Document zzqENm9oN03Nxow3dma1egJ8g
VINELAND MUNICIPAL ELECTRIC UTILITY INSPECTION REPORT
Inspection Date(s):
17 April 2024
Inspection Announced: No
Facility or Site Name: Facility/Site Physical Location:
(city, state, zip code) Mailing address (if different from above): cility/Site Contacts:
Website:
Vineland Municipal Electric Utility 211 N West Ave.
Vineland, NJ 08360
Robert A. Napier, PE Superintendent of Electric Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623 https://utilities.vinelandcity.org/
RCRA ID Number:
NJD000558155
Latitude, Longitude:
39.49107205844595, -75.03484579844569
Facility/Site Personnel Participating in Inspection:
Robert A. Napier
Superintendent Distribution
Michael Neff
Storekeeper
Ary Salazar
Storekeeper 2 [out of office during inspection
(856) 794-4000 x4308 mneff@vinelandcity.org (856) 794-4000 x4311 mneff@vinelandcity.org
Inspector(s):
Carl F. Plssl
US EPA, Enforcement Officer/Engineer
Plossl.Carl@epa.gov (212) 637-4088
Additional Inspection Report Elements:
Photos
Inspection Report Author:
Carl F. Plssl
CARL PLOSSL
Digitally signed by CARL PLOSSL Date: 2024.06.25 16:27:00 -04'00'
Supervisor Leonard Grossman
LEONARD GROSSMAN
Digitally signed by LEONARD GROSSMAN Date: 2024.06.25 16:42:41 -04'00'
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SECTION I - INTRODUCTION Purpose of the Inspection Objective A Compliance Evaluation Inspection (CEI) was conducted to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management. Background The facility has been previously inspected for RCRA compliance in 2004, with a finding of no action, and has had a notification history as a small and very small quantity generator (last notification in 16 Feb 2021 as a VSQG). A review of the facility's waste manifest records show generator status variation from VSQG to SQG to LQG (on a monthly basis). The facility was last inspected under the Clean Air Act in 2023 and under the Clean Water Act in 2022. The facility is in an environmental justice area.
Opening Conference 17 April 2024. I, EPA Region 2 RCRA inspector Plssl, arrived at the main entrance to the Vineland Municipal Electric Utility at ~1:25 pm for an unannounced inspection of the municipal utility. I announced and identified myself at the reception area and was connected with Robert A. Napier, PE, Superintendent of Electric Distribution for the Vineland Municipal Electric Utility. Eng. Napier was quite familiar the nature of federal and state compliance inspections but not 2|Page
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those conducted pursuant to RCRA federal and state hazardous waste regulations. We discussed the facility past and current operations, waste management and disposal practices, and the nature of RCRA inspections. We then began a walk through and inspection of the main building, several smaller buildings, and an outdoor waste management area. Facility/Site Description https://utilities.vinelandcity.org/ https://utilities.vinelandcity.org/distribution/
From Clean Energy Authority: https://www.cleanenergyauthority.com/electric-utility/vineland-municipal-electric-utility
Vineland Municipal Electric Utility is the only municipally-owned electric generating utility in the State of New Jersey. VMEU has been providing electric service to the residents of the City of Vineland since 1899. The Electric Utility's generating capacity is 132,900 kW Summer/143,400 kW Winter. Additionally, the Electric Utility maintains an interconnection with Atlantic City Electric, and membership in the Pennsylvania-New Jersey-Maryland (PJM) Interconnection which includes the major investor owned electric utilities throughout the Mid-Atlantic and Midwest Regions. VMEU also receives a monthly allocation of 4,300 kW of PASNY Hydro Power. Thus, the Electric Utility is able to meet the demands of its users even in times of emergency. Google Maps shows the inspected facility as at:
70 NW Ave, Vineland, New Jersey. Eng. Napier lists the address as:
Vineland Municipal Utilities, Electric Distribution Division, 415 N. West Ave. Vineland NJ 08360
RCRAInfo lists the address as: 211 N West Ave., Vineland, NJ 08360
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According to Eng. Napier, et. al.: General o Facility has been operating since 1899 and has been located at this site since ~1953. o Eng. Napier has worked for the Electric Utility since ~1987. o 54 employees work at this location, with three 8-hour shifts covering 7-days/week. o The majority of the facility operation involve office functions for the Electric Utitity's various operations and other facilities, managing the Electric Utility supplies with, and, to a lesser extent, managing waste equipment from this and other Electric Utility operations. o Warehouse Shopkeepers manage the spent, damaged, and surplus equipment and other materials the determination as to dispositions: transfer to other Electric Utility facilities; resale as viable equipment; disposal as scrap, used oil, recycled, solid waste, hazardous, and universal wastes Large quantities of irregularly generated hazardous wastes primarily consist of transformers of more that 25-35 years of service: o Waste codes from manifests: D001 D008 D018 D039. Other hazardous waste generation o Potassium cyanide, P098 waste code, one-time disposal in Aug 2023 o Spent fluorescent lamps o Spent high intensity lamps o Old paints and spent cleaning and painting solvents o Spent aerosol cans o Spent lead acid, NiCd, and lithium batteries o E-wastes o Old pipes with lead insulation or threads o Parts washers (no available haz waste determination) Likely: GRRRTMSuper Concentrated Cleaner and Degreaser (see SDS attachment) May be contaminated with: Cable Clean High Voltage Splice and Termination Cleaner (see SDS attachment) trans-1,2-dichloroethylene, 1,1,2,2-tetrafluoro-1(2,2,2-trifluoroe thoxy)ethane Flash Point <140F May be contaminated with other chlorinated solvents Other regulated wastes o Used oil Waste dispositions o Universal waste disposal records were unavailable o Manifests and LDR forms were unavailable o No special management for broken fluorescent and high intensity lamps o Spent high intensity lamps were staged for scrap disposal
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Facility originally notified as a large quantity generator (1984) and renotified in 2021, and is operating, as a very small quantity generator. In 2023, the facility averaged some 1,354-lbs/month, with some 2,905-lbs/month in September-December 2023.
Additional records requested during inspection: o Universal waste disposal records (Appendix 3) o Transformer disposal information 2023-2021 (Appendix 3)
Additional records/information requested by phone/email after inspection: o Spent lamps in roll-off/dumpster determinations and disposition (Appendix 4)
Vineland Municipal Electric Utility
Manifest Date Waste QtyUnits
12/15/2023 9,200 Pounds
9/11/2023
20 Pounds
9/11/2023
250 Pounds
9/11/2023
110 Pounds
9/11/2023
40 Pounds
9/11/2023 2,000 Pounds
8/28/2023
800 Pounds
8/28/2023
10 Pounds
8/28/2023
10 Pounds
8/28/2023
305 Pounds
8/28/2023
2 Pounds
5/30/2023
453 Pounds
5/10/2023
140 Pounds
5/10/2023
800 Pounds
4/24/2023 2,102 Pounds
7/20/2022
40 Pounds
4/28/2021 4/28/2021
570 Pounds 630 Pounds
4/28/2021 2,620 Pounds
4/28/2021
240 Pounds
9/19/2019
160 gallons
Waste (kg) Waste Codes 4,173 D001 D008 D018 D039 9 D001 D002 113 D001 D007 50 D002 18 D005 D011 D040 U226 U228 907 D007 363 D001 5 D001 D003 5 D001 D007 138 D002 1 D003 P098 205 D002 D008 64 D018 363 D018 953 D002 D008 18 D009 U151 259 D001 286 D001 D002 1,188 D002 109 D040 605 D002
TSDF ID OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 OHD066060609 PAD987367216 NJD002200046 NJD002200046 PAD987367216 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 PAD067098822
MTN* 024947263JJK 024947230JJK 024947230JJK 024947230JJK 024947230JJK 024947230JJK 024947175JJK 024947175JJK 024947175JJK 024947175JJK 024947175JJK 025305017JJK 025123346JJK 025123347JJK 025307657JJK 023587610JJK 022254871JJK 022254871JJK 022254871JJK 022254871JJK 018901052JJK
Total Waste/
lbs/
shipment Units month
9,200 lbs 2,941 lbs
2,420 lbs 5,357 lbs
1,127 lbs
381 lbs
1,393 lbs 2,102 lbs
40 lbs
2,692 lbs 230 lbs 3 lbs
4,060 lbs 1,334 lbs
211 lbs
LQG
LQG
SQG LQG SQG SQG
Code Description
D001 D002 D003 D007 D008 D009 D011 D018 D040 U151 U226 U228 P098
IGNITABLE WASTE CORROSIVE WASTE REACTIVE WASTE CHROMIUM LEAD MERCURY SILVER BENZENE TRICHLORETHYLENE MERCURY
Ethane, 1,1,1-trichloro TRICHLORETHYLENE Potassium cyanide
VSQG
SECTION II - OBSERVATIONS
The accompanying VINELAND MUNICIPAL ELECTRIC UTILITY INSPECTION REPORT PHOTO ALBUM.pptx document is the complete set of inspection observations made during the facility walkthrough with Eng. Napier.
SECTION III - AREAS OF CONCERN
Concerns Facility, at times, generated in excess of 1,000-kg/month of hazardous waste without meeting the large quantity generator requirements
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Hazardous waste transformers did not meet labeling and other requirements, including: o Accumulation start dates. o Weekly inspections of container storage area. o Labeling as "Hazardous Waste." o Labeling with indication of the nature of the hazard (i.e., ignitable/flammable, lead/toxic, benzene/toxic/carcinogen, tetrachloroethylene/toxic/carcinogen).
Certain spent hazardous waste lamps, located during the inspection in an open, roll-off/dumpster, were managed and designated for disposal as non-hazardous scrap metal. o Corrected post inspection (see Appendices).
May have failed to make a hazardous waste determination on: o "BAD" welding gas cylinders/tanks stored behind warehouse. o Soil contaminated with transformer oils. o Spent parts washer solvents (based on possible contamination by chlorinated spray solvents in regular use). o Spent aerosol cans.
Universal Waste issues: o Some universal waste lamps were not stored in containers. o Universal waste lamps containers were not closed. o Universal waste lamps were stored in unlabeled containers, i.e., not labeled or marked clearly with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." o Universal waste batteries (i.e., each battery), or a container in which the batteries are contained, were not labeled or marked clearly with any one of the following phrases: "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies);" o No demonstration of the length of time that the universal waste had been accumulated from the date it becomes a waste or was received. Accumulation in excess of one year. o Employee universal waste education did not adequately train in the proper handling appropriate to the type(s) of universal waste handled at the facility.
Used oil containers not labeled as "USED OIL."
Closing Conference
Eng. Napier and I reviewed my findings and we discussed any follow up. Eng. Napier said that he would email me the requested documents shortly (see Appendices). We agreed that we would correspond by email regarding the spent lamps, if any, in the roll-off/dumpster (presence subsequently confirmed via email).
INSPECTION PHOTOGRAPHS: See VINELAND MUNICIPAL ELECTRIC UTILITY INSPECTION REPORT PHOTO ALBUM.pptx
UNIVERSAL WASTE REGULATIONS: See Appendix 1
FOLLOW UP EMAILS: See Appendix 2
PROVIDED RECORDS: See Appendix 3
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Appendix 1: Certain, Applicable Universal Waste Regulations
Title 40 Chapter I Subchapter I Part 273 Small quantity handler of universal means a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time.
A small quantity handler of universal waste is: (a) Prohibited from disposing of universal waste; and (b) Prohibited from diluting or treating universal waste, except by responding to releases as provided in 40 CFR 273.17; or by managing specific wastes as provided in 40 CFR 273.13.
Lamps. A small quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:
(1) A small quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.
(2) A small quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions.
A small quantity handler of universal waste must label or mark the universal waste to identify the type of universal waste as specified below:
(a) Universal waste batteries (i.e., each battery), or a container in which the batteries are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste-- Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies);"
(e) Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)".
A small quantity handler of universal waste may accumulate universal waste for no longer than one year from the date the universal waste is generated, or received from another handler, unless the requirements of paragraph (b) of this section are met. A small quantity handler of universal waste who accumulates universal waste must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. The handler may make this demonstration by:
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(1) Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received; (2) Marking or labeling each individual item of universal waste (e.g., each battery or thermostat) with the date it became a waste or was received; (3) Maintaining an inventory system on-site that identifies the date each universal waste became a waste or was received; (4) Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received; (5) Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or (6) Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. A small quantity handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.
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Appendix 2: Follow Up Email Chain
From: Napier Robert <rnapier@vinelandcity.org> Sent: Monday, April 29, 2024 4:19 PM To: Plossl, Carl <Plossl.Carl@epa.gov> Subject: FW: Site Inspection, Vineland Municipal Utilities, Electric Distribution Division, Wednesday April 17, 2024
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links.
Carl My apologies, I thought I sent this out Friday at 2:19pm but it looks like it never went out. We went through our fixture disposal roll off. You were correct there were bulbs in about 45% of the fixtures. I used this as a teaching moment for our staff, but we did remove 89 bulb form 199 fixtures. Please see attached photos showing work in progress. All bulbs will be packaged up and recycled soon.
Robert A. Napier Superintendent Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
From: Napier Robert Sent: Monday, April 22, 2024 3:56 PM To: 'Plossl, Carl' <Plossl.Carl@epa.gov> Subject: RE: Site Inspection, Vineland Municipal Utilities, Electric Distribution Division, Wednesday April 17, 2024
Carl Attached is information concerning bulb recycling. We did not recycle any last year, but attached are 2020 through 2022.
Attached is a photo from our warehouse showing boxed bulbs and tubes for recycling, and a photo of our file drawer showing transformer disposal documentation.
Please let me know if you need anything else.
Thank you for your assistance and instruction.
Robert A. Napier Superintendent Distribution
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Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
From: Napier Robert Sent: Monday, April 22, 2024 11:58 AM To: 'Plossl, Carl' <Plossl.Carl@epa.gov> Cc: Boyle John <jboyle@vinelandcity.org>; Hague Steve <shague@vinelandcity.org> Subject: RE: Site Inspection, Vineland Municipal Utilities, Electric Distribution Division, Wednesday April 17, 2024
Carl Please find attached transformer disposal information 2023-2021
Let me know if you need additional years.
Robert A. Napier Superintendent Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
From: Plossl, Carl <Plossl.Carl@epa.gov> Sent: Monday, April 22, 2024 11:35 AM To: Napier Robert <rnapier@vinelandcity.org> Cc: Boyle John <jboyle@vinelandcity.org>; Hague Steve <shague@vinelandcity.org> Subject: RE: Site Inspection, Vineland Municipal Utilities, Electric Distribution Division, Wednesday April 17, 2024
Confirmed. Carl **************************************************************** CARL F. PLSSL Environmental Engineer, Enforcement Officer plossl.carl@epa.gov Direct Dial: (212) 637-4088 Fax: email Mobile: (646) 567-0597 **************************************************************** U.S. Environmental Protection Agency Enforcement and Compliance Assurance Division RCRA Compliance Branch, RCRA Senior Enforcement Team 290 Broadway, 21st Floor NYC, NY 10007-1866 ****************************************************************
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From: Napier Robert <rnapier@vinelandcity.org> Sent: Monday, April 22, 2024 11:23 AM To: Plossl, Carl <Plossl.Carl@epa.gov> Cc: Boyle John <jboyle@vinelandcity.org>; Hague Steve <shague@vinelandcity.org> Subject: Site Inspection, Vineland Municipal Utilities, Electric Distribution Division, Wednesday April 17, 2024
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Carl This is a follow up from our site inspection for the Vineland Municipal Utilities, Electric Distribution Division, 415 N. West Ave. Vineland NJ 08360, Wednesday April 17, 2024. Thank you for your time, insight and your calm and courteous demeanor during our site inspection. We are reviewing your suggestions and will be implementing some updates to our labeling and storage. We do have centralized transformer disposal records, in our main office area. Can you please confirm this is the correct email address, and which is the best method for submitting some of the scanned documentation you requested. Thank you again for your guidance. Robert A. Napier Superintendent Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
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Appendix 3: Additional Records Provided Post Inspection See: Attached document Bulb Recycle 2022-20.pdf [2020-2022]
Carl Attached is information concerning bulb recycling. We did not recycle any last year, but attached are 2020 through 2022.
Attached is a photo from our warehouse showing boxed bulbs and tubes for recycling, and a photo of our file drawer showing transformer disposal documentation.
Please let me know if you need anything else.
Thank you for your assistance and instruction.
Robert A. Napier Superintendent Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
Vineland XFMR Dis Vineland XFMR Dis Vineland XFMR Dis Vineland XFMR Dis Vineland XFMR Dis
See: Attached documents 2022B.pdf
2022A.pdf
2021D.pdf
2021C.pdf
2021B.pdf
Carl
Vineland XFMR Dis Vineland XFMR Dis Vineland XFMR Dis
2021A.pdf
2023B.pdf
2023A.pdf
Please find attached transformer disposal information 2023-2021
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Let me know if you need additional years. Robert A. Napier Superintendent Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
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Appendix 4: Post Inspection Facility Reports We went through our fixture disposal roll off. You were correct there were bulbs in about 45% of the fixtures. I used this as a teaching moment for our staff, but we did remove 89 bulb form 199 fixtures. Please see attached photos showing work in progress. All bulbs will be packaged up and recycled soon. Robert A. Napier Superintendent Distribution Vineland Municipal Electric Utility rnapier@vinelandcity.org (856) 794-4000 x4304 Fax (856) 405-4623
See VINELAND MUNICIPAL ELECTRIC UTILITY POST INSPECTION REPORT & PHOTOS.pptx
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