NCS000594_HWS Inspection_20151015

HAZARDOUS WASTE SECTION - COMPLIANCE BRANCH
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William Hunneke
NCD986189074
SEPRO CORPORA ION RESEARCH LAIVIPUS
Inspection/Investigation (1)
I - Compliance Evaluation Inspection (CEI)
CEI as a result of a complaint call. Referred to DWR after reviewing sample results.
10/15/2015
William Hunneke
NC060 Suborganization: Eastern Region
CEI as a result of a complaint call. Referred to DWR after reviewing sample results.
County (if not on report): NASH

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
COMPLAINT & COMPLIANCE EVALUATION INSPECTION REPORT
FACILITY INFORMATION:
Facility Name:
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PARTICIPANTS:
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Representing NCDEQ:
DATE OF SITE VISIT:
SEPRO CORPORATION RESEARCH CAMPUS
NCD986189074
Conditionally Exempt Small Quantity Generator (CESQG)
16013 Watson Seed Road, Whitakers, NC 27891
Nash County
252-391-8373
Sepro Development Company, LLC
11550 North Meridian Street, Carmel, IN 46032
Sepro Corporation
Bill Whitford, Director of Manufacturing & Logistics
252-391-8373
[e-mail]
Bill Whitford & Sam Mason
William Hunneke & Harvi Cooper
October 15, 2015 onsite: 1040 hrs. offsite: 1420 hrs.
PURPOSE OF SITE VISIT:
Response to an anonymous complaint posted on the Environmental Protection Agency's website alleging
improper disposal of pesticide/herbicide laboratory waste coupled with an unannounced Compliance
Evaluation Inspection to determine compliance with 40 CFR 261, 262, 265 273, 279 and 268. There is no
record that the facility has had a previous hazardous waste compliance evaluation inspection.
FACILITY DESCRIPTION:
Sepro Corporation (SePro) is a manufacturer of specialty blended aquatic herbicidal products for the
treatment of ponds and other small to mid-sized water impoundments. At the Whitakers research campus,
the company develops and blends customer specific aquatic herbicidal treatment compounds and tests
them in a series of aquatic impoundments located in the north quadrant of the property. Formerly owned
and operated by Syngenta Crop Protection, Inc., the 402 acre site was purchased by SePro in October
2004 from Mr. James Shearin, a farmer who bought the site from Syngenta approximately one year prior
to that. Approximately 90 acres of the property is wooded (southeastern section), the remaining acreage
is in crop production with an approximately ten acre pond created by a dammed creek that feeds Fishing
Creek in the middle of the site.

SePro Corporation Research Campus NCD986189074
Complaint & Compliance Evaluation Inspection Report Page 2 of 9
October 15, 2015
Five buildings populate the site, four of which are clustered toward the western side of the property and
the last, the Field Lab/Formulations Lab which sits adjacent to the aquatic test impoundments. The main
office building is approximately 8,000 square feet and houses all administrative offices plus several small,
one room laboratories each specific hi natule. The facility's Maln Laboiatuly Building (Lab) is
approximately 4,600 square feet and is where the company does its qualitative testing, and initial grow
out of customer's samples. The Lab also houses the facility's waste storage in the form of a hazardous
waste accumulation area and a 2,000 gallon tank which accepts all of the Lab and Manufacturing area's
wastewater. A more complete discussion of the facility's waste disposal system is included later in this
report. The facility's Manufacturing and Packaging building is located immediately adjacent and to the
west of the Lab. Approximately 9,300 square feet in area, the Manufacturing/Packaging Building is
where bulk chemical formulations are blended and packaged into saleable units, primarily 5 and 2.5
gallon containers. The blending plant mixes copper and various other products dissolved in water to
produce concentrated aquatic herbicide suspensions which are placed into 250 -gallon totes used to feed
the facility's consumer packaging line. Drains in the floor of the manufacturing area lead to a sump
which is pumped into the 2,000 gallon tank located next door in the Lab building. A 4,600 square foot
Maintenance Shop/Warehouse completes the cluster of buildings on the west side of the property. The
Maintenance Shop/Warehouse is used to store universal waste used lamps and a covered area adjacent to
the Warehouse stores bulk process chemicals; (RCRA) empty drums; cardboard for recycle, and assorted
used machine parts and farm equipment. The Field Lab/Formulation Lab houses numerous tubs and open
top tanks used to grow a variety of aquatic plants for the company's research. A small lab also occupies
part of the area and is utilized for testing and formulation of materials destined for the aquatic test
impoundments. The aquatic test impoundments are 32 in number arranged in a grid occupying an
approximately eight to nine acre area. Each of the impoundments are approximately 50 x 60 foot sized
rectangles on the average of six feet deep. According to Mr. Whitford, the impoundments are supposedly
plumbed together allowing for water from one to be pumped or diverted to adjacent ponds but to his
knowledge, SePro has never utilized those conduits. There are five "lower" impoundments located at the
bottom of an approximately 20 foot embankment apparently used as overflow areas if needed. The
remaining ponds sit atop the embankment and are on relatively level grade. According to Mr. Whitford,
the five "lower" ponds are lined with bentonite. There is one gentleman working at the facility, Mr. Barry
Hendrix who worked at the site when the impoundments were constructed and has knowledge of some of
the engineering parameters of the impoundments. The company is going to try to locate any "as -built"
drawings for those impoundments. Mr. Whitford indicated that waste from the 2,000 gallon tank at the
Main Laboratory is periodically pumped into one of two impoundments next to the westernmost lower
impoundment. He said that approximately six years ago, the company had the contents of the tank tested.
The company has not been able to locate those test results.
The company employs twenty-six individuals in North Carolina, twenty of whom work regularly at the
subject site, the remainder working at a warehouse in Rocky Mount where the company has plans to
establish another laboratory. Compliance assistance was offered for the Rocky Mount facility once its lab
comes online. Employees at the Whitakers facility generally work one shift. Buildings at the cite are on
municipal water with the exception of the Field Lab/Formulation Lab which accesses water from one of
the two wells on the property. All buildings are on septic systems for sanitary sewer. Hazardous waste
from the lab's high pressure liquid chromatography (HPLC) machines is collected in satellite
accumulation containers and emptied into a 55 -gallon drum for storage until it is removed by a hazardous
waste transporter. The Main Laboratory and Manufacturing/Packaging building sinks and drains are both
plumbed to a system of pipes that lead to sumps which are then pumped into the 2,000 gallon tank in the
Lab Building. Water from the invasive species grow tanks is delivered after it has been bleached to the
2,000 gallon tank mentioned above. According to Mr. Whitford, the 2,000 gallon tank is periodically
pumped into a mobile tank, and driven by tractor to the aquatic test impoundment area where its contents
are pumped into one of the two impoundments next to the westernmost lower impoundment. The facility
has an invasive weed permit but no storm water or other discharge permits. The property is

SePro Corporation Research Campus NCD986189074
Complaint & Compliance Evaluation Inspection Report Page 3 of 9
October 15, 2015
approximately one third of a mile from Fishing Creek, a tributary of the Tar River. The distance to the
nearest offsite well is unknown and the nearest residence is across Watson Seed Road, approximately one
tenth of a mile from the sites' main cluster of buildings.
The facility is operating as a conditionally exempt small quantity generator (CESQG) of hazardous waste,
shipping approximately 300 pounds of hazardous waste on the average of two times per year. The facility
was inspected as a CESQG with guidance provided regarding the small quantity generator (SQG) rules,
many of which the company was following as best practices.
WASTE STREAMS INCLUDE:
Hazardous Waste Streams and Waste Codes:
• Waste acetonitrile solution D001
• Petroleum Distillates (Ligoine) D001
• Assorted lab solvents and lab pack wastes U001/D002
Other Waste Streams:
• Acteo Diquat Dibromide (RCRA empty drums)
• Used Oil, recycled
• Universal Waste
• Cardboard, recycled
AREAS OF REVIEW AND INSPECTION:
Emergency Preparedness/Arrangements with Local Authorities:
The manufacturing/blending/packaging building is completely covered by a wet fire suppression system
which is tested annually. The Whitakers Volunteer Fire Department visits the facility annually, the
facility has an emergency action plan which describes the actions personnel will take in a fire or other
emergency (not reviewed as part of the inspection). The facility is documenting weekly inspections of its
hazardous waste storage area. Every employee is provided general hazard communication awareness
training at the time of hire, and those individuals whose job duties include the management of hazardous
waste are given hazardous waste training. The main lab is an ISO accredited laboratory.
Manifests / LDR:
Hazardous waste manifests were reviewed from August 2011 through the present (last shipment July 28,
2015) and found to be in compliance (with SQG rules) and were complete with land disposal restriction
documents.
Transporters:
• A&D Environmental
• Eastern Environmental Management (for universal waste)
TSDs:
• EcoFlo, Inc.
NCD986232221
NCR000146456
NCTF00000060 (Transfer Facility #)
NCD980842132
Inspection Records (storage):
The facility is documenting weekly inspections of its hazardous waste storage area. Complete log of
inspection records was not reviewed as part of the inspection.
Accumulation Areas:
The facility has satellite accumulation areas for hazardous waste generated from HPLC machines in the
main laboratory. On the day of the inspection, two HPLC machines were observed with satellite
accumulation containers (amber 1.5 liter jugs) properly closed and labeled per SQG rules. Several amber

SePro Corporation Research Campus NCD986189074
Complaint & Compliance Evaluation Inspection Report Page 4 of 9
October 15, 2015
jugs of waste acetonitrile solution were also observed properly labeled and closed. Additional waste
solvents stored under the lab hood in Building 2 were observed properly labeled and closed. One of the
amber jugs was labeled as containing waste methylene chloride. When methylene chloride is used for its
solvent properties III labolatoly applications, wash 1tleatylene ch1wide would likely be chwactelized as
an F002 listed waste. The EPA Environmental Management Guide for Small Laboratories was emailed to
Bill Whitford on October 19, 2015. Please review sections 3.2 and 3.3 and contact Harvi Cooper with
any questions on waste coding of F listed solvents.
Storage Areas:
The facility has one area for the storage of hazardous waste located immediately adjacent to the Lab in the
same building. One the day of the inspection, two 55 -gallon drums containing waste petroleum distillates
and waste acetonitrile solution respectively were observed properly closed, labeled and dated (per SQG
rules) sitting on secondary containment pallets. Though not required under CESQG rules, recommend a
fire extinguisher and spill kit in the area. The storage area is also where the 2,000 gallon tank is located
which is plumbed to the Lab and Manufacturing/Packaging Building drains. The tank sits inside of a
secondary containment area. The tank was sampled on October 21, 2015 to determine if any TCLP
parameters exceeded action limits. Split samples were collected by Brian Polk for NCDEQ and by Sam
Mason for SePro. Analytical results for TCLP metals, volatiles, semi -volatiles, pesticides and herbicide
parameters did not exceed TCLP action limits (see attached results, Appendix B, Shealy Environmental
Services, Inc. Report of Analysis). According to a conversation between Ms. Harvi Cooper and Mr.
Whitford on November 19, 2015, SePro did not have their splits of the samples taken that day analyzed.
Other Areas Visited:
Main Administrative Building
Three small labs are located in this building: Genetics Lab; Biologic Lab and a Grow Lab. Currently,
only the grow lab is staffed. On the day of the inspection, no hazardous waste was observed or reported
to be generated at any of these three labs.
Manufacturing/Packaging Building
Copper based products arc dissolved to produce concentrated aquatic herbicidal solutions in the
Manufacturing Building. A chelated copper blending plant contains seven large above ground storage
tanks (ASTs) between 6,000 and 10,000 gallons in size all located within a secondary containment area
capable of holding approximately 10,000 gallons. This operation feeds 250 and 300 gallon totes which
support the consumer bottling line, filling 5 and 2.5 gallon plastic bottles. Floor drains in the
Manufacturing Building are plumbed to a sump which pumps into the 2,000 gallon tank next door in the
Lab's storage area. No hazardous waste was observed in the Manufacturing/Packaging Building on the
day of the inspection and according to Mr. Whitford, none is customarily generated.
Maintenance Shop/Warehouse/Covered Storage
The Maintenance Shop/Warehouse consists of a light machine shop, enclosed storage area and covered
storage area. On the day of the inspection, used lamps were observed in containers that were closed and
labeled. Bills of lading from Eastern Environmental Management documented shipping of universal
waste on a less than annual basis were reviewed. No hazardous waste was observed at the enclosed and
covered storage areas.
Field Lab/Formulation Lab
On the day of the inspection, a wide variety of chemicals were observed in the Field/Formulation Lab but
no hazardous waste was observed stored. Numerous tubs and large containers were being utilized to
grow aquatic plants. Field lab staff was not present at the time of the inspection and additional
information on the types of waste generated and how it is stored and disposed of will require another site
visit.

SePro Corporation Research Campus NCD986189074
Complaint & Compliance Evaluation Inspection Report Page 5 of 9
Oclobei 15, 2015
Aquatic Test Impoundments
The test impoundments described earlier were observed to be approximately four to six feet deep with
plenty of freeboard remaining to prevent overflow and a piping system connected to overflow ponds on
the lower level. The five overflow ponds were in similar condition as far as current water levels, however
an aerial photo showed brown vegetation from the lower edge of the northern overflow pond trailing
toward a drainage ditch downgradient. A sampling event for two of the lower ponds and downgradient
soils was conducted by NC Division of Water Resources personnel Cheng Zhang and Laura Robertson on
October 21, 2015. Additional testing of any sludge and wastewater removed from the lower ponds will
be required prior to disposal or treatment to delettttine if either wastes are characteristic hazardous wastes.
Prior to removal of sludge or wastewater, contact the selected treatment storage and disposal facilities to
ensure any additional analytical tests that they may require are conducted.
CONCLUSIONS:
There do not appear to be any hazardous waste violations at this facility. The facility must ensure all
hazardous waste is contained and no hazardous waste is released to the collection tank or surface
impoundment system. Additionally, a waste determination must be completed on any sludge dredged
from the ponds or wastewater removed from the ponds. The facility may not transfer waste water of any
kind into surface impoundments without a discharge permit. The complaint was assigned a Tips &
Complaint System ID# FY15-134603-3709 by EPA and has been referred to the NC Department of
Environmental Quality Division of Water Resources Raleigh Regional Office.
➢ Please review sections 3.2 and 3.3 of The EPA Environmental Management Guide for Small
Laboratories and contact Harvi Cooper with any questions on waste coding of F listed solvents.
November 9, 2015
William Hunneke Date
Environmental Senior Specialist, NCDEQ
Copy of report provided to facility contact
Guidance documents provided with report:
EPA Environmental Management Guide for Small Laboratories
CESQG checklist including used oil and universal waste rules.
Small quantity generator checklist

SePro Corporation Research Campus
Complaint & Compliance Evaluation Inspection Report
October 15, 2015
Appendices
Aerial Photos of SePro Campus including detail of Aquatic Test Impoundments.
Report of Analysis, Shealy Environmental Services, Inc.
2,000 Gallon Tank sampled on October 21, 2015
NCD986189074
Page 6 of 9

SePro Corporation Research Campus
Complaint & Compliance Evaluation Inspection Report
Oclober 15, 2015
Appendix A
Aerial View of SePro Research Campus
160113 Watson Seed Road, Whitakers, NC 27891
NCD986189074
Page 7 of 9