Document 2X22dvpmoEV8eRjb1XvvXJZp

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 03/11/2024 10:12 AM (AKT) Announced: No 03/11/2024 11:18 AM (AKT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Mailing Address/Secondary Address Costco Wholesale Corporation Costco Wholesale #63 AK0000882274 4125 Debarr Road Anchorage, AK 99508 N/A Small Quantity Generator (SQG) 452311 Warehouse Clubs and Supercenters 61.209736, -149.809073 Mr. Allen Arnold, Warehouse Manager N.E. Anchorage Costco #63 907 269-9501 4125 Debarr Road Anchorage, AK 99508 w063mgr@costco.com Cc: Mr. Tim Sitter, Assistant General Manager w063mgr3@costco.com Michael Cotton, Regional Vice President mcotton@costco.com Mario Omoss, District Vice President momoss@costco.com Jessica Stapleton, Regional Environmental Sustainability & Compliance Manager jstapleton@costco.com Traci Morgan, Director of Global Sustainability Operations tracimorgan@costco.com Gavin Pendleton, Director of Global Environmental Compliance gpendleton@costco.com Costco Environmental Compliance Team environmentalcompliance@costco.com City, State, Zip Code Anchorage, AK 99508 Lead Inspector: Jon Jones EPA Region 10 Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Matt Quarterman EPA Region 10 Quarterman.matthew@epa.gov (206) 553-2146 1 of 9 Costco Wholesale #63 Inspection Date(s): 03/11/2024 - 03/11/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) EPA Region 10 Lead Inspector, Jon Jones, arrived at the Costco Wholesale #63 Facility (the "Site" or "Facility"), located at 63 Debarr Road, Anchorage, AK 99508, at 10:12 AM (AKT) on 03/11/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Tim Sitter that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 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). The inspection was conducted as part of a Core Program requirement for FY 2024. This report is based on information supplied by Costco Wholesale #63 Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Email Opening Conf. Lead Inspector/EPA Jon Jones REGION 10 RCRA Inspector-in- Vanessa training/ADEC Schmidt RCRA Inspector-in- Emily training/ADEC Vannortwick Assistant General Tim Sitter Manager/Costco Admin Manager/Costco Sarah Bonholdt (907) 271-6329 Jones.Jon@epa.gov Yes Yes Yes (907) 269-9510 w063mgr3@costco.com Yes Ext.231 Yes Closing Conf. Yes Yes Yes Yes Yes Opening Conference After arriving at Costco Wholesale #63, I spoke with a store representative at the customer service counter and asked to speak with the manager. A short time later, we were met by Mr. Tim Sitter, Assistant General Manager. I presented my inspector credentials and informed him that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). Mr. Sitter told us that he had to run something back to his RTV Clerk, in receiving, ahead of us holding an opening conference. Given that this was an area that needed to be inspected, we offered to join him. Mr. Sitter agreed, and the opening conference was conducted while walking back to the receiving area. During the opening conference, I explained that the focus of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. Only those areas in which I observed potential compliance concerns or noted other pertinent issues are 2 of 9 Costco Wholesale #63 Inspection Date(s): 03/11/2024 - 03/11/2024 discussed in Section III of this inspection report. Facility/Site Information Operating Hours Monday through Friday, from 10:00am to 8:30pm. Saturday, from 9:00am to 6:00pm, and Sunday from 10:00am to 6:00pm. Length of Facility at Location 31 years Number of employees ~300 total, 189 full-time Safety Training No Provided to Inspector(s)? Size of Facility 168,000 square feet What type of generator facility notified? Small Quantity Generator (SQG) What type of generator facility verified as? SQG status was verified by Tim Sitter, Assistant General Manager, during the inspection. Process Description During the opening conference, Mr. Sitter told us the wastes generated at the facility were generated either due to product being damaged as it enters the store through receiving, damaged on the shelf at the store, or customer returns that cannot be resold. Ms. Sarah Bonholdt, Administrative Manager joined us while we were in the receiving area at the CAA. We were accompanied during the rest of the inspection by Mr. Sitter and Ms. Bonholdt. We looked at the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. We also observed the facility's universal waste. Building(s) Building/Area/Sub-area Costco Hearing Aid Center Pharmacy Return to Vendor (RTV) Tire Shop Process Description Area of Concern Yes Testing and fitting hearing aids Generation and No collection of waste hearing aid batteries managed as universal waste. Generation of hazardous Waste pharmaceuticals No (HWPharms). Central Accumulation Area (CAA) for the No accumulation of hazardous waste and the collection of universal waste lamps and batteries and a satellite accumulation area (SAA) for waste aerosol can residue from waste aerosol can popping/puncturing. Tire changeovers and battery replacement, with a Yes waste aerosol satellite accumulation area (SAA) 3 of 9 Costco Wholesale #63 Inspection Date(s): 03/11/2024 - 03/11/2024 SECTION II - OBSERVATIONS Building: Costco/Tire Shop Observation #: JJ1-OB-001 Date: 03/11/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Tim Sitter Title: Assistant General Manager The "Tire Shop" is an automotive shop where tire changeovers and battery replacements occur. Mr. Sitter told us that used lead acid batteries are recycled with Interstate. There is an SAA also located in the shop for the accumulation of waste aerosol cans. During the inspection of the shop, we observed two aerosol cans on a counter that was adjacent to a flammable storage cabinet. I picked up the aerosol cans and shook them to determine if they were empty or if they still held any product. Both felt as though they were empty, and I asked Mr. Sitter if they were waste aerosols. Mr. Sitter confirmed that they were empty and were waste aerosols and that this would be corrected by staff. This waste aerosol cans included a brake parts cleaner and a bathroom cleaner. At the time of the inspection, neither of the two waste aerosol cans were labeled with the words, "Hazardous Waste" or marked with a hazard indicator. Facility personnel placed the two waste aerosol cans in the waste aerosol SAA container during the inspection. On 4/5/24, I received an email from Mr. Sitter that included an attached response letter, dated 4/5/24, from Mr. Allen Arnold, Costco #63 Warehouse Manager, addressing the areas of concern that were identified during the inspection. In that letter, Mr. Arnold stated, "These were corrected at the time of inspection. In addition, all Tire Shop personnel have been retrained on the proper handling of empty aerosol cans." Photo(s) 1. IMG-202403111054065462361061.jpg 2. IMG-2024031110541454142024811.jpg 3. IMG-2024031110543054302211893.jpg SECTION III - RECORDS REVIEW Record: Manifests AOC: Yes Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 03/11/2024 At the time of the inspection, the facility's hazardous waste manifests were located in the RTV area of receiving, adjacent to the CAA. While there, we met Mr. Jeremy Gore, RTV Clerk. We asked Mr. Gore for the last three years of manifests, covering the period of March 11, 2021, through March 11, 2024. During the manifest review, we identified that there was no original manifest # 004899460FLE that had been signed and dated by the designated TSDF facility. Mr. Gore began looking for the signed copy and I suggested that he contact the designated TSDF, listed on the manifest, and have them email the signed copy to him. I asked him to provide a copy of the signed manifest when he received it. We departed the area and while we continued with the inspection, Mr. Gore contacted the designated facility and had a signed copy of the manifest faxed to the store. Prior to the end of our inspection, Mr. Gore received a signed copy of the manifest and brought it to us for review during the inspection. I saw that the manifested waste shipment had been signed by the TSDF and according to the date, had been received within 60 days. On 4/5/24, I received an email from Mr. Sitter that included an attached response letter, dated 4/5/24, from 4 of 9 Costco Wholesale #63 Inspection Date(s): 03/11/2024 - 03/11/2024 Mr. Allen Arnold, Costco #63 Warehouse Manager, addressing the areas of concern that were identified during the inspection. In that letter, Mr. Arnold stated, "We were able to correct this during the inspection. In addition, both the Costco personnel responsible for completing and retaining the manifest records and the personnel responsible for periodic inspection of the records have been retrained." Document(s) 1. HW Manifest 004899460FLE.pdf Photo(s) 1. IMG-2024031110344034403310121.jpg Record: Inspections Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/11/2024 During the inspection, we went up to Mr. Sitter's office and I reviewed the last three years of electronic weekly hazardous waste inspections for the period of March 11, 2021, through March 11, 2024. At the time of the inspection, I saw that no weekly inspections were conducted for the following weeks: October 31-November 6, 2021 April 30-May 6, 2023 Mr. Sitter concurred that the weekly inspections had not been conducted. On 4/5/24, I received an email from Mr. Sitter that included an attached response letter, dated 4/5/24, from Mr. Allen Arnold, Costco #63 Warehouse Manager, addressing the areas of concern that were identified during the inspection. In that letter, Mr. Arnold stated, "Having previously discovered the potential for this issue, Costco has implemented a program of electronically tracking weekly inspections. If inspections are not completed by Wednesday of each week, emails are sent to the responsible managers of each warehouse and followed up on by the Regional Environmental Sustainability and Compliance Manager. In addition, the responsibility for completing the inspections has been broadened to a larger group in order to increase consistency during periods of vacation or leave." SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Costco JJ1-OB-001 Two waste aerosol cans were not labeled with the words "Hazardous Waste" or marked with a hazard indicator. Area: Tire Shop Regulation: Sub-area: Sections: Facility personnel placed the two waste aerosol cans in the waste aerosol SAA container during the inspection. 5 of 9 Costco Wholesale #63 Inspection Date(s): Record: Manifests JJ1-RR-001 There was no original returned hazardous waste manifest for Manifest #004899460FLE that had been signed and dated by the designated facility (TSDF). Regulation: Mr. Gore, RTV Clerk, obtained a copy of the signed and dated manifest, from the TSDF, during the inspection. Record: Inspections JJ1-RR-002 At the time of the inspection, no Regulation: weekly hazardous waste inspections were conducted for the following weeks: October 31-November 6, 2021 April 30-May 6, 2023 03/11/2024 - 03/11/2024 Sections: Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP 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. Follow Up N/A SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 6 of 9 Costco Wholesale #63 Inspection Date(s): APPENDIX 1: PHOTO LOG 03/11/2024 - 03/11/2024 [Title] IMG-2024031110344034403310121.jpg 03/11/2024 10:34 AM (AKT) No CBI No PII Photographer: Jon Jones Costco/RTV 61.21107416, -149.80443527 View of hazardous waste manifest # 004899460FLE, for which there was no original returned copy that had been signed and dated by the designated facility (TSDF). [Title] IMG-202403111054065462361061.jpg 03/11/2024 10:54 AM (AKT) No CBI No PII Photographer: Jon Jones Costco/Tire Shop 61.21118961, -149.80468622 View of two waste aerosol cans, seen here on a counter adjacent to a flammable storage cabinet, that were not labeled with the words "Hazardous Waste" or marked with hazard indicators. 7 of 9 Costco Wholesale #63 Inspection Date(s): 03/11/2024 - 03/11/2024 [Title] IMG-2024031110541454142024811.jpg 03/11/2024 10:54 AM (AKT) No CBI No PII Photographer: Jon Jones Costco/Tire Shop 61.21118965, -149.80468624 Close-up view of two waste aerosol cans, seen here on a counter adjacent to a flammable storage cabinet, that were not labeled with the words "Hazardous Waste" or marked with hazard indicators. [Title] IMG-2024031110543054302211893.jpg 03/11/2024 10:54 AM (AKT) No CBI No PII Photographer: Jon Jones Costco/Tire Shop 61.21121235, -149.8047242 Another close-up view of two waste aerosol cans, seen here on a counter adjacent to a flammable storage cabinet, that were not labeled with the words "Hazardous Waste" or marked with hazard indicators. 8 of 9 Costco Wholesale #63 Inspection Date(s): 03/11/2024 - 03/11/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Records Review Communications HW Manifest No No Jon Jones 004899460FLE.pdf Response letter from No No Jon Jones Costco #63 04/05/2024 04/05/2024 9 of 9