John R. Kasich, GovernorMary Taylor, It. GovernorScott J. Nally, Director

August 16, 2013

WASHINGTON COUNTYRICHARDSON PRINTINGDMWM/SEDO0HD987029451

Mr. Dennis ValentineRichardson Printing201 Acme StreetMarietta, Ohio 45750

Dear Mr. Valentine:

On August 7 and 13, 2013, Ohio EPA inspected Richardson Printing's 201 Acme Streetlocation in Marietta, Ohio. The purpose of the inspection was to determine compliancewith Ohio's hazardous waste laws as found in Chapter 3734 of the Ohio Revised Code(ORC) and Chapter 3745 of the Ohio Administrative Code (OAC).

I found the following violations of Ohio's hazardous waste laws:

1. OAC 3745-273-13(D)(1), Waste Management-Standards for Small Quantity Handlers ofUniversal Waste: A handler must manage lamps in a way that prevents releases. Lampsmust be contained in packages that are closed.

Richardson Printing was not properly containing spent fluorescent lamps in boxes.Uncontained spent lamps were observed in various areas of the facility. Other spent lampswere boxed but boxes were not closed. Following Ohio EPA's August 7, 2013 inspection,Richardson properly contained lamps. This was observed during Ohio EPA's August 13,2013 inspection. Therefore, this violation has now been abated.

2. OAC 3745-273-14 (E), Labeling/Marking Standards for Small Quantity Handlers ofUniversal Waste: Each lamp or container in which lamps are contained must be marked clearlywith the words "Universal Waste Lamps" or 'Waste Lamps" or "Used Lamps".

Richardson Printing failed to properly label boxes of spent lamps. Boxes were unlabeled ordid not have the proper markings. Following Ohio EPA's August 7, 2013 inspection,Richardson properly labeled the lamp containers. This was observed during Ohio EPA'sAugust 13, 2013 inspection. Therefore, this violation has now been abated.

Richardson Printing has now abated all violations discovered during the August 7 and August13, 2013 inspections.

Southeast District Office 2195 Front Street • Logan, OH 43138-8637www.epa.ohio.gov • (740) 3858501 (740) 385-6490 (fax)

RICHARDSON PRINTINGAUGUST 16, 2013PAGE 2

Enclosed, you will find a copy of the checklists that were completed as a result of theinspection. You can find copies of the rules and other information on the division's webpage at http://www.epa.state.oh.us/dhwm . If you have any questions, please contactme by telephone at (740) 380-5293 or by e-mail at donnaqoodnian@epa.state.oh.us .

Sincerely,

Donna GoodmaInspectorDivision of Materials and Waste Management

Enclosure

DGIrnr

I NOTICE:Ohio EPA's failure to list specific deficiencies or violations in this letter does not relieve yourL company from having to comply with all applicable regulations.

Send to Central Office Ohio Environmental Protection Agency For Ohio EPA use only

El

RCRA SUBTITLE C SITEIDENTIFICATION/VERIFICATION FORM

Completed verification forms required to be submitted to Co should be e-mailed to RCRAInfoData(epa.ohio.govSite EPA ID No. EPA ID Number: 0HD987029451Site Name Name: Richardson Printing Website:

Site Location information Street Address: 201 Acme StreetCity, Town, or Village: Marietta State: OHCounty Name: WASHINGTON Zip Code: 45750

Site Land Type Private- District Federal Indian Municipal State Other(check only one) - ---------- - -

- - ----Eli - -- -- -El ---D - ------- El - --- El ---ElNAICS code(s)

---

www.census.gov/epcd/ww 323111-w/naics.htmlFacility Representative First Name: Dennis --1-1Last Name: Valentine

Title: PresidentAdditional names can berecorded in number 12 Phone Number 740-373-536-jPlioneNumberExtension:

E-Mail Address:Only provide address Fax Number: ---Fax Number Extension:information if it is different-Street or P.O. Box: 201 Acme Streetthan the site address City, Town or Village:

State: OH Zip Code:Legal Owner And Name of Site's Legal Owner: Date Became OwnerOperator of the Site. (mm/dd/yyyy):List Additional Owners Owner Private County District i Federal Indian Municipal State Otherand/or Operators in the Type: El El El El El El ElComment Section or on Street or P.O. Box:another copy of this form City Town orVillage: --wnerPhone#-page State Country Zip Code

mNae of Site's Operator: Date Became Operator(mrn/dd/yyyy):

Operator Private County District Federal Indian Municipal State OtherType: El El El El El El El El

Street or P.O. Box:City, TownorVillage: Operator. Phone #:State: Country Zip Code:

VIOLATIONS CITED? Yes LI No

TYPE OF HANDLER - MARK "X" AS APPROPRIATENot a HW Generator LI UNKNOWN: Large Quantity Generator (LOG)

Cited _for _violation _of_3745-52-1_1El Short-Term/Temporary Generator LISmaII Quantity Generator (SQG)

(generates from a short-term or ElConditionally Exempt Small Quantity Generator

one-time event and not from on-going LIU.S. Importer of Hazardous Wasteprocesses). Check the box for theapplicable generator status and provide El Mixed Waste (Hazardous and Radioactive)

Generatora comment

TYPE OF REGULATED WASTE ACTIVITY (MARKEl Hazardous Waste TransporterEl Hazardous Waste Transfer FacilityEl Treater, Storer or Disposer of Hazardous WasteEl Recycler of Hazardous Waste

72-Hour Recycler

IN ALL OF THE APPROPRIATE BOXES)El Exempt Boiler and/or Industrial Furnace

El Small Quantity On-Site Burner ExemptionEl Smelting, Melting, Refining Furnace Exemption

El Underground Injection Control FacilityReceives Hazardous Waste from Off-site

UNIVERSAL WASTE ACTIVITIES (INDICATE TYPES OF UNIVERSAL WASTE MANAGED(CHECK ALL BOXES THAT APPLY)

Small Quantity Handler of Universal Waste El Destination Facility for Universal Wastefl Large Quantity Handler of Universal Waste

(accumulates 5,000 kg. or more)CHECK ALL BOXES BELOW THAT APPLY FOR THE TYPES OF UNIVERSAL WASTE THE FACILITY MANAGESJ Batteries

PesticidesMercury containing equipmentLamps

USED OIL ACTIVITIES (INDICATE TYPE(S) OF ACTIVITY(S)Z Used Oil GeneratorEl Used Oil Transporter

Used Oil Transfer FacilityEl Used Oil ProcessorEl Used Oil Re-refiner

Off-Specification Used Oil BurnerO Used Oil Fuel Marketer who directs shipment of Off-Spec Used OilO Used Oil Fuel Marketer who first claims the Used Oil meets the specificationsEligible Academic Entities with Laboratories: Facility has previously notified that they are opting into managing laboratory hazardous wastepursuant to OAC rules 3745-52-200 through 3745-52-216. Check the box(es) below to indicate the laboratory type.

El College or UniversityEl Teaching hospital that is owned by or has a formal written affiliation agreement with a college or universityEl Non-profit Institute that is owned by or has a formal written affiliation agreement with a college or universityWaste Codes for Federally Regulated Hazardous Wastes. Please list the codes for the federally regulated hazardous waste handled at thesite. List them in the order they are presented in the regulations (e.g., 0001, 0003, F007, UI 12). Use an additional page or list them in the commentsmore space is needed. If the waste codes are the same as listed in the most recent RCRAInfo source record, you do not need to list them. Instead justindicate the date of the most recent source record.

COMMENTS: USE THIS AREA TO DESCRIBE WHETHER THE INSPECTION WAS ANNOUNCED WHETHER THEWASTE IS STORED IN TANKS OR CONTAINERS, ETC.Announced 0 Yes E No Additional Facility Representatives:Tanks LII Yes Z NoContainers El Yes Z No

Date of Inspection/TimeName of Inspector(s) Name of Inspector(s) (mm/dd/yyyy) (hh:mm)Donna Goodman 8/1312013 1:00 PM

Comments:Company is no longer a generator of hazardous waste at this address, 201 Acme Street, Marietta. RichardsonPrinting consists of three separate buildings, each with an individual address and generator ID number. This IDnumber for 201 Acme Street should be deactivated.

Revised 09.05. 10

PROCESS, WASTE, P2 SUMMARY SHEET

Facility Name: Richardson Printing Facility Type: Non Generator Date of Inspection: 08/13/2013 EPA ID#: 0HD987029451

Waste Generated On- or Off-Site P2 ActivitiesManagement

Process/Activity Waste QTY Generated Type of On- Name, state, and Current P2 P2 OpportunitiesGenerating Waste Description per Month, Type of Site type of activity Activities(e.g. plating bath, machining, (e.g. sludge, Accumulation (container, Treatment occurring at thebaghouse, painting, general solvent, ash, used tank, etc) and location of (recycle, W"Vt off-site facility.maintenance, etc) oil, spent lamps, waste accumulation area etc)

etc.) and EPAWaste Code, if

applic.

I Printing Waste Ink Varies. Stored in 55- Safety Kleen Use vegetable oilgallon drums based inks

Non hazardous Smithfield, KY

Used OilVaries

afetyen, recycledMaintenance

2

Spent lamps Varies. ReLights, recycled

Universal Waste Marietta, OH3 Lighting

REMARKS/GENERAL INFORMATION

General Process Information:Richardson Printing is a general commercial printer that has been in business since 1944. The facility has 44 employees and consists of threeseparate buildings, each with individual addresses (173, 201 and 202 Acme Street, Marietta) and individual generator ID numbers. The operations

PSS Table Format Electronic UseJune 2007 Page lof2

at 201 Acme St. involve sheet feeding five color printing and single color machines, letter press operations, multilithe presses, and a binderydepartment where folding and stitching is performed when needed. A bulk mail processing department also is operated as needed. Vegetablebased inks are used. When inks get old or are no longer useable, they are disposed of as a non hazardous waste. Used oil is generated from oilchanges performed on press equipment and company vehicles. 201 Acme St is a nongenerator of hazardous waste.

Regulatory/Enforcement History (if applicable):Last inspected in January 2010 and July 1994. Company has two other ID numbers at 173 and 202 Acme St. but only the 202 Acme St. locationgenerates hazardous waste at this time. The ID numbers for 201 and 173 Acme St. will be deactivated.

Additional P2 remarks and information:

Would this facility be interested in a P2 assessment? Yes No If yes, refer promptly to your district P2 coordinator.Office of Compliance Assistance and Pollution Prevention - 1-800-329-7518 or p2maiIepa. state. oh. us or www.epa. state. oh. us/ocapp/ocapp.htmi

Other:NA

PSS Table Format Electronic UseJune 2007 Page 2of2

SMALL QUANTITY UNIVERSAL WASTE HANDLER REQUIREMENTS - BATTERIES AND LAMPSLarge Quantity Universal Waste Handier (L.QUWH) = 5,000 Kg or moreSmall Quantity Universal Waste Handler (SQUWH) 5,000 Kg or lessPROHIBITIONS1. Did the SQUWH dispose of universal waste? [3745-273-11 (A)] Yes L No M N/A E2. Did the SQUWH dilute or treat universal waste, except when responding to Yes No E N/A

releases as provided in OAC rule 3745-273-17 or managing specific wastesas provided in OAC rule 3745-273-13? [3745-273-11(B)]

WASTE MANAGEMENT AND LABELING/MARKINGUNIVERSAL WASTE BATTERIES3. Are batteries that show evidence of leakage, spillage or damage that could Yes EJ No D N/A

cause leaks contained? [3745-273-13(A)(1)]4. If batteries are contained, are the containers closed and structurally sound, Yes No fl N/A

compatible with the contents of the battery and lack evidence of leakage,spillage or damage that could cause leakage? [3745-273-13(A)(1)1

5. Are the casings of the batteries breached, not intact, or open (except to Yes D No D N/Aremove the electrolyte)? [3745-273-1 3(A)]

6. If the electrolyte is removed or other wastes generated, has it been Yes No LI N/Adetermined whether the electrolyte or other wastes exhibit a characteristicof hazardous waste ? 13745-273-13(A)(3)]a. If the electrolyte or other waste is characteristic, is it managed in Yes LI No N/A

compliance with OAC Chapters 3745-50 through 3745-69? [3745-273-1 3(A)(3)(a)]

b. If the electrolyte or other waste is not hazardous, is it managed in Yes No D N/Acompliance with applicable law? (3745-273-13(A)(3)(b)]

7. Are the batteries or containers of batteries labeled with the words Yes U No fl N/A"Universal Waste - Batteries" or "Waste Battery(ies)" or "Used Battery(ies)?"[3745-273-14(A)]

UNIVERSAL WASTE LAMPS8. Does the SQUWH contain lamps in containers or packages that are Yes LI No Z N/A LI

structurally sound, adequate to prevent breakage, and compatible withcontents of the lamps? Are containers or packages closed and do they lackevidence of leakage, spillage or damage that could cause leakage? [3745-273-13(D)(1)]

9. Are lamps that show evidence of breakage, leakage or damage that could Yes D No D N/Acause a release of mercury or hazardous constituents into the environmentimmediately cleaned up? Are they placed into a container that is closed,structurally sound, compatible with the contents of the ramps, and lackevidence of leakage, spillage or damage that could cause leakage orreleases of mercury or hazardous waste constituents to the environment?[3745-273-1 3(D)(2)]

NOTE: Treatment (such as crushing) by a UWH is prohibited under this rule unless the facility is permittedfor such activities [3745-273-31(B)]. A generator crushing lamps must manage lamps according to hazardouswaste rules (OAC Chapter 3745-52). Lamp crushing is a form of generator treatment (OAC rule 3745-52-34).Crushed lamps must be transported by a registered hazardous waste transporter to a permitted hazardous wastefacility using a hazardous waste manifest.10. Are the lamps or containers or packages of lamps labeled with the words Yes LI No 0 N/A L

"Universal Waste - Lamp(s)" or "Waste Lamp(s)" or "Used Lamp(s)?" [3745-273-14(E)]

ACCUMULATION TIME11. Is the waste accumulated for less than one year? [374527315(A)] Yes N No U N/A

a If not, is the waste accumulated over one year in order to facilitate Yes D No 0 N/Ai-icnarason rintingiuitiiwi

0HD987029451RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER - BATTERIES & LAMPS INSPECTION CHECKLIST

SQUWH-B&L/May 2012Page 1 of 2

proper recovery, treatment or disposal? (Burden of proof is on thehandler to demonstrate) [3745-273-15(B)]

NOTE: Accumulation is defined as date generated or date received from another handler.12. Is the handler able to demonstrate the length of time the universal waste Yes Z No 0 N/A 1J

has been accumulated? [3745-273-15(C))

If yes, describe below;

EMPLOYEE TRAINING13. Are employees who handle or have the responsibility for managing Yes Z No l N/A

universal waste informed of waste handling/emergency procedures, relativeto their responsibilities? 13745-273-16]

RESPONSE TO RELEASES14. Are releases of universal waste and other residues immediately contained? Yes El No 0 N/A Z

[3745-273-17(A)]15. Is the material released characterized? [3745-273-17(B)] Yes El No LI N/A

16. If the material released is a hazardous waste, was it managed as required Yes LI No D N/Ain OAC Chapters 3745-50 through 3745-69? (If the waste is hazardous, thehandler is considered the generator of the waste and is subject to OAC

___ Chapter 3745-52) 13745-273-17(B)]OFF-SITE SHIPMENTSNOTE: If a SQUWH self-transports waste, then the handler must comply with the Universal Waste transporterrequirements.17. Are universal wastes sent to either another handler, destination facility or Yes Z No N/A

foreign destination? [3745-273-18(A)]18. Is the handler aware of DOT requirements for packaging and shipping? Yes No D N/A LI

If no, make aware of 49 CFR 171-180.19. Prior to shipping universal waste off-site, does the originating handler Yes 0 No 0 N/A LII

ensure that the receiver agrees to receive the shipment? [3745-273-18(D)]20. Has the originating handler ever had an off-site shipment rejected by Yes LI No Z N/A

another handler or destination facility?a. If yes, did the originating handler receive the waste back or agree to Yes LI No LI N/A

where the _shipment _was sent? [3745-273-18(E)(2))21. If a handler rejects a partial or full load from another handler, does the Yes No IIJ N/A

receiving handler contact the originating handler and discuss and do one ofthe following:a. Send the waste back to the originating handler or send the shipment Yes No U N/A

to a destination facility (If both the originating and receiving handleragree)? [3745-273-18(F)(2)]

22. If the handler received a shipment of hazardous waste that was not a Yes El No LI N/Auniversal waste, did the SQUWH immediately notify Ohio EPA? [3745-273-18(G)]

EXPORTSNOTE: Small quantity handlers that export waste to the countries listed in 40 CFR 262.58(a)(1) are subject to 40CFR 262 subpart H. Small quantity handlers that export waste to a foreign destination other than the countries listedin 40 CFR 262,58(a)(1) are subject to 40 CFR 262.53, 40 CFR 262.56(a)(1) to (a)(4), (a)(6), and (b), 40 CFR 262.57,and 40 CFR 262 subpart E. [3745-273-20]

NOTE: Violations regarding exporting universal waste to foreign destinations should be referred to U. S. EPA Region5 because the federal counterpart provisions are not delegable to states.

Richardson Printing/0811 3/20130HD987029451

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER - BATTERIES & LAMPS INSPECTION CHECKLISTSQUWH-B&L/May 2012

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USED OIL INSPECTION CHECKLISTGENERATORS, COLLECTION CENTERS AND AGGREGATION POINTS

NOTE: I. A facility is subject to the federal SPCC regulations (40 CFR 112) if it is non-transportation related (e. g., fixed)and has an aggregate above ground storage capacity greater than 1,320 gallons or a total underground storage capacitygreater than 42,000 gallons of oil (including used oil), and there is reasonable expectation of a discharge to navigablewaters.2. Inspectors can check BUS TR's web-site at https./Iwwwcomapps.ohio.gov/sfmlfire_apps/bust/bustr/Publiclnquiry.asp todetermine if a UST containing used oil is registered with BUSTR. inspectors may call BUSTR at 614-752-7938 or aBUSTR site coordinator to report an unregistered UST or a UST that appears to not be in compliance with BUSTRregulations. A list of BUSTR coordinators by county are at:https://www. comapps. Ohio. gov/sfm/fire_appslbustlbustr/SearchByCounty . asp.PROHIBITIONS1. Does the generator manage used oil in a surface impoundment or waste pile? Yes 0 No Z N/A 0

If yes:a. Is the surface impoundment or waste pile regulated as a hazardous Yes El No El N/A

waste management unit? [3745-279-12(A)]NOTE: For example, used oil contaminated scrap metal stored in a pile.2. Is used oil used as a dust suppressant? [3745-279-12(B)] Yes D No Z N/A LI3. Is off-specification used oil fuel burned for energy recovery in devices specified Yes LI No N/A

in 3745-279-12(C)? NOTE: Multiple used oil checklists may be applicable if used oil handler is performing multiple tasks (e.g., If generatingused oil and shipping directly to a burner, complete generator and marketer checklists at a minimum).GENERATOR STANDARDS4. Does the generator mix hazardous waste with used oil? If SO, Yes LII No M N/A LI

a. Is the mixture managed as specified in 3745-279-10(B)? [3745-279- Yes L] No LI N/A21(A)]

NOTE: Used Oil mixed with listed (3745-51-30 to 3745-51-35) or characteristic (3745-51-20 to 3745-51-24) hazardouswaste are subject to regulation as a hazardous waste, unless the listed hazardous waste is listed solely because itexhibits a hazardous characteristic, and the resultant mixtures do not exhibit a characteristic. Mixtures of used oil andCESQG hazardous waste are subject to OA Chapter 3 745-279.5. Does the generator of a used oil containing greater than 1,000 ppm total Yes 0 No N/A

halogens manage the used oil as a hazardous waste unless the presumptionis rebutted successfully? [3745-279-21(B)]

NOTE: If used oil contains greater than 1000 ppm total halogens, it is presumed to be listed hazardous waste until thepresumption is successfully rebutted.6. Does the generator store used oil in tanks; or containers; or a unit(s) subject to Yes Z No 0 N/A LI

regulation as a hazardous waste management unit? [3745-279-22(A)] ___________________________

7. Are containers and aboveground tanks used to store used oil in good condition Yes Z No N/A LIwith no visible leaks? [3745-279-22(B)]

8 Are containers, above ground tanks, and fill pipes used for underground tanks Yes E No El N/A Eclearly labeled or marked "Used Oil?" [3745-279-22(C)]

9. Has the generator, upon detection of a release of used oil, done the following: Yes No 0 N/A E[3745-279-22(D)]a. Stopped the release? Yes Lii No D N/A

b. Contained the release? Yes LI No 111 N/A

C. Cleaned up and properly managed the used oil and other materials? Yes No N/A

d. Repaired or replaced the containers or tanks prior to returning them to Yes El No 0 N/A Zservice, if necessary?

Richardson Printing/ 08113/2013]0HD98702945 1

Used Oil Checklist for Generators/August 2009Page 1of2

ON-SITE BURNING IN SPACE HEATER10. Does the generator burn used oil in used-oil fired space heaters? [3745-279-

23]lf so:a. Does the heater burn only used oil that owner/operator generates or Yes LI No D N/Aused oil received from household do-it-yourself (DIY) used oil

rators?b. Is the heater designed to have a maximum capacity of not more that Yes No D N/A0.5 million BTU per hour?C. Are the combustion gases from heater vented to the ambient air? Yes LI No D N/A

NOTE: Ash accumulated in a space heater must be managed in accordance with 3745-279-10(E).GENERATOR TRANSPORTATION11. Does the generator have the used oil hauled only by transporters that have Yes Z No 0 N/Aobtained a U.S. EPA lD#? [3745-279-24]12. If the generator self-transports used oil to an approved collection site or to an

aggregation point owned by the generator: [3745-279-24) _______________________________a. Does the generator transport used oil in a vehicle owned by the Yes 0 No LI N/Agenerator or an employee of the generator? [3745-279-24]b. Does the generator transport more than 55 gallons of used oil at any Yes El No N/Atime? [3745-279-24]

NOTE: Used oil generators may arrange for used oil to be transported by a transporter without a U. S. EPA ID # if theused oil is reclaimed under a contractual agreement (i.e., tolling arrangement).COLLECTION CENTERS AND AGGREGATION POINTS13. Is the DIY used oil collection center in compliance with the generator Yes No El N/Astandards in 3745-279-20 to 3745-279-24? [3745-279-30]14. Is the non-DIY used oil collection center registered with Ohio EPA? [3745-279- Yes El No D N/A

1!13745-279-20Is the used oil aggregation point in compliance with the generator standards in Yes No N/A to 3745-279-24? [3745-279-32]

NOTE: Complete Used Oil Generator and any other applicable used oil handler checklist (e.g., marketer, burner, etc.) forused oil collection centers and aggregation points.

Richardson Printing/ 08/13/2013]0HD987029451

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