Regulations and Policies

RCRA (HAZARDOUS WASTE) INSPECTION REPORT

LARGE QUANTITY GENERATOR

Name(s) of inspector(s): ___ Janet Marsh ______________________________.

Date(s) of inspection: April 1-5, 2020 Complaint Number: Not applicable. .

Previous RCRA inspection: February 17, 20018 Active RCRA enforcement: None .

SITE INFORMATION

EPA ID Number: CTD012345677 .

Site Name: InspectorGadgets, Inc. .

Street Address: 10 Daffodil Street, New Haven, CT 06106

Mailing Address: Same .

Contact Name(s) and Title: Eli Manning, President .

Contact Phone #: (203) 555-1010 Date established at present location: January 3, 1981. .

Property owned/leased: Owned Previous occupants of site: Lucky Copper Company .

STATUS (actual – operating)

CESQG (<100kg/mo) X Large Quantity Handler Universal Waste Recycle/Reclaim

SQG (100 – 1000kg/mo) __ Small Quantity Handler Universal Waste Burner/Blender

X Large Quantity Generator (>1000kg/mo) Transporter

Episodic Generator

Receiving waste from off-site: .

Other: .

NOTIFICATION

Notification as:

Hazardous Waste: Large Quantity Generator. .

Universal Waste (if applicable): Mercury containing lamps, computer monitors, batteries, thermostats

Any discrepancies between notification & actual operations: Yes (comments below) X No

If yes, has a status change been requested: Yes No

Comments: The company has been working with a vendor to change products to a less hazardous solvent cleaner. To date, bench testing has been unsuccessful and company has been working to find additional consultants to support the work.

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TYPE(S) OF WASTE HANDLED

X Ignitables (D001) ___F or K listed wastes X Used Oil

X Corrosives (D002) P or U listed wastes CT Regulated Wastes

Reactives (D003) Precious Metals Unknown Wastes

X TCLP (D004 – D043) Hazardous Scrap Metals

XUniversal Wastes, type: Mercury containing lamps batteries and thermostats. Old Computer monitors.

Other: .

Comments: .

HANDLING METHOD (actual)

X Containers Tanks - aboveground

___ Wastewater Treatment Tanks – underground

Drip pads Containment building

Other: .

Comments: .

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SITE DESCRIPTION

Proximity to residential areas/surface water/recharge zone: The company is located in an industrial and commercial area. .

Water supply (if wells, give approximate location): Public water supply. .

Types of waste/water discharges: The company has a general permit to discharge non contact cooling water.

Evidence of on-site disposal: X Yes No. If yes, give specifics: There is a path down to the river behind the building and dead vegetation along the riverside. Soil samples were taken at the time of the inspection.

Groundwater monitoring wells on-site: Yes X No. Groundwater classification: GB .

If yes: RCRA (complete GWM checklist) Non-RCRA (briefly describe why installed and any information available): .

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Comments: .

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SITE ACTIVITY

Number employees/shifts: 450 employees/two shifts Type of activity: Metal finishing shop. .

Products: The company manufactures parts associated with aerospace industries and field goal uprights and crossbars.

Process description: The company performs aluminum anodizing. Each process line has cleaning, drag-out and rinse tanks associated with the process tank. Sulfuric acid is used in the anodizing process and nickel acetate is used to harden the surface after anodizing. A small alodine process uses chromic acid. Passivation of stainless steel is performed using a bath consisting of a solution of nitric and hydrofluoric acid. Once the sodium hydroxide etchant becomes spent it is pumped to one of six, 55 gallon, dedicated waste drums where it is accumulated for less than 90 days before it is transported off-site for treatment.

WASTE PROFILE

WASTE STREAM	EPA WASTE CODE(S)	EST. GENERATION RATE	HANDLING METHODS	TRANSPORTER	RECEIVING FACILITY
SLUDGE FROM PROCESS LINE	D008	1500 GALLONS/MONTH	55 gallon drums	MNH Trucking CAT000070707	MDS Trucking FLT000060606
SODIUM HYDROXIDE	D002, D007	3000 GALLONS/MONTH	55 gallon drums	CAT000070707	FLT000060606
SULFURIC ACID	D002, D007 D008	3000 GALLONS/YEAR	55 gallon drums	CAT000070707	FLT000060606

40 CFR 262.11, 262.40(c) HAZARDOUS WASTE DETERMINATIONS (GHW) 22a-449(c)-102(a)

Determination conducted for all waste streams: Yes X No (explain): The process at this company has changed four times since the last inspection as they try to transition to a less hazardous degreaser. It is still using the same hazardous waste determinations that were conducted during the last inspection.

Determination updated annually (documentation on-site): Yes X No (explain): The company did not possess documentation showing that the hazardous waste determinations for their waste streams have been updated on an annual basis. The sludge from the process line should have EPA waste codes including D002 and D007 as well as D008. The sodium hydroxide should have D008 included in the waste code.

Comments: Used oil is generated during maintenance on the delivery trucks. Mercury containing lamps are generated by the company. At the time of the inspection, the company did not know they should dispose of them as a universal waste and had been throwing them in the trash. On rare occasions, the company will generate ignitable waste from a process used only for one specific client. They give it to the company next door to dispose for them.

40 CFR 262.20-23; 262.42 SHIPPING RECORDS (GMR) 22a-449(c)-102(a); 102(b)(3);

40 CFR 273.18, 38, 39 22a-449(c)-113(a)(1)

Dates/months of shipping records reviewed: February 2018 through present – these were the only shipping records on site at the time of the inspection. Manifests used for all hazardous waste shipments: Yes X No (explain): The shipment sent off site two weeks ago still does not have all signed manifests back from transporters. There is no documentation for the waste given to the neighbor company to dispose .

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Shipping records used for universal wastes: Yes XNo (explain) The company has been throwing their mercury containing lamps and batteries as well as old computer monitors in the dumpster. They have just been storing the thermostats in a corner of the building.

Shipping records used for used oil: Yes XNo: (explain): The company used their own fleet of trucks to ship their products to their client with hope of free tickets when they drop cross bars. They conduct their own maintenance on the trucks. They bring their used oil to the local transfer station once a 5 gallon bucket is full.

Appropriate copy(ies) on-site: X Yes No: (explain): Hazardous waste manifests were incorrectly filled out based on previous hazardous waste determinations. Some manifests were missing, including the manifests of waste to the neighbor.

Any exception reports: Yes XNo: (explain): .

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Comments: .

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40 CFR 268 LAND DISPOSAL RESTRICTIONS (GLB) 22a-449(c)-108

Has the generator determined whether the waste meets X doesn’t meet the treatment standard(s) by

testing the waste and/or X knowledge of waste: X Yes No N/A: (explain): .

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If the waste or contaminated soil does not meet the treatment standard(s), has the generator sent a one-time written notification (or subsequent notification(s) if the waste changes) to each receiving facility: X Yes No N/A: (explain): _________________________________________________ .

If the waste or contaminated soil meets the treatment standard(s) at the original point of generation, has the generator sent a one time written certification (or subsequent notification(s) if the waste changes) to each receiving facility:

Yes No X N/A: (explain): .

If the generator’s waste is subject to a case-by-case extension, no-migration petition, or national capacity variance, has the generator sent a one time written notification (or subsequent certification(s) if the waste changes) to each receiving facility: Yes No X N/A: .

If the generator is managing and treating a restricted waste or contaminated soil in tanks, containers, or containment buildings to meet the applicable treatment standards, has the generator developed and followed a waste analysis plan: Yes No X N/A

Has the generator retained on-site a copy of all LDR documentation for 3 years: X Yes No

Comments: .

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40 CFR 262.41 BIENNIAL HAZARDOUS WASTE REPORT (GRR) 22a-449(c)-102(a)(1)

Reports filed on a biennial basis: ___Yes X No

Comments: The most recent report for 2018 was never received at DEEP and there is no information from the previous report on site.They did not have additional information on this last report or the upcoming 2020 report.

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40 CFR 265.17 IGNITABLES/REACTIVES/INCOMPATIBLES (GSC) 22a-449(c)-102(a)(2)(X)

Ignitable & reactive wastes separated from sources of ignition or reaction & handled per 265.17: X Yes No

No smoking signs (for ignitable & reactive wastes): Yes XNo

Comments:

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40 CFR 262.34(a)(4); 265.30-37 PREPAREDNESS & PREVENTION (GPP) 22a-449(c)-102(a);

40 CFR 273 Subpart A, B, C 22a-449(c)-113(a)(1)

Arrangements with local authorities: No arrangements for response with local authorities.

Immediate accessible to internal communications/alarm system: Yes, phone connected to emergency system nearby..

Telephone/hand-held two-way radio: Yes, telephone. .

Emergency equipment (fire extinguishers, spill control decon equip) Yes, equipment includes personal protection equipment and fire extinguishers; however, the company did not have any spill socks or a spare recovery drum. It also appeared that several safety kits at emergency stations has been opened and partially used, but then not replaced with new kits.

Equipment maintenance: Yes, contractors have been signed on to respond to any emergencies.

Access to emergency equipment: Poor. .

Adequate aisle space: No. The drums were stored side by side with no room for emergency overpack drums in the case of a leak. .

Source of water in the event of a fire: Public water supply. .

Comments: The drums are stored next to each other with no room to inspect for markings or labels.

40 CFR 262.30 – 34; 40 CFR 273.14 & 34 PRE-TRANSPORT REQUIREMENTS (GPT) 22a-449(c)-102(a); 22a-449(c)-113(a)(1)

Packaging: Adequate .

Labeling (if applicable, DOT hazard class): Adequate. .

Marking (words “Hazardous Waste”, generator information if being shipped): Three drums missing words “hazardous waste”. .

Contents described: Three drums not well closed and missing description of contents..

Proper DOT shipping name: Yes. .

Accumulation date: Eight drums did not have proper accumulation dates. .

Inventory system (universal waste): No Inventory System.

Comments: .

40 CFR 262.34(c)(1) SATELLITE ACCUMULATION (GMC) 22a-449(c)-102(a)

Approximate number of satellite accumulation areas: Eleven.

Less than 55 gallons (or 1 quart acutely hazardous waste) per waste stream per satellite accumulation area: X Yes No

Containers marked and contents described: Yes X No. Containers closed when not in use: Yes X No.

Comments: The six drums used for satellite accumulation were not marked or closed.

40 CFR 264.175(b); 40 CFR 265.170-178; CONTAINERS (GMC) 22a-449(c)-102(a);

40 CFR 273.13 & 273.33 for transport vehicle/ vessel 22a-449(c)-113(a)(1)

Number of areas: Seven

Location(s): At the rear of the building, at the northeast corner of the building, at the southwest corner of the building near the loading dock.

Impermeable base: Yes at two, No at five.

Secondary containment: Yes at four, No at three.

Approximate number & sizes of containers: Twenty 55-gallon drums of hazardous waste were stored in each of the three areas .

Type(s): X steel poly fiber bag/sack lab pack roll-off, Other:

Management of containers:

Condition (leaks, ruptures, corrosion, heat, pressure): Adequate

Containers closed when not in use: Yes in hazardous waste storage area.

50 foot buffer zone for ignitable and reactive waste: Yes.

Incompatibles separated by dike/wall, etc.: Yes.

Storage less than 90 days (hazardous waste): Yes.

Storage less than one year (universal waste): Unknown – all lamps thrown in the dumpster.

Does the generator store F006 hazardous waste for up to 180 days follow 262.34(g): Yes No X N/A

Does the generator store F006 hazardous waste for up to 270 days follow 262.34(h): Yes No X N/A

Comments: .

40 CFR 262.34 ; 40 CFR 265.190-201 WASTE TANKS (GTM) 22a-449(c)-102(a)(1);

40 CFR 273.13(b)(3) & 33.(b)(3) 22a-449(c)-113(a)(1)

Tank inventory/description (note above/underground, location, age, construction, ancillary equipment, capacity & waste type): .N/A .

Adequate secondary containment for tanks and ancillary equipment: __Yes No N/A: explain: .

Describe leak detection system (including ancillary equipment): .

Describe corrosion protection system: .

Special requirements for ignitable and reactive waste: Yes No N/A: explain:

Labeling:

-Hazardous waste tanks, words “Hazardous Waste” and description of contents: ___Yes No N/A

-Universal waste tanks, marked to describe contents (pesticides): Yes No N/A

Storage less than 90 days (LQG): __Yes No: explain: .

Storage less than one year for universal wastes: Yes X No N/A: explain: Universal wastes thrown in the dumpster. .

Evidence of releases/leaks: Yes X No: if yes describe: ____________________________________________ .

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Was release reported: Yes No: if yes, date (if known): .

Certification of major repairs to tank: Yes No N/A. Any out of service tanks: Yes No: if yes, describe: .

Comments: .

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Existing Tank Systems (installed before January 12, 1987)

Written tank integrity assessment on-site (P.E. certified): Yes No N/A

Does assessment address all required items: Yes No: if no, explain: .

New Tank Systems (installed after January 12, 1987)

Written tank design, construction/installation assessment on-site(P.E. certified): Yes No N/A

Does assessment address all required items: Yes No: if no, explain: .

Documented installation & tightness test on-site: Yes No.

Comments: ________________________________________________________________________________ .

40 CFR 279 Subparts B, C, G, & H USED OIL GENERATOR (WOV) 22a-449(c)-119(a)(1)

Does the facility generate used oil: X Yes No

Does the generator receive used oil from off-site: Yes X No

Is the site a: collection center, does it have a permit Yes No

aggregation point (list other owner/operator sites shipping used oil to this facility in comments section below)

Has the total halogen content of the used oil been determined: Yes X No

Was the total halogen content determined by testing or generator knowledge

Did the generator retain documentation demonstrating the halogen content: Yes No

Are the total halogens: less than 1,000 ppm greater than 1,000 ppm

If the total halogens are greater than 1,000 ppm, did the generator:

manage as a hazardous waste, or adequately rebut the hazardous waste presumption.

Explain: .

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Store used oil in: X containers tanks (describe type, method and condition): 5 gallon containers in poor condition .

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Are tank(s) and/or container(s) marked or labeled with the words “Used Oil”: __ Yes X No

For each container or tank storing greater than 55 gallons of used oil:

Stored on an impervious surface: X Yes No

Stored within an enclosed building: X Yes No

If not within an enclosed building, has adequate secondary containment been provided: Yes No

Comments: .

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Does the generator market used oil: Yes X No

If yes, is it: on-spec off-spec

Have they notified for this activity: Yes No

Are invoices and analyses for shipments of off-spec used oil retained for three years: Yes No

Has the marketer received burner certification from burners: Yes No

Does the generator burn used oil on-site in a space heater: Yes X No

If yes, does the space heater comply with 279.23: Yes No

Note: If the unit does not comply with 40 CFR 279.23, the generator must comply with the used oil burner requirements of 279 Subpart G.

List off-site destination(s) for used oil: .

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Comments: .

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40 CFR 265.15 INSPECTION SCHEDULE AND LOG (GIS) 22a-449(c)-102(b)(2);

22a-449(c)-106(c)(1) batteries

Does contact claim inspections are conducted: Yes .

Written inspection schedule: .Yes, inspection schedule is adequate.

Inspection log (adequacy of contents: date, time, items inspected, corrective action): Inspections did not include date and time of inspection .

Documentation:

Daily

All Loading/unloading areas subject to spills (when in use): .Yes .

Tanks Containment, detection, ancillary equipment: No tanks on-site. .

Trtmt Treatment equipment: Not applicable. .

Weekly

Containers Physical condition: Yes .

Containers Containment system: Yes. .

Batteries Storage area: No batteries on-site

Other

All Safety and emergency equipment (monthly): .No .

Tanks Cathodic protection (within six months, then yearly): Not applicable. .

Tanks Impressed current (every other month) Not applicable. .

Comments: ​​​​​​​​​​​​​​​ .

40 CFR 262.34(a)(4) & 265.50-56 CONTINGENCY PLAN (GCP) 22a-449(c)-102(a)

Plan on-site: __ Yes X No. Date of plan: N/A Prepared by: N/A .

Plan to local authorities: (police, fire, hospital, emergency response teams): Emergency Response Plan indicating what to do in case of a fire was sent to local authorities. No other plan was on-site at the time of the inspection.

Emergency procedures (fire, explosions, releases/spills): Plan needs to address the company’s response to other types of emergencies including hazardous waste chemical spills that could occur at the site.

Emergency coordinator(s) name, address, home and office phone: A primary emergency coordinator was called out in the ERP, but no alternate.

Emergency equipment list location, description, capabilities: Yes .

Evacuation plan (signal, primary and alternate routes): Description is vague and needs to be expanded to include description of evacuation signal. Map of facility is outdated and missing a new addition to the facility.

Comments: .

40 CFR 262.34(a)(4); 265.16 PERSONNEL TRAINING RECORDS (GPR) 22a-449(c)-102(a)(2)(K)

40 CFR 273.16 & 36 22a 449(c)-113(a)(1)

Training conducted: Yes X No: Partial training conducted. All employees on the first shift have received training but only half of the second shift employees have received training. .

Last annual review (date): February 10, 2014. New employees: 47 new employees.

Written description of training: Yes. .

Job title, description, and name of employee: Yes .

Records maintained on-site until closure/3 years for former employees: Yes.

Comments: .

40 CFR 262.34 & 265.111 & 114 GENERATOR CLOSURE STANDARD (GOR) 22a-449(c)-102(a)(2)(k)

Has the generator closed or stopped using any drum or tank accumulation/storage areas: Yes X No

If yes, has all hazardous waste been removed from area and/or unit: Yes No

Hazardous waste management unit(s) decontaminated and/or equipment, structures and soil removed for proper disposal: Yes No

Describe precautions instituted to control, minimize or eliminate escape of hazardous waste or hazardous constituents to the environment once “closure” is complete (i.e., during “post closure”): .

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Comments: .

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40 CFR 263 HAZARDOUS WASTE TRANSPORTATION (TOR) 22a-449(c)-11 & 103

40 CFR 273 Subpart D 22a-449(c)-113(a)(1)

Does the handler transport waste: Yes X No Does the transporter have a 22a-449(c)-11 permit: Yes No

If yes, and permit is not required:

Shipping documents maintained on-site (hazardous waste): .

Less than 1,000 kg/mo using handler’s vehicle (hazardous waste): .

Universal waste transported to: another handler destination facility other: Incinerated

Comments: The company walks the waste to the neighbor on an as needed basis. .

WASTE MINIMIZATION PROGRAM

Is a program in place: X Yes No (if written program, obtain a copy)

If yes, briefly describe the elements of the program and identify waste types and any reduction achieved: Water reduction assessed on a monthly basis with on-site employees .

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If no, did the inspector recommend that the company:

Assess their processes and waste streams for potential reductions in waste quantities: Yes No

Assess their raw materials for less hazardous alternatives: Yes No

Assess their water usage for potential reductions: Yes No

Assess their energy usage for better efficiency: Yes No

Evaluate the potential for closed loop processes: Yes No

Comments: (Identify specific areas for further assessments: .

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PHOTOS TAKEN

(number, location and brief description or attach photocopy of log)

Photos taken of the dead vegetation near the river.

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SAMPLES TAKEN

Soils samples taken in the area of the dead vegetation by the river.

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COMMENTS ON OTHER AREAS OF ENVIRONMENTAL CONCERN

(AIR, WATER, WASTE)

None. .

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ATTACHMENTS

(If generator’s operations include the following regulatory areas, please check-off the appropriate subject and attach to report)

X NO ATTACHMENTS APPLICABLE

ATTACHMENT A: Import/Export requirements

ATTACHMENT B: Spent Lead Acid Batteries Being Recycled

ATTACHMENT C: Recycle/Reclaim

ATTACHMENT D: Use Constituting Disposal

ATTACHMENT E: Accumulation for Recycling

ATTACHMENT F: Scrap Metals

ATTACHMENT G: Precious Metal Recovery

EXIT MEETING

Closing meeting held at conclusion of inspection: X Yes No

List attendees and their titles: __ Eli Manning with Kelly Walsh. __________________________

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Areas reviewed: __ All areas where violations had occurred were reviewed with Mr. Manning and his brother the CFO. ___________________________________________________________________ .

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Field citation issued: Yes X No; if yes, citation number:

INSPECTOR: Kelly Walsh DATE: April 12, 2020