Document wqdOeNo1zXKywwv6db8xgMzJ4

REPORT OF RCRA COMPLIANCE EVALUATION INSPECTION At NORDSTROM INC 808 7700 18th Street SW Cedar Rapids, Iowa 52404 (202) 604-8676 EPA RCRA ID No. IAR000523548 ON October 11-12, 2023 By TOEROEK ASSOCIATES, INC. For U.S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division INTRODUCTION At the request of the Enforcement and Compliance Assurance Division/Chemical Branch/RCRA Section of the U.S. Environmental Protection Agency (EPA) Region 7, Toeroek Associates, Inc. and its subcontractor CLAENE Group (Toeroek team) conducted a hazardous waste compliance evaluation inspection (CEI) at Nordstrom Inc. 808 (Nordstrom), at 7700 18th Street SW, Cedar Rapids, Iowa. The CEI was conducted under the authority of Section 3007 of the Resource Conservation and Recovery Act (RCRA), as amended. The CEI covered hazardous waste generator, used oil, and universal waste requirements as applicable. This report and its attachments present the findings of the CEI. PARTICIPANTS Nordstrom: Myles Fishel, Senior Facilities Manager Theresa Cavros, Area Manager Sheillah Bentley, Safety Manager Toeroek Team: William F, Starks, Environmental Consultant, (816) 286-6951 INSPECTION PROCEDURES Prior to the CEI at Nordstrom on October 10, 2023, I conducted a drive-by visual inspection. I did not observe any areas of concern during the drive-by. Upon my arrival, I entered the main entrance and explained the purpose of the CEI to the receptionist. I asked to speak with Mr. Bruce Kiesling, identified on the Notification Acknowledgement/Verification Report (Verification Report) as the site contact (Attachment 1). The receptionist stated that Mr. Fishel had assumed Mr. Kiesling's position, and asked me to fill out the visitor's online form. She explained that would contact Mr. Fishel to advise him of my arrival. I filled out the form, and Mr. Fishel arrived at the lobby a short time later. After a brief introduction, I explained the purpose of the CEI and asked if we could adjourn to his office or a conference room to conduct an entry briefing. Mr. Fishel and I proceeded to the Return Area, where he introduced me to Ms. Cavros. The Return Area is Nordstrom's less than 90-day hazardous waste container accumulation area (CAA), which is located in an aisle in the warehouse. I proceeded to conduct an entry briefing with Mr. Fishel and Ms. Cavros in the Return Area. During the entry briefing, I presented my business card and EPA credentials to Mr. Fishel and Ms. Cavros. I explained the scope and procedures for the CEI. I explained the facility's right to make confidentiality claims and provided a Notice Regarding Proprietary/Confidential Business Information. I stated that at the conclusion of the CEI, they would be presented with a Confidentiality Notice (Notice) with which they could make or not make a claim of confidentiality for the facility. I also provided Mr. Fishel and Ms. Cavros a copy of U.S. Federal Codes 1001 and 1002, concerning communication of false statements and documents to federal inspectors, and RCRA Section 3007, explaining EPA's inspection authority. Mr. Fishel and Ms. Cavros read both of these documents. A copy of each of the following documents was left with the facility during the inspection: x RCRA Facility Access Information Sheet x Mr. Trevor Urban's contact information x RCRA Section 3007 x U.S. Federal Codes 1001 and 1002 x Instructions for Responding to a Notice of Preliminary Findings x Notice Regarding Proprietary/Confidential Business Information x E-Manifest Fact Sheet: Generators x Small Quantity Generator Reminder to Re-notify x Managing your Hazardous Waste: A Guide for Small Businesses x Part 279 Requirements: Used Oil Management Standards x EPA Region 7 Emergency Response Program x Recycling Electronics: A Guide for Businesses x Battery Recycling/Disposal x Management of Fluorescent Lamps for Businesses x Universal Wastes - Including Aerosol Cans x Iowa Environmental Guide for Businesses 2 I reviewed the Verification Report with Mr. Fishel (Attachment 1). Based on this review, as well as observations during the CEI, I updated the Site Contact Information to reflect Mr. Fishel's contact information. I updated the Hazardous Waste Generator section on the Verification Report to small quantity generator (SQG). I deleted hazardous waste codes U002, U019, U037, U057, U108, U112, U134, U154, U159, U161, U196, U220, and U239 from the Description of Hazardous Waste section. I also changed the NAICS Code from 452210 (Department Stores) to 493110 (General Warehouse and Storage). I conducted the visual inspection and a majority of the records review on October 11, 2023, accompanied by Mr. Fishel. During the records review, I reviewed facility documentation such as inspection logs, training records, shipping records, and hazardous waste determination records. I returned to Nordstrom on October 12, 2023, to complete the records review and conduct an exit briefing. I prepared and completed a site-specific inspection checklist to document my observations. At the conclusion of the CEI on October 12, 2023, I conducted an exit briefing with Mr. Fishel and Mses. Cavros and Bentley. During the exit briefing, I provided a Receipt for Documents and Samples, which Mr. Fishel signed, acknowledging receipt (Attachment 2). I provided Mr. Fishel the Notice, which he signed indicating no confidential business information had been provided (Attachment 3). I then provided Mr. Fishel a Notice of Preliminary Findings (NOPF), which he signed to acknowledge receipt (Attachment 4). A diagram of the facility was obtained during the CEI and is in Attachment 5. An aerial photograph of the facility was downloaded after the CEI and is in Attachment 6. The 17 photographs taken during the CEI are included in Attachment 7. FINDINGS AND OBSERVATIONS 1. Facility Description and General Information Nordstrom is dedicated to the warehousing and distribution of consumer products such as clothing, housewares, electronics, and health and beauty products. No raw materials are used at the facility and no manufacturing is performed. Nordstrom receives and warehouses packaged consumer products from various manufacturing facilities and ships products to stores. The facility's primary North American Industrial Classification System (NAICS) code is 493110 (General Warehousing and Storage). Waste is generated when products are returned from the stores, expire in the warehouse, or become damaged during the warehousing or distribution process. Damaged or expired products are brought to the Return Area. The manufacturer is contacted about disposition of the returned/damaged/expired product. There are three disposition options--return to the manufacturer, ship to a last chance store (to be sold at a discount), or destroy in field (DIF). If the returned/damaged/expired product is a DIF waste, a hazardous waste determination is made. If the DIF waste is deemed hazardous waste (for example, waste flammable liquids or waste aerosol cans), it is removed from packaging and containerized in a hazardous waste accumulation container until shipment. Nonhazardous DIF waste is also removed from 3 packaging and containerized. If the DIF waste contains a battery, the battery is removed and containerized in a universal waste accumulation container. All product packaging is segregated for general trash disposal (compostable, non-compostable, recycled paper, cardboard, or recycled plastic). All DIF wastes (hazardous and nonhazardous) are shipped to Heritage Environmental Services in Indianapolis, Indiana. Facility and equipment maintenance generates used oil, waste aerosol cans, used batteries (alkaline, nickel cadmium, lithium, and lead acid), waste lamps, and scrap metal. Used oil is managed according to provisions of Title 40 Code of Federal Regulations (40 CFR) Part 279 and is shipped to Heritage Environmental Services in Indianapolis, Indiana for recycling. Waste aerosol cans are managed as hazardous waste and accumulated in a hazardous waste accumulation container. Waste aerosol cans are shipped to Heritage Environmental Services in Indianapolis, Indiana, for bulking and offsite transfer. Used nickel cadmium, lithium, and lead acid batteries are managed as universal waste according to provisions of 40 CFR Part 273. Used alkaline batteries are managed as nonhazardous waste. All used batteries are shipped to Heritage Environmental Services in Indianapolis, Indiana, for recycling. Waste lamps are also managed as universal waste according to provisions of 40 CFR Part 273, and are shipped to Heritage Environmental Services in Indianapolis, Indiana for recycling. Scrap metal is considered to be excluded from the definition of solid waste when recycled, and is transported to Alter Metal Recycling in Cedar Rapids, Iowa, for recycling. According to Ms. Fishel, Nordstrom has been operating at its current location since 1997. Nordstrom employs approximately 1,500 full-time personnel. The facility operates 24 hours per day, 7 days per week, and personnel work multiple shifts on a Monday through Sunday rotating schedule. The facility consists of approximately 980,000 square feet under one roof, and is divided into six main areas (Warehouse, Order Fill, Shipping/Receiving, Return Area, Maintenance, and Office). Prior to this inspection, Nordstrom had not been inspected for RCRA compliance by the EPA. 2. RCRA Status Nordstrom was identified as a large quantity generator (LQG) of hazardous waste (generating more than 1,000 kilograms [kg] or 2,200 pounds of hazardous waste per month) on the Verification Report provided by EPA (Attachment 1). During the CEI, I determined Nordstrom's generator status through a review of current operations, interviews with Mr. Fishel and Mses. Cavros and Bentley, and a review of waste shipping/tracking records (hazardous waste manifest) and Nordstrom hazardous waste calculations. During the entry briefing, Mr. Fishel stated that Nordstrom's primary hazardous wastes are waste aerosol cans (D001 characteristic hazardous waste), and waste flammable liquids (D001, characteristic hazardous waste). He explained that waste aerosol cans are generated fairly consistently throughout the year; however, waste flammable liquids (perfume) is generated in batches when product expires. 4 During the CEI, I reviewed the uniform hazardous waste manifests generated from October 13, 2020, through October 10, 2023. I noted that the facility generated one to four uniform hazardous waste manifests per month from October 13, 2020, through October 10, 2023. Manifest records do not identify which calendar month each waste was generated. However, with the frequency of shipments, it appeared that the manifest totals would be sufficient basis for calculation of the facility's hazardous waste generation rate. Based on the manifests, the facility generated more than 2,200 pounds of hazardous waste during three months in 2023 (February, March, and July), four months in 2022 (January, March, May, and June), and six months in 2021 (January, March, May, June, November, and December). According to Mr. Fishel and Ms. Bentley, the majority of the weight associated with waste flammable liquids listed on the manifests is the container (both glass and plastic). Per EPA Publication Number 530-SW-83-001K (RCRA Online Number 12151), the weight of the container is not counted when determining generator status or for biennial reporting (Attachment 8). I explained this to Mr. Fishel and Ms. Bentley during the CEI. Ms. Bentley calculated the weights of waste flammable liquids containers to reflect the weight of the waste product only. She showed me her notes on how she recalculated the weights during the CEI, and emailed her calculation notes to me on October 20, 2023 (Attachments 9 and 10). Ms. Bentley performed the following steps to estimate the weight of waste flammable liquids shipped on each manifest, to exclude the weight of the containers. This recalculation was performed only for waste flammable liquids, listed on the manifests as RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128. 1. A plastic collection bin, used to collect the waste flammable liquids, was filled with an assortment of perfumes and other beauty products in glass and plastic containers. 2. The full collection bin was weighed and determined to weigh 50.6 pounds (lbs). 3. Each item in the collection bin was removed and the volume was recorded in fluid ounces (fl oz). The bin held 215 fl oz of product. 4. The total of 215 fl oz was divided by 128 fl oz/gallon to obtain a total bin volume of 1.6797 gallons per bin. This was rounded up to 2 gallons per bin. 5. The total of 2 gallons per collection bin times 8.34 pounds per gallon (weight of water) equals 16.68 pounds of waste flammable liquids per collection bin. 6. The calculated weight of 16.68 pounds per collection bin was multiplied by 2 to account for variables. The tables below show waste flammable liquids weight recalculations for the three months in 2023. Nordstrom appeared to exceed 2,200 pounds of hazardous waste per month based on the weights listed on the uniform hazardous waste manifests. 5 February 6, 2023 Manifest # Not Obtained RQ, UN1950, Waste Aerosols, Flammable, N.O.S., 2.1, (Paint, Lubricant), (D001), ERG# 126 February 6, 2023 Manifest # Not Obtained RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128 February 20, Manifest # Not Obtained 2023 RQ, UN1950, Waste Aerosols, Flammable, N.O.S., 2.1, (Paint, Lubricant), (D001), ERG# 126 February 20, Manifest # Not Obtained 2023 RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128 Total Manifested Weight - February 2023 February 2023 Manifest Calculations Weight 308 No Calculations pounds Manifest Weight 1,250 pounds Manifest Weight 60 pounds Manifest Weight 1,080 pounds 2,698 pounds Calculations 1,250-lbs 50.6=lbs/bin = 24.7 bins 24.7 bins x 16.68 lbs = 412 lbs 412 lbs x 2 (variables factor) Calculations No Calculations Calculations 1,080-lbs 50.6=lbs/bin = 21.3 bins 21.3 bins x 16.68 lbs = 356 lbs 356 lbs x 2 (variables factor) Total Calculated Weight - February 2023 Calculated Weight 308 pounds Calculated Weight 824 pounds Calculated Weight 60 pounds Calculated Weight 712 pounds 1,904 pounds March 07, 2023 Manifest # 014988754FLE RQ, UN1950, Waste Aerosols, Flammable, N.O.S., 2.1, (Paint, Lubricant), (D001), ERG# 126 March 07, 2023 Manifest # 014988755FLE RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128 March 21, 2023 Manifest # 014988756FLE RQ, UN1950, Waste Aerosols, Flammable, N.O.S., 2.1, (Paint, Lubricant), (D001), ERG# 126 March 21, 2023 Manifest # 014988757FLE RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128 Total Manifested Weight - March 2023 March 2023 Manifest Calculations Weight 60 No Calculations pounds Manifest Weight 975 pounds Manifest Weight 125 pounds Manifest Weight 1,550 pounds 2,710 pounds Calculations 975-lbs 50.6=lbs/bin = 19.3 bins 19.3 bins x 16.68 lbs = 322 lbs 322 lbs x 2 (variables factor) Calculations No Calculations Calculations 1550-lbs 50.6=lbs/bin = 30.6 bins 30.6 bins x 16.68 lbs = 510 lbs 510 lbs x 2 (variables factor) Total Calculated Weight - March 2023 Calculated Weight 60 pounds Calculated Weight 644 pounds Calculated Weight 125 pounds Calculated Weight 1,020 pounds 1,849 pounds 6 July 3, 2023 Manifest # 009642018FLE RQ, UN1950, Waste Aerosols, Flammable, N.O.S., 2.1, (Paint, Lubricant), (D001), ERG# 126 RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128 July 18, 2023 Manifest # 009642077FLE RQ, UN1950, Waste Aerosols, Flammable, N.O.S., 2.1, (Paint, Lubricant), (D001), ERG# 126 RQ, UN1993, Waste Flammable Liquids, N.O.S., 3, PGII, (Perfume, Acetone), (D001), ERG# 128 Total Manifested Weight - July 2023 July 2023 Manifest Calculations Weight 120 No Calculations pounds 1,350 pounds Manifest Weight 100 pounds 1350-lbs 50.6=lbs/bin = 26.7 bins 26.7 bins x 16.68 lbs = 445.4 lbs 445.4 lbs x 2 (variables factor) Calculations No Calculations 1,250 pounds 2,820 pounds 1250-lbs 50.6=lbs/bin = 24.7 bins 24.7 bins x 16.68 lbs = 412 lbs 412 lbs x 2 (variables factor) Total Calculated Weight - July 2023 Calculated Weight 120 pounds 891 pounds Calculated Weight 100 pounds 824 pounds 1,935 pounds As shown in the tables above, Nordstrom appeared not to exceed the 2,200-pound LQG threshold limit when container weights were removed from the total weight listed on the manifest. As such, it appeared that Nordstrom operated as a small quantity generator (SQG) of hazardous waste in 2023 (generating between 220 and 2,200 pounds of hazardous waste per calendar month). I used the same approach to recalculate the hazardous waste generation rate, by calendar month, based on the manifests reviewed for October 13, 2020, through October 10, 2023. The table below shows the hazardous waste shipped by month. Month/Year October 2020 November 2020 December 2020 January 2021 February 2021 March 2021 April 2021 May 2021 June 2021 July 2021 August 2021 September 2021 Calculated Weight Shipped 662 pounds 1,560 pounds 622 pounds 1,798 pounds 1,123 pounds 2,835 pounds 1,124 pounds 1,980 pounds 1,722 pounds 867 pounds 635 pounds 950 pounds Month/Year October 2021 November 2021 December 2021 January 2022 February 2022 March 2022 April 2022 May 2022 June 2022 July 2022 August 2022 September 2022 Calculated Weight Shipped 1,142 pounds 1,712 pounds 2,762 pounds 1,792 pounds 963 pounds 1,839 pounds 1,094 pounds 1,543 pounds 1,972 pounds 1,468 pounds 1,173 pounds 962 pounds Month/Year October 2022 November 2022 December 2022 January 2023 February 2023 March 2023 April 2023 May 2023 June 2023 July 2023 August 2023 September 2023 Calculated Weight Shipped 1,334 pounds 1,446 pounds 959 pounds 391 pounds 1,904 pounds 1,850 pounds 606 pounds 1,194 pounds 684 pounds 1,934 pounds 1,078 pounds 524 pounds Based on the recalculated weights above, Nordstrom shipped over 2,200 pounds of hazardous waste in two calendar months in 2021 (March and December). However, Nordstrom has operated as a SQG of hazardous waste since January 2022. Therefore, I determined Nordstrom is currently operating as a SQG of hazardous waste and inspected the facility as such. I also reviewed the manifests from October 13, 2020, through October 10, 2023 for universal waste shipments and used oil shipments. Based on these 2023 manifests, I determined that Nordstrom generates up to approximately 67 pounds of universal waste lamps and 117 pounds of 7 universal waste batteries per year. Based on the universal waste generation rates and onsite accumulation observed during the CEI, I inspected Nordstrom as a small quantity handler (SQH) of universal waste (accumulating less than 5,000 kg of universal waste at any time). Nordstrom also operates as a generator of used oil. 3. Waste Streams This section of the CEI report describes waste streams generated by the facility, including the facility's waste determination and waste codes, generation process and rate, management at the facility, and ultimate disposition. The following discussion of waste streams is based on my interviews with Mr. Fishel and Mses. Cavros and Bentley, the visual inspection, and my review of available documentation. During the CEI, I obtained a copy of the waste determination form for waste aerosol cans (Attachment 11). Following the CEI, Mr. Fishel e-mailed a copy of the waste determination form for waste flammable liquids (Attachments 12 and 13). However, following the CEI, I noted "Business Confidential" was printed at the bottom of the waste determination documentation. I contacted the facility and asked if Nordstrom considered the documents CBI. Ms. Bentley replied, by email, that Nordstrom did not consider the documents CBI and that I could cross out the Business Confidential note on the documents. A copy of Ms. Bentley's email is in Attachment 14. Waste aerosol cans are generated when product is damaged, expired, returned, or during facility maintenance. The waste is accumulated in hazardous waste accumulation containers (HWACs) in the Return Area CAA and the North CAA. The facility considers waste aerosol cans hazardous waste (D001 and other waste codes if applicable) based on product/process knowledge. A copy of the waste determination form for waste aerosol cans is included as Attachment 11. Based on this form, the waste determination for waste flammable liquids appears to be adequate. Based on the 2023 manifests, the facility generates approximately 20 pounds to 308 pounds of waste aerosol cans per month. The waste is transported to Heritage in Indianapolis, Indiana, for bulking and offsite transfer. The waste was last collected on October 10, 2023. During the CEI, I observed a HWAC of waste aerosol cans in the North CAA (Attachment 7, Photograph 10). The HWAC was closed, in good condition, labeled with the words "hazardous waste," labeled with an indication of the nature of the hazard, labeled with an September 14, 2023, accumulation start date, and held approximately 15 gallons of waste aerosol cans. I noted no deficiencies with management of waste aerosol cans during the CEI. I did provide compliance assistance to Mr. Fishel and Ms. Bentley regarding optional management of waste aerosol cans as universal waste. Waste flammable liquids are generated when product is damaged, expired, or returned. The waste is accumulated in hazardous waste accumulation containers (HWACs) in the Return Area CAA and the North CAA. The facility considers waste flammable liquids hazardous waste (D001 and other waste codes if applicable) based on product/process knowledge. A copy of the 8 waste determination form for waste flammable liquids is in Attachment 13. Based on this form, the waste determination for waste flammable liquids appears to be adequate. Based on the 2023 uniform hazardous waste manifests, the facility generates approximately 356 pounds to 1,665 pounds of waste flammable liquids per month. The waste is transported to Heritage in Indianapolis, Indiana, for bulking and offsite transfer. The waste was last collected on October 10, 2023. During the CEI, I observed a HWAC of waste flammable liquids in the Return Area CAA and North CAA. Both HWACs were closed, in good condition, labeled with the words "hazardous waste," labeled with an indication of the nature of the hazard, and labeled with accumulation start dates. The Return Area HWAC held five waste flammable liquid items and was dated October 10, 2023 (Attachment 7, Photographs 1 and 2). The North CAA HWAC held five waste flammable liquid items and was dated April 27, 2023 (Attachment 7, Photograph 14). I noted no deficiencies with management of waste flammable liquids. Used batteries are generated when nickel cadmium, lithium, and lead acid batteries are removed from damaged, expired, or returned products, or during facility maintenance. They are collected in universal waste battery accumulation containers (UWBACs) in the Return Area CAA and the North CAA. Used batteries are managed as universal waste according to provisions of 40 CFR Part 273. Based on the 2023 universal waste manifests, the facility generates approximately 117 pounds of universal waste batteries per year. The waste is transported to Heritage in Indianapolis, Indiana, for recycling. The last shipment of universal waste batteries was on August 22, 2023 (Attachment 15). During the CEI, I observed a one UWBAC in the Return Area CAA (Attachment 7, Photograph 1). The UWBAC was labeled with the words "universal waste batteries," an October 10, 2023, accumulation start date, and held approximately 14 used lithium batteries (Attachment 7, Photographs 3 and 4). During the CEI, I observed a UWBAC of used lead acid batteries in the North CAA. The UWBAC was labeled with the words "universal waste-batteries," a March 31, 2023, accumulation start date, and held three used lead acid batteries (Attachment 7, Photograph 11). I also observed a UWBAC of used lithium batteries in the North CAA. The UWBAC was labeled with the words "universal waste batteries," an August 22, 2023, accumulation start date, and held approximately 25 used lithium batteries (Attachment 7, Photograph 12). I noted no deficiencies with management of used batteries. Waste lamps are generated during facility maintenance. They are transferred to universal waste lamp accumulation containers upon generation in the North CAA. The facility manages waste lamps as universal waste according to provisions of 40 CFR Part 273. Based on the 2023 universal waste manifests, the facility generates approximately 67 pounds of universal waste lamps per year. The waste is transported to Heritage in Indianapolis, Indiana for, for recycling. The last shipment of universal waste lamps was on January 10, 2023 (Attachment 16). 9 During the CEI, I observed two universal waste lamp accumulation containers in the North CAA. The containers were closed, labeled with words "universal waste lamps," and marked with accumulation start dates. One container held four waste fluorescent lamps and was dated March 10, 2023 (Attachment 7, Photograph 15). The other container held three universal waste lamps and 13 nonhazardous used light-emitting diode (LED) lamps and was dated April 1, 2023 (Attachment 7, Photograph 16). I noted no deficiencies with management of waste lamps during the CEI. Waste alkaline batteries are generated when alkaline batteries are removed from damaged, expired, or returned products, or during facility maintenance. They are collected in containers in the Return Area CAA and the North CAA. The facility considers waste alkaline batteries nonhazardous based on product/process knowledge. Based on 2023 manifests, the facility generates approximately 154 pounds of nonhazardous waste alkaline batteries per year. The waste is transported to Heritage in Indianapolis, Indiana, for recycling. The last shipment of nonhazardous waste alkaline batteries was on August 22, 2023 (Attachment 15). During the CEI, I observed containers of waste alkaline batteries in the Return Area CAA and the North CAA (Attachment 7, Photographs 1 and 13). I noted no deficiencies with management of waste alkaline batteries. Used oil is generated during facility equipment maintenance. Used oil is collected and transferred to a 55-gallon used oil storage container in the maintenance area. Used oil is managed according to provisions of 40 CFR Part 279. The facility generates approximately 55 gallons of used oil every 18 to 24 months. Used oil is transported to Heritage in Indianapolis, Indiana, for recycling. Used oil was last collected on August 24, 2021 (Attachment 17). During the CEI, I observed a 55-gallon used oil storage container located in the maintenance area (Attachment 7, Photograph 8). The used oil storage container appeared to be in good condition with no apparent leaks, held approximately 45 gallons of used oil, and was labeled with the words "used oil" (Attachment 7, Photograph 9). I noted no deficiencies with management of used oil. Nonhazardous DIFs are generated when product is damaged, expired, or returned. The waste is accumulated in containers in the Return Area CAA and North CAA. The facility considers nonhazardous DIFs to be nonhazardous based on product/process knowledge. The facility generates approximately 4,584 pounds of nonhazardous DIFs per month. The waste is transported to Heritage in Indianapolis, Indiana, for incineration. The waste was last transported on October 10, 2023. A copy of the last manifest was not obtained during the CEI. During the CEI, I observed two 10-gallon containers of nonhazardous DIFs in the Return Area CAA. I also observed one 10-gallon container of nonhazardous DIFs in the North CAA. I did not photograph the containers of nonhazardous DIFs during the CEI. I noted no deficiencies with management of DIFs. Scrap Metal is generated during facility maintenance. It is accumulated in scrap metal containers and transferred to a 20-cubic-yard roll-off container. Scrap metal is considered to be excluded from the definition of solid waste when recycled. The facility generates approximately 10 20 cubic yards of scrap metal per month. Scrap metal is transported Alter Metal Recycling in Cedar Rapids, Iowa, for recycling. During the CEI, I observed a 20-cubic-yard scrap metal container on the north side of the facility (Attachment 7, Photograph 17). I noted no deficiencies with management of scrap metal. Waste plastic consists of product packaging material generated when product is damaged, expired, or returned. The waste is accumulated and transferred to a compactor in the Dock Area. The facility considers waste plastic to be nonhazardous based on product/process knowledge. The facility generates approximately 4 cubic yards of waste plastic per week. The waste is transported to Cedar Rapids/Linn County Solid Waste Agency (Cedar Rapids, Iowa, or Marion, Iowa) for recycling. I observed a container of compacted waste plastic during the CEI on the south side of the facility (Attachment 7, Photograph 7). I noted no deficiencies with management of waste plastic during the CEI. Waste cardboard consists of product packaging material generated when product is damaged, expired, or returned. The waste is accumulated and transferred to a baler in the Dock Area. The facility considers waste cardboard to be nonhazardous based on product/process knowledge. The facility generates approximately 60 bales of waste cardboard per week. The waste is transported to International Paper in Cedar Rapids, Iowa, for recycling. I noted no deficiencies with management of waste cardboard during the CEI. General trash is generated when product is damaged, expired, or returned, and facility maintenance. It is accumulated in various containers throughout the facility and transferred to one of two trash compactors or a 30-cubic-yard container on the south side of the facility. General trash is considered nonhazardous based on product/process knowledge. The facility generates approximately 60 cubic yards of general trash per week. General trash is transported to Cedar Rapids/Linn County Solid Waste Agency (Marion, Iowa or Cedar Rapids, Iowa) for recycling and/or landfill disposal. I observed a 30-cubic-yard container and two containers of compacted trash on the south side of the facility during the CEI (Attachment 7, Photographs 5 and 6). According to Ms. Bentley, general trash is separated by compostable and non-compostable and compacted separately. I noted no deficiencies with management of general trash. 4. Container Accumulation Areas Nordstrom maintains two CAAs located in the Return Area and north side of the facility (Attachment 5, Numbers 1 and 2). I asked Ms. Cavros if the CAAs are inspected. Ms. Cavros stated that she inspects the CAA in the Return Area weekly and documents the inspection on a Hazardous Waste Accumulation Area Weekly Inspection Checklist. I reviewed the inspection logs from October 11, 2020, through October 5, 2023. I noted that 84 weekly inspections were not performed over the 156 week time span. I asked Ms. Cavros if the missing weekly Return Area CAA inspections had been conducted, but not 11 documented. Ms. Cavros stated the inspections of the Return Area CAA had been performed, but not documented. Specifically, I noted four missed inspections from October 11, 2020, to December 31, 2020; 27 missed inspections in 2021, 34 missed inspections in 2022, and 19 missed inspections to date in 2023. A copy of the inspection log for 2022 and 2023 is included in Attachment 18. I asked Mr. Fishel and Mses. Cavros and Bentley if weekly inspections are performed in the North CAA. Ms. Cavros stated that she did not perform weekly inspections of the North CAA. I determined that Nordstrom failed to perform weekly inspections of the CAAs, as required by 40 CFR 262.16(b)(2)(iv) (NOPF No. 1). I explained this preliminary finding to Mr. Fishel, and Mses. Cavros and Bentley, during the CEI. I asked Ms. Cavros how she would contact assistance in the event of an emergency. Ms. Cavros stated that she has a company-supplied cell phone to summon emergency assistance. During the visual inspection of the CAAs, I observed first aid kits, fire extinguishers, spill kits, and fire alarm pull stations near the CAAs. I did not photograph these items during the CEI. I noted no additional RCRA concerns in the CAAs. 5. Preparedness and Prevention Prior to the CEI, Nordstrom operated as a LQG of hazardous waste, and maintained a RCRA Contingency Plan and a RCRA Quick Reference Guide. Copies of the RCRA Contingency Plan and RCRA Quick Reference Guide are included as Attachments 19 and 20. I noted in Attachments 18 and 19 that Mr. Andrew Rizzo is listed as the Emergency Coordinator (EC) and Mr. Lucas Baethke is listed as the Alternate EC. I asked Mr. Fishel if Messrs. Rizzo and Baethke are still the ECs. Mr. Fishel stated that Messrs. Rizzo and Baethke no longer at this Nordstrom facility. I asked Mr. Fishel who the current EC is at Nordstrom. Mr. Fishel stated he was unsure who assumed the EC position, but thought it would be Mr. Patton. Based on the documentation in Attachments 19 and 20, it appears that Nordstrom failed to designate an EC, as required by 40 CFR 262.16(b)(9)(i) (NOPF No. 3). Per40CFR262.16(b)(9)(ii), a SQG must post by the telephone the name of and contact information regarding the EC; the phone number of the fire department; and locations of fire extinguishers, spill response equipment, and, if present, fire alarms ("emergency response equipment"). I did not observe SQG-required information posted by a telephone during the CEI. I asked Mr. Fishel if this information is posted by a telephone. Mr. Fishel stated that this information is not posted by a telephone. It appears that the facility was following the LQG contingency plan requirements instead of SQG posting requirements. However, I determined that Nordstrom failed to post the required information by a telephone, as required by 40CFR262.16(b)(9)(ii) (NOPF No. 2). I explained these preliminary findings to Mr. Fishel and Ms. Bentley during the CEI. 12 Per 40 CFR 262.16(b)(8)(vi), a SQG must make arrangements with local emergency response agencies and familiarize responders with the facility layout. Mr. Fishel stated that while operating as a LQG, the RCRA Contingency Plan had been delivered to the local emergency agencies (for example, police and fire departments, hospitals, Linn County Emergency Management). I did not identify additional deficiencies related to Preparedness and Prevention. 6. Manifests, Bills of Lading, Biennial Report The facility generated 93 uniform hazardous waste manifests from October 13, 2020, through October 10, 2023. I reviewed a total of 93 uniform hazardous manifests and associated land disposal restriction (LDR) notifications during the CEI. A copy of the last Designated Facility to Generator (signed) manifest, 009642088 FLE, dated August 22, 2023, is included in Attachment 21 as an example. LDR notifications for the two primary hazardous wastes (waste flammable liquids and waste aerosol cans) are included in Attachment 22 as examples. During the pre-CEI file review, I reviewed Nordstrom's 2021 Biennial Report, dated February 9, 2022, and noted no concerns. I did not identify any deficiencies related to manifests, bills of lading, or biennial reports. 7. Personnel Training Requirements Per 40 CFR 262.16(b)(9)(iii), a SQG must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies. According to Ms. Bentley, all employees who manage hazardous waste receive training annually that includes the RCRA Contingency Plan. I reviewed the training materials utilized and noted the materials included procedures for responding to emergencies at the facility. I did not identify any deficiencies related to employee training. 8. Summary of Preliminary Findings In summary, as part of the CEI, I made the following preliminary findings: 1) Failure to conduct weekly inspections of hazardous waste CAAs, as required by 40 CFR 262.16(b)(2)(iv) (NOPF No. 1) 2) Failure to post emergency coordinators name and phone number, fire departments phone number, and location of fire extinguishers and spill control equipment near the phone, as required by 40 CFR 262.15(b)(9)(ii) (NOPF No. 2) 3) Failure to designate an emergency coordinator, as required by 40 CFR 262.16(b)(9)(i) (NOPF No. 3) Other than items specifically noted in the narrative, I observed no additional issues. However, further review by EPA may change or add to my findings. 13 William F Digitally signed by William F Starks _S__ta_r_k_s________18_:5_7:_41_-0_6_'00_' ________________________ Date: _______________ Date: 2023.11.13 William F. Starks Environmental Consultant CLAENE Group, LLC. Whisnant, Digitally signed by Whisnant, Amber Date: 2023.12.18 _A_m__b_e_r________18_:3_2:1_7_-0_6'_00_' ________________________ Date: ___________________ Amber Whisnant Section Chief ECAD/CB/RCRA, EPA Region 7 Attachments: 1. Notification Acknowledgement/Verification Report (2 Pages) 2. Receipt for Documents and Samples (1 Page) 3. Confidentiality Notice (1 Page) 4. Notice of Preliminary Findings (1 Page) 5. Facility Diagram (1 Page) 6. Google Maps Aerial Image of the Facility (1 Page) 7. Photographic Documentation (17 Photos and Photolog) (11 Pages) 8. RCRA Online Number 12151, Document Date, 1983-11-01 (2 Pages) 9. E-mail From Sheillah Bentley RE: Nordstrom #808 - EPA ID# IAR000523548 Inspection Date 10/12/2023: Calculations Requested for EPA Inspection, Dated October 30, 2023 (1 Page) 10. Hazardous Waste Weight Calculations and Process (5 Pages) 11. Waste Aerosol Can Wastestream Survey (7 Pages) 12. E-mail From Myles Fishel RE: Request Waste Stream Survey from Heritage for Aerosols and Perfumes, Dated October 12, 2023 (1 Page) 13. Waste Flammable Liquids Wastestream Survey (8 Pages) 14. E-mail From Sheillah Bentley RE: Confidential Business Information (CBI), Dated October 31, 2023 (2 Pages) 15. Universal Waste Battery Manifest, Dated August 22, 2023 (1 Page) 16. Universal Waste Lamp Manifest, Dated January 10, 2023 (1 Page) 17. Used Oil Manifest, Dated August 24, 2021 (1 Page) 18. CAA Weekly Inspection Log, Dated January 7, 2022, Through October 10, 2023 (39 Pages) 19. RCRA Contingency Plan, Dated May 23, 2018 (13 Pages) 20. RCRA Contingency Plan Quick Reference Guide (6 Pages) 21. Hazardous Waste Manifest 009642088 FLE, Dated August 22, 2023 (1 Page) 22. LDR Notification Forms for Waste Flammable Liquids, and Waste Aerosol Cans (2 Pages) 14