 5-gallon container
2208
- Lead Contaminated
47
Area 481 - EQ No. Mixed Process Waste Two gallons 5-gallon container
3502
- Lead Contaminated
48
Area 481 - Washer Mixed Process Waste 25 gallons
55-gallon drum
Area
- Lead Contaminated
49
Area 480 - EQ No. Mixed Process Waste Two gallons 5-gallon container
4122
- Lead Contaminated
50
Area 480 - EQ No. Mixed Process Waste Four gallons 10-gallon container
1279
- Lead Contaminated
51
Area 480 - By Hoist Mixed Process Waste 25 gallons
55-gallon drum
- Lead Contaminated
52
Employee Entrance Mixed Process Waste Three gallons 10-gallon container
- Lead Contaminated
53
Area 452 - EQ No. Mixed Process Waste Three gallons 10-gallon container
2536
- Lead Contaminated
54
Area 424 - EQ No. Mixed Process Waste Two gallons 5-gallon container
6208
- Lead Contaminated
55
Area 424 - EQ No. Mixed Process Waste Three gallons 5-gallon container
6208
- Lead Contaminated
56
Area 424 - EQ No. Mixed Process Waste One gallon 5-gallon container
8237
- Lead Contaminated
12
57
Area 424 - EQ No. Mixed Process Waste Four gallons 5-gallon container
5428
- Lead Contaminated
58
Area 424 - North Mixed Process Waste Five gallons 55-gallon drum
Corner
- Lead Contaminated
59
Area 416 - EQ No. Mixed Process Waste Three gallons 5-gallon container
5217
- Lead Contaminated
60
Area 416 - EQ No. Mixed Process Waste Three gallons 5-gallon container
5325
- Lead Contaminated
61
Area 416 - EQ No. Mixed Process Waste Three gallons 5-gallon container
2118
- Lead Contaminated
62
Area 416 - EQ No. Mixed Process Waste Three gallons 5-gallon container
12A5
- Lead Contaminated
63
Area 416 - EQ No. Mixed Process Waste Three gallons 5-gallon container
5459
- Lead Contaminated
64
Area 410 - EQ No. Mixed Process Waste 50 gallons
55-gallon drum
8311
- Lead Contaminated
65
Area 416 - EQ No. Mixed Process Waste One gallon 5-gallon container
8328
- Lead Contaminated
66
Area 484 - EQ No. Mixed Process Waste Three gallons 5-gallon container
Pack C/D
- Lead Contaminated
67
Area 428 - EQ No. Mixed Process Waste One gallon 5-gallon container
6630
- Lead Contaminated
68
Area 484 - Packing Mixed Process Waste One gallon 5-gallon container
- Lead Contaminated
69
Area 456 - EQ No. Mixed Process Waste Two gallons 5-gallon container
1230
- Lead Contaminated
70
Area 456 - EQ No. Mixed Process Waste Four gallons 6-gallon container
1230
- Lead Contaminated
71
Shipping - EQ No. Mixed Process Waste One gallon 5-gallon container
0651
- Lead Contaminated
72
Cummins Park - EQ Mixed Process Waste Four gallons 5-gallon container
No. 06A9
- Lead Contaminated
73
Wash House Mixed Process Waste Two gallons 5-gallon container
- Lead Contaminated
74
Wash House - South
Wall
Waste Oil
50 gallons
55-gallon drum
75
Kit Area
Mixed Process Waste Two gallons 5-gallon container
- Lead Contaminated
13
76 Scrap Area - Shipping Mixed Process Waste 40 gallons 55-gallon container
Door
- Lead Contaminated
77
Scrap Area by Door Mixed Process Waste Three gallons 6-gallon container
- Lead Contaminated
78
Central Fixed
Waste Oil
30 gallons 55-gallon container
79
Central Cart
Waste Oil
40 gallons 55-gallon container
80
Area 553 - Under Mixed Process Waste Ten gallons 55-gallon container
Office Stairs - Lead Contaminated
81
Scrap Area
Aerosol Residue
Empty
55-gallon container
82
Plating Lab
Mixed Process Waste Four gallons 5-gallon container
- Lead Contaminated
83
Plating Lab
Mixed Process Waste Four gallons 5-gallon container
- Lead Contaminated
The hazardous waste accumulation containers observed in the SAAs except for SAA #19 were in good condition, closed, labeled with the indication of the nature of the hazard, and labeled with the words "Hazardous Waste" (see Attachment 3, Photo 3). The lid on SAA #19 had holes and was not closed. Therefore, I left the following finding:
NOPF 2 - Failure to keep containers closed when not adding waste or for temporary venting. [262.15(a)(4)].
Bearing Production
During the visual inspection, I observed the beating production operations. In this process, metal strips are fed into a stamping machine after which the bearing is formed, notched, milled, grooved, shaved, and bored. The waste from the stamping and production processes is primarily scrap metal (which is recycled), waste oil/coolant, and mixed process waste. "Mixed" refers to the variety of materials in this waste stream, which includes contaminated debris (floor sweepings, filter paper, plastic, and rags), contaminated equipment, and personal protective equipment (PPE), rather than "mixed waste" (mixed hazardous and radioactive waste). Both mixed process waste and waste oil/coolant are considered hazardous waste by the facility, due to contamination with lead.
Bearings may be cleaned in a vapor degreaser utilizing n-propyl bromide. Waste degreaser is considered hazardous by the facility, also due to contamination with lead. Vapor degreasing is followed by caustic and acid etch baths. Parts are then electroplated with a variety of materials, including nickel, aluminum, lead, indium, copper, and tin; none of the plating processes uses cyanide. Rinse waters from the electroplating process are hard piped to the on-site WWTP.
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Wastewater is discharged to the City of Atlantic publicly owned treatment works (POTW) after treatment. MAHLE also coats bearings with a protective polyimide coating, rather than plating. Paint guns and other equipment are cleaned with butyl acetate, and the paint has a xylene carrier. MAHLE considers the paint waste hazardous waste (D001).
Scrap metal, including lead-plated scrap, is generated from discarded metallic parts. Because the scrap metal is recycled, the facility considers it exempt from the definition of solid waste. The facility generates approximately 40,000 pounds of scrap metal per month. Scrap metal is accumulated in containers around the facility (see Photo 11, Attachment 3). It is collected for recycling by Total Metal Recycling of Granite City, Illinois.
I reviewed the management of bearing production and no issues or findings were noted.
Tool Shop
During the visual inspection, I observed operations at the tool shop. MAHLE machines most of its own tools for production from chrome-plated steel. Tool room operations mostly involve grinding. An exhaust recovery system filters the air, and the used tool room air filters are considered hazardous due to contamination with chromium. Used tool room filters are generated from ventilation systems in the tool room. MAHLE has determined that used tool room filters are hazardous waste (D007) based on product and process knowledge and analysis. I reviewed an analytical report from June 2009, which showed that the material had a chromium TCLP concentration of 3.87 mg/L. Out of an abundance of caution, MAHLE manages this waste stream as hazardous waste The waste is transported to Tradebe in East Chicago, Indiana, for recycling or disposal.
During my inspection of the chemical storage cage CAA, I observed one 1-cubic-yard cardboard container of used tool room filters (see Photo 6, Attachment 3). According to Ms. Allen, the container is brought from the SAA, emptied into the CAA container, and returned to the SAA. The containers were closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard. It was dated May 21, 2022.
I reviewed the management of tool shop waste and no issues or findings were noted.
Mixed Process Waste
Mixed process waste includes contaminated debris (floor sweepings, filter paper, plastic, and rags), contaminated equipment, and used PPE. The facility has determined that mixed process waste is hazardous waste (D008) based on product and process knowledge and analysis. I reviewed the waste Profile in Attachment 11. According to document reviews, this waste profile was based on analytical results from June 2011, which showed that the material failed TCLP analysis for lead.
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During the visual inspection, I observed containers of mixed process waste in at least 70 SAAs around the facility. Each of these containers was a 55-gallon metal drum or a 5- or 10-gallon metal safety can. None of the SAAs had more than 55 gallons of waste. Each container was in good condition, at or near the point of generation, and under control of the operator. Each was closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard. As identified in Section 4.5, the lid on SAA #19 had holes and was not closed. Therefore, I left the following finding:
NOPF 2 - Failure to keep containers closed when not adding waste or for temporary venting. [262.15(a)(4)].
I reviewed the management of the mixed process waste management and no issues or findings were noted.
Groundwater Remediation
MAHLE operates a groundwater remediation system under a Memorandum of Understanding with EPA, due to a release of chlorinated solvent that occurred in 1981 (the facility previously had used trichloroethene [TCE] in its vapor degreaser). The current groundwater remediation system includes two recovery wells and seven monitoring wells. Used granular activated carbon (GAC) from this system is considered nonhazardous waste. Groundwater from the treatment system is combined with process wastewater after proceeding through the WWTP and before discharge to the sanitary sewer. Spent GAC is generated in the groundwater treatment system, which consists of an aeration unit and the GAC. The facility considers the spent GAC nonhazardous based on product and process knowledge (analysis of pre- and post-treatment groundwater). However, the spent GAC is consolidated with the F006 filter cake, so would carry the F006 waste code, based on the mixture rule. According to Ms. Allen, she believes that the generation rate of 400 pounds of spent GAC every 2 to 3 years is accurate. The spent GAC, mixed with the filter cake, is sent to PDC in Peoria, Illinois, for disposal.
I reviewed the management of groundwater remediation waste management and no issues or findings were noted.
Aerosol Can Residuals
I asked Mr. Mathisen if aerosol cans are used on site. Mr. Mathisen stated aerosol cans are used primarily for maintenance activities. Mr. Mathisen stated aerosol cans are used until RCRA empty and punctured. Mr. Mathisen stated that if an aerosol broke or became unusable, an operator would immediately puncture the can and manage the aerosol can residuals as a D001 hazardous waste which are managed in SAA #81. There was no aerosol can residuals managed at the time of the inspection.
I reviewed the management of aerosol can residuals and no issues or findings were noted.
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Used Parts Washer Solvent
Used parts washer solvent is generated in two parts washers around the facility. Mr. Mathisen stated the two parts washers use aqueous solvents but the facility has determined that used parts washer solution is hazardous waste (D008) based on product knowledge and testing. The facility generates approximately 50 gallons of used parts washer solvent every 3 months. The waste is transported to Safety-Kleen in Omaha, Nebraska, for recycling or disposal. A Heritage-Crystal Clean service receipt is included in Attachment 14.
I did not observe any used parts washer solvent management during the inspection.
Wastewater Treatment Plant
During the visual inspection, I observed the on-site WWTP. The WWTP is located on the eastern portion of the plant directly before crossing the railroad tracks as shown on the facility layout (see Attachment 1). Wastewater generated from the on-site WWTP consists of a mix of process wastewater and groundwater from the on-site remediation activities. Because the wastewater is discharged to the City of Atlantic POTW via the sanitary sewer, MAHLE considers it exempt from the definition of solid waste. I reviewed the pretreatment agreement issued by the City of Atlantic. Based on this document, the facility discharged 52,000 gallons per day (approximately 35,000 gallons of process wastewater and 17,000 gallons of groundwater). According to Ms. Allen, the wastewater is sampled before discharge for metals, total suspended solids, oil and grease, and pH (see Attachment 12). Groundwater is sampled regularly as part of the facility's corrective action program.
Filter cake is dewatered sludge generated from on-site treatment of plating wastewater. The facility has determined that filter cake is hazardous waste (F006) based on product and process knowledge. Based on my review of manifests, the facility generates approximately 20-yards of filter cake per month. The waste is transported to Heritage Environmental Services in Indianapolis, IN for disposal.
During my inspection of the WWTP, I observed an empty 1-yard rollaway container under the filter press. According to Mr. Mathisen, the filter cake is generated from a batch process. After dropping into the rollaway container, it is transferred immediately to a 20-yard container just outside the WWTP building (see Photo 4 and Photo 5, Attachment 3). The 20-yard container was closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard. The accumulation start date on the container was May 6, 2022.
I reviewed the management of waste from the WWTP, and no issues or findings were noted.
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Universal Wastes
During the visual inspection, I observed the management of universal waste batteries and lamps. Used lamps are generated during facility maintenance and include both fluorescent tube lamps and high-intensity discharge (HID) lamps. Although the facility is transitioning to lower mercury, nonhazardous lamps, the transition is not complete. MAHLE considers the older lamps characteristic hazardous waste and manages all used lamps as universal waste. Used lamps are collected for recycling by A-TEC of Pleasant Hill, Iowa. An invoice of a shipment of universal waste to A-TEC is included in Attachment 17. During the visual inspection of the area around the wastewater pit, I observed three containers of 8-foot tube lamps and 4-foot tube lamps. All containers were closed, in good condition, and labeled as "Universal Waste-Lamp(s)." The earliest accumulation start date was observed on "07/02/2021" and was on a 4-foot container.
The facility considers the used batteries characteristic hazardous waste and manages all waste batteries as universal waste. MAHLE manages universal waste batteries in the maintenance area. Ms. Allen stated MAHLE generates approximately two 5-gallon containers per year. During the visual inspection, I observed a 5-gallon container of universal waste batteries located in Area 484 Packing. The 5-gallon container was closed, in good condition, and labeled as "Spent Batteries." The container was approximately half full. The container did not have an accumulation start date and was not labeled "Universal Waste Used Batteries." I asked Mr. Mathisen if the facility tracked how long universal waste has been accumulated on site. Mr. Mathisen stated the facility would date the containers with an accumulation start date. I explained to Mr. Mathisen the facility is required per 40 CFR 273.15(c) to demonstrate the length of time that universal waste has been accumulated. Therefore, I left the following findings:
NOPF 3 - Failure to demonstrates the length of time that the universal waste has been accumulated. [40 CFR 273.15(c)].
NOPF 4 - Failure to label individual batteries or their containers "Universal WasteBattery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)". [40 CFR 273.14(a)].
Ms. Allen provided me with invoices for the universal waste lamps and batteries in Attachment 17.
Waste Oil
I visually observed the facility's bearing production operations. MAHLE generates waste oil/coolant from maintenance of cutting, grinding, and fabricating equipment. The facility has determined that waste oil/coolant is a hazardous waste (D008) based on product and process knowledge and analysis. I reviewed an analytical report from 2009, which showed that the material failed the toxicity characteristic leaching procedure (TCLP) analysis for lead (see Attachment 10). The waste is transported to Tradebe in East Chicago, Indiana, for
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disposal. I observed three 55-gallon SAA containers of waste oil/coolant. Each container was closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard. During my inspection of CAA #1 inside the WWTP building, I observed seven 55-gallon containers of waste oil/coolant (see Photo 3, Attachment 3). Each container was closed, labeled as "Hazardous Waste," and labeled with an indication of the nature of the hazard.
I reviewed the management of waste oil and no issues or findings were noted. .
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 two hazardous waste containers CAAs (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 - Section 3 and Section 8 of the contingency plan (see Attachment 19) was on file electronically and was reviewed while on site. The contingency plan had been revised in March 2020 and included, emergency response procedures, emergency coordinators and contact information, and a list of emergency some response equipment. The contingency plan needed to be updated when Ms. Allen became one of the designated emergency coordinators in March 2021. Ms. Allen stated that MAHLE was going to update the emergency coordinators in the contingency plan. Therefore, I left the following finding:
NOPF 5 - Failure to keeps list of emergency coordinators up-to-date. [40 CFR 262.17(a)(6)262.261(d)].
The contingency plan did not include a complete evacuation route or alternative routes. During records review, I asked Ms. Allen if the facility had designated evacuation routes or a map indicating where evacuation routes are located throughout the facility. Ms. Allen stated it must have been an oversight that this was not included in the contingency plan. Therefore, I left the following finding:
NOPF 6 - Failure to include a complete evacuation plan including route, signal, and alternate route in the contingency plan. [40 CFR 262.17(a)(6)40 CFR 262.261(f)].
The facility did not prepare a quick reference guide even though they updated their contingency plan after May 30, 2017. Ms. Allen stated this was an oversight of the previous manager when the contingency plan was updated in March 2020 and MAHLE was going to make it a priority to prepare a quick reference guide. Therefore, I left the following finding:
NOPF 7 - Failure to prepares a quick reference guide and submit it to emergency response agencies. [262.17(a)(6)262.262(b)].
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The facility had submitted the contingency plan to local emergency response agencies including the local police department, fire department, and hospital. Copies of the arrangements with the local response agencies are included in Attachment 20.
I reviewed the entire RCRA contingency plan and no additional issues or findings were noted.
Personnel Training Requirements - Personnel are to be trained to perform hazardous waste duties, and new employees are to be trained within 6 months of start. The training, at a minimum, must be designed to ensure personnel at MAHLE 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 MAHLE receive, I determined the training to be sufficient. Ms. Allen provided yearly records of completed trainings for all employees handling hazardous waste on site and emergency coordinators listed in the contingency plan. Ms. Allen who has taken on the role as an emergency coordinator for approximately three months has not yet taken the training but is scheduled to take the training within the month. I observed both Daniel Riker and Clint Mathisen signed hazardous waste manifests. Clint Mathisen is a designated wastewater treatment operator. During records review, I observed that the wastewater treatment operator job description explained their respective duties but did not provide information on initial training requirements and continual training requirements. Ms. Allen stated the wastewater treatment operator job description would be updated to include all required information. The wastewater treatment operator and material handler job descriptions provided by Ms. Allen are included in Attachment 21. I observed Mr. Mathisen and Mr. Riker completed annual RCRA hazardous waste refresher training on July 22, 2021 and July 8, 2021 respectively. Training records for Mr. Mathisen and Mr. Riker are included in Attachment 22 as examples. I reviewed the personnel training requirements and I left the following finding:
NOPF 8 - Failure to prepare a written description of type and amount of introductory and continuing training. [40 CFR 262.17(a)(7)(iv)(C)].
Manifest and Land Disposal Restriction (LDR) Requirements - MAHLE maintained records of manifests on site at the time of inspection dating back three years. MAHLE generated approximately 20 manifests over the last three years. I reviewed all manifests from the last three years. Two manifests are provided in Attachment 23 as examples.
I reviewed all other manifest and LDR requirements and no issues or findings were noted.
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5.0 SUMMARY OF FINDINGS
NOPF 1 - Failure to inspect CAAs weekly. [40 CFR 262.17(a)(1)(v)].
The facility did not inspect the CAA from 1/29/22 through 2/12/22; 9/17/21 through 10/1/21; 4/17/21 through 4/30/21; and 6/23/20 through 7/17/20.
NOPF 2 - Failure to keep containers closed when not adding waste or for temporary venting. [262.15(a)(4)].
At SAA #19, there was a 5-gallon container of mixed waste/lead-contaminated hazardous waste. The container lid had two holes on the top of the lid and is not closed. The container was labeled as "Hazardous Waste" and labeled with an indication of the nature of the hazard. The container was holding approximately two gallons of hazardous waste.
NOPF 3 - Failure to demonstrates the length of time that the universal waste has been accumulated. [40 CFR 273.15(c)].
NOPF 4 - Failure to label individual batteries or their containers "Universal WasteBattery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)". [40 CFR 273.14(a)].
During the visual inspection, I observed a 5-gallon container of universal waste batteries located in Area 484 Packing. The 5-gallon container was closed, in good condition, and labeled as "Spent Batteries." The container did not have an accumulation start date and was not labeled "Universal Waste Used Batteries."
NOPF 5 - Failure to keeps list of emergency coordinators up-to-date. [40 CFR 262.17(a)(6)262.261(d)].
The contingency plan had been revised In March 2020 and included, emergency response procedures, emergency coordinators and contact information, and a list of emergency some response equipment. The contingency plan needed to be updated when Ms. Allen became one of the designated emergency coordinators in March 2021. Ms. Allen stated that MAHLE was going to update the emergency coordinators in the contingency plan.
NOPF 6 - Failure to include a complete evacuation plan including route, signal, and alternate route in the contingency plan. [40 CFR 262.17(a)(6)40 CFR 262.261(f)].
The contingency plan did not include a complete evacuation route or alternative routes. During records review, I asked Ms. Allen if the facility had designated evacuation routes or a map indicating where evacuation routes are located throughout the facility. Ms. Allen stated it must have been an oversight that this was not included in the contingency plan.
NOPF 7 - Failure to prepares a quick reference guide and submit it to emergency response agencies. [262.17(a)(6)262.262(b)].
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The facility did not prepare a quick reference guide even though they updated their contingency plan after May 30, 2017. Ms. Allen stated this was an oversight of the previous manager when the contingency plan was updated in March 2020 and MAHLE was going to make it a priority to prepare a quick reference guide.
NOPF 8 - Failure to prepare a written description of type and amount of introductory and continuing training. [40 CFR 262.17(a)(7)(iv)(C)].
During records review, I observed that the wastewater treatment operator job description explained their respective duties but did not provide information on initial training requirements and continual training requirements. Ms. Allen stated the wastewater treatment operator job description would be updated to include all required information.
I observed no additional issues or findings during this inspection. However, further EPA review may add findings.
Digitally signed by Joseph
Joseph Watson Watson Date: 2022.07.31 22:13:55 -04'00'
______________________________
Joseph Watson Senior Chemical Engineer Date: July 31, 2022
AMBER
Digitally signed by AMBER WHISNANT
WHISNANT
Date: 2022.08.05 18:05:52 -05'00'
______________________________
Amber Whisnant
Section Chief
ECAD/CB/RCRA, EPA Region 7
Date: _________________
Attachments: 1. Facility Layout (1 page) 2. MAHLE Engine Components USA Inc. Photolog (1 page) 3. MAHLE Engine Components USA Inc. Photos (12 photos/13 pages) 4. EPA Inspection Checklist (42 pages) 5. Confidentiality Notice (1 page) 6. Receipt for Documents and Samples (1 page) 7. Notice of Preliminary Findings (1 page) 8. Notification Acknowledgement Verification Report (1 page) 9. Metal and Cardboard Recycling Invoice (6 pages) 10. Waste Oil, Tool Shop Waste, Filter Cake Analytical Results (3 pages) 11. Mixed Process Waste Waste Profile (5 pages)
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12. Discharge Water Agreement (5 pages) 13. Aerosol Residuals Waste Profile (4 pages) 14. Parts Washer Service Invoice (1 page) 15. Vapor Degreaser Waste Profile (7 pages) 16. Waste Profile Vapor Degreaser (4 pages) 17. Universal Waste Invoice (1 page) 18. CAA Inspection Log (8 pages) 19. Contingency Plan Sections (23 pages) 20. Contingency Plan Arrangements (6 pages) 21. Job Descriptions (5 pages) 22. Training Records (2 pages) 23. Manifests (2 pages)
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Attachment 7, Page 1 of 1