Document zzYbQ6E60g5xp2DNL7Bgp0rnm

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/22-25/2022 RCRA Compliance Evaluation Inspection RCRA Large Quantity Generator Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Starpak LTD. Starpak - Houston 9690 West Wingfoot Road Houston, TX 77041 9690 West Wingfoot Road Houston, TX 77041 Harris County (713)329-9183 Ignacio Aguirre laguirre@starpakltd.com Plant Engineer - Environmental Lead FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110017613377 N/A RCRAID: TXR000057513 326112 Plastics Packaging Film and Sheet (Including Laminated) Manufacturing 3081 Personnel participating in inspection: John Penland EPA Region 6 (ECDSR) Debra Pandak EPA Region 6 (ECDSR) Ignacio Aguirre Starpak LTD. Viktor Manjarrez Starpak LTD. Karla Horak Kassim Mohammed Alan Garcia Bill Garris Starpak LTD. Starpak LTD. Starpak LTD. Starpak LTD. Senior Environmental Scientist Senior Environmental Scientist Plant Engineer - Environmental Lead Project Manager - Assistant Plant Manager Environmental Engineer Pre-press Supervisor Safety Manager Independent Consultant EPA Lead Inspector Signature/Date Supervisor Signature/Date DEBRA PANDAK Digitally signed by DEBRA PANDAK DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=DEBRA PANDAK, 0.9.2342.19200300.100.1.1=68001003655850 Date: 2022.05.06 15:20:07 -05'00' John Penland - Senior Environmental Scientist Digitally signed by MARGARET OSBOURNE Date: 2022.05.06 15:35:49 -05'00' Jeff Yurk - Waste Section Chief Date Date 6ENFORM-019-R8.2 (02/12/2020) 1 Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection Section I - INTRODUCTION PURPOSE OF THE INSPECTION During the week of February 20, 2022, I, John Penland, conducted an unannounced inspection of the Starpak, LTD. facility (Starpak) located at 9690 West Wingfoot Road in Houston, Texas for compliance with the Resource Conservation and Recovery Act (RCRA). I was assisted on this inspection by Environmental Protection Agency (EPA) inspector Debra Pandak. The inspection included a walkthrough of the facility's waste generation and management units; a review of the facility records related to hazardous waste management; and a specific evaluation of the facility's compliance with the RCRA air pollution control requirements. The Starpak facility was targeted for inspection as part of an ongoing investigation into the facility's waste determination and counting procedures. That investigation was initiated by EPA Region 6 during 2019 and remains open. In addition, the solvent wastes generated by the facility have the potential to trigger the RCRA air pollution control requirements; therefore, this inspection is also being conducted as part of the National Compliance Initiative for air emissions from hazardous waste management units. We concluded the inspection of the Starpak facility on February 25, 2022, with a closing conference where we presented our provisional areas of concern. This report serves as documentation of all onsite activities and observations during the inspection of the Starpak Houston facility. Photographs taken during the inspection to document onsite observations are included as Appendix 1. A summary of all areas of concern identified during the inspection is provided in Section III. FACILITY DESCRIPTION The Starpak facility manufactures printed plastic packaging for use in a variety of consumer markets. Starpak blends individual ink formulations for its printed products using an 80%-20% mixture of n-propyl acetate and n-propyl alcohol as its solvent base. Ethyl Acetate is also used as needed to control for the ink's viscosity and drying time. The n-propyl acetate/n-propyl alcohol mixture is also used as a cleaning agent. Starpak has an extensive solvent recovery system throughout the plant, consisting of pumps, piping, a thermal distillation unit, and associated tanks. A general map of the plant is included in Appendix 2. The Starpak Houston facility was issued the EPA ID# TXR000057513. Prior to the date of this inspection and since at least November 12, 2019, Starpak has been operating as a handler of universal waste. The facility operates under the Clean Air Act as a Minor Source of criteria pollutants with New Source Review Permit #108176 governing the operation of its thermal oxidizers and fugitive emissions from the building. 2 Section II - OBSERVATIONS Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection We conducted the onsite inspection during normal business hours from February 22 to-25, 2022. During the inspection, the facility was conducting normal operations and all areas of the facility were in use. Throughout the week we visited each of the facility's waste generation, accumulation, and management areas. We also reviewed the facility's operating records pertaining to the facility's RCRA applicability and compliance requirements. This section provides an abbreviated description of our daily activities. For details Appendix 3 contains the daily summaries provided to facility representatives. These summaries provide information on our observations each day, what was discussed at the end of each day with the facility representatives and any requests for documentation. Unless otherwise specified, the statements cited in this section, or in the daily summaries, reflect those claims made by facility personnel or documents reviewed during the inspection. February 22, 2022 Debra Pandak and I entered the facility at 0950 where we presented our credentials to Mr. Ignacio Aguirre and informed him that we were there to conduct an inspection of the facility under Section 3007 of the Resource Conservation and Recovery Act (RCRA). I also presented the right of Starpak to assert a Confidential Business Information claim for records requested by EPA. This discussion was followed by a presentation of EPA Region 6's Confidentiality Notice (40 CFR Section 2. 203). Following this introduction, we conducted an inspection opening briefing with Ignacio Aguirre, Viktor Manjarrez, Karla Horak, and Alan Garcia. Following the opening briefing we conducted a walkthrough of Starpak's production and support areas. This walkthrough included the Printing Press Area, the Ink Blending Room, the Loading Dock, the Printing Press Distillation Area, and the Plate Etching Area. See Appendix 3 for details of EPA observations. February 23, 2022 On February 23, 2022, I reviewed the contents of the daily summary dated February 22, 2022, with facility representatives. I asked clarifying questions and documented information presented by facility representatives such as how ink returns are generated, identification of waste profiles, and approximate rates of generation for various waste streams including the still bottoms. I also discussed applicability of Hazardous Secondary Materials under 40 CFR 261.4(a)(23). See Appendix 3 for details of EPA observations. February 24, 2022 The day's inspection began with a review of the daily summary from February 23, 2022. Additional requests for documentation were made related to training records, vapor pressure for the spent solvent and pressure set point for the relief valve on the spent solvent tank. I provided comments on Starpak's Emergency Response Procedures document. See Appendix 3 for details of EPA observations. 3 Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection February 25, 2022 I facilitated a closing meeting with facility representatives reviewing the areas of concern. During this meeting, Starpak invited their consultant, Bill Garris via conference call. Together we reviewed the outstanding document requests and established a schedule for submittal. Section III - PRELIMINARY FINDINGS The following is a list of potential areas of concern discussed with the facility representatives. See Appendix 3 for details of EPA observations. Ink Wastes Generation Description- Ink wastes are generated from two separate processes at Starpak: ink formulation and printing. Ink wastes from the blend area are generated when errors occur in formulation and are accumulated in a 55-gallon container near the ink mixers. Ink wastes from the printing operations are collected in 5-gallon buckets when ink is changed from the individual printers and carried by the operators to the PRI distillation room where they are transferred into a 55-gallon drum. Ink wastes are generated by Starpak at a rate of approximately 220 gallons per week. Waste Properties- The Ink wastes are composed of a mix of n-propanol, n-propyl acetate, pigments, and ethyl acetate with a flash point below 140F. Waste Disposition- The wastes are shipped through NSSI for fuel blending. Applicable requirements - Based on the disposition of the ink wastes, the waste meets the definition of solid waste. Based on its low flash point the ink wastes demonstrate the hazardous waste characteristic of flammability (D001). Due to the generating processes and the properties of the ink wastes, the ink wastes qualify for management as universal wastes under the State of Texas' paint and paint related wastes rule 30 TAC 335.262. The profile for this waste describes it as a D001,F003 Universal Waste. Areas of Concern - Two containers of ink wastes were observed during this inspection. At the time of observation, the containers were not marked with the words "Universal Waste - Paint and Paint- Related Wastes" and did not have their lids secured in the closed position. Plate Waste Generation Description - Plate wastes are generated from the distillation of spent solvent from the photo etching process that Starpak uses to manufacture its printing plates. This waste is accumulated at the plate distillation unit in a 55-gallon drum before being moved to the PRI distillation prior to shipping. Waste properties - The Plate Waste is composed of benzyl alcohol, naphtha, and 2-ethylhexyl acetate with a flash point greater that 140F. The profile for this waste describes it as a Class 1 non-hazardous waste. Waste Disposition - The Plate Wastes are shipped for disposal by NSSI as a Class 1 nonhazardous waste. Applicable Requirements - Based on the disposition of the plate wastes, the waste meets the 4 Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection definition of solid waste. As a Class I solid waste, the plate waste would be subject to the reporting requirement of 30 TAC 335.6. Areas of Concern - Generators of a Class I solid waste are required to notify and report annually for their generation of hazardous and Class I non-hazardous waste generation under the requirements of 30 TAC 335.6 and 335.9. Soft Touch Wastes Generation Description - Soft Touch wastes are generated from the printing operations where Soft Touch is used as a varnish for the printed products. Waste Properties - The Soft touch waste is composed of a mix of urethane and poly-isocyanate compounds in ethyl acetate. Analytical reports provided by Starpak suggest that the waste has a flash point greater than 140F. The profile for this waste describes it as a D001 and F003 Universal Waste. Waste Disposition - The wastes are then shipped through NSSI for fuel blending. Applicable Requirements - Based on the disposition of the Soft Touch wastes, the waste meets the definition of solid waste. Due to the generating processes and the properties of the ink wastes, the ink wastes qualify for management as universal wastes (40 CFR 273) under the State of Texas' paint and paint related wastes rule at 30 TAC 335.262. Areas of Concern - Two containers of Soft Touch wastes were observed during this inspection. At the time of observation, the containers were not marked with the words "Universal Waste - Paint and Paint-Related Wastes." Contaminated Rags Generation Description - Contaminated rags are generated throughout the facility from general cleaning activities. The rags are accumulated in 5-gallon buckets before being transferred to large blue bins located in the PRI distillation room. Waste properties - The rags are typically contaminated with solvents n-propanol, n-propyl acetate, ethyl acetate, and inks. These contaminates have a flash point of less than 140F. Waste Disposition - The contaminated rags are laundered offsite and returned to Starpak for reuse. Applicable Requirements - The waste profile for the contaminated rags waste stream describes it as D001 and F003. Contaminated rags are exempt from the definition of solid waste if they meet the exemption requirements described in 40 CFR 261.4(a)(26). Areas of Concern - Containers managing contaminated rags must be labeled with the words: "Excluded Solvent-Contaminated Wipes" none of the four containers of solvent contaminated wipes observed during this inspection were appropriately labeled. Following the initial accumulation of the solvent contaminated rags, they must be placed in a container with the lid affixed to prevent leaks or emissions. The three large bins used for the transport and pre-transport storage of the contaminated rags are not equipped with a seal capable of preventing emissions. Generators of waste excluded under this exemption must maintain a "Description of the process the generator is using to ensure the solvent-contaminated wipes contain no free liquids at the point of 5 Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection being laundered or dry cleaned on-site or at the point of being transported off-site for laundering or dry cleaning". This description had not been provided by Starpak prior to the conclusion of this inspection. Dirty Solvent Generation Description - Dirty Solvent is generated from the cleaning of the printing presses and pumped via hard piping to a dirty solvent accumulation tank located in the PRI distillation area. Additional sources of the dirty solvent are from various cleaning operations throughout the facility and from filter changes on the dirty solvent piping. These additional solvent batches are accumulated in a 275-gallon tote located in the "PRI" distillation area. Waste Properties - Dirty solvent is composed of n-propanol, n-propyl acetate, and ink residues (e.g., pigments and ethyl acetate). The dirty solvent has a flash point of less than 140F. Waste Disposition - The dirty solvent is reclaimed in a solvent distillation unit and then accumulated in a reclaimed solvent tank located also located in the PRI distillation room. This reclaimed solvent is then returned to the process where it is again used to clean the printing presses. Applicable Requirements - Based upon the generation description, the dirty solvent would meet the definition for a spent solvent. A spent solvent being reclaimed under the control of the generator is exempt from the definition of solid waste as a hazardous secondary material so long as Starpak meets the requirements for the exemption at 40 CFR 261.4(a)(23). Should Starpak decide to manage this material as Universal Waste under Texas' Paint and Paint Related Waste definition it would be prohibited from treatment (including reclamation) by 273.31. Areas of Concern - Hazardous Secondary Materials are required to be managed in a manner that meets the definition of contained (40 CFR 260.10). The tote Starpak uses to accumulate dirty solvent in the PRI Distillation Area was open when observed on Tuesday, February 22, 2022. Generators of Hazardous Secondary Materials are required to provide notice as required by 40 CFR 260.42. As of this inspection, no record of notification was provided by Starpak. As part of our evaluation of the hazardous secondary materials exemption requirements, we asked for records concerning the vapor pressure of the dirty solvent and the set pressure for the dirty solvent tank's pressure relief devices. As of the conclusion of this inspection, the vapor pressure of the dirty solvent had been documented but the set pressure for the pressure relief devices equipped on the dirty solvent tank had not. Dirty Solvent Still Bottoms Generation Description - The distillation of spent solvents from the printing process reclaims solvent by removing pigments and other contaminants as still bottoms. These still bottoms are pumped from the unit through hard piping to a 275-gallon container located on the loading dock. According to Ms. Horak, Starpak generates between 3 and 4 containers of this waste per calendar week. Waste Properties - According to the profile provided by Starpak, the distillation bottoms are composed of approximately 98% ethyl acetate with 2% pigment contaminants with a flash point less than 73F. The profile describes this waste as a D001 and F003 Universal Waste. Waste Disposition - According to Mr. Aguirre, this waste is shipped to NSSI for fuel blending prior to burning for energy recovery. 6 Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection Applicable Requirements - Based on the waste disposition, the still bottoms meet the definition of solid waste. Based on its flash point of less than 73F, the waste demonstrates the hazardous waste characteristic of flammability (D001). Even if Starpak wanted to claim its spent solvent as Universal waste, as of June 11, 2020, TCEQ has modified its definition of Paint and Paint Related Waste to exclude materials derived from the reclamation of Paint and Paint Related Waste under the Universal Waste Rules. Therefore, the still bottoms have been determined through this inspection to be hazardous waste. Areas of Concern -Based on the NOR for the facility at the time of this inspection, Starpak's registration reflects the facility does not generate hazardous waste. Therefore, Starpak has not provided notice to TCEQ that it is generating this hazardous waste. The container used for the accumulation of this waste is marked as Universal Waste, however this waste definition does not appear to apply to this waste. Therefore, this waste is not marked appropriately as described in 40 CFR 262.17. According to the records provided by Starpak, this waste has been shipped on multiple occasions on bills of lading but not on a hazardous waste manifest as required by 40 CFR 262.20. Therefore, Starpak has on multiple occasions offered this waste for transport without preparing a hazardous waste manifest. Piping in hazardous waste service is required to be maintained in accordance with 40 CFR 265 Subpart BB. According to Mr. Aguirre, the piping used for transferring the still bottoms from the distillation unit to the still bottom accumulation container is not subject to any fugitive emission monitoring activities. General Facility Standards Based on its claimed rate of generation for hazardous waste (Dirty Solvent Still Bottoms), Starpak is a large quantity generator of hazardous waste and therefore required to comply with the Large Quantity Generator requirements of 40 CFR part 262. Based on its claimed rate of generation for universal waste (Ink Waste, Plate Waste, Soft Touch Waste), Starpak is a large quantify handler of universal waste and therefore required to comply with the requirements of 40 CFR 273 Subpart C. Based on its claimed rate of generation for hazardous secondary materials (Dirty Solvent), Starpak is required to comply with the requirements of 40 CFR 261.410 and 420. Areas of Concern - Facilities subject to 40 CFR 261.410 and/or 40 CFR 262.255 are required to maintain adequate aisle spacing. When observed on February 22, 2022, Starpak was not maintaining adequate aisle spacing for its containers located in the PRI distillation area. Texas requires annual reporting to STEERS for Class 1 Industrial Waste and Hazardous Waste under 30 TAC 335.6. As of this inspection, Starpak had not provided any reporting for its Class 1 Waste or its hazardous waste. Section IV - FOLLOW UP Actions taken by Starpak to resolve areas of concern during and following the inspection, such as drum labeling, were documented by Starpak with photographs or other documentation and 7 Starpak LTD. Houston Facility FY2022 RCRA Compliance Evaluation Inspection submitted to the EPA via the electronic secure online drive. Details of actions taken are provided in Appendix 4. Any information received from Starpak after the inspection was also received via the secure online drive. These documents are accessible to the EPA Enforcement Officer. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - Photos taken on 2/22/2022 Appendix 2 - Facility Diagram Appendix 3 - Daily Summaries Appendix 4 - Starpak Corrective Actions 8 Photo Log Photos Taken on 2-22-2022 Photo Log - Starpak CEI FY2022 RCRA Compliance Evaluation Inspection StarPak Corp, Houston, TX February 22 to February 25, 2022 Camera Make: Nikon CoolPix Model No.: AW120 Camera Serial Number: 31003827 EPA Equipment Number: S68180 Photo # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Image # DSCN0525 DSCN0526 DSCN0527 DSCN0528 DSCN0529 DSCN0530 DSCN0531 DSCN0532 DSCN0533 DSCN0534 DSCN0535 DSCN0536 DSCN0537 DSCN0538 DSCN0539 DSCN0540 DSCN0541 Date 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 Time Subject 11:23am Ink waste drum lid not secured with ring 11:26am Wipes canister in closed position near mixing area. Inside product storea area. 11:29 AM 11:29 AM 11:29 AM 11:31am 11:31 AM 11:34 AM 11:34 AM 11:35 AM 11:37 AM 11:38 AM Tote containing still bottoms. Tote located on loading dock. View of tote receiving waste from distillation process. View of tote being filled with labeling shown. Closeup view of label on tote being filled. View of empty tote behind the one being filled located on loading dock. Note label. View of all totes on loading dock used to receive still bottoms. All empty except the one being filled. View of dirty solvent tote. Large funnel connected to tote on top. Unit open. View of open funnel system connected to dirty solvent tote. View of 1 of 3 observed containers of rags that will go for laundering. Durm of sludge/PRI. View of lable and date. Drum top not secure with ring View of sludge/PRI drum showing label closeup. 11:38 AM Top of drum holding sludge/PRI - showing ring not secured 11:39 AM 11:41 AM 11:41 AM 11:43 AM Three drums of waste located next to clean solvent (product) drums. Plates sludge waste and soft comex in the drums Signage above waste drums-Satellite Accumulation Area Signage above area with empty containers on wall next to the door entering the area. Distillation system overview 1 Photo Log - Starpak CEI FY2022 RCRA Compliance Evaluation Inspection StarPak Corp, Houston, TX February 22 to February 25, 2022 Camera Make: Nikon CoolPix Model No.: AW120 Camera Serial Number: 31003827 EPA Equipment Number: S68180 Photo # 18 19 20 21 22 23 24 Image # DSCN0542 DSCN0543 DSCN0544 DSCN0545 DSCN0546 DSCN0547 DSCN0548 Date 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 2/22/2022 Time 11:45 AM 11:46 AM 11:51 AM Subject View of pump under dirty solven tank Open line - no cap on pipe on dirty sovlent tank Buckets with dirty rags and pads. Pads will go for disposal. Rage will be put into larger rag tote for laundering. Note no covers on containers 11:54 AM View of labeling by bay door to the facility from dock. Area labeled: EPN-FUG-1 11:59 AM 12:00 PM 12:00 PM IHSOLVE recycling system overview Cyrel washout system - piping Cyrel overview - clean washout solvent container. 2 Photo #1 PHOTO #1 PHOTO #2 PHOTO #3 PHOTO #4 PHOTO #5 PHOTO #6 PHOTO #7 PHOTO #8 PHOTO #9 PHOTO #10 PHOTO #11 PHOTO #12 PHOTO #13 PHOTO #14 PHOTO #15 PHOTO #16 PHOTO #17 PHOTO #18 PHOTO #19 PHOTO #20 PHOTO #21 PHOTO #22 PHOTO #23 PHOTO #24 APPENDIX 2 FACILITY LAYOUT Appendix 3 Daily Summaries 2-22- through 2-25-2022 Pandak, Debra From: Sent: To: Cc: Subject: Attachments: Penland, John Tuesday, February 22, 2022 10:54 PM Iaguirre@starpakltd.com; Pandak, Debra Yurk, Jeffrey Daily Summary February 22, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) cbi form RCRA 2-19-20.pdf All, Here is a summary of my notes from today's inspection. If there are any errors or omissions please let me know. Introduction During the week of February 20, 2022, I, John Penland, will be conducting an unannounced inspection of the Starpak, LTD. facility (Starpak) located at 9690 West Wingfoot Road in Houston, Texas for compliance with the Resource Conservation and Recovery Act (RCRA). I will be assisted on this inspection by Environmental Protection Agency (EPA) inspector Debra Pandak. The inspection will include walkthroughs of the facility's hazardous waste generation and management units; a review of the facility records related to hazardous waste management; and a specific evaluation of the facility's compliance with the RCRA air pollution control requirements. Purpose The Starpak facility was targeted for inspection as part of an ongoing investigation into the facility's waste determination and counting procedures. The investigation was initiated by EPA Region 6 during FY2019 and remains open. In addition, the solvent wastes generated by the facility have the potential to trigger the RCRA air pollution control requirements; therefore this inspection is also being conducted as part of the National Compliance Initiative for air emissions from hazardous waste management units. Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Viktor Manjarrez Project Manager Asst. Plant Manager Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer Kassim Pre-press Mohammed Supervisor REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com Daily Summary Initial Entry to the facility - 9:50am Opening meeting start - 10:00am 1 o I presented my credentials to Mr. Aguirre and informed him that Debra Pandak and I were there to conduct an inspection of the facility under the authority of section 3007 of the Resource Conservation and Recovery Act o We discussed the authority for the inspection - RCRA Section 3007 - For purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, any person who generates, stores, treats, transports, disposes of, or otherwise handles or has handled hazardous wastes shall, upon request of any officer, employee or representative of the Environmental Protection Agency, duly designated by the Administrator, or upon request of any duly designated officer, employee or representative of a State having an authorized hazardous waste program, furnish information relating to such wastes and permit such person at all reasonable times to have access to, and to copy all records relating to such wastes. For the purposes of developing or assisting in the development of any regulation or enforcing the provisions of this chapter, such officers, employees or representatives are authorized-- (1)to enter at reasonable times any establishment or other place where hazardous wastes are or have been generated, stored, treated, disposed of, or transported from; (2)to inspect and obtain samples from any person of any such wastes and samples of any containers or labeling for such wastes. o We discussed the purpose of EPA's inspection - Assessment of Starpak's compliance with its requirements under RCRA, including, but not limited to, the requirements for: waste determination and counting; waste marking; waste container management; use of the hazardous waste manifest; emergency planning; personnel training; and air pollution control requirements for hazardous waste units. o Discussed the right of Starpak to assert a Confidential Business Information claim for records requested by EPA (see attachment) o Discussed the process for transferring electronic records - EPA has set up a Microsoft OneDrive folder with access limited to John Penland, Debra Pandak, and Ignacio Aguirre. o Discussed the inspection process - the inspection will be conducted February 22 through February 25, 2022. The participants will meet at the facility at 9:30am each day to conduct the onsite portion of the inspection and discuss the findings of the ongoing records review. The records review will be conducted by the inspectors independently offsite throughout the week. Daily summaries will be provided by the inspectors at the end of each day to ensure a clear communication of questions and findings. The meeting Friday, February 25, 2022 will be reserved for a closing conference, where EPA will summarize the overall findings of the inspection to that point and provide a plan for concluding any unfinished evaluation. o Meeting concluded with a safety briefing at approximately 11:00am General Facility Process - The Starpak facility manufactures printed plastic packaging for use in a variety of consumer markets. The facility production operations include a photo etching process and ten, high-volume printing presses. The photo etching process includes a solvent reclamation unit (plate distillation unit) to recycle the mask removal agent. The printing presses generate a spent solvent which is accumulated in a spent solvent tank prior to reclamation in a distillation unit. The distilled solvent is recycled into the printing process. o According to Mr. Aguirre, the printing solvent is a blend of n-propanol and n-propyl acetate. Clean Air Act Permitting - According to Mr. Aguirre, the facility is under the emissions threshold for CAA title V permitting. The facility operates under a minor source New Source Review Permit. Facility Walkthrough o Beginning at approximately 11:00am o Printing press area - We physically inspected 3 of the individual presses. Each press is equipped with an enclosure where ink blend feed containers and the solvent cleaning pumps are located. The solvent cleaning pumps are each hard piped to the spent solvent tank in the distillation area. Strong solvent odors are pervasive in the area. The entire building is maintained at negative pressure to prevent solvent emissions to the outside atmosphere. 2 o Ink Blending Area - The ink blending area is used to formulate each individual ink batch used in the printing process. Blends are controlled for color, drying time, and consistency. One 55-gallon container of ink waste was located in the area. The drum was marked with the words "ink waste" and the lid was open. One small can was located in the area for the accumulation of ink contaminated rags. The can was unmarked and the lid unsecured. Solvent odors are pervasive in the area. o Dock area - Four totes located in this area are used for the accumulation of still bottoms from the press solvent distillation unit. At the time of this inspection, 3 of the totes were empty and one was attached to the distillation unit via piping and a flex hose. The totes were each marked as "Universal Waste - Paint and Paint Related Material." The rolling door leading to this area from the main building was marked as EPN-FUG-1, a designation usually associated with a CAA permit provision. o Press distillation area - spent solvent from the printing press area is accumulated in the spent solvent tank located in this area. 2 solvent reclamation distillation units are located in this area, but only one is routinely in use. The second smaller unit is in place as a backup. Each of the 2 distillation units has an associated clean solvent tank to accumulate the reclaimed solvent. The bottoms from the distillation units are pumped via hard piping through the wall to the dock area tote. Two hazardous waste storage area signs are located in this room, one for hazardous waste storage and one for satellite accumulation. However, these signs did not appear to designate segregated management areas dedicated to hazardous waste accumulation. Instead, raw material containers were intermingled with waste containers resulting in a scenario where it was difficult to differentiate the containers. 3 large blue bins marked as "Dirty Rags" and "Flammable Liquid" were located in this area, each with an unsecured lid. 4 unlabeled five-gallon pails (3 without lids) full of ink and solvent contaminated rags and pads were located beneath a work bench. One tote marked as "dirty solvent" was located in this area. The tote was being used to accumulate spent solvent at the time of this inspection. The tote was equipped with an open funnel/drip tray which allowed the tote contents to volatilize to the building. According to Mr. Kassim Mohammed, the tote received solvent and sludges from the inline filter one the dirty solvent tank (cleaned 3x per day). The tote was not being actively filled or emptied throughout the observation period. One open-ended line was identified on the spent solvent tank. One 55-gallon drum marked as "Sludge PRI" was located in this area One 55-gallon drum marked as "Plates Sludge Waste" was located in this area 2 Drums marked as "waste Soft. Comexi" were located in this area No containers present in this area were marked as "Universal Waste" or as "Hazardous Waste" Several drums of Ethyl Acetate were present in this area. According to Mr. Aguirre, ethyl acetate is used as an ingredient in the ink blending process. Several drums of Isopropyl Alcohol were present in this area. According to Mr. Aguirre, isopropyl alcohol is used as a surface disinfectant in the facility. Solvent odors were pervasive in this area. o Plate Distillation Unit The plate distillation unit is connected to the photo-etching process via hard piping without any intermediate spent solvent accumulation unit. The distillation bottoms are collected in a 55-gallon drum, accessible through a door on the unit. Daily Wrap up meeting 3 o Following the conclusion of the facility walkthrough we discussed extent of the records request presented to Mr. Aguirre but not discussed in-depth prior to the walkthrough. A current notice of Regulated Waste Activity (typically presented as part of a biennial waste report or as part of the STEERS submittal) A current copy of the facility Contingency Plan and Emergency Procedures (may also be part of a broader Emergency Response Plan) Personnel training records related to hazardous waste activities for selected personnel. The current request includes: Mr. Ignacio Aguirre Ms. Karla Horak Mr. Kassim Mohammed Facility Maps - preferably identifying the solid waste generation and management areas Facility waste profiles for any solid waste generated since 2019. Include documentation relevant to the waste determination made for each waste (i.e. analytical reports or documentation to support generator knowledge) Safety Data Sheets for each solvent used throughout the facility. Manifests and accompanying land disposal restriction notices for any hazardous waste shipped for offsite disposal since 2019 Bills of lading or any other document used to accompany any shipment of any waste since 2019 Any active RCRA or CAA permits Engineering diagrams for the waste generating processes and solvent reclamation systems. Annual Waste Summaries since 2019. Any agreement between Starpak and any subsequent waste handler or Treatment, Storage, or Disposal Facility pertaining to the disposition of Starpak's wastes. SOPs related to waste generating, reclamation, or management processes Departed Facility at approximately 12:30pm Topics for discussion on February 23, 2022 o Profiles associated with solvent and ink wastes (including rags) indicate the presence of ethyl acetate in significant concentrations o Profile for the plate waste indicates a flash point of 145F. o Current NOR indicates Universal Waste only - Effective 6-11-2020, still bottoms destined for disposal or for recycling by burning for energy recovery are excluded from the definition of Universal waste. See, 30 TAC 335.262(b) and RG-370 John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 4 Pandak, Debra From: Sent: To: Cc: Subject: Penland, John Thursday, February 24, 2022 12:30 PM Iaguirre@starpakltd.com; Pandak, Debra Yurk, Jeffrey Daily Summary February 23, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Viktor Manjarrez Project Manager Asst. Plant Manager Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer Alan Garcia Safety Manager REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com Daily Summary Inspection start - 9:43am o Review of Daily Summary February 22, 2022 A more accurate process description is available in Starpak's CAA NSR permit application. Printing Process 11 printing presses are operated at Starpak. 10 in the main printing press area and an 11th in another area of the building. Ink returns are generated in the printing area and carried to the Distillation (PRI) Room where they are added to a 55-gallon drum. This is the drum observed on February 22 and marked as PRI Sludge/Ink waste. This Ink waste is assigned profile # PL1-182705 (8-17-2018) and generated at a rate of approximately 110-gallons per week Blending Process Ink waste generated in blend room assigned to profile # PL1-182705 (8-17-2018) and is generated at a rate of approximately 110-gallons per week Profile PL1-182705 designates the waste as being D001,F003 Universal Waste with up to 10% ethyl acetate. According to Mr. Aguirre, this is incorrect since the ethyl acetate is present as an ingredient in the ink and not being used as a solvent. Dock Area Still bottoms are generated at a rate of between approximately 825 and 1100 gallons per week. 1  The still bottoms are assigned to profile # PL1-182705 (7-19-2018) - This is an identical profile # to the ink waste but describes a completely different waste stream with different composition The profile for the still bottoms designates the waste as D001, F003 and indicates a composition of up to 99% Ethyl Acetate. According to Mr. Aguirre this is incorrect since the still bottoms should be primarily composed of Propanol and Propyl Acetate. Any Ethyl acetate present is from its use as part of the ink blend and not because of its use as a solvent. Distillation area The rags present in the area are being laundered and reused in the plant. However, they are not marked or managed in accordance with 40 CFR 260.4(a)(26) The Dirty solvent tote in the distillation room is used to accumulate spent solvent generated through cleaning activities throughout the facility and filter changes on the dirty solvent tank. The solvent in this tote is then siphoned into the dirty solvent tank for reclamation. Soft Touch drums observed on February 22 are assigned Profile # AG1-190216 which designates the waste as D001, F003 Universal Waste with up to 100% Ethyl Acetate. This needs clarification since this profile was not directly discussed on February 23. Spill cleanup of the dirty solvent or inks, regardless of the activity that resulted in the spill, need to be collected and contained in a timely fashion. Otherwise these spills become solid(and potentially hazardous) waste. Plate Distillation The plate waste is assigned profile # PL1-190410 which designates the waste as Non- hazardous. Review of the SDS for the raw material solvent shows that the Flash Point is >62C and the solvent is not composed of any listed ingredients. Applicable Standards based on our current review of the process and documents provided by Starpak o Since the facility is claiming the spent solvent as a Hazardous Secondary Material being reclaimed under control of the generator (40 CFR 261.4(a)(23)), Starpak would be required to comply with the Emergency Preparedness Standards of 40 CFR 261.400 o As a Hazardous Secondary Material management process, all units managing the dirty solvent waste would need to meet the requirements of the contained definition at 40 CFR 260.10 o As of June 11, 2020, the still bottoms generated from the solvent distillation unit would not qualify for management under the universal waste standards. Based on the claimed rate of generation stated above, the facility would be generating >1000 kg of hazardous waste per calendar month and be required to comply with the large quantity generator standards of 40 CFR part 262 o Since the facility is laundering and reusing its contaminated rags, Starpak would be need to comply with the requirements of 40 CFR 261.4(a)(26) in order to exempt these rags from the solid and hazardous waste rules. o Piping and ancillary equipment conveying still bottoms between the bottom of the distillation unit and the container accumulating that waste would be subject to the requirements of 40 CFR 265 Subpart BB, as incorporated by reference in 40 CFR 262.17(1)(i). o For any waste being managed as universal waste under Texas' Paint and Paint Related Waste rules, Starpak would need to comply with the requirements of 30 TAC 335.262 Departed Facility at approximately 1:45pm Discussion topics planned for February 24 Employee Training o Contents of Hazardous waste Training o Emergency preparedness training o DOT Training o Operator Training o One additional employee requested: Juan Espara(sp?) 2  Missing Generation rate info o Plate waste (PL1-190410) o Rags (PL2-190604) Duplicate Profile numbers o PL1-182705 Missing profiles o PL1-190210 (Ink and Still bottom Waste?) o PL1-200325 (battery?) o PL1-190703 (used oil?) o PL1-190403 (Fluorescent Lamps?) o PL1-190604 (Anilox Cleaner?)(Dibasic Ester?) o LP1-102021 (Absorbent Sand?) o PL1-190719 (Lead Acid Batteries?) o PL1-210211 (Used Oil Rags?) Content of ERP Facility inspections Contained definition for HSM units o Vapor pressure of dirty solvent o Set pressure for tank relief valves Requested documents John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 3 Pandak, Debra From: Sent: To: Cc: Subject: Penland, John Thursday, February 24, 2022 11:11 PM Iaguirre@starpakltd.com; Pandak, Debra Yurk, Jeffrey Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com Daily Summary Inspection start - 3:45pm (start delayed due to an emergency at the facility) Reviewed February 23, 2022 Daily Summary o Plate waste is generated at a rate of approximately 330-440 gallons per week o Soft Touch waste is generated at a rate of approximately 110-165 gallons per week o Requested DOT training records o Requested ERP training records o Requested position descriptions for employees subject to training requirements of RCRA Discussed the definition of contained for the Hazardous Secondary Materials units (see 260.10) o Requested the vapor pressure for the spent solvent and the pressure set point for the pressure relief valve for the spent solvent tank Reviewed the facility inspection checklist. This inspection checklist includes the waste containers and many of the requirements for large quantity generators of hazardous waste. o Requested the completed facility inspection checklists for the prior 3 years (2019-2022) Discussed content and disposition of the Starpak ERP o The ERP will be reviewed for compliance with the standards of 261 Subpart M and 262 Subpart M o The ERP does not include a list of emergency response equipment o According to Ms. Horak, the ERP was sent via certified mail to the local emergency response contacts. Requested these certified mail receipts Discussed documentation of corrective measures o Please upload documentation or any actions that Starpak takes to address Areas of Concern identified by EPA during this inspection. I have added a new subfolder to the OneDrive for these records. Departed Facility at 5:45pm 1 John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2 Pandak, Debra From: Sent: To: Cc: Subject: Penland, John Sunday, March 6, 2022 8:18 PM Iaguirre@starpakltd.com; Pandak, Debra Yurk, Jeffrey Closing Meeting Summary - February 25, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Viktor Manjarrez Project Manager Asst. Plant Manager Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer Bill Garris Independent Consultant REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 336-462-7064 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com Closing Meeting Summary Meeting start - 10:12am Introduction o RCRA 3007 - This inspection was conducted under the authority of RCRA section 3007. The findings of this inspection will be documented in an inspection report which will be sent to Starpak upon completion. I strongly recommend that Starpak respond, in writing, to the findings contained in that report. o CBI - As of the conclusion of the inspection, Starpak has not asserted any claims of confidential business information for the records or photographs obtained. Should Starpak wish to make a claim of CBI, I encourage you to complete and return the CBI packet I attached to my email on Tuesday, February 22. o Process based inspection description - This inspection followed a process based inspection process. Using this method, EPA inspectors review the waste generating processes, waste characteristics, and waste management procedures to determine the applicable standards that pertain to the facility's operations. Provisional Inspection Findings o Ink Wastes Generation Description- Ink wastes are generated from two separate processes at Starpak: ink formulation and printing. Ink wastes from the blend area are generated when errors occur in formulation and are accumulated in a 55-gallon container near the ink mixers. Ink wastes from the printing operations are collected in 5-gallon buckets when ink is changed from the individual 1 printers and carried by the operators to the PRI distillation room where they are transferred into a 55-gallon drum. Ink wastes are generated by Starpak at a rate of approximately 220 gallons per week Waste Properties- The Ink wastes are composed of a mix of n-propanol, n-propyl acetate, pigments, and ethyl acetate with a flash point below 140F Waste Disposition- The wastes are shipped through NSSI for fuel blending. Applicable requirements - Based on the disposition of the ink wastes, the waste meets the definition of solid waste. Based on its low flash point the ink wastes demonstrate the hazardous waste characteristic of flammability (D001). Due to the generating processes and the properties of the ink wastes, the ink wastes qualify for management as universal wastes under the State of Texas' paint and paint related wastes rule. The profile for this waste describes it as a D001,F003 Universal Waste. Areas of Concern: 2 containers of ink wastes were observed during this inspection. At the time of observation the containers were not marked with the words "Universal Waste - Paint and Paint-Related Wastes" and did not have their lids secured in the closed position. o Plate Waste Generation Description - Plate wastes are generated from the distillation of spent solvent from the photo etching process that Starpak uses to manufacture its printing plates. This waste is accumulated at the plate distillation unit in a 55-gallon drum before being moved to the PRI distillation prior to shipping. Waste properties - The Plate Waste is composed of benzyl alcohol, naphtha, and 2-ethylhexyl acetate with a flash point greater that 140F. The profile for this waste describes it as a Class 1 non-hazardous waste. Waste Disposition - The Plate Wastes are shipped for disposal by NSSI as a Class 1 non- hazardous waste Applicable Requirements - Based on the disposition of the plate wastes, the waste meets the definition of solid waste. As a class I solid waste, the plate waste would be subject to the reporting requirement of 30 TAC 335.6 Areas of Concern - Generators of a Class I solid waste are required to notify and report annually for their generation of hazardous and class I non-hazardous waste generation under the the requirements of 30 TAC 335.6 and 335.9 o Soft Touch Wastes Generation Description - Soft Touch waste are generated from the printing operations where Soft Touch is used as a varnish for the printed products. Waste Properties - The Soft touch waste is composed of a mix of urethane and poly-isocyanate compounds in ethyl acetate. Analytical reports provided by Starpak suggest that the waste has a flash point greater than 140F. The profile for this waste describes it as a D001,F003 Universal Waste. Waste Disposition - The wastes are then shipped through NSSI for fuel blending. Applicable Requirements - Based on the disposition of the Soft Touch wastes, the waste meets the definition of solid waste. Due to the generating processes and the properties of the ink wastes, the ink wastes qualify for management as universal wastes (40 CFR 273) under the State of Texas' paint and paint related wastes rule at 30 TAC 335.262 Areas of Concern 2 containers of Soft Touch wastes were observed during this inspection. At the time of observation the containers were not marked with the words "Universal Waste - Paint and Paint-Related Wastes" o Anilox Cleaner Waste (not directly observed during the inspection) 2  Generation Description - Anilox Cleaner is used to clean and remove ink from the anilox (the roller that applies ink to the printing plate in the press) between printing runs. The cleaner is generated as a batch when it is removed from the anilox cleaning unit. Waste Properties - The anilox cleaner is composed of potassium hydroxide, ethanolamine, 2- butoxyethanol, pigments, and water. The pH for this waste is indicated on the profile as being greater than 12.5. The profile for this waste describes it as a D002, F003, F005 Universal Waste. Waste Disposition - The waste is shipped by NSSI as a universal waste for disposal. However, the ultimate means of disposal for this waste was not discussed as of the end of this inspection. Applicable Requirements - As a declared Universal Waste, the anilox cleaner is subject to the universal waste rules of 40 CFR 273 and the Paint and Paint Related Waste Rule of 30 TAC 335.262 Areas of Concern - None, since this waste was not observed during this inspection. o Contaminated Rags Generation Description - Contaminated Rags are generated throughout the facility from general cleaning activities. The rags are accumulated in 5 gallon buckets before being transferred to large blue bins located in the PRI distillation room. Waste properties - The rags are typically contaminated with solvents n-propanol, n-propyl acetate, ethyl acetate, and inks. These contaminates have a flash point of less than 140F Waste Disposition - The contaminated rags are laundered offsite and returned to Starpak for reuse. Applicable Requirements - The waste profile for the Contaminated Rags waste stream describes it as D001, F003. Contaminated Rags are exempt from the definition of solid waste as long as they meet the exemption requirements described in 40 CFR 261.4(a)(26). Areas of Concern Containers managing contaminated rags must be labeled with the words: "Excluded Solvent-Contaminated Wipes" none of the four containers of solvent contaminated wipes observed during this inspection were appropriately labeled. Following the initial accumulation of the solvent contaminated rags, they must be placed in a container with the lid affixed so as to prevent leaks or emissions. The three large bins used for the transport and pre-transport storage of the contaminated rags is not equipped with a seal capable of preventing emissions. Generators of waste excluded under this exemption must maintain a "Description of the process the generator is using to ensure the solvent-contaminated wipes contain no free liquids at the point of being laundered or dry cleaned on-site or at the point of being transported off-site for laundering or dry cleaning". This description had not been provided by Starpak prior to the conclusion of this inspection. o Dirty Solvent Generation Description - Dirty Solvent is generated from the cleaning of the printing presses and pumped via hard piping to a dirty solvent accumulation tank located in the PRI distillation area. Additional sources of the dirty solvent are from various cleaning operations throughout the facility and from filter changes on the dirty solvent piping. These additional solvent batches are accumulated in a 275-gallon totes located in the PRI distillation area. Waste Properties - Dirty Solvent is composed of n-propanol, n-propyl acetate, and ink residues (including pigments and ethyl acetate). The dirty solvent has a flash point of less than 140F. Waste Disposition - The dirty solvent is reclaimed in a solvent distillation unit and then accumulated in a reclaimed solvent tank located the PRI distillation room. This reclaimed solvent is then returned to the process where it is again used to clean the printing presses. Applicable Requirements - Based upon the generation description, the dirty solvent would meet the definition for a spent solvent. A spent solvent being reclaimed under the control of the generator is exempt from the definition of solid waste as a hazardous secondary material so long as Starpak meets the requirements for the exemption at 40 CFR 261.4(a)(23). Should 3 Starpak decide to manage this material as Universal Waste under Texas' Paint and Paint Related Waste definition it would be prohibited from treatment (including reclamation) by 273.31. Areas of Concern Hazardous Secondary Materials are required to be managed in a manner that meets the definition of contained (40 CFR 260.10). The tote Starpak uses to accumulate dirty solvent in the PRI Distillation Area was open when observed on Tuesday, February 22, 2022. Generators of Hazardous Secondary Materials are required to provide notice as required by 40 CFR 260.42. As of this inspection, no record of notification was provided by Starpak. As part of our evaluation of the hazardous secondary materials exemption requirements, we asked for records concerning the vapor pressure of the dirty solvent and the set pressure for the dirty solvent tank's pressure relief devices. As of the conclusion of this inspection, the vapor pressure of the dirty solvent had been documented but the set pressure for the pressure relief devices equipped on the dirty solvent tank had not. o Dirty Solvent Still Bottoms Generation Description - The distillation of spent solvents from the printing process reclaims solvent by removing pigments and other contaminants as still bottoms. These still bottoms are pumped from the unit through hard piping to a 275-gallon container located on the loading dock. According to Ms. Horak, Starpak generates between 3 and 4 containers of this waste per calendar week. Waste Properties - According to the profile provided by Starpak, the distillation bottoms are composed of approximately 98% ethyl acetate with 2% pigment contaminants with a flash point less than 73F. The profile describes this waste as a D001, F003 Universal Waste. Waste Disposition - According to Mr. Aguirre, this waste is shipped to NSSI for fuel blending prior to burning for energy recovery. Applicable Requirements - Based on the Waste's disposition, the still bottoms meet the definition of solid waste. Based on its flash point of less than 73F, the waste demonstrates the hazardous waste characteristic of flammability (D001). Even if Starpak wanted to claim its spent solvent as Universal waste, as of June 11, 2020, TCEQ has modified its definition of Paint and Paint Related Waste to exclude materials derived from the reclamation of Paint and Paint Related Waste under the Universal Waste Rules. Therefore, the still bottoms have been determined through this inspection to be hazardous waste. Areas of Concern Based on the NOR for the facility at the time of this inspection, Starpak does not generate hazardous waste. Therefore, Starpak has not provided notice to TCEQ that it is generating this hazardous waste. The container used for the accumulation of this waste is marked as Universal Waste, however that definition does not appear to apply to this waste. Therefore, this waste is not marked appropriately as described in 40 CFR 262.17. According to the records provided by Starpak, this waste has been shipped on multiple occasions on bills of lading but not on a hazardous waste manifest as required by 40 CFR 262.20. Therefore, Starpak has on multiple occasions offered this waste for transport without preparing a hazardous waste manifest. Piping in hazardous waste service is required to be maintained in accordance with 40 CFR 265 Subpart BB. According to Mr. Aguirre, the piping used for transferring the still bottoms from the distillation unit to the still bottom accumulation container is not subject to any fugitive emission monitoring activities. o General Facility Standards 4  Based on its claimed rate of generation for hazardous waste (Dirty Solvent Still Bottoms), Starpak is a large quantity generator of hazardous waste and therefore required to comply with the Large Quantity Generator requirements of 40 CFR part 262. Based on its claimed rate of generation for universal waste (Ink Waste, Plate Waste, Soft Touch Waste), Starpak is a large quantify handler of universal waste and therefore required to comply with the requirements of 40 CFR 273 Subpart C. Based on its claimed rate of generation for hazardous secondary materials (Dirty Solvent), Starpak is required to comply with the requirements of 40 CFR 261.410 and 420. Areas of Concern Facilities subject to 40 CFR 261.410 and/or 40 CFR 262.255 are required to maintain adequate aisle spacing. When observed on February 22, 2022, Starpak was not maintaining adequate aisle spacing for its containers located in the PRI distillation area Starpak has provided its facility response plan. This document and the associated attachments will be reviewed for compliance with the requirements of 40 CFR 261 and 262 Subpart M. Texas requires annual reporting to STEERS for Class 1 Industrial Waste and Hazardous Waste under 30 TAC 335.6. As of this inspection, Starpak had not provided any reporting for its Class 1 Waste or its hazardous waste. Large quantity generators of hazardous waste are required to comply with the training requirements of 40 CFR 262.17. As of this inspection, Starpak has provided training records for the specific personnel requested. These records will be reviewed for compliance with the aforementioned requirements. o Next Steps Starpak will continue to provide records for evaluation by EPA. EPA will issue a final inspection report following the conclusion of this inspection. The document submission link will remain open until the inspection report is finalized. Departed Facility at approximately 1:45pm John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 5 APPENDIX 4 STARPAC CORRECTIVE ACTIONS Pandak, Debra From: Sent: To: Cc: Subject: Ignacio Aguirre <IAguirre@starpakltd.com> Friday, February 25, 2022 9:51 AM Penland, John; Pandak, Debra Yurk, Jeffrey RE: Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) Hello John, I have reviewed the records for 2021, and for the soft touch we were generating waste at a rate of 55-65 gal/week. Also I do have records of training for the items that the ERP is pointing. I am working to upload those. Thanks, Ignacio From: Penland, John <Penland.John@epa.gov> Sent: Thursday, February 24, 2022 11:11 PM To: Ignacio Aguirre <IAguirre@starpakltd.com>; Pandak, Debra <Pandak.Debra@epa.gov> Cc: Yurk, Jeffrey <yurk.jeffrey@epa.gov> Subject: Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com Daily Summary Inspection start - 3:45pm (start delayed due to an emergency at the facility) Reviewed February 23, 2022 Daily Summary 1 o Plate waste is generated at a rate of approximately 330-440 gallons per week o Soft Touch waste is generated at a rate of approximately 110-165 gallons per week o Requested DOT training records o Requested ERP training records o Requested position descriptions for employees subject to training requirements of RCRA Discussed the definition of contained for the Hazardous Secondary Materials units (see 260.10) o Requested the vapor pressure for the spent solvent and the pressure set point for the pressure relief valve for the spent solvent tank Reviewed the facility inspection checklist. This inspection checklist includes the waste containers and many of the requirements for large quantity generators of hazardous waste. o Requested the completed facility inspection checklists for the prior 3 years (2019-2022) Discussed content and disposition of the Starpak ERP o The ERP will be reviewed for compliance with the standards of 261 Subpart M and 262 Subpart M o The ERP does not include a list of emergency response equipment o According to Ms. Horak, the ERP was sent via certified mail to the local emergency response contacts. Requested these certified mail receipts Discussed documentation of corrective measures o Please upload documentation or any actions that Starpak takes to address Areas of Concern identified by EPA during this inspection. I have added a new subfolder to the OneDrive for these records. Departed Facility at 5:45pm John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2 Pandak, Debra From: Sent: To: Cc: Subject: Ignacio Aguirre <IAguirre@starpakltd.com> Friday, February 25, 2022 6:00 PM Penland, John; Pandak, Debra Yurk, Jeffrey RE: Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) John, The profile Pl-1-182705 signed on 8-17-18 supersedes the one signed on 7-19-18. I spoke to our waste disposal company and we have verified that the profile you see as 180725 should have been 182705 and they have mistyped the profile. They also have assured me that the waste is being treated as hazardous waste from day one and that the end use has been fuel blending. They will provide me with the necessary documentation to prove the mentioned statement. I will be uploading the documents you have request within the timeline you have set. Thanks, Ignacio From: Penland, John <Penland.John@epa.gov> Sent: Thursday, February 24, 2022 11:11 PM To: Ignacio Aguirre <IAguirre@starpakltd.com>; Pandak, Debra <Pandak.Debra@epa.gov> Cc: Yurk, Jeffrey <yurk.jeffrey@epa.gov> Subject: Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com 1 Daily Summary Inspection start - 3:45pm (start delayed due to an emergency at the facility) Reviewed February 23, 2022 Daily Summary o Plate waste is generated at a rate of approximately 330-440 gallons per week o Soft Touch waste is generated at a rate of approximately 110-165 gallons per week o Requested DOT training records o Requested ERP training records o Requested position descriptions for employees subject to training requirements of RCRA Discussed the definition of contained for the Hazardous Secondary Materials units (see 260.10) o Requested the vapor pressure for the spent solvent and the pressure set point for the pressure relief valve for the spent solvent tank Reviewed the facility inspection checklist. This inspection checklist includes the waste containers and many of the requirements for large quantity generators of hazardous waste. o Requested the completed facility inspection checklists for the prior 3 years (2019-2022) Discussed content and disposition of the Starpak ERP o The ERP will be reviewed for compliance with the standards of 261 Subpart M and 262 Subpart M o The ERP does not include a list of emergency response equipment o According to Ms. Horak, the ERP was sent via certified mail to the local emergency response contacts. Requested these certified mail receipts Discussed documentation of corrective measures o Please upload documentation or any actions that Starpak takes to address Areas of Concern identified by EPA during this inspection. I have added a new subfolder to the OneDrive for these records. Departed Facility at 5:45pm John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2 Pandak, Debra From: Sent: To: Cc: Subject: Attachments: Ignacio Aguirre <IAguirre@starpakltd.com> Friday, March 4, 2022 5:23 PM Penland, John; Pandak, Debra Yurk, Jeffrey RE: Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) Starpak Waste Good evening John, As I mentioned before NSSI miss typed the profile # 182705 as # 180725, see please the statement from NSSI regarding the profile #182705. I will upload this e mail into your one drive and a picture of a tote with the correct label (Hazardous waste) as a corrective action regarding to still bottoms. Regarding the pressure setting you were asking for the tank vent is 0.4psi, which is above the 0.33 psi vapor pressure of the solvent contained in the tank. If you want any more information please let me know. Thanks, Ignacio From: Penland, John <Penland.John@epa.gov> Sent: Thursday, February 24, 2022 11:11 PM To: Ignacio Aguirre <IAguirre@starpakltd.com>; Pandak, Debra <Pandak.Debra@epa.gov> Cc: Yurk, Jeffrey <yurk.jeffrey@epa.gov> Subject: Daily Summary February 24, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com 1 Daily Summary Inspection start - 3:45pm (start delayed due to an emergency at the facility) Reviewed February 23, 2022 Daily Summary o Plate waste is generated at a rate of approximately 330-440 gallons per week o Soft Touch waste is generated at a rate of approximately 110-165 gallons per week o Requested DOT training records o Requested ERP training records o Requested position descriptions for employees subject to training requirements of RCRA Discussed the definition of contained for the Hazardous Secondary Materials units (see 260.10) o Requested the vapor pressure for the spent solvent and the pressure set point for the pressure relief valve for the spent solvent tank Reviewed the facility inspection checklist. This inspection checklist includes the waste containers and many of the requirements for large quantity generators of hazardous waste. o Requested the completed facility inspection checklists for the prior 3 years (2019-2022) Discussed content and disposition of the Starpak ERP o The ERP will be reviewed for compliance with the standards of 261 Subpart M and 262 Subpart M o The ERP does not include a list of emergency response equipment o According to Ms. Horak, the ERP was sent via certified mail to the local emergency response contacts. Requested these certified mail receipts Discussed documentation of corrective measures o Please upload documentation or any actions that Starpak takes to address Areas of Concern identified by EPA during this inspection. I have added a new subfolder to the OneDrive for these records. Departed Facility at 5:45pm John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 (214)665-9717 2 Pandak, Debra From: Sent: To: Cc: Subject: Attachments: Ignacio Aguirre <IAguirre@starpakltd.com> Tuesday, March 8, 2022 5:18 PM Penland, John; Pandak, Debra Yurk, Jeffrey RE: Closing Meeting Summary - February 25, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) 8540_SPEC.pdf; 7800_SPEC-1.pdf Good evening John, Attached are the cut sheets for the conservation vents, as mentioned in my previous communications, the set pressure is 0.4 psi. Thanks, Ignacio From: Penland, John <Penland.John@epa.gov> Sent: Sunday, March 6, 2022 8:18 PM To: Ignacio Aguirre <IAguirre@starpakltd.com>; Pandak, Debra <Pandak.Debra@epa.gov> Cc: Yurk, Jeffrey <yurk.jeffrey@epa.gov> Subject: Closing Meeting Summary - February 25, 2022 - FY2022 RCRA Investigation at the Starpak facility located in Houston, Texas (TXR000057513) CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders. Inspection Attendees: NAME TITLE John Penland Sr. Environmental Scientist - Lead Inspector Debra Pandak Sr. Environmental Scientist - Asst. Inspector Viktor Manjarrez Project Manager Asst. Plant Manager Ignacio Aguirre Plant Engineer Environmental Lead Karla Horak Environmental Engineer Bill Garris Independent Consultant REPRESENTING US EPA Region 6 US EPA Region 6 Starpak LTD Starpak LTD Starpak LTD Starpak LTD PHONE 214-665-9717 214-665-7565 713-201-5801 336-462-7064 EMAIL Penland.john@epa.gov Pandak.debra@epa.gov iaguirre@starpakltd.com 1 Closing Meeting Summary Meeting start - 10:12am Introduction o RCRA 3007 - This inspection was conducted under the authority of RCRA section 3007. The findings of this inspection will be documented in an inspection report which will be sent to Starpak upon completion. I strongly recommend that Starpak respond, in writing, to the findings contained in that report. o CBI - As of the conclusion of the inspection, Starpak has not asserted any claims of confidential business information for the records or photographs obtained. Should Starpak wish to make a claim of CBI, I encourage you to complete and return the CBI packet I attached to my email on Tuesday, February 22. o Process based inspection description - This inspection followed a process based inspection process. Using this method, EPA inspectors review the waste generating processes, waste characteristics, and waste management procedures to determine the applicable standards that pertain to the facility's operations. Provisional Inspection Findings o Ink Wastes Generation Description- Ink wastes are generated from two separate processes at Starpak: ink formulation and printing. Ink wastes from the blend area are generated when errors occur in formulation and are accumulated in a 55-gallon container near the ink mixers. Ink wastes from the printing operations are collected in 5-gallon buckets when ink is changed from the individual printers and carried by the operators to the PRI distillation room where they are transferred into a 55-gallon drum. Ink wastes are generated by Starpak at a rate of approximately 220 gallons per week Waste Properties- The Ink wastes are composed of a mix of n-propanol, n-propyl acetate, pigments, and ethyl acetate with a flash point below 140F Waste Disposition- The wastes are shipped through NSSI for fuel blending. Applicable requirements - Based on the disposition of the ink wastes, the waste meets the definition of solid waste. Based on its low flash point the ink wastes demonstrate the hazardous waste characteristic of flammability (D001). Due to the generating processes and the properties of the ink wastes, the ink wastes qualify for management as universal wastes under the State of Texas' paint and paint related wastes rule. The profile for this waste describes it as a D001,F003 Universal Waste. Areas of Concern: 2 containers of ink wastes were observed during this inspection. At the time of observation the containers were not marked with the words "Universal Waste - Paint and Paint-Related Wastes" and did not have their lids secured in the closed position. o Plate Waste Generation Description - Plate wastes are generated from the distillation of spent solvent from the photo etching process that Starpak uses to manufacture its printing plates. This waste is accumulated at the plate distillation unit in a 55-gallon drum before being moved to the PRI distillation prior to shipping. Waste properties - The Plate Waste is composed of benzyl alcohol, naphtha, and 2-ethylhexyl acetate with a flash point greater that 140F. The profile for this waste describes it as a Class 1 non-hazardous waste. Waste Disposition - The Plate Wastes are shipped for disposal by NSSI as a Class 1 non- hazardous waste Applicable Requirements - Based on the disposition of the plate wastes, the waste meets the definition of solid waste. As a class I solid waste, the plate waste would be subject to the reporting requirement of 30 TAC 335.6 Areas of Concern - 2  Generators of a Class I solid waste are required to notify and report annually for their generation of hazardous and class I non-hazardous waste generation under the the requirements of 30 TAC 335.6 and 335.9 o Soft Touch Wastes Generation Description - Soft Touch waste are generated from the printing operations where Soft Touch is used as a varnish for the printed products. Waste Properties - The Soft touch waste is composed of a mix of urethane and poly-isocyanate compounds in ethyl acetate. Analytical reports provided by Starpak suggest that the waste has a flash point greater than 140F. The profile for this waste describes it as a D001,F003 Universal Waste. Waste Disposition - The wastes are then shipped through NSSI for fuel blending. Applicable Requirements - Based on the disposition of the Soft Touch wastes, the waste meets the definition of solid waste. Due to the generating processes and the properties of the ink wastes, the ink wastes qualify for management as universal wastes (40 CFR 273) under the State of Texas' paint and paint related wastes rule at 30 TAC 335.262 Areas of Concern 2 containers of Soft Touch wastes were observed during this inspection. At the time of observation the containers were not marked with the words "Universal Waste - Paint and Paint-Related Wastes" o Anilox Cleaner Waste (not directly observed during the inspection) Generation Description - Anilox Cleaner is used to clean and remove ink from the anilox (the roller that applies ink to the printing plate in the press) between printing runs. The cleaner is generated as a batch when it is removed from the anilox cleaning unit. Waste Properties - The anilox cleaner is composed of potassium hydroxide, ethanolamine, 2- butoxyethanol, pigments, and water. The pH for this waste is indicated on the profile as being greater than 12.5. The profile for this waste describes it as a D002, F003, F005 Universal Waste. Waste Disposition - The waste is shipped by NSSI as a universal waste for disposal. However, the ultimate means of disposal for this waste was not discussed as of the end of this inspection. Applicable Requirements - As a declared Universal Waste, the anilox cleaner is subject to the universal waste rules of 40 CFR 273 and the Paint and Paint Related Waste Rule of 30 TAC 335.262 Areas of Concern - None, since this waste was not observed during this inspection. o Contaminated Rags Generation Description - Contaminated Rags are generated throughout the facility from general cleaning activities. The rags are accumulated in 5 gallon buckets before being transferred to large blue bins located in the PRI distillation room. Waste properties - The rags are typically contaminated with solvents n-propanol, n-propyl acetate, ethyl acetate, and inks. These contaminates have a flash point of less than 140F Waste Disposition - The contaminated rags are laundered offsite and returned to Starpak for reuse. Applicable Requirements - The waste profile for the Contaminated Rags waste stream describes it as D001, F003. Contaminated Rags are exempt from the definition of solid waste as long as they meet the exemption requirements described in 40 CFR 261.4(a)(26). Areas of Concern Containers managing contaminated rags must be labeled with the words: "Excluded Solvent-Contaminated Wipes" none of the four containers of solvent contaminated wipes observed during this inspection were appropriately labeled. Following the initial accumulation of the solvent contaminated rags, they must be placed in a container with the lid affixed so as to prevent leaks or emissions. The three large bins used for the transport and pre-transport storage of the contaminated rags is not equipped with a seal capable of preventing emissions. 3  Generators of waste excluded under this exemption must maintain a "Description of the process the generator is using to ensure the solvent-contaminated wipes contain no free liquids at the point of being laundered or dry cleaned on-site or at the point of being transported off-site for laundering or dry cleaning". This description had not been provided by Starpak prior to the conclusion of this inspection. o Dirty Solvent Generation Description - Dirty Solvent is generated from the cleaning of the printing presses and pumped via hard piping to a dirty solvent accumulation tank located in the PRI distillation area. Additional sources of the dirty solvent are from various cleaning operations throughout the facility and from filter changes on the dirty solvent piping. These additional solvent batches are accumulated in a 275-gallon totes located in the PRI distillation area. Waste Properties - Dirty Solvent is composed of n-propanol, n-propyl acetate, and ink residues (including pigments and ethyl acetate). The dirty solvent has a flash point of less than 140F. Waste Disposition - The dirty solvent is reclaimed in a solvent distillation unit and then accumulated in a reclaimed solvent tank located the PRI distillation room. This reclaimed solvent is then returned to the process where it is again used to clean the printing presses. Applicable Requirements - Based upon the generation description, the dirty solvent would meet the definition for a spent solvent. A spent solvent being reclaimed under the control of the generator is exempt from the definition of solid waste as a hazardous secondary material so long as Starpak meets the requirements for the exemption at 40 CFR 261.4(a)(23). Should Starpak decide to manage this material as Universal Waste under Texas' Paint and Paint Related Waste definition it would be prohibited from treatment (including reclamation) by 273.31. Areas of Concern Hazardous Secondary Materials are required to be managed in a manner that meets the definition of contained (40 CFR 260.10). The tote Starpak uses to accumulate dirty solvent in the PRI Distillation Area was open when observed on Tuesday, February 22, 2022. Generators of Hazardous Secondary Materials are required to provide notice as required by 40 CFR 260.42. As of this inspection, no record of notification was provided by Starpak. As part of our evaluation of the hazardous secondary materials exemption requirements, we asked for records concerning the vapor pressure of the dirty solvent and the set pressure for the dirty solvent tank's pressure relief devices. As of the conclusion of this inspection, the vapor pressure of the dirty solvent had been documented but the set pressure for the pressure relief devices equipped on the dirty solvent tank had not. o Dirty Solvent Still Bottoms Generation Description - The distillation of spent solvents from the printing process reclaims solvent by removing pigments and other contaminants as still bottoms. These still bottoms are pumped from the unit through hard piping to a 275-gallon container located on the loading dock. According to Ms. Horak, Starpak generates between 3 and 4 containers of this waste per calendar week. Waste Properties - According to the profile provided by Starpak, the distillation bottoms are composed of approximately 98% ethyl acetate with 2% pigment contaminants with a flash point less than 73F. The profile describes this waste as a D001, F003 Universal Waste. Waste Disposition - According to Mr. Aguirre, this waste is shipped to NSSI for fuel blending prior to burning for energy recovery. Applicable Requirements - Based on the Waste's disposition, the still bottoms meet the definition of solid waste. Based on its flash point of less than 73F, the waste demonstrates the hazardous waste characteristic of flammability (D001). Even if Starpak wanted to claim its spent solvent as Universal waste, as of June 11, 2020, TCEQ has modified its definition of Paint and Paint Related Waste to exclude materials derived from the reclamation of Paint and Paint 4 Related Waste under the Universal Waste Rules. Therefore, the still bottoms have been determined through this inspection to be hazardous waste. Areas of Concern Based on the NOR for the facility at the time of this inspection, Starpak does not generate hazardous waste. Therefore, Starpak has not provided notice to TCEQ that it is generating this hazardous waste. The container used for the accumulation of this waste is marked as Universal Waste, however that definition does not appear to apply to this waste. Therefore, this waste is not marked appropriately as described in 40 CFR 262.17. According to the records provided by Starpak, this waste has been shipped on multiple occasions on bills of lading but not on a hazardous waste manifest as required by 40 CFR 262.20. Therefore, Starpak has on multiple occasions offered this waste for transport without preparing a hazardous waste manifest. Piping in hazardous waste service is required to be maintained in accordance with 40 CFR 265 Subpart BB. According to Mr. Aguirre, the piping used for transferring the still bottoms from the distillation unit to the still bottom accumulation container is not subject to any fugitive emission monitoring activities. o General Facility Standards Based on its claimed rate of generation for hazardous waste (Dirty Solvent Still Bottoms), Starpak is a large quantity generator of hazardous waste and therefore required to comply with the Large Quantity Generator requirements of 40 CFR part 262. Based on its claimed rate of generation for universal waste (Ink Waste, Plate Waste, Soft Touch Waste), Starpak is a large quantify handler of universal waste and therefore required to comply with the requirements of 40 CFR 273 Subpart C. Based on its claimed rate of generation for hazardous secondary materials (Dirty Solvent), Starpak is required to comply with the requirements of 40 CFR 261.410 and 420. Areas of Concern Facilities subject to 40 CFR 261.410 and/or 40 CFR 262.255 are required to maintain adequate aisle spacing. When observed on February 22, 2022, Starpak was not maintaining adequate aisle spacing for its containers located in the PRI distillation area Starpak has provided its facility response plan. This document and the associated attachments will be reviewed for compliance with the requirements of 40 CFR 261 and 262 Subpart M. Texas requires annual reporting to STEERS for Class 1 Industrial Waste and Hazardous Waste under 30 TAC 335.6. As of this inspection, Starpak had not provided any reporting for its Class 1 Waste or its hazardous waste. Large quantity generators of hazardous waste are required to comply with the training requirements of 40 CFR 262.17. As of this inspection, Starpak has provided training records for the specific personnel requested. These records will be reviewed for compliance with the aforementioned requirements. o Next Steps Starpak will continue to provide records for evaluation by EPA. EPA will issue a final inspection report following the conclusion of this inspection. The document submission link will remain open until the inspection report is finalized. Departed Facility at approximately 1:45pm John Penland Senior Environmental Scientist (ECDSR) Enforcement and Compliance Assurance Division Waste Enforcement Branch EPA Region 6 1201 Elm St., Suite 500 Dallas, Texas 75270 5 (214)665-9717 6 SERIES 7800 End-of-Line Emergency Pressure Vent Sizes 2" (DN 50) through 24" (DN 600) Settings achieved by weight loading Reduces costly evaporation losses Provides emergency relief in the event of external fire Leakage rate of less than 1 SCFH of air at 90% of set point Patented, FEP film "Air-Cushioned Seating" Low-leak pallet design - certified test reports Conforms to the latest ATEX Directive Factory tested / certified for leakage and correct settings Available in Aluminum, Stainless Steel, Carbon Steel, and Alloy C / C276 PROTECTOSEAL OBJECTIVE The Protectoseal Series 7800, End-of-Line Emergency Pressure Vents are designed to provide emergency relief capacity beyond that furnished by the operating vents on tanks, low pressure vessels and piping in the event of external fire involvement. Vapors are relieved to atmosphere. TECHNIQUE Under normal operating conditions, the pallet assembly is closed providing a vapor-tight seal. In the event of an emergency (fire involvement of the tank) the pallet lifts to vent excess vapors thereby protecting the tank from dangerous over-pressurization. Pallet automatically closes and reseals when the pressure is reduced. Optimized Performance VentsTM Protectoseal's "Optimized Performance Vents" incorporate patented features that provide the optimum overall vent performance with regard to sealing, set point, flow and resealing (blow down). SPECIAL FEATURES Fast Inspection, Easy Maintenance. Design and light weight of entire unit permits easy, convenient handling for inspection and maintenance. Coarse mesh screen prevents entry of foreign matter into seating area. Maintains Accurate Pressure Settings. Set points are accurate to within +/- 3% based on weight per area of mean seat diameter. Air-Cushioned Seating. A flat, smooth diaphragm of FEP film is supported on both sides of an annular channel to form a floating air seal with the seat. An outer support rim assures proper seating. Low-Leakage. Vent leakage is no more than 1 SCFH at 90% of the set pressure. Sizes Available. 2" (DN 50) through 12" (DN 300) aluminum units flanged to mate with 125# ANSI and DIN PN 16 flat face flanges. All other materials mate with 150# ANSI and DIN PN 16 raised face flanges. 16" (DN 400) through 24" (DN 600) units flanged to mate with applicable ANSI or API flat face flange connections. PRO-FLOW Sizing and Selection Software. Use PRO-FLOW to select the correct size unit for pressure relief calculated in accordance with API 2000, ISO 28300, NFPA 30 and OSHA 1910.106. CONSTRUCTION A comprehensive range of materials is offered as shown in the chart below. Non-metallic (thermoplastic resin & FRP), construction available. Other materials and features can be furnished upon request. Available Options. Alternate diaphragm materials Material certifications for castings Lower than standard minimum pressure settings Mechanical or electronic indication of vent opening FEP coating Kynar coating (Kynar is a Registered Trademark of Arkema, Inc.) Special cleaning & packaging for the storage of ultrapure liquids Series Size Base Flange/ Weather- Seat Hood Pallet* Pallet Diaphragm 7800 12"-12" Aluminum Aluminum Aluminum FEP Film 7800 16"-24" Steel/316 S.S. Steel Aluminum FEP Film C7800 12"-12" Steel/316 S.S. Steel 316 S.S. FEP Film C7800 16"-24" Steel/316 S.S. Steel 316 S.S. FEP Film E7800 12"-12" Aluminum Aluminum 316 S.S. FEP Film F7800 12"-12" 316 S.S. 316 S.S. 316 S.S. FEP Film F7800 16"-24" 316 S.S. 316 S.S. 316 S.S. FEP Film M7800 12"-12" Alloy C C276 C276 FEP Film M7800 16"-24" C276 C276 C276 FEP Film * On steel and aluminum vents, weights are steel or lead. On stainless steel vents, weights are stainless steel or lead. On C276 vents, weights are C276 or lead. 2" through 12" Aluminum vents flanged to mate with 125# ANSI and DIN PN 16 flat face flanges. Steel, stainless steel and C276 units flanged to mate with 150# ANSI and DIN PN 16 raised face flanges. 16" through 24" vents flanged to mate with applicable ANSI or API flat face flange connections. www.protectoseal.com Specifications Series 7800 End-of-Line Emergency Pressure Vent Pressure Relief FEP Film Air-Cushioned Pallet Seat Dimensions shown are for reference only, contact Factory for certified drawings. DIMENSIONS & ORDERING INFORMATION Pipe Size Ht. Cat. No.* K A Width B C B.C. Dia. Dia. Holes D E G N 7802H 7802DNH 7803H 7803DNH 7804H 7804DNH 7806H 7806DNH 7808H 7808DNH 7810H 7810DNH 7812H 7812DNH 7816ASA 7816DN 7820ASA 7820API 7820DN 7824ASA 7824API 7824DN 12" DN 50 13" DN 80 14" DN 100 16" DN 150" 18" DN 200 10" DN 250 12" DN 300 16" DN 400 20" 20" DN 500 24" 24" DN 600 81/4" 210mm 101/4" 260mm 109/16" 268mm 131/8" 333mm 151/4" 387mm 165/8" 422mm 185/8" 473mm 20" 508mm 20" 20" 508mm 21" 21" 533mm 181/2" 216mm 121/4" 311mm 121/4" 311mm 141/2" 362mm 17" 432mm 223/4" 578mm 251/8" 638mm 263/4" 679mm 32" 32" 813mm 40" 40" 1016mm 113/4" 119mm 121/8" 154mm 123/8" 160mm 1211/16" 168mm 133/8" 186mm 121/4" 157mm 123/4" 170mm 165/8" 168mm 165/8" 165/8" 168mm 165/8" 165/8" 168mm 143/4" 125mm 16" 160mm 171/2" 180mm 191/2" 240mm 113/4" 295mm 141/4" 355mm 17" 410mm 211/4" 525mm 25" 231/2" 650mm 291/2" 271/2" 770mm 15/8"-11 16" Stud M16x2 165mm Stud 113/4" 171/2" 14 118mm 200mm 18 113/4" 19" 18 118mm 220mm 18 117/8" 11" 18 122mm 285mm 18 117/8" 131/2" 18 122mm 340mm 12 11" 16" 12 126mm 405mm 12 11" 19" 12 126mm 460mm 12 111/8" 231/2" 16 130mm 580mm 16 111/4" 271/2" 20 113/4" 26" 16 133mm 715mm 20 113/8" 32" 20 113/4" 30" 20 133mm 840mm 20 * Cat. No. designates Aluminum Housing & Pallets, see chart on the reverse for other materials of construction. PRESSURE AND/OR VACUUM SETTINGS (Consult factory for settings outside of STANDARD range.) Flange Size STANDARD MINIMUM SETTINGS PRESSURE ONLY Aluminum Other Materials oz./in.2 in.W.C. kPa oz./in.2 in.W.C. kPa STANDARD MAXIMUM SETTINGS PRESSURE VACUUM All Materials All Materials oz./in.2 in.W.C. kPa oz./in.2 in.W.C. kPa 12" / DN 50 13" / DN 80 14" / DN 100 16" / DN 150 18" / DN 200 10" / DN 250 12" / DN 300 16" / DN 400 18" / DN 450 20" / DN 500 24" / DN 600 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 1.00 1.73 0.43 48.00 83.04 20.68 N / A N / A N / A 48.00 83.04 20.68 N / A N / A N / A 48.00 83.04 20.68 N / A N / A N / A 48.00 83.04 20.68 N / A N / A N / A 48.00 83.04 20.68 N / A N / A N / A 48.00 83.04 20.68 N / A N / A N / A 48.00 83.04 20.68 N / A N / A N / A 11.90 20.59 15.13 N / A N / A N / A 11.90 20.59 15.13 N / A N / A N / A 18.00 13.84 13.45 N / A N / A N / A 11.00 19.03 14.74 N / A N / A N / A PROTECTOSEAL Safety Without Compromise 225 Foster Ave., Bensenville, IL 60106-1690 P 630.595.0800 F 630.595.8059 info@protectoseal.com www.protectoseal.com 2016 The Protectoseal Company V-7800/6 SERIES 8540 End-of-Line Conservation Pressure / Vacuum Breather Vent Sizes 2" (DN 50) through 12" (DN 300) Settings achieved by weight loading Reduces costly evaporation losses Leakage rate of less than 1 SCFH of air at 90% of set point Patented, FEP Film "Air-Cushioned Seating" Low-leak pallet design - certified test reports Conforms to the latest ATEX Directive Factory tested / certified for leakage and correct settings Available in Aluminum, Ductile Iron, Stainless Steel, Carbon Steel, and Alloy C / C276 PROTECTOSEAL OBJECTIVE The Protectoseal Series 8540, End-of-Line Pressure / Vacuum Conservation Vent provides both pressure and vacuum relief to maintain tank's vapor space within safe operating parameters. Vent settings minimize loss of product. Under pressure venting conditions, tank vapors are expelled to atmosphere. TECHNIQUE Pallets in the vent housing allow intake of air and outflow of vapors as the tank normally breathes in and out. Pallets open and close to permit only the intake or outlet relief necessary to remain within permissible working pressures and avoid damage to tank Peripheral pallet assembly guides and center pallet stem guides insure proper alignment of pallet assembly on the seat and smooth lifting and reseating action. Optimized Performance VentsTM Protectoseal's "Optimized Performance Vents" incorporate patented features that provide the optimum overall vent performance with regard to sealing, set point, flow and resealing (blow down). SPECIAL FEATURES Fast Inspection, Easy Maintenance. Design and light weight of entire unit permits easy, convenient handling for inspection and maintenance. Maintains Accurate Pressure Settings. Set points are accurate to within +/- 3% across the entire range of available settings. Air-Cushioned Seating. A flat, smooth diaphragm of FEP film is supported on both sides of an annular channel to form a floating air seal with the seat. An outer support rim assures proper seating. Automatic Condensate Drainage. Self-draining housing body and drip rings keep condensate away from seating surfaces. Vent is protected from freezing, binding and clogging. Low-Leakage. Vent leakage is no more than 1 SCFH at 90% of the set pressure. Pressure tested against leakage through castings and gasketed joints. Sizes Available. 2" (DN 50) through 12" (DN 300) sizes. Aluminum flanged to mate with 125# ANSI and DIN PN 16 flat face flanges. All other materials mate with 150# ANSI and DIN PN 16 raised face flanges. Other drilling patterns are also available upon special request. PRO-FLOW Sizing and Selection Software. Use PRO-FLOW to select the correct size unit for pressure and vacuum relief calculated in accordance with API 2000, ISO 28300, NFPA 30 and OSHA 1910.106. CONSTRUCTION A comprehensive range of materials is offered as shown in the chart below. Non-metallic (thermoplastic resin & FRP) construction available. Other materials and features can be furnished upon request. Available Options. Alternate diaphragm materials Material certifications for castings Lower than standard minimum pressure and vacuum settings Higher than standard maximum vacuum settings Mounting connections added to vacuum port Steam jacketing available Electronic indication of vent opening FEP coating Kynar coating (Kynar is a Registered Trademark of Arkema, Inc.) Special cleaning & packaging for the storage of ultrapure liquids Series Housing Pallet Pallet Weight Diaphragm Material 8540H Aluminum 356 Aluminum FEP Film Steel or Lead C8540H Ductile Iron 316 S.S. FEP Film Steel or Lead CS8540H Cast Steel 316 S.S. FEP Film Steel or Lead F8540H 316 S.S. 316 S.S. FEP Film S.S. or Lead RE8540H Aluminum 356 316 S.S. FEP Film Steel or Lead M8540H Alloy C C276 FEP Film C276 or Lead Note: Aluminum flanged to mate with 125# ANSI and DIN PN 16 flat face flanges. All other materials mate with 150# ANSI and DIN PN 16 raised face flanges. www.protectoseal.com Specifications Dimensions shown are for reference only, contact Factory for certified drawings. Series 8540 End-of-Line Conservation Pressure / Vacuum Breather Vent DIMENSIONS & ORDERING INFORMATION Flange Ht. Width Length B.C. Cat. No.* K A B C D Dia. Dia. Holes G E N 8542H 12" 14" 191/2" 151/2" 143/4" 16 3/4" 14 8542DNH 8543H DN 50 13" 356mm 163/4" 241mm 111/2" 1394mm 125mm 165mm 18mm 14 171/2" 16" 171/2" 3/4" 14 8543DNH 8544H DN 80 14" 425mm 181/2" 292mm 13" 1445mm 160mm 200mm 18mm 18 201/4" 171/2" 19" 3/4" 18 8544DNH 8546H DN 100 16" 470mm 231/8" 330mm 17" 1514mm 180mm 220mm 18mm 18 261/2" 191/2" 11" 7/8" 18 8546DNH 8548H DN 150" 587mm 18" 25" 432mm 191/2" 1673mm 240mm 285mm 22mm 18 311/4" 113/4" 131/2" 7/8" 18 8548DNH 8550H DN 200 635mm 10" 27" 495mm 231/4" 1794mm 295mm 340mm 22mm 12 371/4" 141/4" 16" 1" 12 8550DNH 8552H 8552DNH DN 250 12" DN 300 686mm 301/2" 775mm 591mm 251/2" 648mm 1946mm 355mm 405mm 26mm 12 41" 17" 19" 1" 12 1041mm 410mm 460mm 26mm 12 * Cat. No. designates Aluminum Housing & Pallets, please refer to chart on the reverse for other materials of construction. PRESSURE AND/OR VACUUM SETTINGS (Consult factory for settings outside of STANDARD range.) Flange Size STANDARD MINIMUM SETTINGS PRESSURE & VACUUM Aluminum Other Materials oz./in.2 in.W.C. kPa oz./in.2 in.W.C. kPa STANDARD MAXIMUM SETTINGS PRESSURE VACUUM All Materials All Materials oz./in.2 in.W.C. kPa oz./in.2 in.W.C. kPa 12" / DN 50 13" / DN 80 14" / DN 100 16" / DN 150 18" / DN 200 10" / DN 250 12" / DN 300 0.50 0.87 0.22 0.75 1.30 0.32 0.50 0.87 0.22 0.75 1.30 0.32 0.50 0.87 0.22 0.75 1.30 0.32 0.50 0.87 0.22 0.75 1.30 0.32 0.50 0.87 0.22 0.75 1.30 0.32 0.50 0.87 0.22 0.75 1.30 0.32 0.50 0.87 0.22 0.75 1.20 0.32 48.00 83.04 20.68 11.00 19.03 4.74 48.00 83.04 20.68 11.00 19.03 4.74 48.00 83.04 20.68 17.40 12.80 3.19 48.00 83.04 20.68 18.00 31.14 7.76 48.00 83.04 20.68 18.00 31.14 7.76 48.00 83.04 20.68 19.00 32.87 8.19 48.00 83.04 20.68 23.00 39.79 9.91 C8542H C8543H C8544H C8546H C8548H C8550H C8552H CS8542H CS8543H CS8544H CS8546H CS8548H CS8550H CS8552H F8542H F8543H F8544H F8546H F8548H F8550H F8552H RE8542H RE8543H RE8544H RE8546H RE8548H RE8550H RE8552H ADDITIONAL PRODUCTS FROM PROTECTOSEAL Series 18540 Series 7800 Series 4950 Series 830 Pipe-Away Pressure Vacuum Relief Vent for applications that require hazardous vapors be processed into manifolded piping and not released into the atmosphere. Emergency Vent protects tanks against rupture or explosion resulting from excessive internal pressure caused by exposure to fires. Vent Line / In-Line Parallel Plate Flame Arrester is designed for installation in open vent pipe or bleed lines from storage or processing tanks. Suitable for NEC Group D (IEC Group IIA) vapors. Combination Pressure / Vacuum Relief Vent & Flame Arrester provides pressure and vacuum relief as well as protection from propagation of externally introduced flames. Suitable for NEC Group D (IEC Group IIA) vapors. PROTECTOSEAL Safety Without Compromise 225 Foster Ave., Bensenville, IL 60106-1690 P 630.595.0800 F 630.595.8059 info@protectoseal.com www.protectoseal.com 2016 The Protectoseal Company V-8540/4