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Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 01/10/2022 and 01/24/2022 Announced: No Entry: 09:57 AM (AKT) Exit: 03:05 PM (AKT) Resource Conservation and Recovery Act (RCRA) Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) (City, state, zip code) County: Carlile Transportation Systems, LLC 1800 East 1st Avenue Anchorage, AK 99501 Transportation and 10-day transfer facility 20 acres Since 2003 61.22148, -149.84714 Ms. Lisa Marquiss, Corporate Director of Safety and Compliance lmarquiss@carlile.biz 1800 E. 1st Avenue Anchorage, AK 99501 Anchorage, AK 99501 N/A Facility/Site Identifier: Media Number: NAICS: AKR000005611 N/A 484121 GENERAL FREIGHT TRUCKING, LONG-DISTANCE, TRUCKLOAD 484122 GENERAL FREIGHT TRUCKING, LONG-DISTANCE, LESS THAN TRUCKLOAD 48422 SPECIALIZED FREIGHT (EXCEPT USED GOODS) TRUCKING, LOCAL 48423 SPECIALIZED FREIGHT (EXCEPT USED GOODS) TRUCKING, LONGDISTANCE Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.02.10 10:07:58 -09'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 1 of 20 Digitally signed by Jennifer A Sullivan Date: 2022.02.10 12:29:57 -08'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection. This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2022. Attendees Title Lead Inspector Safety Supervisor, Alaska Hazardous Materials Coordinator Corporate Director of Safety and Compliance Name Jon Jones Thad Hamilton Steve Viotto Lisa Marquiss Phone 9072716329 (907) 865-3602 Email Jones.Jon@epa.gov Present in Opening Conf. Yes thamilton@carlike.biz Yes (907) 865-3609 sviotto@carlile.biz Yes (907) 343-3238 lmarquiss@carlile.biz Yes Present in Closing Conf. Yes Yes No Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the Carlile Transportation Systems, LLC at 09:57 AM (AKT) on 01/10/2022 for an inspection. I presented my credentials to Ms. Lisa Marquiss, Corporate Director of Safety and Compliance, and informed her that this was an EPA RCRA inspection. The table above presents all the opening and closing conference participants. Facility/Site Description Carlile Transportation Systems, LLC is an over the road transportation company located in an industrial area on the north side of Anchorage, AK. The facility consists of a freight staging area, loading dock, administrative office, trailer shop, truck shop, and maintenance shop. Additional information about the company can be found on their website at www.carlile.biz. Facility Info Weather Conditions Cold and icy Number of employees 164 2 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 Operating Hours Safety Training Provided to Inspector(s)? What type of generator facility notified? What type of generator facility verified as? 8:00 a.m. to 5:00 p.m., Monday through Friday No Current notification indicated that the facility is not a generator of hazardous waste Very Small Quantity Generator (VSQG) Process Description The following information was obtained from Ms. Lisa Marquiss, Corporate Director of Safety and Compliance, during the opening conference of the inspection. The Carlile facility operates as a 10-day transfer facility for transportation of hazardous waste. Waste is either picked up at the generator or another transporter and is either taken directly to the Port of Anchorage or to the Carlile facility for consolidation prior to delivery to the Port of Anchorage. At the Port, waste is loaded on a boat and shipped to a permitted waste processing facility in the lower 48 states. There are three shops on site. Two of the three shops generate used oil and hazardous waste. One shop maintains trailers and the other shop maintains trucks. I explained to Ms. Marquiss that I wanted to review paperwork related to the management of hazardous waste passing through the facility's 10-day transfer facility. At the time of the inspection, Ms. Marquiss told me that there was no hazardous waste currently in their 10-day transfer facility. Ms. Marquiss explained that there was both hard copy paperwork that included manifests and bills of lading as well as, a computer program called "Truck Mate." I conducted a preliminary review of the paperwork and was unable to determine how long shipments of hazardous waste were being held at the facility. I asked Ms. Marquiss if a report could be generated in "Truck Mate" that would show how long shipments of hazardous waste were being held. She told me that she wasn't familiar enough with the program to know. Ms. Marquis then told me that Ms. Kisha Jackson, the previous Regulatory Compliance Manager used to manage the transportation paperwork but resigned without notice since the previous inspection and that Mr. Steve Viotto, Hazardous Materials Coordinator was hired approximately five months ago. She told me that Mr. Viotto was on vacation and would be returning on January 17, 2022. She told me that Mr. Viotto would be much more familiar with the paperwork and the "Truck Mate" program. I told Ms. Marquiss that I would contact Mr. Viotto upon his return and set up a time to come back to the facility to review the applicable paperwork. I contacted Mr. Viotto on January 18, 2022, and he agreed to meet with me on January 24, 2022, to review transportation paperwork. I returned to the facility on January 24, 2022, to inspect the transportation paperwork and the results of this paperwork inspection are contained in the Records Review section of this inspection report. During the inspection of the facility on January 10, 2022, I was accompanied by Mr. Thad Hamilton, Safety Supervisor, Alaska and Mr. Patrick Quiambao, Anchorage Shop Manager. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's and used oil management. At the time of the inspection, the facility was not managing any universal waste. According to facility personnel, all their fluorescent lighting had been replaced with LED lighting and they had yet to generate any LED lighting waste. Specifically, I inspected the following areas of the facility listed below. 3 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 Building(s) Building/Area/Sub-area Maintenance Shop Trailer Shop Bay #1 Truck Shop Bay #3 Process Description Bodywork on trucks and trailers, excluding paint. Painting of trucks and trailers, if required, is contracted locally. Full-service trailer shop. Wastes generated include: - Used oil - Waste aerosols Used oil storage area and aerosol puncturing. Full-service truck shop. Wastes generated include: - Used oil - Waste aerosols - Used antifreeze (Recycled) - Used parts washer solvent (Recycled) - Used lead-acid batteries (Recycled) Aerosol puncturing. Area of Concern No Yes Yes Yes Yes SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Trailer Shop Contains CBI: No Observation #: JJ1-OB-001 Date: 01/10/2022 While in the trailer shop, I saw a fiberboard container that was labeled with the words "Used Aerosols Cans Only." While in the shop, I met Mr. Patrick Quiambao, Anchorage Shop Manager. I looked in the fiberboard container and saw approximately five aerosol cans. I inquired about the aerosols and Mr. Quiambao said that aerosol cans are punctured in the fiberboard container using a tool referred to as a "Crowfoot." According to Mr. Quiambao, the shop generates approximately five waste aerosol cans each week. Mr. Quiambao said the punctured aerosol cans are then thrown into the trash. According to Mr. Quiambao, aerosols are punctured when empty and sometimes if they stop working (i.e., clogged spray nozzle or lack of propellant) they are still punctured into the fiberboard container which allowed the residue from the waste aerosols to be absorbed into the fiberboard container and evaporate. At the time of the inspection, the inside of the fiberboard container was stained with residue from waste aerosol cans. I looked in the shop's flammable storage cabinets and I saw a variety of aerosol products that were in use at the facility. I did this to gain a better understanding as to what the various types of waste aerosols were that the facility was puncturing into the fiberboard container. The aerosols consisted of brake cleaners, lubricants, paints, and coatings. Mr. Quiambao told me they were told during the last inspection that they could puncture their waste aerosols. I told Messer's Hamilton and Quiambao that I was present during the last RCRA compliance inspection which took place on February 13, 2018. I explained to Messer's Hamilton and Quiambao that puncturing waste 4 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 aerosol cans was treatment and their current method of managing waste aerosols was not appropriate. I explained that waste aerosols could be punctured using a puncturing system that captured both the aerosol can residue and propellant, such as a drum-top can popper with a filter. I covered required generator status and container management requirements related to the treatment of waste aerosols. I also covered the management of waste aerosols as universal waste. Mr. Quiambao asked how they should manage the waste aerosols. I explained that I would be conducting a closing conference at the end of the inspection with Ms. Marquiss and at that time I would cover the various management options. I explained that Ms. Marquiss could then determine how the facility would manage waste aerosols. Photo(s) 1. IMG-202201101117191719866180.jpg 2. IMG-2022011011173717371021257.jpg 3. IMG-202201101118071871039939.jpg 4. IMG-202201101123142314762936.jpg 5. IMG-2022011011233723371039126.jpg 6. IMG-20220110112409249832030.jpg 7. IMG-202201101128492849996822.jpg Building: Trailer Shop/Bay #1 Observation #: JJ1-OB-002 Contains CBI: No Date: 01/10/2022 At the time of the inspection, I saw a wheeled, used oil drain pan and a spill pallet on the east side of Bay #1, adjacent to the bays roll-up door. Both the drain pan and the spill pallet held used oil which was confirmed by Mr. Quiambao. Neither the drain pan nor the spill pallet were labeled with the words "Used Oil." I explained to Messer's Hamilton and Quiambao that used oil storage containers were required to be labeled with the words, "Used Oil." After the inspection, I received an email, dated January 13, 2022, that included photos which documented that the used oil storage units observed during the inspection had been labeled with the words, "Used Oil." Photo(s) 1. IMG-2022011011515251521126057.jpg 2. IMG-202201101152155215826495.jpg 3. IMG-202201101152265226733799.jpg Building: Truck Shop/Bay #3 Observation #: JJ1-OB-003 Contains CBI: No Date: 01/10/2022 Mr. Quiambao mentioned that waste aerosols were also being punctured in the truck shop. While in the truck shop, Mr. Quiambao took me to where the waste aerosol cans were being punctured. At the time of the inspection, there were approximately 30 - 40 punctured aerosol cans in an open 55-gallon container. According to Mr. Quiambao the waste aerosol cans are being managed in the same way that they are being managed in the trailer shop, allowing the residue from the waste aerosols to drain into the container and evaporate. The flammable storage cabinets in the truck shop contain the same aerosol products as the trailer shop too. Photo(s) 5 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 1. IMG-20220110120810810901991.jpg 2. IMG-20220110120926926690153.jpg Building: Truck Shop/Bay #3 Observation #: JJ1-OB-004 Contains CBI: No Date: 01/10/2022 At the time of the inspection, I saw two, wheeled drain pans, a half of a 55-gallan container, and three spill pallets. All contained various amounts of used oil, and none were labeled with the words "Used Oil." After the inspection, I received an email, dated January 13, 2022, that included photos which documented that the used oil storage units observed during the inspection had been labeled with the words, "Used Oil." Photo(s) 1. IMG-202201101217471747896353.jpg 2. IMG-202201101218191819907484.jpg 3. IMG-2022011012184118411052897.jpg Records Review Record: Shipping Documents/Tolling agreements Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 01/28/2022 I returned to the facility on January 24, 2022, at 1057 hours to review facility Bills of Lading (BOL) and hazardous waste manifests for the purposes of determining how long shipments of hazardous waste were being held onsite. As a registered transporter of hazardous waste, Carlile Transportation Systems, LLC is allowed to hold shipments of hazardous waste at their facility for 10 days or less. I reviewed BOLs and manifests at the facility covering the period of July 2021 through November 2021. During the document review, I told Mr. Viotto that I had additional manifests that I had retained from previous inspections which listed Carlile Transportation Systems as a transporter and that some of those manifests, according to the dates, indicated that shipments of hazardous were held for more than 10 days. I sent several emails to Mr. Viotto following the inspection, dated January 25, 2022, and January 28, 2022, providing him with a list of those BOL and manifest numbers following the inspection and requested that he send me copies. During the on-site review on January 24, 2022, I saw 40 manifests for shipments that had been held at the facility for more than 10 days. After receiving the requested documentation from Mr. Viotto in emails dated January 25, 27, and 28, 2022 I saw 17 additional manifests for shipments that had been held at the facility for more than 10 days for a total of 58 shipments. According to the transporter dates on each manifest, Carlile Transportation Systems held the shipments for periods of time that ranged from 11 to 26 days. The following BOLs and associated hazardous waste manifests were obtained from Mr. Viotto and are included as attachments to this report: BOL# HW Man# #days 81636549 000385284 JJK 14 018852580 JJK 14 81633994 003248209 CLE 12 81017075 012698342 FLE 14 6 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 012698343 FLE 14 BOL# HW Man# #days 81017075 015840942 FLE 14 015840950 FLE 14 81017075 015840951 FLE 14 81084564 003476150 FLE 14 003476155 FLE 14 003476160 FLE 14 003476179 FLE 14 003476183 FLE 14 81017090 015839877 FLE 15 81017086 015840998 FLE 20 81634006 015977505 FLE 15 003312871 CLE 15 81017095 015841011 FLE 16 81017098 008415375 FLE 14 81017102 015840961 FLE 11 015840962 FLE 11 015840967 FLE 11 015840971 FLE 11 015840972 FLE 11 81084577 004899341 FLE 15 81084574 004899109 FLE 11 81017107 012706225 FLE 11 012706227 FLE 11 012706228 FLE 11 012706234 FLE 11 012706249 FLE 11 012706380 FLE 11 012706381 FLE 11 7 of 20 01/10/2022 - 01/24/2022 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 012706384 FLE 11 BOL# HW Man# #days 81017107 008415380 FLE 11 81017105 012706378 FLE 11 81017105 012706382 FLE 11 008415382 FLE 11 81017108 012706385 FLE 11 012706223 FLE 11 81765919 009994732 FLE 23 81567643 012698427 FLE 22 012698436 FLE 22 012698431 FLE 22 012698435 FLE 22 81567647 012698434 FLE 18 012698429 FLE 18 81765614 012698444 FLE 23 81192059 012698430 FLE 22 81521507-1 009994409 FLE 26 81765615 012698439 FLE 12 012698336 FLE 12 81192041 009994682 FLE 15 81192052 012698138 FLE 15 81017152 012698322 FLE 26 81192052 012698143 FLE 15 81788516 016896852 JJK 11 81192038 012698136 FLE 14 Document(s) 1. BOL#81017075.pdf 2. BOL#81017080.pdf 3. BOL#81017086.pdf 4. BOL#81017090.pdf 5. BOL#81017095.pdf 8 of 20 01/10/2022 - 01/24/2022 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 6. BOL#81017098.pdf 7. BOL#81017102.pdf 8. BOL#81017105 and BOL#81017108.pdf 9. BOL#81017107.pdf 10. BOL#81017152.pdf 11. BOL#81084564.pdf 12. BOL#81084574.pdf 13. BOL#81084577.pdf 14. BOL#81192032.pdf 15. BOL#81192041.pdf 16. BOL#81192052.pdf 17. BOL#81192059.pdf 18. BOL#81521507-1.pdf 19. BOL#81567643.pdf 20. BOL#81567647.pdf 21. BOL#81633994.pdf 22. BOL#81634006.pdf 23. BOL#81636549.pdf 24. BOL#81636554.pdf 25. BOL#81765614.pdf 26. BOL#81765615.pdf 27. BOL#81765919.pdf 28. BOL#81788516.pdf 29. Manifest#009994593FLE - SEA000567562.pdf 30. Manifest#012598561FLE - SEA000583316.pdf 31. Manifest#012698136FLE - SEA000577395.pdf SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: JJ1-RR-001 Area: Sub-area: I reviewed BOLs and manifests at the facility covering the period of July 2021 through November 2021. During the document review, I told Mr. Viotto that I had additional manifests that I had retained from previous inspections which listed Carlile Transportation Systems as a transporter and that some of those manifests, according to the dates, indicated that shipments of hazardous were held for more than 10 days. I sent several emails to Mr. Viotto following the Regulation: 264.1(g)(9) 9 of 20 Sections: CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): inspection, dated January 25, 2022, and January 28, 2022, providing him with a list of those BOL and manifest numbers following the inspection and requested that he send me copies. During the on-site review on January 24, 2022, I saw 40 manifests for shipments that had been held at the facility for more than 10 days. After receiving the requested documentation from Mr. Viotto in emails dated January 25, 27, and 28, 2022 I saw 17 additional manifests for shipments that had been held at the facility for more than 10 days for a total of 58 shipments. According to the transporter dates on each manifest, Carlile Transportation Systems held the shipments for periods of time that ranged from 11 to 26 days. Building: Trailer Shop JJ1-OB-001 Area: While in the trailer shop, I saw a fiberboard container that was labeled with the words "Used Aerosols Cans Only." While in the shop, I met Mr. Patrick Quiambao, Anchorage Shop Manager. I looked in the fiberboard container and saw approximately five aerosol cans. I inquired about the aerosols and Mr. Quiambao said that aerosol cans are punctured in the fiberboard container using a "Crowfoot." Regulation: 273.13(e)(4) According to Mr. Quiambao, the shop generates approximately five waste aerosol cans each week. 10 of 20 01/10/2022 - 01/24/2022 Sub-area: Sections: CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): Building: Trailer Shop JJ1-OB-002 Area: Bay #1 At the time of the inspection, I saw a wheeled drain pan and a spill pallet on the east side of Bay #1, adjacent to the Bay roll-up door. Both the drain pan and the spill pallet held used oil which was confirmed by Mr. Quiambao. Neither the drain pan nor the spill pallet were labeled with the words "Used Oil." Regulation: 279.22(c)(1) Building: Truck Shop JJ1-OB-003 Area: Bay #3 While in the truck shop, Mr. Quiambao took me to where the waste aerosol cans are being punctured. At the time of the inspection, there were approximately 30 - 40 punctured aerosol cans in an open 55-gallon container. According to Mr. Quiambao the waste aerosol cans are being managed in the same way that they are being managed in the trailer shop. The flammable storage cabinets contain the same hazardous materials as the trailer shop too. Regulation: 273.13(e)(4) JJ1-OB-004 At the time of the inspection, I saw two, wheeled drain pans, a half of a 55-gallan container, and three spill pallets. All contained various amounts of used oil, and none were labeled with the words "Used Oil." Regulation: 279.22(c)(1) 11 of 20 01/10/2022 - 01/24/2022 Sub-area: Sections: Sub-area: Sections: Sections: CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection. Closing Conference At the conclusion of the inspection, I conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern (listed in Section III - Areas of Concern) that I observed during my inspection of the facility. I then explained the follow-up process that would take place once I finished the report. I explained they would receive a copy of the report as would a case officer. I told them the case officer would review the report to determine if any of my areas of concern documented violations. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log 12 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-202201101117191719866180.jpg 01/10/2022 11:17 AM (AKT) Jon Jones Trailer Shop No CBI No PII While in the trailer shop, I saw a fiberboard container that was labeled with the words "Used Aerosols Cans Only." While in the shop, I met Mr. Patrick Quiambao, Anchorage Shop Manager. I looked in the fiberboard container and saw approximately five aerosol cans. I inquired about the aerosols and Mr. Quiambao said that aerosol cans are punctured in the fiberboard container using a "Crowfoot." According to Mr. Quiambao, the shop generates approximately five waste aerosol cans each week. [Title] IMG-2022011011173717371021257.jpg 01/10/2022 11:17 AM (AKT) Jon Jones Trailer Shop No CBI No PII While in the trailer shop, I saw a fiberboard container that was labeled with the words "Used Aerosols Cans Only." While in the shop, I met Mr. Patrick Quiambao, Anchorage Shop Manager. I looked in the fiberboard container and saw approximately five aerosol cans. I inquired about the aerosols and Mr. Quiambao said that aerosol cans are punctured in the fiberboard container using a "Crowfoot." According to Mr. Quiambao, the shop generates approximately five waste aerosol cans each week. 13 of 20 01/10/2022 - 01/24/2022 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-202201101118071871039939.jpg 01/10/2022 11:18 AM (AKT) Jon Jones Trailer Shop No CBI No PII While in the trailer shop, I saw a fiberboard container that was labeled with the words "Used Aerosols Cans Only." While in the shop, I met Mr. Patrick Quiambao, Anchorage Shop Manager. I looked in the fiberboard container and saw approximately five aerosol cans. I inquired about the aerosols and Mr. Quiambao said that aerosol cans are punctured in the fiberboard container using a "Crowfoot." According to Mr. Quiambao, the shop generates approximately five waste aerosol cans each week. [Title] IMG-202201101123142314762936.jpg 01/10/2022 11:23 AM (AKT) Jon Jones Trailer Shop No CBI No PII I looked in the flammable storage cabinets to view the aerosols that were in use, to see the various types of products used. 01/10/2022 - 01/24/2022 14 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-2022011011233723371039126.jpg 01/10/2022 11:23 AM (AKT) Jon Jones Trailer Shop No CBI No PII I looked in the flammable storage cabinets to view the aerosols that were in use, to see the various types of products used. [Title] IMG-20220110112409249832030.jpg 01/10/2022 11:24 AM (AKT) Jon Jones Trailer Shop No CBI No PII I looked in the flammable storage cabinets to view the aerosols that were in use, to see the various types of products used. [Title] IMG-202201101128492849996822.jpg 01/10/2022 11:28 AM (AKT) Jon Jones Trailer Shop No CBI No PII According to Mr. Quiambao aerosols are punctured when empty and sometimes if they stop working, they are still punctured into the fiberboard container. At the time of the inspection, the inside of the fiberboard container appeared to be stained with residue from waste aerosol cans. 15 of 20 01/10/2022 - 01/24/2022 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-2022011011515251521126057.jpg 01/10/2022 11:51 AM (AKT) Jon Jones Trailer Shop/Bay #1 No CBI No PII At the time of the inspection, I saw a wheeled drain pan and a spill pallet on the east side of Bay #1, adjacent to the Bay roll-up door. Both the drain pan and the spill pallet held used oil which was confirmed by Mr. Quiambao. Neither the drain pan nor the spill pallet were labeled with the words "Used Oil." [Title] IMG-202201101152155215826495.jpg 01/10/2022 11:52 AM (AKT) Jon Jones Trailer Shop/Bay #1 No CBI No PII At the time of the inspection, I saw a wheeled drain pan and a spill pallet on the east side of Bay #1, adjacent to the Bay roll-up door. Both the drain pan and the spill pallet held used oil which was confirmed by Mr. Quiambao. Neither the drain pan nor the spill pallet were labeled with the words "Used Oil." 01/10/2022 - 01/24/2022 16 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-202201101152265226733799.jpg 01/10/2022 11:52 AM (AKT) Jon Jones Trailer Shop/Bay #1 No CBI No PII At the time of the inspection, I saw a wheeled drain pan and a spill pallet on the east side of Bay #1, adjacent to the Bay roll-up door. Both the drain pan and the spill pallet held used oil which was confirmed by Mr. Quiambao. Neither the drain pan nor the spill pallet were labeled with the words "Used Oil." [Title] IMG-20220110120810810901991.jpg 01/10/2022 12:08 PM (AKT) Jon Jones Truck Shop/Bay #3 No CBI No PII While in the truck shop, Mr. Quiambao Took me to where the waste aerosol cans are being punctured. At the time of the inspection, there were approximately 30 - 40 punctured aerosol cans in an open 55-gallon container. According to Mr. Quiambao the waste aerosol cans are being managed in the same way that they are being managed in the trailer shop. The flammable storage cabinets contain the same hazardous materials as the trailer shop too. 01/10/2022 - 01/24/2022 17 of 20 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-20220110120926926690153.jpg 01/10/2022 12:09 PM (AKT) Jon Jones Truck Shop/Bay #3 No CBI No PII While in the truck shop, Mr. Quiambao Took me to where the waste aerosol cans are being punctured. At the time of the inspection, there were approximately 30 - 40 punctured aerosol cans in an open 55-gallon container. According to Mr. Quiambao the waste aerosol cans are being managed in the same way that they are being managed in the trailer shop. The flammable storage cabinets contain the same hazardous materials as the trailer shop too. [Title] IMG-202201101217471747896353.jpg 01/10/2022 12:17 PM (AKT) Jon Jones Truck Shop/Bay #3 No CBI No PII View of the drain pans, half container and spill pallets that are not labeled with the words Used Oil. [Title] IMG-202201101218191819907484.jpg 01/10/2022 12:18 PM (AKT) Jon Jones Truck Shop/Bay #3 No CBI No PII View of the drain pans, half container and spill pallets that are not labeled with the words Used Oil. 18 of 20 01/10/2022 - 01/24/2022 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): [Title] IMG-2022011012184118411052897.jpg 01/10/2022 12:18 PM (AKT) Jon Jones Truck Shop/Bay #3 No CBI No PII View of the drain pans, half container and spill pallets that are not labeled with the words Used Oil. 01/10/2022 - 01/24/2022 Document Log Document Type Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Document Name BOL#81017075.pdf BOL#81017080.pdf BOL#81017086.pdf BOL#81017090.pdf BOL#81017095.pdf BOL#81017098.pdf BOL#81017102.pdf BOL#81017105 and BOL#81017108.pdf BOL#81017107.pdf BOL#81017152.pdf BOL#81084564.pdf BOL#81084574.pdf BOL#81084577.pdf BOL#81192032.pdf BOL#81192041.pdf BOL#81192052.pdf BOL#81192059.pdf BOL#81521507-1.pdf Contains Contains Uploaded By CBI PII No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones Date Received 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones 19 of 20 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 CARLILE TRANSPORTATION SYSTEMS LLC Inspection Date(s): 01/10/2022 - 01/24/2022 Records Review BOL#81567643.pdf No No Jon Jones Records Review BOL#81567647.pdf No No Jon Jones Records Review BOL#81633994.pdf No No Jon Jones Records Review BOL#81634006.pdf No No Jon Jones Records Review BOL#81636549.pdf No No Jon Jones Records Review BOL#81636554.pdf No No Jon Jones Records Review BOL#81765614.pdf No No Jon Jones Records Review BOL#81765615.pdf No No Jon Jones Records Review BOL#81765919.pdf No No Jon Jones Records Review BOL#81788516.pdf No No Jon Jones Records Review Manifest#009994593FLE SEA000567562.pdf No No Jon Jones Records Review Manifest#012598561FLE SEA000583316.pdf No No Jon Jones Records Review Manifest#012698136FLE SEA000577395.pdf No No Jon Jones Facility Map Facility Drawing.pdf No No Jon Jones Communications RE_ Small Business Resource Info No No Jon Jones Sheet and HW Guidebook.pdf Other - Photos documenting the labeling of used oil storage units. Stenciled.msg No No Jon Jones 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 01/31/2022 20 of 20