Document 3Qj0MD2x2wRqz4DxdV7gbVrBD

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 04/14/2022 - 04/14/2022 Announced: No Entry: 09:47 AM (AKT) Exit: 12:15 PM (AKT) 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) Delta Western, LLC Delta Western, LLC - Juneau Bulk Facility 120 Mount Roberts Street Juneau, AK 99801 Fuel terminal and tank farm ~5 acres Since 1994 58.28835, -134.39021 Ms. Christina Bentz, Environmental Manager 450 Alaskan Way South, Suite 707 Seattle, WA 98104 (907) 265-3836 christinab@nsenergy.com CC: Mr. Nelson Bjork, Site Manager nelson.bjork@deltawestern.com Mr. Tyman Comstock, Operations Manager tymanc@deltawestern.com Facility/Site Identifier: Media Number: NAICS: AKR000000521 N/A 424710 - Petroleum Bulk Stations and Terminals Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.05.18 10:16:42 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2022.05.19 13:08:21 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 9 DELTA WESTERN JUNEAU Inspection Date(s): 04/14/2022 - 04/14/2022 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 Name Lead Inspector Jon Jones Site Manager Nelson Bjork Operations Manager Tyman Comstock Phone Email 9072716329 Jones.Jon@epa.gov Present in Opening Conf. Yes (907) 586-2800 nelson.bjork@deltawestern.com Yes (907) 586-2800 tymanc@deltawestern.com Yes Present in Closing Conf. Yes Yes No Opening Conference EPA Lead Inspector Jon Jones arrived at the Delta Western, LLC - Juneau Bulk Facility at 09:47 AM (AKT) on 04/14/2022 for an inspection. I presented my credentials to Mr. Tyman Comstock, Operations Manager and informed him that this was an EPA RCRA inspection. We were joined soon after by Mr. Nelson Bjork, Site Manager. The table above presents all the opening and closing conference inspection participants. Facility/Site Description Delta Western, LLC - Juneau Bulk Facility is a bulk fuel terminal in Juneau, AK. Additional information about the facility can be found on their website at https://www.deltawestern.com/. Facility Info Number of employees 8 Weather Conditions Sunny and cool Operating Hours Monday through Friday from 8:00 a.m. to 5:00 p.m., Saturday 8:00 a.m. to 5:00 p.m. (Terminal only). Safety Training No Provided to Inspector(s)? What type of generator facility notified? Very Small Quantity Generator (VSQG) What type of Verified as a VSQG by Mr. Tyman Comstock, Operations Manager. 2 of 9 DELTA WESTERN JUNEAU Inspection Date(s): generator facility verified as? 04/14/2022 - 04/14/2022 Process Description According to Messrs. Bjork and Comstock, wastes generated at the facility include: Used oil recycled thru Emerald Services in Seattle via Alaska Marine Lines (AML). Absorbent pads contaminated with either oil or diesel fuel burned in an onsite smart ash burner. Sodium vapor, fluorescent, and LED lamps Empty aerosols are disposed of into the trash as a solid waste. The facility does not puncture waste aerosols. Periodic cleanouts that include waste aerosols, that might may not be empty, go to the local household hazardous waste (HHW) facility at the local landfill. During the opening conference I photographed a facility map which is included in the photo log. During the inspection of the facility, I was accompanied by Mr. Bjork. 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 used oil management. At the time of the inspection the facility was not managing any waste as a universal waste. Specifically, I inspected the following areas of the facility listed below. Photo(s) 1. IMG-20220414100153153524469.jpg Building(s) Building/Area/Sub-area Load rack and tank farm Office/Warehouse Tank Farm Southwest side of the facility, just outside the tank farm perimeter. Process Description Area of Concern Used oil storage tank No Warehouse is the accumulation area for any wastes No generated that are ultimately disposed of at the HHW facility. Area where fuel product is stored in tanks. No No SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Load rack and tank farm Observation #: JJ1-OB-001 Contains CBI: No Date: 04/14/2022 While inspecting the area, I saw a Used Oil storage tank. According to Mr. Bjork the tank has a capacity of 6,000 gallons. The container was labeled with the words "Used Oil." Photo(s) 3 of 9 DELTA WESTERN JUNEAU Inspection Date(s): 04/14/2022 - 04/14/2022 1. IMG-202204141029012911074586.jpg Building: Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. Observation #: JJ1-OB-002 Contains CBI: No Date: 04/14/2022 While inspecting the area outside the bermed perimeter of the tank farm, I saw a blue, 55-gallon container that was on a pallet. The container had some sort of white liquid staining that appeared to have been splashed on or run down the exterior surface of the container. I jostled the container back and forth and could hear the contents sloshing back and forth. It felt as though it was approximately half full of a liquid. The exterior of the container was void of any markings or labeling and I asked Mr. Bjork if he knew what kind of liquid the container held. Mr. Bjork told me he thought it was leftover waste paint and solvent from a previous project in which a contractor came out and applied a sealer to the interior of the tank farm's secondary containment. He went back to the office to ask Mr. Comstock about the container. Mr. Bjork returned and opened the bung on the container to determine what the container held. He used the light on his iPhone to see what was in the container and said it appeared to be white paint. He waved his hand over the opening and at that point I could smell a solvent odor. Mr. Bjork concurred that it was some type of solvent that was mixed with paint/coating. Mr. Comstock confirmed that the container held some waste paint related material. Mr. Comstock contacted the contractor that had performed the job and he said the contractor told him it was a mix of the product that had been used to seal the surface of the tank farm's secondary containment and Methyl Ethyl Ketone (MEK) used to clean the paint guns. I asked for an SDS for the product used and Mr. Comstock had the contractor provide one during the inspection. During the inspection, I explained to Mr. Bjork that my concern was the amount of waste in the container and that if more than 220 pounds had been generated, his facility's generator category would have moved up to Small Quantity Generator. Following the inspection, on 4/14/2022, Mr. Bjork worked with AML to have a forklift scale brought over to weigh the container. Mr. Bjork called me on the afternoon of 4/14/2022 to tell me that the weight of the container, after subtracting the weight of the pallet, was 215 pounds, including the weight of the container. . Mr. Bjork followed up with an email on 4/14/2022 that included a description of what he spoke to me about as well as photo documentation of weighing the container, the container weight, and verification that the scale used was certified. Photo(s) 1. IMG-2022041410453945391077819.jpg 2. IMG-2022041410455345531263325.jpg 3. IMG-2022041410472047201105380.jpg Records Review The facility was verified as VSQG, and no records were reviewed. 4 of 9 DELTA WESTERN JUNEAU Inspection Date(s): SECTION III - AREAS OF CONCERN I observed no areas of concern at the time of the inspection. 04/14/2022 - 04/14/2022 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 Mr. Bjork for his time and cooperation during the inspection and we discussed the potential area of concern that if the weight of the waste paint and solvent mixture exceeded 220 pounds, then the facility's generator category would have moved up to at least Small Quantity Generator. 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 Mr. Bjork the case officer would review the report to determine if any areas of concern documented violations. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log 5 of 9 DELTA WESTERN JUNEAU Inspection Date(s): [Title] IMG-20220414100153153524469.jpg 04/14/2022 10:01 AM (AKT) Jon Jones Office/Warehouse No CBI No PII View of facility layout. [Title] IMG-2022041411195919591206201.jpg 04/14/2022 11:19 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII View of the container bung opening (Photographed while Mr. Bjork attempted to view the contents of the container). [Title] IMG-2022041411201720171168177.jpg 04/14/2022 11:20 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII Close-up view of the container bung opening (Photographed while Mr. Bjork attempted to view the contents of the container). 6 of 9 04/14/2022 - 04/14/2022 DELTA WESTERN JUNEAU Inspection Date(s): [Title] IMG-20220414113906396160320.jpg 04/14/2022 11:39 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII Close-up view looking into the container through the bung opening (Photographed while Mr. Bjork attempted to view the contents of the container using an iPhone light). [Title] IMG-202204141139143914107154.jpg 04/14/2022 11:39 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII View of the container contents, illuminated by Mr. Bjork's iPhone light. [Title] IMG-202204141029012911074586.jpg 04/14/2022 10:29 AM (AKT) Jon Jones Load rack and tank farm No CBI No PII View of used oil storage tank. 04/14/2022 - 04/14/2022 7 of 9 DELTA WESTERN JUNEAU Inspection Date(s): [Title] IMG-2022041410453945391077819.jpg 04/14/2022 10:45 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII View of the 55-gallon container that held waste paint related material (Mix of MEK/coating from paint gun cleaning). [Title] IMG-2022041410455345531263325.jpg 04/14/2022 10:45 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII Another view of the 55-gallon container that held waste paint related material (Mix of MEK/coating from paint gun cleaning). [Title] IMG-2022041410472047201105380.jpg 04/14/2022 10:47 AM (AKT) Jon Jones Tank Farm/Southwest side of the facility, just outside the tank farm perimeter. No CBI No PII Another view of the 55-gallon container that held waste paint related material (Mix of MEK/coating from paint gun cleaning). Document Log 8 of 9 04/14/2022 - 04/14/2022 DELTA WESTERN JUNEAU Inspection Date(s): Document Type Document Name Other - Safety Data Sheet Communications Envirolastic SDS.pdf Delta Western Juneau-EPA Review.pdf 04/14/2022 - 04/14/2022 Contains Contains Uploaded By CBI PII No No Jon Jones Date Received 04/21/2022 No No Jon Jones 04/21/2022 9 of 9