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

September 16, 2013

Mr. Donald NicholsonAdvanced Secondaries3137 Sackett Ave.Cleveland, Ohio 44109

Dear Mr. Nicholson:

RE: ADVANCED SECONDARIES, INC.NON-GENERATOROHD 982 613 713CUYAHOGA COUNTYNOV

Thank you for accompanying me during my August 15, 2013 inspection of AdvancedSecondaries, Inc. (Advanced) in Cleveland, Ohio. I inspected Advanced to determineits compliance with Ohio's hazardous waste laws as found in Chapter 3734 of the OhioRevised Code (ORC) and Chapter 3745 of the Ohio Administrative Code (OAC). Myinspection included a review of company operations and written documentation.

Advanced is a machine shop which specializes in secondary machining operations tomanufactured parts. Primarily serving automotive parts manufacturers, the facilitymachines parts made from steel, aluminum and brass. No hazardous waste is currentlygenerated at your facility. The facility does generate a used water-soluble cutting fluid(Starsol 775) which is subject to Ohio's used oil rules. This used oil is currentlycomingled with, for disposal, the facility's metal cuttings which are then sold to metalrecycling companies. Advanced also generates spent universal waste lamps(fluorescent bulbs) which you indicated are disposed of with your facility's solid waste.

The inspection revealed the following violations of Ohio's hazardous waste and used oilrules:

1. GAC Rule 3745-52-11, Waste evaluation:Any person who generates a waste must evaluate the waste to determine if thewaste is a hazardous waste in accordance with the criteria set forth in OAC Chapter3745-51. Advanced violated this regulation by disposing of spent lamps (primarilyfluorescent lamps) as solid waste without determining whether or not the lamps werea hazardous waste. The spent fluorescent lamps contain mercury or otherhazardous metals and may therefore be a hazardous waste. As an alternative todetermining whether your particular waste lamps are hazardous waste, you maywish to manage them as universal waste. In general, this would involve saving the

Northeast District Office • 2110 East Aurora Road • Twinsburg, OH 44087-1924www.epaohio.gov (330) 963-1200 (330) 487-0769 (fax)

Mr. Donald NicholsonAdvanced SecondariesSeptember 16, 2013Page 2

waste lamps in a properly labeled ("used lamps" and date accumulation began) andclosed container (such as a cardboard box) and having them recycled by a lamprecycler. Please be advised, however, that universal wastes may be accumulated atthe property for no longer than one year.

To abate this violation, submit documentation indicating how Advanced will managethe spent lamps in compliance with Ohio's hazardous and/or universal wasteregulations.

2. OAC Rule 3745-279-81, Disposal of hazardous and of nonhazardous used oils:

Advanced generates water soluble cutting fluid (Starsol 775 mixture) which whenspent meets Ohio's definition of a used oil. You indicated during my inspection thatthis fluid is generated by Advanced at a rate of approximately 30 gallons per month.You further indicated it is disposed of by pouring it in with the metal cuttingsgenerated by Advanced which are then purchased by a metal recycling company.

Used oil must either be properly recycled or disposed of according to Ohio's used oilrules. Because Advanced disposed of this used cutting fluid in its metal chips anddid not either properly recycle or dispose of this fluid, your facility is in violation ofOAC 3745-279-81. To return to compliance with this regulation, Advanced mustindicate in the response to this letter how the used cutting fluid will be managedgoing forward in accordance with Ohio's used oil rules. Indicate whether Advancedwill have the material recycled as used oil and if so, by which company. If the usedcutting fluid cannot be recycled and must be disposed of, Advanced must determineif the waste cutting fluid is a hazardous waste prior to disposal, especiallyconsidering that advanced machines brass which may cause lead contamination ofthe fluid. Submit the analytical results from a representative sample of the wastecutting fluid with your response to this letter. If it will be managed as a hazardouswaste, indicate which hazardous waste Treatment, Storage, Disposal Facility(TSDF) you have contracted with. If the used cutting fluid is not hazardous, indicatethe disposal company you have contracted with for its proper disposal in accordancewith Ohio law.

Advanced needs to immediately take the necessary measures to return to compliancewith Ohio's environmental laws. Within 14 days of receipt of this letter, Advanced isrequested to provide documentation to this office including the steps taken to abate theviolations cited above. Documentation of steps taken to return to compliance includeswritten correspondence and updated policies, as appropriate, and may be submitted viathe postal service or electronically to tom.roth(epa.ohioqov.

Mr. Donald NicholsonAdvanced SecondariesSeptember 16, 2013Page 3

Please be advised that the violations will continue until the violations have beenproperly abated. Failure to comply with Chapter 3734 of the Ohio Revised Code andrules promulgated thereunder may result in a civil penalty of up to $10,000 per day foreach violation. It is imperative that you return to compliance. If circumstances delay theabatement of the violations, Advanced is requested to submit written correspondence ofthe steps that will be taken by date certain to attain compliance.

Should you have any questions, please feel free to call me at (330) 963-1231. You canfind copies of the rules and other information on the Division's web page athttp://www.epa.state.oh.us/dhwm/.

Sincerely,

,*"1—r-,, P̂ unt(—Tom RothDistrict RepresentativeDivision of Materials and Waste Management

TR/clEnclosure

ec: Jeff Mayhugh, DMWM, COMarlene Kinney, DMWM, NEDONyall McKenna, DMWM, NEDONatalie Oryshkewych, DMWM, NEDO

LI

Ohio Environmental Protection Agency For Ohio EPA use only

RCRA SUBTITLE C SITEIDENTIFICATIONNERIFICATION FORM

E-mail this completed form to kristinadurnel!epastate.ohusor mail it to Kristina Durnell, Central Office

Site EPA ID No. EPA ID Number: OHD 982 613 713Site Name Name: Advanced Secondaries, Inc. Website:

(Optional)Site Location Information Street Address: 3137 Sackett Ave.

City, Town, or Village: Cleveland State: OHCounty Name: Cuyahoga Zip Code: 44109

Site Land Type Private County District Federal Indian Municipal State Other(check only one) El El El El El El ElNAICS code(s)www.census.ciov/epcdlwww/naics.htmlFacility Representative First Name: Donald MI: Last Name: Nicholson

Phone Number: 216-749-3320 Phone Number Extension:Additional names can be E-Mail Address:recorded in number 12 Fax Number: Fax Number Extension:

Street or P.O. Box:Only provide address City, Town or Village:information if it is different State: Zip Code:than the site addressLegal Owner And Name of Site's Legal Owner:Operator of the Site. Date Became Owner (mm/dd/yyyy):List Additional Owners Owner Private County District Federal Indian Municipal State Otherand/or Operators in the Type: E El El El El El El ElComment Section or on Street or P.O. Box:another copy, of this form City, Town or Village: Owner Phone #:page State: Country: Zip Code:

Name of Site's Operator: Date Became Operator(mm/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, Town or Village: Operator Phone #:State: United States Zip Code:

VIOLATIONSCITEt? Yes El No

TYPE OF HANDLER— A MINIMUM OF ONE BOX MUST BE CHECKED

El Not a HW Generator

UNKNOWN: ElLarge Quantity Generator (LQG)Cited for violation of 3745-52-11

ElSmaIl Quantity Generator (SQG)ElConditionally Exempt Small Quantity Generator[]U.S. Importer of Hazardous WasteElM ixed Waste (Hazardous and Radioactive)

Generator

TYPE OF REGULATED WASTE ACTIVITY (MARK "X" IN ALL OF THE APPROPRIATE BOXES)E Recycler of Hazardous Waste El Exempt Boiler and/or Industrial FurnaceE Underground Injection Control Facility E Small Quantity On-Site Burner ExemptionE Hazardous Waste Transporter Smelting, Melting, Refining Furnace ExemptionEl Treater, Storer or Disposer of Hazardous Waste

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 WasteLarge 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 MANAGESEl Batteries

PesticidesF-1 Mercury containing equipment

LampsUSED OJL .AcTIVJflES (INDICATE TYPE(S) OF ACTMTY(S)

Used Oil GeneratorUsed Oil TransporterUsed Oil Transfer Facility

LI Used Oil Processorfl Used Oil Re-refiner

Off-Specification Used Oil BurnerF] Used Oil Fuel Marketer Who Directs Shipment of Off-Spec. OilEl Used Oil Fuel Marketer to Off-Specification Used Oil BurnerWaste Codes for Federally Regulated Hazardous Wastes. Please list the codes for the federally regulated hazardous waste handled at the site, Listthem in the order they are presented in the regulations (e.g., DOOl, D003 1 F007, U112). Use an additional page if more space is needed. If there aremore Ahan 7 wastecodes and they are the same as listed in the most recent RcRAlnfo source record, you do not need to list them all. Instead justindicate the date of the most recent source record.

COMMENTS: USE THIS AREA JO DESCRIBE WHETHER THE INSPECTION WAS ANNOUNCED, WHETHER THEWASTE IS STORED IN TANKS OR CONTAINERS, ETC.Announced LI Yes E No Additional Facility Representatives:Tanks U Yes No Other Comments:Containers El Yes No

Date of Inspection/TimeName of Inspector(s) Name of Inspector(s) (mm/dd/yyyy) (hh:mm)Tom Roth 0811512013OPTIONAL CERTIFICATION.] certify under penalty of law that this document and all attachments-were-prepared undermy direction or supervision in accordance with a system designed to assure that qualified personnel properly gather andevaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or thosepersons directly responsible for gathering the information, the information submitted is, to the best of my knowledge andbelief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,including the possibility of fine and imprisonment for knowing violations.

Signature of Owner, Operator, or an AuthorizedRepresentative Name and Title (Print) Date (mm/dd/yyyy)

Revised 11 .03.08.SiteVerifyForm.doc