Document 3QvQy1GNEdG60wLXVQKjNQ2m3

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 07/12/2023 10:45 AM (AKT) Announced: No 07/12/2023 12:23 PM (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 City, State, Zip Code North Slope Borough (NSB) Oxbow Landfill AKR000210245 1234 Site 12 Road Prudhoe Bay, AK 99734 North Slope Borough Very Small Quantity Generator (VSQG) 562212 - Solid Waste Landfill Class 1 (Freeze back) Landfill for both Construction & Demolition (C&D) waste and Municipal Solid Waste (MSW). 70.28556, -148.51875 Eric Lervig, Landfill Supervisor 1234 Site 12 Road Prudhoe Bay, AK 99734 elervig@iceservices.net CC: Rich Helinski, Projects/Operations Manager rhelinski@iceservices.net Patricia Brower, NSB Landfill Liaison patricia.brower@north-slope.org Mike Monnin, NSB Landfill Liaison mike.monnin@north-slope.org Cynthia Trapp, NSB, DPW, Environmental Official cynthia.trapp@north-slope.org Prudhoe Bay, AK 99734 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA Region 10 Jones.Jon@epa.gov (907) 277-4316 Supervisor Review: Matt Quarterman EPA Region 10 Quarterman.matthew@epa.gov (206) 553-2146 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection 1 of 15 Oxbow Landfill Inspection Date(s): Type of inspection: Compliance Evaluation Inspection (CEI) 07/12/2023 - 07/12/2023 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Oxbow Landfill Facility (the "Site" or "Facility"), located at 1234 Site 12 Road, Prudhoe Bay, AK 99734, at 10:45 AM (AKT) on 07/12/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Eric Lervig that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 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 2023. This report is based on information supplied by Oxbow Landfill Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its HQ 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 Lead Inspector/EPA REGION 10 Jon Jones RCRA Inspector/EPA Region 10 Matt Quarterman RCRA Inspector-in- Alan Pefley training/ADEC Landfill Supervisor/NSB Oxbow Landfill Eric Lervig Phone (907) 2716329 (907) 6701014 Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes quarterman.matthew@epa.gov Yes No Yes No elervig@iceservices.net Yes Yes Opening Conference Shortly after arriving at the Oxbow Landfill, I called the phone number listed on the door and we were met in the landfill office by Mr. Eric Lervig, Landfill Supervisor and I held the opening conference. 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. Mr. Lervig told us that the North Slope Borough owned the Oxbow Landfill. He told us he was a contractor with Ice Services. He said that Ice Services operated the landfill on behalf of the North Slope Borough. Mr. Lervig told us the landfill was a Class 1 freeze back landfill that started operating in the early 1980's. He told us the landfill operates under Solid Waste Permit #SW1A008-27. I reviewed a copy of the permit and saw that it expires on 4/30/2027. 2 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 Only those areas in which we observed potential compliance concerns or noted other pertinent issues are discussed in Section III of this inspection report. Facility/Site Information Number of employees 3 Length of Facility at Location Since the early 1980s Operating Hours 8:00 a.m. to 4:30 p.m. Monday - Saturday; 8:00 a.m. to 3:00 p.m. Sunday Safety Training No Provided to Inspector(s)? Size of Facility Unknown What type of generator facility notified? Non-Notifier What type of generator facility verified as? Verified Very Small Quantity Generator (VSQG) by Eric Lervig, Landfill Supervisor Weather Conditions Rainy Process Description According to Mr. Lervig, the following wastes are generated at the landfill: Used oil - managed through US Ecology. Used oil filters - hot drained, crushed and disposed of into the landfill. Used antifreeze - managed through US Ecology. Waste aerosol cans - waste aerosol cans that last contained product (paints, lubricants, and solvents) are punctured onsite with the empty aerosol cans being landfilled. Waste aerosol can residue - not being collected during can puncturing. Lead-acid batteries - recycled through Brooks Supply in Deadhorse, AK. Waste tool and radio batteries - managed through US Ecology. Waste lamps - lamps are changed out by another section of Ice Services and taken to the Ice Services camp site. We were accompanied during the inspection by Mr. Lervig. 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. Building(s) Building/Area/Sub-area Incinerator Building Maintenance Shop Process Description Sorting of oily waste that comes into the landfill, double bagged, in ~27 cubic yard roll-off containers from entities operating within Prudhoe Bay, AK. Vehicle/equipment maintenance, generating used oil, used oil filters, used antifreeze, and lead-acid vehicle batteries. Area of Concern No Yes 3 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 Waste aerosol cans are being punctured in the maintenance shop. SECTION II - OBSERVATIONS Building: Maintenance Shop Observation #: JJ1-OB-001 Date: 07/12/2023 Person Interviewed: Eric Lervig Contains AOC: Yes Contains CBI: No Title: Landfill Supervisor While in the Maintenance Shop, we saw a 275-gallon tote that appeared to contain used oil. I asked Mr. Lervig if the tote contained used oil and he told us that it did. At the time of the inspection, the tote contained approximately 225-gallons of used oil and was not labeled with the words "Used Oil." I explained the regulation requiring that all used oil storage units be labeled, and Mr. Lervig labeled the tote with the words "Used Oil" during the inspection. At the time of the inspection, there was also a 55-gallon container that was being used to accumulate used oil from filter draining. This container was labeled with the words used oil. Photo(s) 1. IMG_1585.jpg 2. IMG_1587.jpg 3. IMG_1586.jpg 4. IMG_1588.jpg 5. IMG_1589.jpg Building: Maintenance Shop Observation #: JJ1-OB-002 Date: 07/12/2023 Person Interviewed: Eric Lervig Contains AOC: Yes Contains CBI: No Title: Landfill Supervisor We returned to the Maintenance Shop after inspecting the Incinerator building. Mr. Lervig mentioned during the opening conference that his facility generates several waste aerosol cans each month that get punctured in the Maintenance Shop. Upon our return, I asked Mr. Lervig to show me where and how the waste aerosol cans were being punctured. Mr. Lervig told me that the waste aerosol cans were being punctured, using a hammer and a punch, on a bench in the shop. I asked him how the punctured aerosol cans were being managed and he told us that they were being disposed of into the scrap metal pile. I asked Mr. Lervig for the name of the scrap metal recycler that the landfill was using. Mr. Lervig told us that most of the time it was cost prohibitive for the metal to go to a recycler. He told us that, most of the time, the scrap metal gets landfilled onsite. I explained that VSQGs were required to manage their waste properly and suggested that they make a waste determination and either manage them as a hazardous waste or a universal waste without puncturing the aerosol cans. Photo(s) 1. IMG_1602.jpg 2. IMG_1603.jpg Building: Incinerator Building Observation #: JJ1-OB-003 Date: 07/12/2023 Contains AOC: No 4 of 15 Contains CBI: No Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 Person Interviewed: Eric Lervig Title: Landfill Supervisor While inspecting the Incinerator building, we went to the area where the facility was sorting through oily waste that arrives in ~27 cubic yard roll-off containers from entities within the Prudhoe Bay oilfield. According to Mr. Lervig, the landfill burned the oily waste in incinerators that were operated in the landfill from ~2008 until ~2009/2010. In ~2009/2010, the North Slope Borough (NSB) purchased new incinerators, that were built by someone in Deadhorse, AK. These newly installed incinerators would be used to incinerate the oily waste that came into the landfill, however; the incinerators were shut down during start-up because they did not meet Clean Air Act (CAA) requirements and the incinerator doors were welded shut. According to Mr. Lervig, once the incinerators were shut down, they started sending the oily waste down to the lower 48 to be incinerated. At the time of the inspection, there were two, ~27 cubic yard, roll-off containers in the Incinerator building. According to Mr. Lervig, one roll-off container (#68-25) held the oily waste that had come into the facility from Hilcorp's Milne Point facility and the other was being used to accumulate the less oily, oily waste. According to Mr. Lervig, the oily waste that comes into the facility ultimately goes to the City of Spokane, WA for incineration in their Waste to Energy facility. Mr. Lervig explained that prior to this waste going down to Spokane, WA., the incoming oily waste is sorted. Mr. Lervig told us there were items comingled with the oily waste that needed to be removed before it would be accepted by the Waste to Energy facility. According to Mr. Lervig, the following wastes are removed during the sorting process: Leather gloves Drained oil filters Trash Empty buckets Empty containers Gravel Rubber gloves Mr. Lervig also told us that only those bags of oily waste that contain absorbent pads, booms, and materials that are heavily contaminated with oil go on to the Waste to Energy facility. He told us that the bags of oily waste that weren't heavily contaminated with oil are removed from the roll-off during the sorting process and placed into another roll-off container that eventually gets dumped into the landfill. He said that some of the less contaminated absorbents are pulled out and used to soak up the oil from the bags that just contain oily liquids. Mr. Lervig went on to tell us that the bags of oily waste that are destined for the Waste to Energy facility, go into 1.7 cubic yard boxes. Once filled they are filled, the boxes are numbered and marked with the weight. He said that when the accumulation of oily waste boxes reaches 44,000 pounds, they ship the oily waste down to Spokane, WA. via Lyndon Transport. Lyndon Transport has a facility located in Deadhorse, AK. Just outside the Incinerator building, we saw two additional roll-off containers of oily waste that required sorting. According to Mr. Lervig, the roll-off marked #6802 came in from Hilcorp's Prudhoe Bay Unit (PBU) Pad 9 and the other marked #6801 came in from Hilcorp's PBU Flow Station 1 (FS-1). 5 of 15 Oxbow Landfill Inspection Date(s): Photo(s) 1. IMG_1590.jpg 2. IMG_1592.jpg 3. IMG_1593.jpg 4. IMG_1591.jpg 5. IMG_1594.jpg 6. IMG_1595.jpg 7. IMG_1596.jpg 8. IMG_1597.jpg 07/12/2023 - 07/12/2023 SECTION III - RECORDS REVIEW The facility is a VSQG and there were no records to review. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Maintenance Shop JJ1-OB-001 Area: Sub-area: A tote containing approximately 225-gallons of used oil was not labeled with the words "Used Oil." Mr. Lervig labeled the tote with the words "Used Oil" during the inspection. Regulations: Sections: Building: Maintenance Shop JJ1-OB-002 Area: Sub-area: Mr. Lervig told me that the waste aerosol cans were being punctured, using a hammer and a punch, on a bench in the shop. Regulations: 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 Mr. Lervig for his 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 the 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. 6 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 7 of 15 Oxbow Landfill Inspection Date(s): APPENDIX 1: PHOTO LOG 07/12/2023 - 07/12/2023 [Title] IMG_1585.jpg 07/12/2023 11:17 AM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28545277, -148.51875277 View of 275-gallon used oil tote that is not labeled with the words "Used Oil." [Title] IMG_1586.jpg 07/12/2023 11:17 AM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28545277, -148.51875277 Another view of the used oil tote, showing that it is not labeled with the words "Used Oil." 8 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1587.jpg 07/12/2023 11:17 AM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28545277, -148.51875277 Close-up view of the used oil tote, showing that it is not labeled with the words "Used Oil." [Title] IMG_1588.jpg 07/12/2023 11:19 AM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28545277, -148.51875277 View of a 55-gallon container being used to accumulate used oil. At the time of the inspection, this container was labeled with the words "Used Oil." 9 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1589.jpg 07/12/2023 11:20 AM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28545277, -148.51875277 View of the used oil tote after being labeled with the words "Used Oil," during the inspection. [Title] IMG_1590.jpg 07/12/2023 11:31 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28527777, -148.5195 View of the roll-off containers in the oily waste sorting area. Container on the left contains oily waste from Hilcorp's Milne Point facility. Container on the right contains less contaminated oily waste that will be landfilled. 10 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1591.jpg 07/12/2023 11:32 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28526388, -148.51956111 View of the bags of oily waste that come into the facility prior to sorting. [Title] IMG_1592.jpg 07/12/2023 11:32 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28526388, -148.51957777 View inside of the roll-off that contains sorted oily waste that will be landfilled. 11 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1593.jpg 07/12/2023 11:33 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28526388, -148.51957777 View of less oily absorbents, that came in with oily waste, that will be used to soak up liquids in the bags of heavily contaminated oily waste. [Title] IMG_1594.jpg 07/12/2023 11:34 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28528611, -148.51962222 View of the boxed bags of oily waste that will be sent to the City of Spokane, WA. Waste to Energy facility. 12 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1595.jpg 07/12/2023 11:47 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28526944, -148.51959166 View of the incinerators that were shut down and are not in operation. [Title] IMG_1596.jpg 07/12/2023 11:48 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28526388, -148.51957777 Close-up view of the incinerator, showing that the door had been welded shut. 13 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1597.jpg 07/12/2023 11:57 AM No CBI No PII Photographer: Jon Jones Incinerator Building 70.28511111, -148.52131666 View of additional roll-off containers holding bags of oily waste that require sorting. The roll-off on the left contains oily waste from Hilcorp's PBU Pad 9 and the roll-off on the right contains oily waste from Hilcorp's PBU Flow Station 1. [Title] IMG_1602.jpg 07/12/2023 12:08 PM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28546111, -148.51876944 View of the bench and the punch used to puncture waste aerosol cans. 14 of 15 Oxbow Landfill Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1603.jpg 07/12/2023 12:08 PM No CBI No PII Photographer: Jon Jones Maintenance Shop 70.28546111, -148.51875277 View of yellow paint on the bench where waste aerosol cans are punctured using a hammer and punch. 15 of 15