Document zzgwaYdE55z6exgNrp2RbRNq7

RCRA Compliance Branch INSPECTION REPORT Inspection Date(s): Facility or Site Name: Facility/Site Physical Location: (City, state, zip code) Mailing address (if different from above): Facility/Site Contact: RCRA ID Number: Inspector: Areeba Khan Supervisor: Derval Thomas 6/22/2023 Frequency Electronics 55 Charles Lindbergh Blvd Mitchel Field, NY 11553 N/A Dennis Montano Dennis.montano@freqelec.com (516) 376- 9090 NYD001321611 Inspection Announced: No Facilities Manager AREEBA KHAN Date: 2023.08.21 15:02:18 -04'00' Digitally signed by AREEBA KHAN DERVAL THOMAS Digitally signed by DERVAL THOMAS Date: 2023.08.21 15:55:24 -04'00' SECTION I - INTRODUCTION Purpose of the Inspection Objective The purpose of the inspection was to perform a Resource Conservation and Recovery Act (RCRA) comprehensive evaluation inspection (CEI) at this facility. The inspection was conducted by EPA RCRA inspector Areeba Khan. Opening Conference EPA Region 2 RCRA inspector Areeba Khan arrived at Frequency Electronics on June 22, 2023, for an unannounced inspection. I was greeted by the receptionist in the front lobby. The receptionist called Dennis Montano the facility's manager to the lobby. I presented my credentials to Mr. Montano and informed him that this was an EPA inspection to determine the facility's compliance with RCRA regulations. The scope of the inspection was to conduct a compliance evaluation inspection (CEI). Facility/Site Description Frequency Electronics is a satellite and telecommunicating manufacturing company. The company has four subsidiaries located across the United States. The location I inspected was 1 their FEI Communications Inc and FEI Government Systems Inc located in Uniondale, New York. This facility designs, develops, and manufactures electronics for satellites and commercial applications. The hazardous waste generated by the facility is the following hazardous waste: epoxies, isopropyl alcohol, ammonium hydroxide, hydrogen peroxide, and cyanide. The facility also generates deionized water with a mixture of oil containing traces of lead, which is nonhazardous. The facility does not generate universal waste. The hazardous and non-hazardous waste generated are stored in 55-gallon drums. At this location, the facility has five satellite accumulation areas (SAA) and three central storage areas (CSA). The facility has a consultant whose name is Tom Petralia at Gianco Environmental Services (GES) and he provides specialized compliance and training. The hazardous waste was arranged by GES and picked up by AARCO Environmental Services. This location also partakes in military contract work. At this location, Frequency Electronics has 135 employees. The hours of operation are Monday through Friday 7:30 am to 5:15 pm. After review of the manifest information and statements made by Mr. Montano, the facility was determined to be a Small Quantity Generator (SQG) of hazardous waste at the time of the inspection. SECTION II - OBSERVATIONS High Rail Area (SAA) In the high rail area, the facility manufactures circuit boards. Mr. Montano stated this area is one of their satellite accumulation areas. The facility representative stated that the facility conducts weekly inspections which were documented in a log nearby the drum. Inside the high rail area there was one 55-gallon drum containing D001 waste (isopropyl alcohol) that was labeled and grounded. However, the funnel attached to the drum had no gasket and was therefore not closed. Lapping Area (SAA) In the lapping area, the facility as a part of their manufacturing process creates crystals from raw material. The facility would then take the crystals and grind them down to be used in their products. During the grinding process of the crystals the waste generated is D002 (cyanide) waste. Mr. Montano showed me inside the lapping area. The lapping area is one of their satellite accumulation areas. The following was observed: One 75-gallon drum containing D002 waste that was labeled and had a funnel on top of the drum that was locked; therefore, it was closed. Conducts weekly inspections which were documented in a log nearby the drum. There was also a side room in the area that contained the following: One 75-gallon drum that was empty. Three 75-gallon drum that were closed, had placards, and had a hazardous waste label. 2 Crystal Prep Area (SAA) Mr. Montano stated the crystal prep area is where the facility preps the crystal. The facility representative stated that they conduct weekly inspections which were documented in a log nearby the drum. The crystal prep area is one of their satellite accumulation areas. Inside the crystal prep area it contained the following: One 75-gallon drum that contained hydrogen peroxide and amonium peroxide which were labeled and closed. One 75-gallon drum that contained D001 (isopropyl alchol) waste that was labeled, grounded and the funnel on top of the drum had no gasket; therefore, it was not closed. Lower-Level Production (SAA) The Lower-Level Production was another one of their satellite accumulation areas. Lower-Level Production was located in the main building on the basement floor. Inside the lower-level production area there was one 75-gallon drum that was empty. Mr Montano explained that the drum is used as a satellite accumulation area to contain D001 waste (alchol epoxies). The facility representative stated that the facility conducts weekly inspections. Central Storage Area (Solids) Mr. Montano explained that this central storage area contained solid hazardous waste. The central storage area had a fire extinguisher present but there was no phone number listed in case of an emergency. The facility representative stated that the facility conducts weekly inspections. The hazardous waste observed was expired materials (epoxies) and lab packs kept in the original container. Manufacturing Area (SAA) Mr. Montano stated that in the manufacturing area the facility cuts the material (lead) to be used in making the circuit boards. The manufacturing area is one of their satellite accumulation areas. Inside the manufacturing area there was one 55-gallon drum containing non-hazardous waste that was labeled, dated, and closed. Central Storage Area (Liquids) Mr. Montano explained that this central storage area contained liquid hazardous waste. The central storage area had a fire extinguisher present but there was no phone number listed in case of an emergency. The hazardous waste observed was as follows: Two 75-gallon drum that was empty, grounded, closed, placards and labeled. One 55- gallon drum of non-hazardous waste that was closed and dated 6/2022. Mr Montano changed the date in front of me to 6/2023. 3  One lab pack that was empty. One sodium hydroxide product container that was empty. Weekly Inspections log documented. Outside Central Storage Area There was one central storage area located outside the main building. Mr. Montano explained that this central storage area is used to store their hazardous waste however there none at the time of the inspection. The central storage area had no fire extinguisher present and there was no phone number listed in case of an emergency. However, all the containers were empty. Universal Waste: Mr. Montano stated that there was no universal waste, all the lightbulbs were changed to LED. Records Review Basic Plan After review of the emergency response plan, there were no discrepancies. Manifests and Land Disposal Restrictions After review of the manifest and land disposal restriction documentation, there were no discrepancies. Personnel Training After reviewing the facility's records I determined there was sufficient personnel training. Arrangement with Local Authority The facility representative stated that their consultant sent out the letter and will follow up. SECTION III - AREAS OF CONCERN Regulatory Concerns 1. Pursuant to 6 NYCRR 373-3.9(d)(1), management of containers. (1) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste. a. At the time of the inspection, there were one 75-gallon drum containing D001 waste (isopropyl alchol) located in the high rail area that had a funnel but there was no gasket, therefore it was not closed. b. At the time of the inspection, there were one 75-gallon drum containing D001 waste (isopropyl alcohol) located in the crystal prep area that had a funnel but there was no gasket, therefore it was not closed. 4 On August 4, 2023, Mr. Montano followed up in an email regarding the area of concerns. Mr. Montano attached to the email a photo showing a gasket attached to the funnel (Figure 1). (Figure 1: Shows a funnel with a gasket on top of a 55-gallon drum.) 2. Pursuant to 6 NYCRR 372.2(a)(8)(iii)(e)(2)(i) The name and phone number of the emergency coordinator must be posted next to the telephone. a. At the time of the inspection, there were no name and phone number posted near the three central storage areas. On August 3, 2023, Mr. Montano followed up in an email regarding the area of concerns. Mr. Montano stated: "Here is the emergency telephone numbers along with the locations of the inspection logs. The photos come first then the location of the inspection logs." 5 (Figure 2: Phone numbers located on the outside central storage area door.) 6 (Figure 3: Phone numbers located on the liquids central storage area door.) (Figure 4: Phone numbers located inside of the solids central storage area). 7 3. Pursuant to 6 NYCRR 373-3.3(g)(1)(i), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (i) arrangements to familiarize police, fire departments and emergency response teams with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to and roads inside the facility, and possible evacuation routes. a. At the time of the inspection, the facility had not made arrangements with the local police department about the type of waste handled at the owner or operator's facility and the potential need for the services. On August 1, 2023, Mr. Montano followed up in an email regarding the area of concerns. Mr. Montano stated: "Please see the attached return receipts for the letters of notification to the three local authorities. The fire department did not sign the receipt, so I downloaded proof of delivery from USPS website." 4. Pursuant to 6 NYCRR 373-3.3(g)(1)(ii), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (ii) where more than one police and fire department might respond to an emergency, agreements designating primary emergency authority to a specific police and a specific fire department, and agreements with any others to provide support to the primary emergency authority; a. At the time of the inspection, the facility had not made arrangements with the local police department about the type of waste handled at the owner or operator's facility and the potential need for the services. On August 1, 2023, Mr. Montano followed up in an email regarding the area of concerns. Mr. Montano stated: "Please see the attached return receipts for the letters of notification to the three local authorities. The fire department did not sign the receipt, so I downloaded proof of delivery from USPS website." 5. Pursuant to 6 NYCRR 373-3.3(g)(1)(iv), The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at the owner or operator's facility and the potential need for the services of these organizations: (iv) arrangements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions or releases at the facility. i. At the time of the inspection, the facility had not made arrangements to familiarize local hospitals with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility. 8 On August 1, 2023, Mr. Montano followed up in an email regarding the area of concerns. Mr. Montano stated: "Please see the attached return receipts for the letters of notification to the three local authorities. The fire department did not sign the receipt, so I downloaded proof of delivery from USPS website." General Concerns There were no regulatory concerns at the time of the inspection. Closing Conference The closing conference was conducted by EPA inspector Areeba Khan and the facility representative Dennis Montano. Inspector Khan explained to the facility representative the areas of concerns. Mr. Montano stated that he will follow up and tend to the areas of concern immediately. 9