rcra inspection report

UNITED STATES ENVIRONMENT AL PROTECTION AGENCY REGIONS

FACILITY NAME:

77 W. JACKSON BOULEVARD CIDCAGO, ILLINOIS 60604

RCRA SAMPLING REPORT

FACILITY U.S. EPA ID NO.:

MID-AMERICA STEEL DRUM me

WIR 000 162 438

FACILITY TYPE:

FACILITY ADDRESS:

Small Quantity Generator

2300 West Cornell Street Milwaukee, Wisconsin 53209

U.S. EPA REPRESENTATIVE: Walt Francis

DATE OF INSPECTION: May 4, 2017

NAICS CODE: 332439 - Other Metal Container Manufacturing

PREPARED BY: W~..s::==2 -, Walt Francis Environmental Scientist

APPROVED BY: ~,,,----Jurorris~f Compliance Section 2 RCRABranch

? /J. ,,/>,017 Date

-J{-z't/11 Date

2

Purpose of Sampling Event

An unannounced Sampling Event at Mid-America Steel Drum IBC ("MASD-CS") located at 2300 West Cornell Street, in Milwaukee, Wisconsin took place on May 4, 2017. MASD-CS has notified as small quantity generator (SQG) of hazardous waste. Robert Kendreck accompanied me during this event. In addition to facility representatives, an attorney from the law firm Foley & Lardner LLP was present during the event.

The Sampling Event was conducted at three MASD facilities in the Milwaukee area simultaneously in order to obtain analytical data in order to supplement an evaluation of MASD's compliance at these three facilities with the appropriate hazardous waste regulations codified at the Wisconsin Administrative Code and the code of Federal Regulations. Tbis report is a record of the MA SD-CS facility sampling event only. Reports for the other two facilities are written under separate cover.

Participants

United States Environmental Protection Agency (U.S. EPA) -Walt Francis, RCRA Program Robert Kondreck, Superfund Program

Representatives of Mid-America IBC -Rodney Knash, Plant Supervisor Jared Suhm- Plant Employee Scott Allen, Attorney Foley and Lardner, LLP

Introduction

Mid-America Steel Drum Company was established in 1975. Mid-America Steel Drum has three locations in Milwaukee County (3950 S. Pennsylvania Avenue, St. Francis, 8570 S. Chicago Road, Oak Creek, and 2300 W. Cornell St., Milwaukee, Wisconsin). The Cornell Street facility receives 275-gallon plastic and metal totes. The totes are typically stored prior to processing. Tote processing includes the removal of any liquid contents with a shop vacuum apparatus. The removed liquids are accumulated in 275-gallon totes and sent off-site to Badger Disposal. The next step includes an internal cleaning with soapy water and caustic. The used cleaning solution is pumped over a paper filter which removes debris. The exterior of the totes are then power washed. Based on customer specifications, either a reused plastic tote or a new plastic tote is placed in the metal tote cage and then sold to the customer. Mid-America IBC also operated a "Cut and Scrape Operation" at the Milwaukee facility. Totes which had residues on the bottom were placed in a saw apparatus which cuts off the bottom of the tote. At the time of the Sampling Event, the Cut and Scrape Operation had been discontinued. The MASD-CS building occupies 30,000 square feet, and 2.66 acres. According to Mid America lBC personnel any shipping papers are stored at the Oak Creek facility.

3

Pre-Site Visit Prior to the sampling event, EPA personnel completed a Health and Safety Plan (HASP), a Sampling and Analysis Plan (SAP), and a Quality Assurance Project Plan (QAPP). An ex parte administrative warrant from the U.S. District Court Eastern District of Wisconsin was issued on May2,2017.

Site Visit

Mr. Kondreck and I arrived at the MA SD-CS facility at approximately 10:00 am. The sampling team entered the facility through the truck gate and entered the facility by the loading dock. We went to the office and introduced ourselves to Mr. Rodney Knash and handed him the sampling warrant. We explained that we would be sampling at the site that day, and the warrant allowed ns access to the site. Mr. Knash stated that he should make a few telephone calls and to wait for their attorney's. We told Mr. Knash that the sampling warrant allowed us access to the facility without their attorney's present. We then toured the facility with Mr. Knash and discussed sampling locations. All totes had been removed from the outside areas around the building, the "Cut and Scrape Area" activities had been discontinued, the Shop Vacuum area waste tote was labeled "Non-Regulated", and facility operations had stopped. A short time later, Mr. Scott Allen from Foley and Lardner, LLP arrived at the facility. Mr. Knash had sent an employee from the facility out to purchase sampling bottles for split samples. The sampling team worked on labeling sampling containers, Chain of Custody form, and donned our safety PPE.

The first sample (CS-01) was taken from a tote staged near the office which was labeled "Dow Ringwood Returns Heavy'', see photograph numbers 1 through 3. Mr. Suhm was given split samples for MASD at each sampling location. We then sampled two totes (CS-02 and CS-03) that were staged near the office waiting to be processed which appeared to be not "RCRA Empty'', see photographs number 4 through 6. We then walked back to the Shop Vacuum area and sampled a waste tote (CS-04) which was labeled "Non-Regulated, see photograph number 7. We then sampled another tote (CS-05) from the Shop Vacuum Area which was labeled "NonRegulated" which was staged in the wastewater tank area, see photograph number 8. The sampling team walked back to the Warehouse Area where we sampled a tote (CS-06) labeled "Pre-Flush #3 Non-Regulated" (see photograph number 9) and a 55-gallon container labeled "Pre-Flush Tank Residue Non-Regulated" (CS-07), see photograph number 10. We walked through the Warehonse Area and selected a tote waiting to be processed labeled "Sodium Hydroxide I 0%", which appeared to have more than one gallon ofresidue in the bottom (CS-08), see photograph number 11. About this time, EPA, Region 5, Clean Air Act personnel, Ms. Alexandra Letuchy and Manojkurnar Patel arrived in the Warehouse Area_

We then walked back to the lunch room to take off our PPE.

4

Mid America Steel Drum - Cornell Street Sampling

Sample Location Sample Time Information From Tote Label and Multi-Rae Number SDS Information PID

Reading-CS-01 Near 11:48 am Dow Rocima BT 2S Microbicide 190 ppb

Office EPA Reg No. 707-314 Area Danger - Corrosive

pH= 12 to 13.5 Flash Point = 199° F

CS-02 Staged near 12:31 pm Silicone Fluid Office Wacker AK350 220 ppb Area for Wacker 25595122 Processing pH=7 Off-loaded Flash Point= 500°F 5/4/2017

CS-03 Staged near 12:35 pm · Poly G-30-168 Office Brenntag Monument MIL 140 ppb Area for pH=6 Processing Flash Point = Unknown Off-loaded 5/4/2017

CS-04 ShopVac 1:02pm Tote of combined waste residues 120 ppb Area labeled "Non-Regulated"- Syrupy

consistency CS-05 Wastewater 1:12pm Shop Vac Area tote stored in

Tank Wastewater tank room labeled "Non- 1,120 ppb Room Regulated". Tote of combined waste

residues. CS-06 Northwest 1:29 pm Tote labeled "Pre-Flush Tank #3 -

Comer of Non-Regulated" 70ppb Warehouse Wash water waste from tote rinsing

from 500 gallon tank. CS-07 Northwest 1:55pm 55-Gallon Container labeled "Pre-

Comer of Flush Tank Residue Non-Regulated" 0ppb Warehouse Residue waste from washwater tank.

CS-08 Southside 2:15 pm Sodium Hydroxide 10% of Brenntag Corrosive 0ppb Warehouse DOT 1824 Area UN1824

0153584 pH= 14 (5% solution) Flash Point = Non-combustible.

5

Sampling Completion We prepared a sample receipt for Mr. Knash and departed the facility at approximately 3:15 pm. The EPA Multi-Rae PIO recorded VOC readings ranging from Oto 1,120 ppb, see table. Samples were packed in a cooler with ice for transport to the EPA, Region 5, Central Regional Laboratory.

Attachments Photographs Chain of Custody Receipt for Samples

Mid-America Steel Drum IBC Milwaukee, Wisconsin 5/4/2017

Photograph #1 - Dow Ringwood Tote "Return Heavy Too Much Product" Near Office Area 11:34 am CST

Photograph #2 - Dow Ringwood Tote "Return Heavy Too Much Product~' Near Office Area, 11:34 am CST

Mid America Steel Drum IBC Milwaukee, Wisconsin 5/4/2017

Photograph #3 - Sample CS-01, Dow Ringwood Tote "Too Much Product Return Heavy" Near Office Area, 12:05 pm CST

Photograph #4 - Sample CS-02, Tote to be processed labeled Silicone Fluid Wacker AK350, 12:16 pm CST

r

Mid-America Steel Drum IBC

Photograph #6 - Sample CS-03, Tote to be processed labeled Poly-G-30-168, 12:41 pm CST

Mid America lBC Milwaukee, Wisconsin 5/4/2017

c Area, 12:53 pm CST

Photograph #8 - Sample CS-05, Tote of Residues from Shop Vac Area, 1:05 pm CST

I _

Mid America IBC ·

-Regulated "Pre-Flush #3", 1 :22 pm

Photograph #10 - Sample CS-07, 55-Gallon Container labeled Non-Regulated "Pre-Flush", 1:45pm CST

I '

Mid America me Milwaukee, Wisconsin 5/4/2017

Photograph #11 - Sample cs.08, Tote to be processed labeled "Sodium Hydroxide", 2:07 pm CST

Name of Facility Jy[jd America Steel Drum

Facility Location

U.S. Environmental Protection Agency Region 5

· RECEIPT FOR SAMPLES

Project Number MASD-05-04-17

2300 W. Cornell Street, Milwaukee, Wisconsin 53209

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D1stribunon: Origmal to Facility Representahve; Copy to Proiect File

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ENVIRONMENTAL PROTECTION AGENCY Office of Enforcement

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U.S. ENVIRONMENTAL PROTECTION AGENCY Region 5, Land and Chemicals Division RCRA Branch, LR-8J 77 West Jackson Boulevard Chicago, Illinois 60604

RCRA SAMPLING REPORT

INSPECTION DATE: May 4, 2017

SITE NAME: Container Life Cycle Management, LLC d/b/a Mid-America Steel Drum, Inc.

ADDRESS: 3950 South Pem1sylvania Avenue St. Francis, Wisconsin 53235

EPA ID NUMBER: WIR 000 131 367

RCRA STATUS: Small Quantity Generator (2017)

NAICS CODE: 332439 Other Metal Container Manufacturing

FACILITY CONTACT: Mark Furgason Plant Manager

.EPA CONT ACT: Brian Kennedy Enviromnental Engineer Compliance Section 2 RCRA Branch

PREPARED BY:

APPROVED BY:

Land and Chemicals Division

Morris, Chief Compliance Section 2

7 / 7 / .2o /7 Date

Date

Mid-America Steel Drum, Inc. WIR 000 13 I 367 May 4, 2017

Purpose of Inspection An unannounced sampling event at Mid-America Steel Drum, Inc. (MASD), located at 3950 South Pennsylvania Avenue in St. Francis, Wisconsin, took place May 4, 2017. The sampling event was conducted by U.S. Environmental Protection Agency personnel as part ofan investigation of the facility's compliance with the regulations of the Resource Conservation and Recovery Act (RCRA), as codified in the Wisconsin Administrative Code and the Code of Federal Regulations. Simultaneous sampling events of additional Mid-America Steel Drum, Inc. facilities in Oak Creek and Milwaukee, Wisconsin took place on the same day. The details of the sampling events at the Oak Creek and Milwaukee facilities are not covered in this report.

Participants The following persons were present for part or all of tl1e inspection:

Mark Furgason - Plant Manager

Robert Janowski - Plant Engineer

Linda Benfield- Attorney for MASD

Brian Kennedy - Environmental Engineer

Jamie Paulin - Chemist

Alexandra Letuchy - Environmental Engineer

Manojkumar Patel - Environmental Engineer

Pre-Site Visit

MASD

MASD

Foley and Lardner, LLP

U.S. EPA

U.S. EPA

U.S. EPA

U.S.EPA

Prior to the sampling event, EPA inspectors completed a Health and Safety Plan (HASP), a Sampling Analysis Plan (SAP), and a Quality Assurance Project Plan (QAPP). A.n ex parte administrative warrant from the United States District Court for the Eastern District of Wisconsin was procured on May 2,2017.

Introduction EPA inspectors Paulin, Letuchy, Patel and myself arrived on site at approximately 10:00 AM CST. There was a strong chemical odor on the public roads surrounding the facility upon arrival. Entering the front office, we presented the administrative warrant to Ms. Tiffany Hupp, MASD's Office Manager. We explained the purpose of the warrant and our site visit, and that we intended to sample at the facility that day. We also explained the administrative warrant allowed for immediate access to the facility. Ms. Hupp claimed she needed to make several calls before allowing ns on site. We expressed our disagreement with this decision.

While waiting for permission to enter the site, Inspector Paulin took photos of the north side of the facility from the sidewalk on South Pennsylvania Avenue (See Attachment A: Photos I and 2). Semi-trailers were observed parked along a north-side loading dock.

2

Mid-America Steel Drum. Inc. WlR 000 131 367 May 4, 2017

After several minutes of delay, I called Mr. Michael Carter, Assistant United States Attorney for the Eastern District of Wisconsin, to explain that we were not allowed immediate access to the site after presenting the warrant. Mr. Carter was eventually put in contact by phone with Ms. Linda Benfield, MASO's Attorney of Foley and Lardner, LLP, to discuss the situation .. After several minutes of discussion, Ms. Hupp stated that we could enter the facility. At 10:25 AM, Mr. Mark Furgason, MASD' s Plant Manager, arrived to the front office and escorted us on site.

Initial Site Tour EPA inspectors Paulin, Letuchy, Patel and myself were first directed by Mr. Furgason to MASD' s outdoor loading and ''heavies" dock on the north side of the facility. Here, MASD employees unload incoming 55-gallon drums for sorting and processing (Photographs 3 - 6). The only drums handled here are steel closed-top drums. We observed MASD employees shake and "feel" the 55-gallon drums to determine if they contained any material. Those drums determined to contain little to no material were rolled to the nearby conveyor line, which led inside the facility for processing. Inspector Paulin and I examined several of the numerous drums on the outdoor portion of the conveyor line, and those about to be placed on the conveyor. The drums we examined to did not appear to contain material.

For those drwns determined to contain material, MASD employees place them on the east side of the loading dock in the "heavies" area. These rejected drllllls are refen-ed to as "heavies." We observed approximately 103 heavy drwns stored in this area (Photographs 7 - 10). The drwns were packed together closely and it was difficult to examine drum labels or tags. MASD placed yellow tags on the heavy drums with numbers that denote the customer that sent the drum (Photograph 11 ). Some, but not all, of.the yellow tags were marked with the date of arrival of the drum to MASO. Dates from April 2017 were observed on those drums that were dated. Inspector Paulin and I selected and marked seven heavy drums from this area to be sampled (Photograph 12). The drums were selected, in part, because oflabeling indicative of hazardous materials.

At this time, Mr. Furgason and Inspectors Patel and Letuchy proceeded inside the facility. Inspectors Patel and Letuchy later departed MASO in the early afternoon. Mr. Robert Janowski, MASD's Plant Engineer, joined Inspector Paulin and I on the heavies dock

After selecting and marking the seven heavy drums for sampling, Mr. Janowski led Inspector Paulin and I inside the facility through a north-side entrance near the heavies storage area. Upon entrance, the chemical odor noted outside the facility intensified. We observed a standing fog or haze inside the facility (Photographs 13 - 14). It was unclear from where the fog was originating. Mr. Janowski led us through MASD's poly (plastic) drum loading areas along the east side of the facility. Here, MASO employees also "feel" incoming poly drums to determine if they· are heavy. r ·examined approximately four of the numerous poly drums placed on the conveyor line leading to processing. The drums I examined did not appear to contain material.

At the southeast corner of the facility we observed a hazardous waste storage area There were 13 55-gallon drums and two 5-gallon containers marked as hazardous waste and dated. We also observed five open buckets in the area that were covered in plastic and did not appear labeled (Photographs 15 - 19). The 55-gallon drums in the area had markings on their lids which stated "Mercury Wash Water." All hazardous waste labels in the area were marked as D009 hazardous

3

Mid-America Steel Drum, Inc. WIR000 131367 May 4, 2017

waste for mercury content. We asked Mr. Janowski the source ofthis waste. He stated that SET Environmental was hired to come to the facility on weekends to perform cleaning of MASD equipment, and that this waste was generated during the cleaning event(s). Mr. Janowski could not provide further information on the source of the mercury.

The tour continued west along the south side of the facility. We observed four large cardboard boxes across from MASD's wastewater treatment area that were labeled as hazardous waste for mercury (Photographs 20-21). Mr. Janowski was unsure of the source of the waste, but stated it might be filter cake from wastewater treatment operations. Adjacent to these four boxes were four 55-gallon drums that were labeled as hazardous waste for mercury (Photograph 22). One 55-gallon cl.tum near these four hazardous waste drums had its lid marked as "Boots" (partially visible in Photograph 22). Mr. Janowski stated this drum contained the boots ofMASD employees that were contaminated with mercury. This drum did not have a ha:mrdous waste label. Another 55-gallon drum near the four hazardous waste drums was not labeled and was covered with tape (Photograph 23) .. Mr. Janowski stated the drum contained mercury waste. The drum was not labeled as hazardous waste.

Continuing west along the south side of the facility, near the wastewater treatment area, we observed four 55-gallon drums that were labeled as non-hazardous waste (Photographs 24 - 25). Mr. Janowski stated this waste was material that had accumulated along the bottom of machinery in MASD's process line. Two of these drums were marked to be sampled.

Mr. Janowski briefly directed us through MASD's steel drum processing line, which is on a raised steel catwalk above the ground level. Along the north side of the facility, l\1ASD blasts cleaned drums with steel shot as part of the reconditioning process. Shot blast dust from a dust collector is accumulated in 55-gallon drums and shipped off-site as a non-hazardous waste. MASD stages 55-gallons of this dust for shipment near the center of its steel drum processing line. We observed at least a dozen of these drums in the area. One of these drums was marked to be sampled.

Around this time, Ms. Linda Benfield, MASD's Attorney, arrived on site and joined the tour. Ms. Benfield requested that split samples be taken for all samples. l\1ASD provided its own jars to collect split samples.

Inspector Paulin and I returned to our vehicle to ready sampling equipment and don protective gear. Toe pre-marked drums on the heavies dock were sampled first, and staging was completed for each drum prior to sampling (Photograph 26). Sampling was then conducted on those premarked drums near the wastewater treatment area inside the south end of the facility, and then on the pre-marked drum in the shot blast dust storage area in the center of the facility.

Mr. Janowski and Ms. Benfield were present for the duration of sampling activities.

4

Mid-America Steel Drum, Inc. WIR 000131 367 May 4, 2017

Sampling - Heavies Dock All drums on the heavies dock were sampled using the following equipment: Glass Coliwasa samplers, pH paper, a ruler, 16 oz. glass jars, drums covers, a bung wrench, and a Multi-Rae. A split sample for MASD was taken for each sample.

The following table summarizes the notes and observations made during the sampling conducted on the heavies dock:

:tf ,~'r,:mtiilli~: :r.ti11!!tl&~lit~1~~er~~t::;.;t:*1; ~; SFS0l 1:06 PM 2 inches

SFS02 1:20PM 3 inches

SFS03 1:31 PM 2.5 inches

·sFS04 1:39 PM 2 inches

SFS05 NIA NIA

SFS06 · 1 :55 PM 3.2 inches

SFS07 2:03 PM 2.75

inches

1

8

6

6

1

6

Black poly drum marked "Sulfuric Acid." Four aliquots per sample jar. Limited sample material available. Blue poly drum with corrosive and flammable markers. Four aliquots per sample jar. Limited sample material available. Blue poly drum marked as MDG ZymoBac GTLS lOx. Four aliquots per sample jar. Limited sample materjal available. Blue steel drum marked "Toluene.'; Multi-Rae hit 300 ppm VOCs. Four aliquots per sample jar. Limited sample material available. Black poly drum marked "Muriatic Acid." When bung opened, vigorous fume/smoke exited. Fumes turned pH paper bright red. Decided not to samole as a precaution. Black poly drum marked "Muriatic Acid." Four aliquots per sample jar. Limited san1ple material available. Green steel drum marked "EtOH I TrietlJyl Citrate Kosher" and flammable. Four aliquots per san1ple jar. Limited sample material available.

5,

27 - 31

32- 36

37 - 40

41 - "44

45-48

49-52

53 - 55

Mid-America Steel Drum, Inc. WIR 000 131. 367 May 4, 2017

. •. !

Sampling - Near Wastewater Treatment Area Two drums in this area were sampled using the following equipment: Glass Coliwasa samplers, pH paper, 16 oz. glass jars, and a Multi-Rae. A split sample for MASD was taken for each sample. Mr. Janowski opened these drums at our request.

The following table summarizes the notes and observations made during the sampling conducted in this area:

-• .. Tµne.· ·· ··· · ... · ::.~pph>X{: ·:: ...

·. Tak~n .· :: _;/. p~_:_·· .. _CST) =.

Black steel open-top drum marked as "NonHazardous Waste.'' Material was brown in color

SFS08 3:10 PM 10 ·with a sludgy consistency. Liquid had separated 56- 59 to fmm a thin top layer. Drum was almost full. Two full 16 oz. · ars taken. Black steel open-top drum marked as "NonHazardous Waste." Material was brown in color

SFS09 3 :23 PM 10 with a sludgy consistency. Liquid had separated 60 - 62 to form a thin top lay~r. Drum was almost full. Two full 16 oz. jars taken.

Sampling - Shot Blast Dust Storage Area One dmm in this area were sampled using the following equipment: Plastic scoops and 16 oz.

glass jars. A split sample for MASD was taken. Mr. Janowski opened this drum at our request.

SFSl0

SFSlO Dup

Red steel open-top drum with no clear marking or label 3:37 PM Material was a very fine gray dust. Drum was almost full.

Two full 16 oz. jars taken with three scoops per jar Red steel open-top drum with no clear marking or label

3:37 PM Material was a very fine gray dust. Drum was almost full. Two full 16 oz. jars taken with three scoops per jar.

Sampling Completion

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63 - 64

63-64

After sampling was completed, Inspector Paulin and I proceeded to bag and tag the samples. We prepared a chain of custody form for the samples in addition to a sample receipt for MASD. Mr. Furgason signed the sample receipt and copies of both documents were left with MASD. A copy of the receipt for samples and chain of custody fom1 is in Attachment B.

Inspector Paulin and I left the facility at approximately 5 :30 PM.

NOTE: When available, sample results will be placed in Attachment C.

6

Mid-America Steel Drum, Inc. WIR 000 13 I 367 May 4, 2017

Attachments A. Photographs B. Sample Receipt and Chain of Custody C. Sample Results (Pending)

7

Photographs for MASD St. F.rancis 5/4/2017 Media: RCRA

Disk Number 1 Pltoto Number l Pltoto Filename DSCNJ 061.JPG

Date/Time 5/4/2017 10:23:00AM

PT,otogropl,er Jamie Paulin

Description

Northside dock. View from Pennsylvania Avenue. Tru,cks were parked at the dock wl1ere 55-gallon containers were being offloaded.

Disk Number I

Pltoto JVumber 2

Plzoio File11ame DSCNI062.JPG

Date/Time 5/4/2017 10:23:00AM

Pflotographer Jamie Paulin

Descripti!}n

Northside dock. View from Pennsylvania Avenue. Trucks were parked at the dock where 55-gallon containers were being offloaded.

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MASD St. Frm1ds5/i//1017 5122/2017-Page 1 of 32

Photographs for MASD St~ J;rrancis 5/4/2017 · Media:. RCRA

Disk Number I

Pho_to Number 3

Photo Filename PSCNl 063'.JPG

Dote/Time

Photographer

Desc_ription .

5/4/2017 10:38.:00 AM Jamie Paulin

Northside Pock. Stacks of empty 55-gallon containers were being stored in this location.

DiskNumher Photo Number Photo File11ame Date/Time

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Description'

1

4

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514/2_017 10:39:00AM J~ie,Paulin

Nortbside Dock. Stacks o:f empty 55-gallon containers were being ~toredfa this location. Some hai;I been washed.but mire b~ing rejected.

l'IIASD St. Frand~ 5/4/2017 . .. ·=

5/2112017 -Page 2 of 32

Photographs for MASD St.. Francis 5/4/2017 Media: RCRA

Disk Number I

Photo N11mber 5 Pltoto Filename DSCN1065.JPG

Date/Time 5/4/2017 10:40:00AM

Photographer Jamie Paulin

Descript/011

Northside dock - storage prior to conveyor belt. Several metal 55-gallon containers were being off-loaded at the time of the sampling event. These metal drums felt emtpy and appeared to be empty.

Disk Number 1

Photo Number 6

Photo Fi/e11ame DSCNl 066.JPG

Date/Time 5/412017 10:41:00AM

Pltotograplter Jamie Paulin

Descript/011

Northside dock. Several trailers of55-gal1on containers were being off-loaded at the time of the sampling event.

=--------MASD St. Fra1rcis 514/2017

I_ ' · 1

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- .._. 5/22/2017 - Page 3 of 32

Phot~graphs for MASO St~ Francis 5/4/2017 Media: RCRA

Disk Number 1 Pltoto Number 7

Pltoto Filmame DSCN1067.JPG

Date/Time 5/4/2017 10:41:00AM

Pltotograp_l,er Jamie-Pauliq

Descriptio11

Storage of "heavies." About 103 x 55-gallon containers were being stored in this location awaiting removal from customers. There was no aisle space and it was difficult to read the assigned tag numbers. Each customer received a number assigned per drum.

Disk Number 1

P!,oto Number ~

Photo File11a111e DSCNI068.JPG

Date/Time 5/4/2017 10:41 :00 Al\1

Plwtogril_pl,er Jamie Paulin

Description

Stprage of "heavies." About lOJx ~5-~lfon con~iners were being stored._he~ awaiting removal from ¢ustomers. There was no aisie, spac~ and it was difficult to read the assigne~ tag numbers. Each customer received a number assigned per drum --ye! low tag.

Photographs for MASD St. Francis 5/4/2017 Media: RCRA

Disk Number I Pl,oto Number 9

Pl,oto Filename DSCN1069.JPG

Date/Time 5/4/2017 10:41:00 AM

Pl1otograp/1er Jamie Paulin

Description

Storage of "heavies." About 103 x 55-gallon containers were being stored here awaiting removal from customers. There was no aisle space and it was difficult to read the assigned tag numbers. Each customer received a number assigned per drum - yellow tag.

Disk Number I

Pl,oto Number 10

Photo Filename DSCN1070.JPG

Date/Time

Photographer

Description

5/4/2017 10:43:00AM

Jamie Paulin

Stor~e of"heavies." About 103 x 55-gallon containers were being stored here awaiting removal from customers. There was no aisle space and it was difficult to read the assigned · tag numbers. Each customer received a uumbel' assigned per drum - yellow tag.

'----·~----- .;g;.

MASD St. Francis 5/4/2017 = il.. " 5/12/ltfff:Fage 5 of 32

Photographs-for fyl.ASD St. Fr,a~c~ 5/4/2017 Media: RCRA

DiskNwnlJer -l

Photo Number- 11

Pltoto Fife,rame DSCN1071 .JPG

Datell'inte

Plwtograpl,er

Description

5/4/2,017 10:45:00AM

Jamie Paulin

Storage of "heavies." Each 55-gallon container was assigned a tag·number placed on top of each drum associated with a customer. One of the drums per tag number was dated. Ill.is tag was dated 4/28/17.

Disk Nµmher l

Photo Nun;IJer 12 Pltoto Filen'aiiie ·.QSQN1072.JPG

Datenime 5/412011 10:59:00AM


Des'criptlon

Storage of "h~vies." Seven 55-gallon containers were selected from the "heavies" ~torage area to s~ple, based on hazardous materjal labeling. The drums were not labeled as hazardous waste nor did they contain a date. I did not. contain a tag number label

~~~Ar-.;:-..~~trr? .. -r-·=· ~.,~,=~rn~:==~•~!:!!l:...~ ~~-~~.::::n=··~··~·=·===~~~·~·~=··~·-~·:...::::====z~·-~,:::n=::r=::::==~-~c:=:==·=====µ===• MASD St. Fra11cis 514/2017• 5/22/2017 - Page 6 of 32,


DiskN11mber 1

Pl,oto Number 13


Date/Time 5/4/2017 11:08:00AM

Photograplter Jamie Paulin

Description

Poly drum process area. Stacks of empty poly 55-gallon containers were being loaded onto the conveyor belt for processing. The air was foggy and misty. There was a strong odor inside the facility.

Disk Nuntber Pf,oto Number

Photo Filename Date/Time

Pftotograpfler

Descriptio11

1

14

DSCNI074.JPG

5/4/2017 . 11 :08:00 AM

Jamie Paulin

Poly drum process area. Stacks of empty poly 55-gallon containers were being loaded onto the conveyor belt for processing. The air was foggy and misty. There was a strong odor inside the facility.

L..,,-.....,,,,----,,-~~-~ ~-,,--_.:.:====;a:lli:!:==========:.;-::.========•=== ..... .,,..~=""*'E::-'-"""""-"' • MASD St. Fra11cis 5/4/2017 5/2212017 - Page 7 of 32

-.--


Disk Number 1 Pltoto Nu_inb'er 15


Date/Time 5/4/2017 11:16:00AM

Pltotograp*er Jamie Paulin

Descrlptio,i

Hazardous waste storage area. Waste that had been collected by deaning off of and under equipment was stored in 5 open buckets tied io a plastic bagwith no lids, labels or dates.

Disk Jvumb,er 1

Photo Number 16

Photo J:ilename. DSCN1076JPG

Datt:/Time 5l4/2017 11:16.00M{

Plto(ogrgplter Jamie"?iiulin

Desctiptio1i ·

Hazardous waste storag~ area. Waste that had been, collected by cleaning off of and underequipmeqtwas stored in5 open buckets. The bllckets were tied hi a plastic bag with no iids, labels or dates.

r r-~ u-·-... ~ '""" ,.. -, ~~·r::.::0w:~::::i~1=· ·•:Jl:!'"'"""~=- =~::,,:,~o.::. = ==,:r, !"'~~-.,--.. =r,~:.:,,.......,.,..=,="'-:::::1,,:,:==·c:::~==='°"'===::c===· = :...'!:3

!lfASD Sf;' Frmzcls 5/,/(2017 5/21/1017 - Pag_e 8 of 32


Disk Number l

PltotoNumher 11

PT,oto File11ame DSCN1077.JPG

Datel'l'i,ne

Photograplter

Description

5/4/2017 11:18:00 AM Jamie Paulin

Hazardous waste storage area. 13 x 55-galton containers and 2 x 5-gallon containers were labeled as hazardous waste and were being stored in this area. SET cleaned the equipment over the previous weekend and stored the hazardous waste in this area.

Disk Number Photo Number Plwto File11ame Date/Time

Pltotograplter

Description

1

18

DSCN1078.JPG

5/4/2017 11:18:00 AM Jamie I>aulin

Hazardous waste storage area. 13 x 55-gallon contajne~ and 2 x 5-gallon containers were labeled as hazardous waste and were bemg stored in this area. SET cleaned the equipment over the previous weekend and stored the hazardous waste in this area.

I --,>-:'". =1,;a;,._7,c--:;: __ c:,,::,c_=::::,=:_:,,:_=-:====-=~=· ;:,;:••;:tl'Gl"Sl;;msl.,:ll!C:2il:i l!ll&b:!!Flt:ll!IJl"""""'=:,"s•..,,,,,c.:.::;==~ ...__- Z: _j

MASD St. Fra11ds 5/412017 5/12/2017- Page 9 of 32

Photographs for MASO: St. Francis 5/4/2017 Media: RCRA

Disk Number 1

Photo Number 19 Pltofo,Filename. DSCN1079JPG

Date/Time

Pllotograplrer

Descrlpt/011

5/4/2017 11:2'1:00AM

Jamie Paulin

HazardQus waste storage ai:ea. 13 x 55-gallon containers and 2 x 5-gallon cont;iiners were labeled as.hazardous waste·and were being stored in this area. SET clt;aned the equipment over the previous weekend and stored the hazardous waste in this area.

JJisic Number 1

Pltoto 1Number 20 Pltoto ;Fil¢11ame DSCN1080.JPG

Date/Time 5/4/2011 11:24:00 AM

Pltotograpller Jamie Paulin

Descripf!o1,

Conveyor belt located across from waste wat~r treament unjt (WWTU) area1 4 cardboard totes were being·st9red with b~dous waste labels. Robert JlllloWski· did not know the source of the waste. He stated that it might be WWTU filter cake;

~]Js~·-~:r=~s.~i~F.~~=d~~,cz~~S.~1/4.='/2~0=1~7=====:~==l!c,===·===============i=·· ====·=·~·=·~s1.~121.2=0~1~1=-~P.~ag=e=1=0~~1=r:=~·


Disk Number l

Photo Number 21

Photo Filename DSCNI08 l.JPG

Date/Time 5/4/2017 11:24:00 AM

Pltotographer Jamie Paulin

Description

Conveyor belt located across from waste water treament unit (WWTlJ) area. 4 cardboard totes were being stored with hazardous waste labels. Robert Janowski did not know the source of the waste. He stated that it might be WWTU filter cake.

Disk Number l Photo Number 22

Photo File11ame DSCN1082.JPG

Date/Time

Photographer

Description

5/4/2017 11:25:00AM

Jamie Paulin

Near the process area and WWTU. 4 x 55-gallon containers were labeled as hazardous waste for mercury contamination. One 55-gallon container was storing mercury · contaminated boots; however did not contain a hazardous waste label.

..__ MASDSt. Frai1cis 5/4/2017 5/22/2017 - Page 11 of 32

Photographs for MASO St. l?rancjs 5/4/2017 Media: RCRA

Disk Number 1 Pl,oto·Number 23

Photo Fl/e11ame DSCN1083.JPG

Date/I'i,ne 5/4/2017 11:26:00AM

Pl10tograpl1er Jamie Paulin

Description

Near the process area and WWTU. One 55~ gallon container-was being stored without labeling an:d sealed with tape rather tbah with · a lid. Robert Janowski s~ted that the CO[!tainer was storing mercury contaminated waste. ·


Pltoto File11ame DSCNI084.JPG

Date/Time

Pltotogr.apher

Description

5/4/2017 11:28:00AM

~amie Paulin

Near the pr_ocess area and WWTU. Four x 55-gaUon containers were being stored as non-hazarclow; wasfe._ Robei:t fanow,ski sta:ted that the waste was ~ollected from the bofto_m of machinery, The drum we labeled as "H'' was sampled.

G.t::!l!:l:z.cr:.:::r.:.-.:..-;,•i""i"'- 1...,.,r.:::.::i!:::~ ........ o: -.... , ... ~~-c.•~~--~-xrn:m~cs:·:;:;;;m;::+i]c;rr=====•====·.::==··-:c,,~-c:::--===:=::==""· e::,•=:::,'1=;,,=-s,,:=n,-c, MASD St. Fra11cls SN/2017 S/2212017 -.. Page J2' of JJ ..


DiskN11mher I

Photo Number 25

Pltoto Filename DSCN1085.JPG

Date/Time 5/4/2017 11:30:00 AM

Photograplter Jamie Paulin

Descrlptio11

Near the process area and WWTU. Six x 55-gallon containers were being stored as nonhazardous waste, Robert Janowski stated that the waste was collected from the bottom of machinery. The drum we labeled as "I" was sampled.

Disk Number 1

_ Photo Number 26


Date/Time 514/2017 12:57:00PM

Plwtograpl1er Jamie Paulin

Description

Storage of ''heavies." Seven 55-gallon containers were staged and prepared to be· sampled with coliwasas.

L..;,;_ __ -~,.,,...,.l!li....,,._,,.,,._,-.--~-:!Li':!Li'l'"c'•'!:.:'-""""=============== =====-=...at.211m:111=1C"'=-= = - ---~ ---_J MASD St, Francis 5/tf/2017 5/22/2017 -Page 13 of 32

Photographs for MASO St. Francis 5/4/201:7 Media: RCRA

Disk Number 1

Plioto 'Number 27

Pltoto FJlename DSCN1087.JPG

Date/rime 5/4/2017 12:58:00PM

Pltotograp1,er Jamie Paulin

Descriptio,t

Storage of"heavies." One 55-gallon container was labeled as sulfuric acid. SFSO 1. Sampled, I :06pm. Level of contents was 2 inches. pH paper showed pH of 1. 4 aliquots each sample jar. Split taken.

Dl$k Number 1 P!Jo_tq Number" 28

Photo File1tame DSCN1088.JPG

Dati!/Ti111e 514/2017 l:06:00PM

P/1otog,:apl1er Jamie~Paulin

Descriptiii1i

Storage of "heavi~s." One 55-gallon con~ainer was labeled as sulfuric acid. SFS0l. Sample~ 1 :06prri. Level of contents was 2 inches. pH paper showed plf of 1. 4 aliquots each sampie jar. Split taken.

~1!It'f''-i7'itin;;::,;:;n--r--<~~l::C,;=--""":f',_:1!r: ...--.....••..-.J"'::i,;,.~;;r.,:J~:lf'i"'" ""'l";:::!"~~ ·11 ,_...::,: .. , •11,----. .. ,....----,..- ~-"':1'"-"::_::::--z::-c:i:,===· :C:I -=· --:-r-:,•·::::t:::::..---- ~ "u

MASD St. Fra11ds 5/!/2017 5/22120!7-Page 1-! o/32 ...

Photographs for MASO St. Francis 5/4/2017 Media: RCRA

Disk Number 1

Pltoto Number 29

Pltoto Filename DSCN10&9.JPG

Date/Time 5/4/2017 1:08:00PM

Pltotograpl,er Jamie Paulin

Descriptiolf

Storage of"heavies." One 55-gallon · container was labeled as sulfuric acid. SFS0I . Sampled 1:06pm. Level of contents was 2 inches. pH paper showed pH of 1. 4 aliquots each sample jar. Split taken.

Disk Number 1

P!,oto Number 30

Plloto Filename DSCN1090.JPG

Date/Time 5/4/2017 1:14:00PM


Description

Storage of "heavies.''' One 55-gaUon container was labeled as sulfuric acid. SFSOl. Sampled 1 :06pm. Level of contents was 2 inches. pH paper showed pH of 1. 4 aliquots each sample jar. Split taken .

.--:.a- ;.:aJhEWWW:m.:..:u c:,;-;===---===================::m==.a======= MASD St. Frauds 51412017 ---===:a:--= 5/21/1017 ~ Pnge 15 of 32

,Photographs for MASD, St .. Francis 5/4/20\ 7 Media: RCRA

Disk Number - 1 Photo Number 31


Date/Time 5/4/2017 1:14:00PM


Descrip~ion

Storage of"heavies." One 55-gallon container was labeled as sulfuric acid. SFS0l. Sampled 1:06pm. Level of contents was 2 inches. pH paper showed pH of 1. 4 aliquots each sam_ple jar. Split taken.

Disk JVumher l

Pltoto. N,,,,,ber 3~

Pltoto File11anie DSCN1092.JPG

Datellime.

P/1otograplter

Description

5/4/2017 1:18:00 PM

Jawie Paulin

Storageof"heavies.11 One 5$-gallon C?ntainer v,:as labeleq as corro~iye & flammable. SFS02. Sampled 1 :20pm. Level of contents was 3 inches. pH paper showed pH of°8. 4 aliquots each sample jar. Split taken.

L-...;.....-,-..-r-.:-,.,...._ ::e:::::r·,~·i:':".Zi'f~~- ~~ _t.m;-~::.:i..::~ :rJ?S;":7-- ...,._.~.,...~ - ---.r::+i·- r·:-..:.....i=:i:======-J=~~?:P'.C!':±:-.... JW;'rn~=-"':.I."l MASD St. Fra11cis 5/4/2017 5/:12/201.7 - Page 16 of 32


Disk Number 1

Pftoto Number 33

Photo Filename DSCN1093.JPG .

Date/Time

Photograpfter

Description

5/4/2017 1:20:00PM

Jamie Paulin

Storage of "heavies.'' One 55-gallon container was labeled as corrosive & flammable. SFS02. Sampled I :20pm. Level of contents was 3 inches. pH paper s~owed pH of 8. 4 aliquots each sample jar. Split taken.

Disk Number 1 Photo Number 34


Date/Time 5/4/2017 1:20:00PM

Pllotographer Jamie Paulin

Description

Photograph of working area.

l •r """fL_ -.=C"'E!3!11!!!!!!"_,.,=-...,91•1l\'•"=""Wlta.======= =-=ez:n:::=:=====,,,;,,,,=====----,--_..c:==::::::'::=--_;::,.=..-~ ~ -1 MASDSt. Francis 114(2017 5/22/2017-Pnge 17 o/32

Photographs for MASD St. Francis 5/4/20171

Media: RCRA

»;sk Number 1 PJ,oto ;N1u;_1ber 35

P!,oto Filename DSCN1095:JPG

Date/Time 5/4/2017 1:21:0QPM

Photogr.apl,er Jamie Paul.in

Description

Storage of"heavies." One 55-gallon container was. labeled as corrosive.& flammable. SFSO:i_. S_ainpled 1:20pm. Level of contents was 3. inches. pH paper showed pH of 8. 4 aliquots each sample jar. Split taken.

Disk Number· Photo Numbet Pltoto Filename Da.tellime

P/,otograp/1er

D~$.cription

I

36

Di;CN1096:JPG

5/4/2017 1:26:00PM

Jamie Paulin

Storage of."heavies." dne 55-g;i.llon cqntain~r was l~beled. as corrosive & flrurii:riable. SFS0l. S_ampled l,20pnJ. Level of contents w;is 3 inches, pH paper sho\ved pH of 8. 4 aliquots each sample jar. Split taken.

0~£-:c.~·l"---·~-c~~o··- ~--·,., ........ •r -1"'r•e:re .. ... , .... ,c....:,.·'J71:o:· ======· ==::::·· =·=::,:·c:~·=====·:<!!"'=·::nn:,:~::,:,-e::,= -=·=::.:-:::.·==··;m, ===i==i MASD St. l!rmrcis 5/tl/2017 5/22/2017 - Pag118 of 32 ··.


Disk Number Photo Number 31

Photo Filename- DSCN1097.JPG

Date/Time 5/4/2017 1:30:00PM


Description

Storage of "heavies." One 55-gallon container was labeled as MDG ZymoBac GTLS lOx. SFS03. Sampled l:31pm. Level of contents was 2.5 inches. pH paper showed pH of 6. 4 aliquots each sample jar. Split taken.

Disk Number 1

Photo Number 38

J'/,oto File11ame DSCN1098.JPG

Date/Tinte 5/4/2017 1:34:00 PM

Pltotograplrer Jamie Paulin

Descriptio11

Storage of "heavies." One 55-gallon container was labeled as MDG ZymoBac GTLS lOx. SFS03. Sampled 1:31pm. leyel of contents was 2.5 inches. pH paper sho,¥ed pH of 6. 4 aliquots each sample jar. Split taken.

MASD St. Fra11cis 514/2017 5/12/2017-Page 19of32

------ -


Disk Nutnher 1

Plto_to Numl,er 39

Photo Filename DSCNI099.JPG

Date/Time

Photographer

Descriptio11,

5/4/2017 1:35:00PM

Jamie Paulin

Storage of "h~avies." One 55-gallon container was labeled as J\.1DG ZyinoBac GTLS lOx. SFS03. S~led 1:31pm. Level of contents was 2.5 inches. pH paper showed pH of 6. 4 aliquots each sample jar. Split taken.

Disk Number 1 . '

Pl,oto Numhe_r 40

Photo _f'i/e,zaflle DSCNl 100.JPG

DateiTime 5/4/2017 1:38:00PM·

Photographer

Desctiptio,i

Storage of"hea\'i_es." One 55-gallon container was' labe!e\i as MDG ZymoBac G1Ls·10x, SFS93,.~ani.pled l:3lp.ni, Level of cont¢nts was'2.51 it)ches. P,H_paper sh9wed pH of 6, 4 aliquots each sampie jar. Split taken.


Disk Number 1

Photo Number 41

Pltoto Filename DSCNl 10 I .JPG

Date/Timi!

Pltotograplter

Description

5/4/2017 1:40;00PM

Jamie Paulin

Stor.ige of"heavies." One 55-gallon container was labeled as Toluene. SFS04. Sampled I :39pm. Level of contents was 2 inches. pH paper showed pH of 6. 4 aliquots each sample jar. 300ppm VQCs Oil mu!ti-rae. Split taken.

Disk Number Pftoto Numhe1· 42

Pltoto Filename DSCNI 102.JPG

Date/Time . 5/4/·2017 1:42:00 PM

Pltotograpfler Jamie Paulin

Desc.rip1io11.

Storage of "heavies." One 55-gallon container was labeled as Toluene. SFS04. Sampled 1 :39pm. Level of contents was 2 inches. pH paper showed pH of 6. 4 aliquots each sample jar. 300ppm voes on multi-rae. Split taken.

MASD SI. Fra11cis 514/2017 5/22/2017- Page 21 of 32


Disk N11mher 1

Pl,oto Number 43

Pltoto File11ame DSCN1103.JPG

Date/Time 5/4/2017 1:43:00PM

P/1otograpl1er Jamie Paulin

Descripti.on

Storage of "heavies." One 55-gallon container was labeled as Toluene. SFS04. Sampled I :39pm. Level of contents was 2 inches. pH paper showed pH of 6. 4 aliquots each sample jar. 300ppm voes on multi-rae. Split taken.

Disk Number 1 Photo Number ,, 44


Date/Time 5/4/2017 1:47:00PM


Description

Storage of "heavies." One 55-gallon container was labeled as Toluene. SFS04. Sampled l :39pm. Level of contents was 2 inches. pH paper showed pH of 6. 4 aliquots each sample jar. 300ppm voes on multi-rae. Split taken.

====-..:.....:=============.:========:::,:=---=-=====·'====u:::::::--- t MASDSt. Fra11cis 5/412017 5/22/2017 - Page 22 of 32

Photogr~phs for MASD St. Franci$·5/4/2017' Media: RCRA

Disk Number 1

Photo Number 45'

Photo File,,ame DSCNl 105.JPG

Date/Time 5/4/2,017 1:48:00PM

Plrotograplter Jamie Paulin

Description

Storage of"heavies.•i One 55-gallon container was labeled as Muriatic Acid. SFSOS. Tried to.sample at 1:46pm. When drum was opened, the drum began to fume/smoke. We did not take a sample for safety purposes. The fumes turned the pH paper red, pH of 1.

Disk Num~er 1 . PltotiiNumber 46

Pltoto Filettame, DSCNl 106JPG

Date/Tinte 5/4/2017 1:51:00PM

Pliotographer Jami~ Paulin

De.scription

Sto~ge of"heavies.11 On~ $5-g11llon container was labeled as Miirhitic Acid. SFSOS. Tried to sampie·at 1:46pm. When d11ll!l )VaS opened, ~be dn:im ~egan to · fume/smoke. We diq not take a S!ll11ple for safety purposes. The fumes turned the pH paper red, pH of 1.


Disk Nltmber I Pltoto Number 47

Photo Filename DSCNI 107.JPG

Date/Time

PT,otograpl1er

Description

5/4/2017 1:51:00PM

Jamie Paulin

Storage of "heavies." One 55-gallon container was labeled. as Muriatic Acid. SFS05. Tried to sample at I :46pm. When drum was opened, the drum began to fume/smoke. We did not take a sample for safety purposes. The fumes turned the pH paper red, pH of 1.


Photo Filename DSCNl I 08.JPG

Date/Time 5/4/2017 1:52:00PM

Pltotograph'er Jamie Paulin

Description

Storage of"heavies." One 55-gallon cootainer was labeled as Muriatic Acid. SFS05. Tried to sample at 1 :46pm. When drum was opened, the drum began to fume/smoke. We did not take a samp!~ for safety purposes. The fumes turned the pH paper red, pH ofl .

"'----~.,..--.~___,.:::::i:.:::i:1============-""""-===:i==:e:."Ml!>===========:..._--,---:-':'-c-:0---'-----~ ] MASD S(, Francis 5/412017 5/22/2017- Page 24 of 32

Photographs fo.r MASD· St. Francis 5/4/2017 . Media: RCRA

Disk Number 1

PJ,oto N11mber 49

Pltoto File11ame DSCN1109.JPG

Date/Time 5/4/2017 1:55:00PM


Description

Storage of"heavies." One 55-gallon container was labeled as Muriatic Acid 20 DEG. SFS06. Sampled 1:55pm. Level of contents was 3.2 inches. pH paper showed pH of· I. 4 aliquots each sample jar. Split taken.

Disk Numhe~ I Plto(o Numlier so Photo Filename DSCNll 10.JPG

Datef]'ime: 514/10 I 7 1:58:00PM

Photographer

Descriptii'Jn

Jamie Paulin

Storage· of "heavie~." One 5~-gallon container was laoeled as Muriatic Acid 20 DEG. SFS06. Sampled 1 ;55pm. Lev~l of content!! was J.2 intlies. pl{ p~per showed pH of I. 4 aliquots eacli sample jar. Split taken,

~··-~u-.. ---:~· -·--·-37t- :,r:-~,..-":",,::-~:,;,:=:;:;:;"'===··~--.:.::=-..::::c_~~"Tl-c:~·-~...,..,.c-::;·~~ ~-.,~..--,nr: 'tt- ~ i., ...... .... m: . MASD St. Fra1tds 5/412017

--,.-~~-.,__ •• ,....,"'t" .... ~---=:n

512212017'.. Page'25'of 32 .



Plioto Filename DSCNllll.JPG

-pate/Time 5/4/2017 1:58:00PM


Descript/011

Storage of"heavies." One 55-gallon container was labeled as Muriatic Acid 20 DEG. SFS06. Sampled 1:55pm. Level of contents was 3.2 inches. pH paper showed pH ofl. 4 aliquots each sample jar. Split taken.

Disk Number 1

Photo Number 52


Date/Time 5/4/2017 2:03:00PM


Description

Storage of "beavies." One 55-gallon container was labeled as Muriatic Acid 20 DEG. SFS06. Sampled 1:55pm. Level of contents was 3.2 inches. pH paper showed pH of 1. 4 aliquots each sample jar. Split taken.

MASD SI, Fram;is 5/4/2017 ---- -.:.:., 5/22/2017-Page26of32

Photographs for MASD St. Franci~ 5/4/2017 _ Media: RCM,

Disk Numbe_r 1 Pltoto Number 53

Photo Filename DSCNl 113.JPG

Date/Time

Pl,otograplter

Descript/011

5/4/2017 2:04:00PM

Jamie Paulin

Storage of"heavies." One 55-gallon container was labeled as pTOH/Triethyl Citrate Kosher_ SFS07- Sampled 2:03pm. Level of contents Wl1,S 2 .75 inches. pH paper sho"'<ed pH of 6. 4 aliquots each sample jar. Split taken.

D1'sk Number 1

Pltoto Number 54

Photo File1rame DSCNl i 14.JPG

Date/Time 5/4/2017 2:01:ooPM

Photographer Jamie Paulm

Description

Storage of"heavies.i' 0ne·55-gallon container was.labeled as ETOH/Triethyl Citrate Kosher. SFS07. Sampled 2:03pm. Level of contents was. 2.15 inches. pH papershowed pH of 6. 4 aliquots each sample jar. Split taken.

c.:M..=~=s='D,::S'.:::,:t.=i.Fi=,a=~""'c,::::·s:,;:5/.=~12oif''.::.- ::..-n~:,;;:·c::-======·=·~=-.r ==:n::==:i::~::::-·:i::r:====i,:,,.·=====l'=::.::·-::!!":E:P ====s.::a:V2:.:;2/2:.:::·-_~DI""7""':..._""p,""ag=e=2=1=of=3=,,2-


Disk Number 1

Pltoto Number 55 PT,oto Filename DSCN1115.JPG

Date/Time

Plwtograp!,er

Descriptio11

5/4/2017 2:11:00PM

Jamie Paulin

Storage of "heavies." One 55-gallon container was labeled as ETOH/Triethyl Citrate Kosher. SFS07. Sampled 2:03pm. Level of contents-was 2.75 inches. pH paper showed pH of 6. 4 aliquots each sample jar. Split taken.

Disk Number 1

P!,oto Number 56

Photo File11ame DSCNl 116.JPG

Date/Time 5/4/2017 2:56:00PM

PhotograP,her Jamje Paulin

Description

Storage of"heavies.'' One 55-gallon contatner was labeled as Non Hai.ardous Waste. SFS08. Sampled 3:10pm. Full contents. pH paper showed pH of 10. 8 aliquots each sample jar. 4 x 16 oz sample jars were filled. Split taken.

IIIASDSt. Francis S/tl/2017 5/22/2017- Page 28 of 32

Photographs for MASD St. Francis 5/4/2017 :Media: RCRA

Disk Number 1 Phota Number- 57


Date/Time 5/4/2017 3:01:00PM


Description·

Storage of "heavies." One 55-gallon container was labeled as Non Hazardous Waste. SFS08. Sampled 3:10pm. Full contents. pH pap.er showed pH of 10. 8 aliquots each sample jar. 4 x 16 oz sample jars were f;illed. Split ~en.

Dis!, Number 1

Plioto Number 58

Photo Filename DSCNl 1 J 8.JPG

DatefT.lme 5/4/2017 3:17:00PM

Pft()tograp/ier Jllmie Paulin

Descrip(ioti

Storage of"qeavies~" One 55-gll-lion contaihei; \\73:S labeJe·~ as NQnHuardou.s Waste. SFS08. Sampled 3:10pm. Full contents. pH paper showed pH of IO. 8· aliquots each sample jar~ 4 x 16. oz sample jars were filled. Split taken. .

..... ~ · C ~ ,,..._.,. -er:: MASD St. Frducis 5/4/2017

n=-~-ia:ocr::::cn · :m:,"'!C:?7'"'-r-c:r'i'51t"!T:1'tt.:~~-1t S/12/201'1 '.- Page 29 of 32

Photographs for MA.SD St. Francis 5/4/2017 Media: RCRA

Disk Number 1

Plwto Number 59

Pltoto Filename DSCNl 119.JPG

Date/Time

Pltotographer

Description

5/4/2017 3:17:00PM Jamie Paulin

Storage of"heavies." One 55-gallon container was labeled as Non Hazardous Waste. SFS09. Sampled 3:23pm. Full contents. pH paper showed pH of 10. 8 aliquots each sample jar. 4 x 16 oz sample jars were filled. Split taken.

Disk Number l

Plzoto Number 60

Pltoto Filename DSCNl 120.JPG

Da(e/Time

Pl,otograp/rer

Description

5/4/2017 3:19:00PM Tamie Paulin

Storage of"heavies.'' One 55-gallon container was labeled as Non Hazardous Waste. SFS09. Sampled 3:23pm. Full contents. pH paper showed pH ofl0. 8 aliquots each sample jar. 4 x 16 oz sample jars were filled. Split taken.

Photographs for MASD, St. Francis 5/4/2017 Media: RCRA

DlskNuJnber 1

Pltoto Number 61

Photo File11ame DS<i:Nl 121 .JPG

Date/Time 5/4/2017 3:23:00PM

Pl1otograp/1er Jamie Paulin

Description

Storage of';heavies.'·' One 55-galton container was labeled as Non Hazardous Waste. SFS09. Sampled 3:23pm. Full contents. pH paper showed pH oflO. 8 aliquots each sample jar. 4 x 16 oz sample jars we:r!'l filled. Split taken.

Disk Number Photo IY.1!111her Plwt1tFile1_1ame Date(Time

Plwtograplfer

Des,criptl'o11.

I

62 DSCNl 122.JPG

5/4/2017 3:31:d0PM .

Jamie Pai.llfu

Storage of "heavies.'' One 55-gallon ·contafuer was labeled as Non Hazardous Waste. SFS09. SartlpJe~ 3:23pm. Full contents. pH paper sµowea. pH of 10. 8 aliquots each sample jar. 4 x 16, oz sample jars were filled. Split taken.


Disk Number l

Photo Number 63

Photo Filename DSCNI 123.JPG

Date/Time

Photographer

Description

5/4/2017 3:37:00 PM Jamie Paulin

Storage of"heavies." One 55-gallon container was labeled as Non Hazardous Waste. SFSl 0. Sampled 3:37pm. Full contents. 3 scoops each sample jar. 4 x 16 oz sample jars were filled. Split taken. Duplicate taken.

Disk Number 1 Photo Number 64

Photo File11ame DSCNJ124.JPG

Date/Time

Photographer

Description

5/4/2017 3:43:00PM

Jamie Paulin

Storage of"heavies." One 55-gal!on container was labeled as Non Hazardous Waste. SFSl0. Sampled 3:37pm. Full contents. 3 sco·ops each s_ample jar. 4 x 16 oz sample jars were filled. Split taken. Duplicate taken.

' ~ ..'!!.

JI.IASD St. Frallcis 51412017 5/22/2017-Page32 of32

U.S. Environmental Protection Agency Region 5

Name of Facility /fl1(",(. - A"'e.ri°' r:1-e.d D~

RECEIPT FOR SAMPLES

Project Number

f1 If- J D - t>S- - o'--/ - I 7

Facility Location 3"'JS-O 5 _ PE'l'l..,.s._,lv4,,, A-ve._ S I-. Fr-.t:.i_s , WT- S-3.J.3,<

DESCRIPTION

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f)<!-....,,- WwTV F/A..5J, f';Y'I r ,-1 TC.LP )lleJv...r

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1-l~sJ.. ro1h. f- I pl// T cLp fl/1c...klr /

/CL(> HJ,, Tc.LP VtJC-J,, JCL,f' SV6C--r

Date Signed

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EPA Representative (signature)

/~C-...- ~

Name (print)

Br;"'-" )t({.nf1e,,l Title

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Distribution: Original to Faci lity Representative; Copy to Project File

--Date Signed

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--------------------------·"""-""····--·-··-

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS

Date of Sampling Event:

Facility Name:

Facility Address:

EPA RCRA ID Number:

Generator Status:

Facility Contact:

EPA Contact:

Prepared By:

Approved By:

77 WEST JACKSON BOULEY ARD CHICAGO, ILLINOIS 60604

Sampling Report

May 4, 2017

Container Life Cycle Management, LLC d/b/a Mid-America Steel Drum

8570 South Chicago Road Oak Creek, Wisconsin 53154

WID045953189

Small Quantity Generator

Kevin Meyer Plant Manager

Brenda Whitney - Environmental Engineer RCRABranch Compliance Section 2 Land and Chemicals Division

~-e-y---E-nv~i~_m,_,,,_en_tal_E_n_g_in-eer

Morris - Chief, Compliance Section 2

Purpose of the Sampling Event

7-",>/7 Date.

An unannounced Sampling Event at Mid-Ame1ica Steel Drum ("MASD-OC") located at 8570 Chicago Road, in Oak Creek, Wisconsin, took place on May 4, 2017. MASD-OC has notifie<l as a small quantity generator (SQG) of hazardous waste. Graciela Scambiatterra accompanied me during this event. In addition to facility representatives, attorneys from the Foley & Lardner LLP ("F&L") were present during the event.

The Sampling Event was conducted at three MASD facilities in the Milwaukee area simultaneously in order to obtain analytical data to supplement an evaluation of MASD's compliance at these three facilities with the appropriate hazardous waste regulations codified at · the authorized Wisconsin Administrative Code and the Code of Federal Regulations. This report is a record of the MASD-OC facility sampling event only. Reports for the other two facilities are Vl'ritten tmder separate cover.

Participants

111e following people were pres~nt for part or all of this event:

Chris Mosely - Maintenance Engineer

David Lowry - Assistant Plant Manager

Kevin Meyer - Plant Manager

Sherry Kannenberg - Receptionist

Mike Flanagan - Attorney

Sarah ~1ack - Attorney

Graciela Scambiatterra - Envirnnmental Scientist'

Brenda Whitney - Environmental Engineer

Introduction

MASD-OC

MASD-OC

MASD-OC

·MASD-OC

F&L

F&L

EPA

EPA

The sampling event was conducted simultaneously at three MASD facilities. as the next logical step in an on-going effort to respond to inquiries made by State representatives as well as by citizens in the areas surrounding the facility pursuant to an article published in the Milwaukee Journal Sentinel on February 15, 2017. The article discussed potential enviromnental aod human hea1th hazards presented by the operations at .the MASD faci)jties, prompting an inter-agency response. An initial inspection was conducted at this facility on March 2, 2017~ in coordination with PHMSA (DOT) and WDNR. Based on observations made during that inspection, EPA procured a federal warrant in order to conduct this sampling event.

Pre-Site Visit

Prior to the san1pli11g event, EPA inspectors completed a Health and Safety Plan (HASP), a Sarnp1ing Analysis Plan (SAP), and a Quality Assurance Project Plan (QAPP). An ex parte administrative warrant from the U.S. Dist.Iict Court Eastern District of Wisconsin was procured on May 2, 2017.

Site Visit

Ms. Scambiatterra and I made entry at the Facility at 10:10 am. We noticed a distinct chemical odor in the air. I observed visible gray emissions from the stack associated with the furnace. As we walked into the office, we presented the warrant to Ms. Kannenberg. We infonned the MASD personnel that we would be sampling at the site that day, and that the warrant allowed us unimpeded access to the site. Mr. Mosely was assigned to assist us through the site and accompanied us to their storage dock, hereinafter referred to as the "Heavies Dock," which is a holding area for containers that are to be returned to the vendor without being processed. MASD

2

........ ·········-····-----------------

questioned our ability to enter the site without MASD's attorneys present. Ms. Scambiatterra provided Ms. Kannenberg with the phone number for the Assistant U.S. Attorney, Michael Carter, who was put in contact MASD's attorneys at F&L in order that they may discuss the warrant, and F&L could counsel MASD regarding access to the Facility. Access was acknowledged by MASD at approximately 10:35am.

-- ---- ----· ----

Photographs were taken at the Heavies Dock (See Appendix A: Photographs 1-3). We instructed the facility representatives not to move the photographed containers from the area. We then proceeded to the drum storage dock at the furnace, hereinafter referred to as the "Furnace Dock." Photographs were taken at this dock (See Appendix A: Photographs 4-1 0A) We observed a drnm of paint-booth filters and cardboard (See Appendix A: Photograph 11). We were told that they were awaiting sample results for those filters.

We next chose to select and stage containers for sampling on the Furnace Dock(See Appendix A: Photographs 12-13). One container was chosen from a truck trailer that had backed up to the Furnace Dock. Two drums were pulled from the conveyor that was heading to the furnace. Two additional drums, which had not yet been placed onto the conveyor, were chosen from the Furnace Dock. Three drums that were used to consolidate silicon-based wastes from off-site vendors were left in place, as they were full, and could not be lined np with the other containers.

After selecting and staging the eight containers, we came down from the Furnace Dock and observed a full drum outside of the main facility building that appeared to contain the same type of waste that was being accumulated in the three full drums on the Furnace Dock (See Appendix A: Photograph 14). Mr. Lowry confim1ed that this drum was also a consolidation container. This container was labeled "Non-Regulated." In a garage area, identified by facility personnel as "The Hole", near the "Non-Regulated" container, were approximately 10 additional containers (_See Appendix A: Photograph 15). These containers were labeled as "Non-Ha7.,ardous." Ms. Scambiatterra asked Messers. Lowry and Mosely if they knew what was in the containers, and they stated that they did not.

We then proceeded to the Heavies Dock to photograph, select and stage containers for sampling (See Appendix A: Photographs 16-17 and 19-20). A photograph was taken of a "Rejected" label on one of the containers (See Appendix A: Photograph 18). It did not appear that all containers were identified with one of these "Rejected" labels. After the selection, we returned to the car to collect our sampling equipment and to don protective gear.

Sampling - Heavies Dock

OCS-01

CoLiWaSa, 1.5 pH paper, inches ruler, 16oz glass jars.

4.5 Yes 21-23

3

OCS- 1:28pm CoLiWaSa, 1.25 5 Yes 02 pH paper, inches

ruler, 16oz glass jars.

OCS- 1:50pm CoLiWaSa, 1.5 2.5 Yes 03 pH paper, inches

ruler, 16oz glass jars.

Sampling - Furnace Dock ·

OCS-04

OCS-05

OCS-06

OCS-07

OCS-08

OCS-09

OCS-. 10 and OCS-10-Dup

2: 17pm Scoop, pH paper, ruler, 16oz glass Jars

· Unable to 9 get depth.

Yes

2:32pm Scoop, pH 5 inches Jncon- Yes paper, ruler, elusive 16oz glass Jars

2:45pm Scoop, pH 3.5 Incon- Yes paper, ruler, inches elusive 16oz gl~s jars

2:57pm CoLiWaSa, 7 inches 6 Yes pH paper, ruler, 16oz glass jars

3:09pm Scoop, pH 0.25-0.5 4 Yes paper, ruler, inches 16oz glass Jars

3:16pm Scoop,pH Full 6 Yes paper, 16oz Drum glass jars

3:30pm CoLiWaSa, Full 6 Yes pH paper, Drum 16oz glass Jars

4

Waste had a thin consistency and was pourable. Strong solvent odor.

24-26

27-29

Waste was gummy 32-33 and had a strong solvent odor.

Waste was gummy 34-35 and had a strong · solvent odor.

Clear watery consistency with black inky residual. Waste had a thin consistency and w~ pourable. Strong solvent odor.

36-38

39-41

Waste was gummy 4 3 * and had a strong solvent odor. Consolidation drum. Waste was gwnmy 45* and had a strong solvent odor. Consolidation dnun.

----- ·-·· -···-·--·---····-·· .. ...... ·······-··--··--·--·- ··---- -------- -----------·- -··--········-· .................... ________ _

OCS- 3:45pm Scoop, pH Full 6 Yes Waste was gummy 47* 11 paper, 16oz Drum and had a strong

glass jars solvent odor. Consolidation drum.

OCS- 3:55pm Scoop, 16oz NIA NIA Yes Ash luggar box. 48 12 j ars

*NOTE: Entries for photographs 42, 44, and 46 were mistakenly logged into the logbook, however, these photos were never taken. The tin-zes associated with these entries in the logbook are attributed to the time zhe pH readings were made.

Sampling - Comp)etiou

The final sample was taken at 3:55pm. We proceeded to bag and tag the samples at that time. We prepared a chain of custody form for the samples as ..yell as a sample receipt. Copies of these documents were provided to MASD upon our departure from the facility at 6: 1 0pm.

Appendices

Appendix A: Photograph Log Appendix B: Carbon Copy of Chain of Custody Appendix C: Receipt for Samples

5

Appendix A

Photograph Log

Sampling Even Date: May 4, 2017

Facility Name and ID Number: }vfid-America Steel Drum EPA ID: WID045953189

Photographers: Brenda Whitney Compliance Section 2 -and-Graciela Scambiatterra Compliance Section l RCRABranch Land and Chemicals Division

Camera Used: Olympus Stylus 600 Serial Number: A47525904

- ------- -----~-··-·-··-····· .. ·· . .. .. ... ..... . . . . ... ..... . .

Photograph 1 Taken at 10:19 am CST

Photo ID: P5040001

Heavies Dock.


Photo ID: ?5040002

Heavies Dock

. . •.. .. .. ... ····· ········------------

7/3/2017

1


Photo ID: P5040003

Heavies Dock.

Pho_tograph 4 Taken at 10:40 am CST

Ph~to ID: P5040004

Furnace Dock.

7/3/2017

2

. ....... . .. . .... ..... . . ··-·· ·-·-·······-------- --------------·-·-················· .. . , ..

Photograph 5 Taken at 10:41 a m CST

Photo ID: P5040005

Furnace Dock.

Note: Two containers in background are tipped into Consolidation Drums,


PhotolD:P5040006

Fu mace Dode.

i ,..

. - .. ...... -·------·-------------

7/3/2017

3


Photo ·io: PS040007

First trailer at Furnace Dock.


Photo ID: P5040008

Second trailer at Furnace Dock.

7/3/2017

4 ·

,r-,

-~

... . .. .. . .. . ..... . . . . .. _, , ....... _,, ... ,,., _ ., __________________ ,, ___ , -·--- . ..... -......


Photo ID: ?5040009

Third trailer at the Furnace Dock.


Photo1D:P5040010

Fourth trailer at the Furnace Dock.

Note: the foremost container was initially selected for sampling.

7/3/2017

5

Photograph 10-A Taken at 10:41 am CST

· Photo 10: P5040011

Close up of drum in the fourth trailer at the Furnace Dock identified In Photograph 10.


PhotolD:P50400U

Full Drum of Paint Booth filters located at the Furn.ice Dock.

7/3/2017

~ '

l t:t.:_) 6

---·· ··-··--·- --,- ---------------··- -- ···· -··-- ... . .


Photo ID: P5040013

Five drums staged for Sampling at the Furnace Dock.


Photo ID: P5040014

Three drums closed to the railing are staged _for sampling at the Furnace Dock.

11111!1!'.rf" ~l~

'.

~

f.==,,i w--;

_ j ;

7/3/2017

7

·;_


Photo1D: PS040015

Full container of "Non-Regulated Material:'


Photo ID: PS040016

The "Hofe:' Containers were marked as "Non-Haza~dous:'

7/3/2017

8

"Photogra ph 16 Taken al 11:50 am CST

Photo ID: PS040017

Heavies Dock.


Photo ID: P5040018

Heavies Dock.

-------------------·---·-"· . --h ··~· ·

7/3/2017

tt:r~

, .... :~,r~~~:~1~1-~

9


Photo1D;P5040019

Rejected label on drum on the Heavies Dock.

Photograph 19 Taken at 12:15pm CST

Photo1D:P5040020

S_taged drums for sampling at the Heavies Dock. ·

·- . .

~l~!-b:~~'-~

' --L~ . . F--

7/3/2017

10

- ·--·--·-------------------


Photo ID: P5040021

Staged drums at the Heavies Dock with sampling equipment.


Photo ID: P5040022

Waste depth measurement for OCS-01.

... ...... . . - ··- - ··-----·--------------

7/3/2017

-· ,.

11


Photo ID: P5040023

pH paper for OCS-01.


Photo1D:P5040024

OCS-01 completed sample and split.

7/3/2017

. ' :

12

--······ - ······-····- ----,------- ---····- ··· .. .


Photo ID: PS040025

Waste depth measuremi:nt for OCS-02.


Photo ID: PS040026.


' i: . i .... • ··1 ~ :: ·~: ' . I'.;

-··-·· ·· ····-···------

7/3/2017

13


Photo1D:PS040027



Photo ID: PS040028

Waste depth measurement for OCS-03.

.7/3/2017

i .

14

.. . . --·-· - ~-··~·· ... ...... . . .. .. . .. . . . _,, . ......... , . , _____________ _

Photpgraph 28 Taken at 1:36pm CST

Photo ID: P5040029



Photo ID: ?5040030

OCS-03 completed sample and split. Only one 16oz jar was taken for EPA portion of sample.

7/3/2017

15


Photo ID: PS040031


Photograph 31 T~ken at 2:17pm CST

Photo10:PS040032

OCS-04 completed sample and split. Only one 16 ounce Jar was taken by EPA for this sample.

7/3/2017

·16

.. ,


Photo ID: PS040033

OCS-05 waste depth measurement.

Photograph 33 Taken af 2:32pm CST

Photo ID: P5040034

OCS--05 completed sample and split.

. . -···-"··· -·----------------- ·~···--·

l

.. ~ I I

7/3/2017

17


Photo ID: PS040035

OCS-06 waste depth measurement.

Photograph 35 Taken at 2:4Sphl CST

Photo ID: PS040036

OCS-06 competed sample and split.

A label on the drum states "Rejected:'

7/3/2017

18

_________ ___:. ______________ . ·-·-·· ·· .


Photo1D:PS040037

OCS_07 waste depth measurement.


Photo ID: PS040038


. ·· -- -····----·---- ~~- - ------------ , ...

7/3/2017

19

Phqtograph 38 Taken at 2:57pm CST

PhotolD:P5040039



Photo ID: PS040040

OCS-08 waste depth measurement demarcated by faint brown line on the scoop.

> i , .,, ii

7/3/2017

20


Photo ID: PS040041

pli pa per for OCS-08.


Photo ID: PS040042


_...-:,· -~ :: =-· .. --:-.--- -~-~:-£"~+:~~~~- ·--~·--:··~::~~"Y--i:- ;;. ' . . ', -··· -:_::::..-.z::~--:· .. : . -· -:~:~

.. . ' ~--

~ ,~~- ~ ~~--

- ·-----·---···------------

7/3/2017

t ~t':,;:

tt1lj;~$, ,

21

r

. ; ; f


Photo ID: P5040043


Please note: Photograph 42 was logged In "the log book. No photograph was taken.


PhotolD:P5040044

OCS-10 completed sample, duplicate sample, and split.

Please note: Photograph 44 was logged in the logbook, but was never taken.

' -~ , ·

7/3/2017

22

. ... . ... - .. -- ···· ···-·«······--------------- -

Phot.ograph 47 Taken at 3:45pm CST

Photo ID: P5040045


Please note: Photograph 46 was logged in the logbook. No photo was taken.


Photo ID: PS040046


t .. r

. ... ! ·;

· - . - . - ····"

7/3/2017 ; ·

23

--- ' , ____ ,, __ . ,_ .. ,,. " ' " "' '" ' "" " " ' " " ' .... .. .... .. .. - ---------------- .-- ·----~ , .. -.. ,,,~,.,,, ....... .

AppendixB

Documents Provided to Facility: • Chain of Custody Record 5-

50252. • Receipt for Samples

Sampling Event Date: May 4, 2017

Facility Name and ID Number: Mid-America Steel Drum EPA ID: WID045953189

Samplers: Brenda Whitney Compliance Section 2 -and-Graciela Scambiatterra Compliance Section 1 RCRABranch Land and Chemicals Division

ENVIRONMENTAL PROTECTION AGENCY Office of Enforcement

.

PROJ. NO. PROJECT NAME

: SAMPLERS: (Print Name and Sign)

a: ro

.. -----

--.

Vi U"'IUI-. ....,. 'VY'-# I...,..., • • •---• •-

NO. .. ·-

--

OF

·- . CON- ,;,-" TAINERS iii

STA.NO. DATE TIME ::;; <,:

STATION LOCATION -f' 0 a: 0 Cl

-· • -__ ·. ..

-, >, ' --_ -- ·.

" -· ·. ---

• . . . .

. -! . ·- -· . .

. ; .

--· . . .. ·._ .

. · .

·. .-- . ..

" .· . .

_-- .

----

I . -· • • . ---- :7' : . . ·

Relinquished by: (Signature) Date/Time Received by: (Signature)

'"' ·-., .

Relinquished by: (Signature) · · Date/Time Received by: (Signature) .

I Relinquished by: (Signature) Date /Time Received for Laboratory by: Date/Time

(Signature) /

--• .- .. f .. ;_ /-. -·; .... -i:_i-, - /•. ·.:·;-.. . -· .-Distribution: White - Accompanies Shipment; Plnk - Coordinator Field Flies; Yellow - Laboratory File

@ Printed on Recycled Paper/Printed with Soy-Based Ink

REGIONS 77 West Jackson Boulevard

Activity Code:

. -

TAG NUMBERS

---

-· · . .

_-.

. .

..

·- .. .

.,

. · . -· --· .

'

... . . · .. :· . ·--

Ship To:

ATTN: Airbill Number

Chain of Custody Seal Numbers

2\ f\ ,':, !?; ~~,,

/

U.S. Environmental Protection Agency Regions

RECEIPT FOR SAMPLES

Project Number Name of Facility .S,L. /J n Ir\,•£ ~'t' <- ru-c <tJrl{fYl {}11'.\sD- os- -oif-11

Facility Location SS'rC S;. <..h.t~J"' R..,o ... ~ o.,._fc. u--ee.k,1/tt. 'S?IS'f

3 s M1A-f le.& ~{t_,e,n ~ 'Ifµ_ /)odz_ Vl-rea... ( H ea V i ,e

o-t' 3 6S'-~ t:V't,{M-lS.

- e si;:IIW-flu ~~ ~ '1k -Ci.v-nace..

o,f B S''='> -r» im cf..,-.IA..;v.S

- ~ tM'V'-fl lt a..P ~ ()1....£:'h /;--tJrVL

Facility Representative (signature)

Name (print)

kevitv Title Date Signed

i;_ L{- {1" Title ' n ri

6'11 VI nm~~ • y\. e.e--('

Distribution: Original to Facility Representative; Copy to Project File

Jock....

~j3U" bb;(.

Date Signed

,5' 4 r fJ

/ /

I /.-