Document z4j4mgejRXmXZwmD93MDN1n

RCRA Inspection Report 1) Inspector and Author of Report Alan Newman Environmental Engineer Phone: 404-562-8589 newman.alan@epa.gov 2) Facility Information U.S. Environmental Protection Agency, Region 4 Enforcement and Compliance Assurance Division Chemical Safety and Land Enforcement Branch RCRA Enforcement Section 61 Forsyth Street, S.W. Atlanta, Georgia 30303 Rohm & Haas Chemicals LLC (RHC) 730 Dale Avenue Knoxville, Tennessee 37921 Knox County 3) Responsible Officials EPA ID#: TND058660390 NAICS #: 325211 - manufacturing of resins, plastics materials, a non-vulcanizable thermoplastic elastomers and mixing and blending resins on a custom basis and or manufacturing non-customized synthetic resins. Christopher Golden, EHS Leader cngolden@dow.com (865) 521 - 8479 4) Inspection Participants Stacy Bryson, RHC Christopher Golden, RHC Laura Johns, RHC Benny Fuller, RHC 5) Date of Inspection Jennifer McClellan, Tennessee Department of Environment and Conservation (TDEC) Central Office G. M. Webster, TDEC - Knoxville Field Office Alan Newman, USEPA September 12, 2023; 8:35 am - 4:30 pm. 6) Applicable Regulations1 Resource Conservation and Recovery Act (RCRA) Sections 3002 (42 U.S. Code - Annotated U.S.C.A. 6925 and 6927), and 40 Code of Federal Regulation (C.F.R.) Parts 260 - 270, 273, 278, & 279; [State Code (see below)] and Hazardous Waste Permit TNHW-148. 1 As the State's authorized hazardous waste program operates in lieu of the federal RCRA program, the citations of those authorized provisions will be to the authorized State program. However, for ease of reference, the federal citations will follow in brackets. Tennessee Hazardous Waste Management Act of 1977, Tennessee Code Annotated (Tenn. Code Ann.) 68-212-101 et seq., and Chapter 0400-12-01 of the Rules and Regulations of the State of Tennessee (Tenn. Comp. R. & Regs.). Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.01(2)(a) [40 C.F.R. 262.10], a large quantity generator (LQG) is a generator who generates greater than or equal to 1,000 kilograms (2,200 lbs) of non-acute hazardous waste in a calendar month. Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.12(1)(i) [40 C.F.R. 273.9], a small quantity handler of universal waste (SQHUW) is a universal waste handler who accumulates less than 5,000 kilograms total of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(4)(e)5.(i) [40 C.F.R. 262.34(c)(1)], a generator may accumulate as much as 55 gallons of hazardous waste in containers at or near the point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or without having interim status, as required by Section 68-212-108 of the THWMA, Tenn. Code Ann. 68- 212-108 [Section 3005 of RCRA, 42 U.S.C. 6925], and without complying with Tenn. Comp. R. & Regs. 0400-12-01-.03(4)(e)2. [40 C.F.R. 262.34(a) (2016)], provided that the generator complies with the satellite accumulation area (SAA) conditions listed in Tenn. Comp. R. & Regs. 0400-12-01.03(4)(e)5.(i)(I)-(II) [40 C.F.R. 262.34(c)(l)(i)-(ii)) (hereinafter referred to as the "SAA Permit Exemption"). Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(4)(e)2. [40 C.F.R. 262.34(a) (2016)], a large quantity generator (LQG) may accumulate hazardous waste on-site for 90 days or less without a permit or without having interim status, as required by Section 68-212-108 of the THWMA, Tenn. Code Ann. 68-212-108 [Section 3005 of RCRA, 42 U.S.C. 6925], provided that the generator complies with the conditions listed in Tenn. Comp. R. & Regs. 0400-12-01.03(4)(e)2.(i)-(v) [40 C.F.R. 262.34(a)(1)-(4) (2016)] (hereinafter referred to as the "LQG Permit Exemption"). TDEC issued RCRA Permit Number: TNHW-174, in effect since September 26, 2018, and expires on September 26, 2028. 7) Purpose of Inspection The purpose of this inspection was to conduct an unannounced compliance evaluation inspection to determine Rohm and Haas's compliance with the conditions of its RCRA Hazardous Waste Facility Operating Permit (TNHW-174) the applicable requirements of RCRA and the corresponding Tennessee regulations. This was an EPA lead inspection. 8) Facility Description Rohm and Haas Chemical (RHC) is a subsidiary of Rohm and Haas Company which is in turn a wholly owned subsidiary of The Dow Chemical Company. RHC is a manufacturer of acrylic EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 2 of 12 polymers used as ingredients, by other manufacturers of consumer products (i.e., paints, laundry detergents, paper coatings, etc.) The facility started operations as a government owned entity in 1943 when it manufactured Plexiglas acrylic sheet used in the production of American military aircraft during the World War II. After the war, Rohm and Haas purchased the facility. The facility covers about 60 acres, and it is in a mixed use (industrial and residential) zone, west of downtown Knoxville. Including contractors, RHC has about 180 employees and operates 24 hours a day, seven days a week. The facility manufactures a product line of water-based acrylic emulsions and dispersants for the paint, textile, paper, and detergent markets. Hazardous, ignitable wastes are generated from raw material handling and quality control procedures and from some of the production processes. RHC has two production departments: the Emulsion Department and the Polymers Department. The Emulsion Department uses monomers, soap, water, and other ingredients while the Polymer Department (Polymers 300's unit) uses acrylic acid and other monomers. RHC most recently registered with the TDEC on March 1, 2022, as a Large Quantity Hazardous Waste Generator, a Small Quantity Handler of Universal Waste (batteries, lamps and mercury containing equipment), and a used oil generator. In addition, the facility has a TDEC issued RCRA permit (#TNHW-174) for a hazardous waste container storage pad and a hazardous waste storage tank. The permit was approved on September 26, 2018, and expires on September 26, 2028. According to permit TNHW-174: hazardous wastes associated with the handling of wet solvent in the `Polymers 300' unit, typically containing a mixture of polymer, water, and wet solvent (xylene, di isobutylene, and toluene), are piped directly from the point of generation into a 7900-gallon stainless steel upright tank (generally referred to as `Tank 660'), with walled secondary containment, overfill alarms, and emergency backup pumps. On August 23, 2021, the TDEC received notification that RHC intended closure of permitted storage Tank 660; closure was approved by the TDEC in correspondence dated August 25, 2022. A closure inspection was conducted by the TDEC on April 1, 2022, with the closure effective June 30, 2022. Hazardous waste formerly managed in the permitted tank are now managed in Tank 650 which currently operates as a central accumulation area (CAA) hazardous waste storage tank. In addition to the above-ground tank for hazardous waste storage, RHC also has a three-sided sheet-metal structure that contains both a CAA and a permitted storage area (HWSU-1) for hazardous waste containers. RHC has initiated in situ remediation for a groundwater plume for solid waste management units 16, 20G, 20H, and 20N. TDEC is managing the ongoing treatment and corrective action for this groundwater plume. EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 3 of 12 The waste generated at the facility include: Waste Waste Name Generation Process Stream Number 15 Laboratory Disposal of unused Waste laboratory chemicals 24 Wet Solvent Spent solvent from plant production process, maintenance and equipment clean out. 29 Burnable liquids Pumpable liquids from various plant operations. 45 Tamol solids Generated from the cleanout of process equipment and from the filtration of wet solvent. 46 Waste Drains from process and Acrylonitrile storage equipment. 49 Groundwater RCRA corrective action contaminated with chlorinated VOC's 50 Contaminated Left blank by the facility glass 56 Tamol crude Production process 63 Composited Cleanup of spilled absorbed monomers monomers 64 Maleic Cleanup of spilled maleic Anhydride anhydride or obsolete material. 75 Paint solvent Discard of paint sludge sludge & rags and rags 78 Lead paint chips Removal of paint coating & debris 82 Styrene & Disposal of unusable or Styrene Polymer polymerized raw material. Waste Codes D001, D002, F003, U121, U147 D001 D001, U009, U113, U118, U162 D001 D001, U009 D039, D040, D043, U210 D001, F005, U113, U162, U239 D001 U007, U008, U009, U113, U162, D001 D002, U147 D001 D008 D001 EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Amount generated in 2022 (lbs) 169 30 285 2,767 523 302 175 383,727 2,000 26 650 24 420 Page 4 of 12 86 Sodium Disposal of obsolete D001, D003 Hydrosulfite product or unusable material. 93 Monomer flush Cleaning of equipment for D001, U008, water maintenance U113, U162 94 Aerosol cans Disposal of empty or D001, D002, unused aerosol cans D003 97 Waste Aqueous Maintenance activities D002 Ammonia 30 4,600 106 38 98 CN-100 Cleaning Equipment cleaning D002 solution 105 Copper nitrate Disposal of absorbed or D001 obsolete raw material. 112 Caustic Laden Packed column scrubber D002 Filters filtration (air pollution control device). 118 WEDAC Cleaner Metal equipment D002 & Water cleaning. 119 Alcohol Hand Disposal of unused or D001 Sanitizer spilled material. 120 Nitric acid Spill during passivation of D002 contaminated equipment debris 19,795 173 165 708 1,155 212 9) Previous Inspection History TDEC has conducted two RCRA CEIs at the subject facility between 2021 and 2022 and found no violations during those inspections including the most recent inspection on December 13, 2022. 10) Opening Conference On September 14, 2023, EPA inspector Alan Newman, accompanied by TDEC inspectors Gerald Webster and Jennifer McClellan, arrived at Rohm and Haas at approximately 8:35 a.m. Stacy Bryson, Manufacturing EHS Leader, immediately received the inspectors. Stacy Bryson, and the inspectors were joined by Christopher Golden, EHS Leader, for the opening conference. The inspectors introduced themselves, showed their credentials to Christopher Golden, and explained the purpose of the visit. The inspectors provided a request for records. The EPA inspector explained that the Small Business Regulatory Enforcement Fairness Act's classification of a "small business" is generally set by the Small Business Administration using the business' SIC/NAICS code and annual receipts or number of employees. A copy of the EPA's information sheet for small businesses can be found at https://www.epa.gov/sites/production/files/2017- EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 5 of 12 06/documents/smallbusinessinfo.pdf. The EPA inspector also discussed the company's ability, pursuant to 40 C.F.R. 2.203, to assert a business confidentiality claim for information submitted to EPA. The company did not assert a business confidentiality claim. Christopher Golden provided an overview of the facility's history and current operations during the opening conference. The inspection participants also discussed health and safety protocols and required personal protective equipment before Facility representative led the inspectors on a tour of the Facility operations. 11) Inspection Observations Permitted Hazardous Waste Container Storage Area The inspection tour started at the permitted hazardous waste container storage area which is co-located with a CAA for containers. A three-sided shed with an asphalt base was bifurcated into a permitted section and a section designated as a CAA. Pursuant to Permit TNHW-174 Section 8.1-7, the container storage pad has a design capacity of 12,096 gallons. The permitted volume for storage at any one time is 9,900 gallons (the equivalent of 180 55-gallon containers). The container storage pad consists of a 25-foot by 52foot, curbed concrete pad, designed to contain any spills. The pad is bordered on the south side by a grate covered trench. The trench drains to a collection sump. All joints are sealed with a chemical-resistant sealer. The inspection team noted that the volume of waste present on the day of the inspection was for less than the permitted amount (Photos 1-3, 8). The hazardous waste in storage on the day of the inspection included: Container Size Waste (WS#) Accumulation Start Date and Photo Number One 55-gallon black metal Spent aerosol cans (WS94) 8/4/2023 - Photo 3 container One 55-gallon blue poly Diesel and Sand 7/19/2023 - Photo 3 container One 20-gallon container Contaminated Glass 8/24/2023 Two 5-gallon plastic One for Sharps and 8/24/2023 - Photo 3 containers one for Lab Pack Code B 9/1/2023- Photo 3 Each container was in good condition, closed, and labeled with the words "Hazardous Waste" and with the indication of the hazard. The oldest ASD was July 19, 2023. The inspection team noted pre-cursors to cracks developing in the floor of the area (Photo 8). The inspection team also noted that the sump underneath the grates were partially full of dirt and debris. The inspection team recommends that this sump area be cleaned out when buildup of debris is noted. These are areas of concern for the inspection team. Hazardous Waste Central Accumulations Area for Containers EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 6 of 12 RHC manages a CAA adjacent to with their permitted hazardous waste storage area (Photos 48). The area was identified with appropriate signage. The CAA is equipped with an internal communications or alarm system capable of providing immediate emergency instruction to facility personnel; it is equipped with a device capable of summoning emergency assistance from local police departments, fire departments, or state or local emergency response teams; it is equipped with portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment; and it is equipped with water to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray system. At the time of the inspection, there was one 5-gallon plastic pail labeled as non-hazardous waste, three 55-gallon metal containers labeled as WS94, WS75 and WS50 hazardous waste, respectively, six 55-gallon containers labeled as non-hazardous waste, one 50-pound bag labeled as non-hazardous waste, two 55-gallon containers of WS92, and two 55-gallon containers of used oil were stored in the 90-day area of the shed. Each container was in good condition, closed, and labeled as to the indication of hazards of its contents. The oldest ASD for these containers was August 25, 2023. One 55-gallon container of building steel debris was not labeled with an indication of the hazard (Photo 7). The inspection team noted one area where the floor of the CAA had been repaired. This area did not appear to have been resealed after the repair. RHC documented that the floor was re-sealed in this area and added newly painted lines to re-establish aisles. Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(h)1.(v)(I)II. [40 C.F.R. 262.17(a)(5)(i)(B)], which is a condition of the LQG Permit Exemption, a generator must mark or label its containers with the following: an indication of the hazards of the contents clearly visible for inspection on each container. CAA Tank 650 RHC operates one CAA 6,500-gallon hazardous waste tank for storage of process waste which is shipped out as waste flammable liquids (Xylene) D001 (Photos 9-17). The first waste managed in this tank was in November 2021. Hazardous waste is generated during the process and transferred to this tank via pipeline or container. This tank is housed in a secondary containment dike. This tank is subject to RCRA Subpart BB and CC regulations. Tank 650 has a vacuum/pressure relief valve (VPRV) which is the primary means of emission control. The tank is also connected to the site closed-vent system and thermal vapor incinerator. Ancillary equipment for Tank 650, which consist of 51 valves, 1 pump (inspected monthly), 1 spill stop, and 1 relief valve, are subject to subpart BB and inspected on a quarterly basis and recorded in a log. The CAA tank was labeled with the words "Hazardous Waste" and the indication of the hazard. The indication of the hazard label was damaged. Although still legible, the inspection team recommends that the label be replaced. Records show that the tank was last emptied on August 29, 2023, well within the last 90 days. The inspection team noted that the piping to the process was labeled with an incorrect tank number. Formerly these lines were used to transfer waste from the process to the permitted hazardous waste tank (Tank 660) that was closed in EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 7 of 12 2021. There was also a section of the transfer line that had been replaced but was not painted to match the remaining transfer line. The inspection team noted some debris inside the secondary containment of Tank 650. This is an area of concern for the inspection team, and it is recommended that the debris be removed on a regular basis or as accumulated. Facility Process Areas with Satellite Accumulation Areas, Used Oil, and Universal Wastes: RHC manages multiple SAAs and areas where other wastes are stored. These include: Area Container size and waste Comments (Photo #) accumulated Pumphouse Nine One 55-gallon metal (Photo 18) container of mixed monomers (WS 29) Process area near Tank 916 One 55-gallon metal This area was empty on the and 917 container for Cleanout of day of the inspection process equipment and from filtration of wet solvent (WS45) Maintenance shop 55-gallon metal container of (Photo 23) Aerosol Cans (WS94) QC Laboratory Five 5-gallon containers for The Code O container had a Code B, Code C, Code D, Code broken lid and was open K, Code O, and Sharpes (Photos 20-21) hazardous waste (WS15) One 20-gallon container for contaminated glass (WS50) Scrubber area One 55-gallon metal There was no waste in this container for spent caustic container on the day of the Filters (WS112) inspection (Photo 19) Used Oil Room Two 55-gallon containers of (Photo 22) Lower Paint Shop Used oil One 55-gallon container of SAA paint related material (WS75) Each container was closed, in good condition, and labeled with the words "Hazardous Waste" and with the indication of the hazard except as noted in the comments in the table. Each SAA area was equipped with emergency equipment including a fire extinguisher and spill equipment. Radios are used for communication throughout the facility. Pursuant to Tenn. Comp. R. & Regs. 0400-12-01-.03(1)(f)1.(iv) [40 C.F.R. 262.15(a)(4)], which is a condition of the SAA Permit Exemption, a generator is required to keep containers of hazardous waste closed at all times during accumulation, except when adding, removing, or consolidating waste; or when temporary venting of a container is necessary for the proper EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 8 of 12 operation of equipment, or to prevent dangerous situations, such as build-up of extreme pressure. Facility Area for Universal Waste Management: RHC manages universal waste (UW) lamps and batteries in the electrical shop (Photos 24-26). Type of Universal Waste Number, Size, and Type of Accumulation Start Date Container Used Ballast (not UW) Two 5-gallon plastic buckets 8/3/2023 with lid 8/11/2022 Small Lead Acid Batteries One 5-gallon plastic bucket 5/5/2023 with lid NiCad Nickel-Cadmium One 5-gallon plastic bucket 8/11/2022 Batteries with lid Small Lithium-ion One 5-gallon plastic bucket 5/5/2023 Batteries with lid Dry Cell - Alkaline Two 5-gallon plastic buckets 12/1/2023 Batteries with lid 8/3/2023 8-foot fluorescent lamps One fiber cylinder 12/1/2022 4-foot fluorescent lamps Two fiber cylinders 4/19/2023 7/7/2023 Misc UW Lamps One 30-gallon blue poly with 12/1/2022 lid Each of the containers of lamps and batteries was in good condition, closed, labeled as universal waste, and marked with an ASD. The ASD for the NiCad batteries was listed as August 11, 2022; however, shipping records indicated that this date had not been changed on the container when the most recent shipment was sent off site. The oldest date observed on any container of UW batteries was May 5, 2023, and on any container of UW lamps was December 1, 2022. 12) Records Review Contingency Plan and Quick Reference Guide (QRG): The actions that facility personnel should take in response to an emergency are described in the facility's Emergency Response Plan, which was last updated on May 24, 2023. The plan describes actions facility personnel must take in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water at the facility. The plan describes arrangements agreed to with the local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals or the Local Emergency Planning Committee. EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 9 of 12 The plan lists the names and emergency telephone numbers for persons identified as emergency coordinators. The emergency Response Leader is listed as the primary emergency coordinator, and the other individuals are listed in the order in which they will assume responsibility as alternates. The plan includes a list of all emergency equipment at the facility. The list includes fire extinguishing systems, spill control equipment, communications and alarm systems, and decontamination equipment. The list appears to be up to date. The plan includes the location and a physical description of each item on the list, and a brief outline of its capabilities. The plan includes an evacuation plan for personnel. This plan describes signal(s) to be used to begin evacuation, evacuation routes, and alternate evacuation routes. A copy of the Emergency Response Plan (and its quick reference guide) was most recently submitted to the police department, fire department, hospital, State and local emergency response teams and the Local Emergency Planning Committee on May 24, 2023. The quick reference guide includes the types/names of hazardous waste in layman's terms and the associated hazard associated with each hazardous waste present at any one time; the estimated maximum amount of each hazardous waste that may be present at any one time; the identification of any hazardous wastes where exposure would require unique or special treatment by medical or hospital staff; a map of the facility showing where hazardous wastes are generated, accumulated and treated and routes for accessing these wastes; a street map of the facility in relation to surrounding businesses, schools and residential areas; the locations of water supply; the identification of on-site notification systems; and the name of the emergency coordinator(s) and emergency telephone number(s). Training Records: The inspectors reviewed facility job descriptions and employee names that were provided for emergency response leader, immediate response leader, laboratory analyst, site guard, utilities operator, site nurse, other technical personal, and EH&S specialist. Each description included the requisite skill, education, or other qualifications, and duties of facility personnel assigned to that position. RHC provided a written description of the type and amount of both introductory and continuing training to be given to each person filling the positions listed above. The inspectors reviewed records of employee hazardous waste training completed in 2023. Waste Manifest and Land Disposal Restriction (LDR) Records: The inspectors reviewed available hazardous waste manifest records and land disposal restriction forms for shipments of hazardous waste sent since 2022. Hazardous waste manifest records show that D001 hazardous waste flammable liquids (Xylene) are routinely shipped to Safety-Kleen System, Inc. (KYD053348108), and the most recent shipment was made on August 31, 2023. There were no issues noted with manifest or LDR notification records on the day of the inspection. EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 10 of 12 Weekly Inspection Records: The inspectors reviewed RHC available records of inspections of the weekly hazardous waste CAA, the weekly permitted storage area, and the daily CAA hazardous waste Tank 650 since 2022. The inspection log includes a checklist to record observations about leaking containers and for deterioration of containers caused by corrosion or other factors. The records include the date and time of the inspection and the name, signature and initials of the employee conducting the inspection. Employees do routinely record inspection observations and subsequent follow-up actions on the inspection log. The inspection team also reviewed the hazardous waste minimization plan dated March 1, 2023, the closure cost estimate dated December 2022, the fire hydrant monthly inspection form, the emergency response trailer inspection log, the emergency radio inspection log, fire and evacuation alarm inspection log, sprinkler system, fire doors, eye wash/shower inspection log, perimeter inspection log, medical oxygen - escape pack inspection log, fire pump and supply tank inspection form, EHS atmospheric monitoring instrument calibration log, waste determination records, tank assessments, and organic air emission monitoring required by 264/265 Subparts AA, BB and CC. Rohm and Haas needs to examine if this facility will be subject to the pharmaceutical regulations that are found in Tennessee Rule 0400-12-01-.09(16) Hazardous Waste Pharmaceuticals. 13) Closing Conference The inspectors conducted the exit meeting at 4:00 pm with Christopher Golden, Laura Johns, and Stacy Bryson. During this meeting, the inspectors stated their preliminary conclusions of the inspection. RHC agreed to provide financial assurance documentation within one week. On September 14, 2023, Stacy Bryson provided the financial test records in an email to Alan Newman and Gerald Webster. The inspection team also requested an inventory of the permitted storage area, the CAA for containers, the 2022 annual waste report, corrections of laboratory SAA, picture of the cleaned-out dike area for Tank 650, verification that no free liquids are stored in the QC Laboratory SAA. All these items were sent either on September 15, 2023, or on October 26, 2023, to Alan Newman and Gerald Webster. 14) List of Attachments Attachment 1 - Photo Log: 26 Photos taken on: September 14, 2023 Photos taken by: Gerald Webster EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 11 of 12 15) Signed ALAN NEWMAN Alan Newman Environmental Engineer Digitally signed by ALAN NEWMAN Date: 2023.12.14 12:05:56 -05'00' 16) Concurrence Digitally signed by ARACELI ARACELI CHAVEZ CHAVEZ Date: 2023.12.14 12:09:01 -05'00' Araceli B. Chavez RCRA Enforcement Section EPA-RCRA CEI Report Rohm and Haas Chemicals LLC EPA ID# TND058660390 September 14, 2023 Page 12 of 12 Appendix 1 Photograph Log: 26 Photos taken September 14, 2023. Photos taken by Gerald Webster RCRA CEI Report - Appendix 1- Photograph Log Page 1 of 7 EPA ID No.: TND058660390 September 14, 2023 Photograph 1: Permitted Container Storage Area and CAA for containers. Photograph 4: Signage for CAA for containers. Photograph 2: Signage for Permitted Container Storage Area. Photograph 5: CAA for containers. Photograph 3: Permitted Container Storage Area . RCRA CEI Report - Appendix 1- Photograph Log Page 2 of 7 EPA ID No.: TND058660390 September 14, 2023 Photograph 6: CAA for containers. Photograph 7: CAA for containers. Photograph 8: Floor of Hazardous waste container CAA. Photograph 10: Former Hazardous waste permitted tank. Photograph 9: Hazardous waste tank CAA. RCRA CEI Report - Appendix 1- Photograph Log Page 3 of 7 EPA ID No.: TND058660390 September 14, 2023 Photograph 11: Hazardous waste tank CAA. Photograph 14: Hazardous waste tank CAA. Photograph 12: Hazardous waste tank CAA. Photograph 15: Hazardous waste tank CAA. Photograph 13: Hazardous waste tank CAA. Photograph 16: Hazardous waste tank CAA. RCRA CEI Report - Appendix 1- Photograph Log Page 4 of 7 EPA ID No.: TND058660390 September 14, 2023 Photograph 17: Hazardous waste tank CAA. Photograph 18: SAA Pumphouse 9. Photograph 19: SAA Scrubber Area. Photograph 20: SAA laboratory. RCRA CEI Report - Appendix 1- Photograph Log Page 5 of 7 EPA ID No.: TND058660390 September 14, 2023 Photograph 21: SAA laboratory. Photograph 23: SAA Maintenance Shop. Photograph 22: SAA Used Oil Room. Photograph 24: Universal Waste Storage in Electrical Shop. RCRA CEI Report - Appendix 1- Photograph Log Page 6 of 7 EPA ID No.: TND058660390 September 14, 2023 Photograph 25: UW Li-Ion battery storage bucket. Photograph 26: UW Li-Ion battery storage bucket. RCRA CEI Report - Appendix 1- Photograph Log Page 7 of 7 EPA ID No.: TND058660390 September 14, 2023