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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 08/06/2024 08:49 AM (AKT) Announced: No 08/06/2024 04:44 PM (AKT) Access: Granted Resource Conservation and Recovery Act (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 Alyeska Pipeline Service Company Alyeska Taps Valdez Marine Terminal AKD052581758 300 Dayville Road, Pipeline MP 800 Valdez, AK 99686 Unorganized Large Quantity Generator (LQG) 48611 - Pipeline Transportation of Crude Oil Crude Oil Terminal 61.084857, -146.388531 Allison Iverson, HSEC Director Allison.iverson@alyeska-pipeline.com Alyeska Pipeline Service Company P.O. Box 196660, MS 507 Anchorage, AK 99519 907-787-8061 CC: Gretchen W. Stoddard, Waste Management SME gretchen.stoddard@alyeska-pipeline.com City, State, Zip Code Valdez, AK 99686 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA Region 10 Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Matthew Quarterman EPA Region 10 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI Quarterman.Matthew@epa.gov (206) 553-2146 1 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Alyeska Taps Valdez Marine Terminal Facility (the "Site" or "Facility"), located at 300 Dayville Road, Pipeline MP 800, Valdez, AK 99686, at 08:49 AM (AKT) on 08/06/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Dan Gilson 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) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2024. This report is based on information supplied by Alyeska Taps Valdez Marine Terminal 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 Phone Lead Inspector/EPA Region 10 Waste Management SME /Alyeska Pipeline Service Company VMT Director/Alyeska TAPS Valdez Marine Terminal (VMT) VMT Operations Manager/Alyeska TAPS Valdez Marine Terminal (VMT) Environmental Coordinator Supervisor /Alyeska TAPS Valdez Marine Terminal (VMT) VMT Environmental Jon Jones Gretchen Stoddard Klint VanWingerden Weston Branshaw Cathy Gerard Dan Gilson (907) 2716329 (907) 7878946 (907) 7878422 (907) 8347557 (907) 4505583 (907) 8347590 Email Jones.Jon@epa.gov Opening Conf. Yes gretchen.stoddard@alyeska- No pipeline.com klinton.vanwingerden@alyeska- Yes pipeline.com weston.branshaw@alyeska- Yes pipeline.com catherine.girard@alyeska- Yes pipeline.com dan.gilson@alyeska- Yes pipeline.com 2 of 45 Closing Conf. Yes Yes Yes Yes No Yes Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Coordinator /Alyeska TAPS Valdez Marine Terminal (VMT) RCRA Inspector-in- Grace Tapulgo (907) 269- Grace.tapulgo@alaska.gov Yes Yes training/ADEC 7578 RCRA Inspector-in- Sable McGovern (907) 269- Sable.mcgovern@alaska.gov Yes Yes training/ADEC 4556 Opening Conference Jon Jones, along with Alaska Department of Environmental Conservation (ADEC) Inspectors Grace Tapulgo and Sable McGovern arrived at the facility at 8:49 am and met with Valdez Marine Terminal (VMT) Environmental Coordinator, Dan Gilson, who led us to a conference room for the opening conference. We were joined by VMT Director Klint VanWingerden, VMT Operations Manager Weston Branshaw, and Environmental Coordinator Supervision Cathy Gerard. During the opening conference we presented our inspector credentials, provided business cards, and informed the group that this was a routine hazardous waste compliance inspection in accordance with RCRA. We explained that the ADEC inspectors were accompanying the inspection for training purposes. Additionally, we explained that the focus of the RCRA inspection was to identify and observe types of waste generated, points of waste generation, methods of waste management, and review related documents. These documents include manifests, hazardous waste training, and weekly inspections from the last three years. Dan Gilson provided us with a packet of the facility and map areas, which included each building at the VMT and their waste streams. We were accompanied throughout the inspection by Dan Gilson. We were not denied access to any part of the facility, and we were allowed to take photographs. Facility/Site Information What type of generator facility verified as? Large Quantity Generator (LQG) status verified by Mr. Gilson. What type of LQG generator facility notified? Size of Facility Approximately 1,000 acres Safety Training No Provided to Inspector(s)? Operating Hours 24 hours a day/7 days a week Length of Facility at Location Since 1977 Number of employees Approximately 200 Weather Conditions Partly Cloudy 3 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Process Description The 800-mile long Trans Alaska Pipeline System (TAPS) transports crude oil from Prudhoe Bay's Pump Station 1 to the Alyeska Marine Terminal where it is stored in tanks prior to shipment. The process for cleaning these tanks includes emptying the tank, purging it, and removing tank bottoms. At the time of the inspection there were no tanks being cleaned out. Hazardous waste sources include, but are not limited to, pigging, sandblasting, and sumps. Additional hazardous waste generated at this facility include waste leather gloves, waste paint, compressed gas cylinders, flammables in the form of ethyl alcohol and petroleum distillates, used oil, and corrosive wastes. They also generate universal waste aerosol cans, universal waste LED lamps, and universal waste batteries. During the inspection we examined the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representative had not yet identified or designated as hazardous. We also observed the facility's universal waste management. Lastly, we reviewed the facility records and documents that were available at the time of the inspection. We inspected the areas of the facility listed in the building(s) table below. Building(s) Building/Area/Sub-area Valdez Marine Terminal Ballast Water Treatment (BWT) Sludge tank BWT Sludge Tank Central Accumulation Area (CAA) BWT BWT Satellite Accumulation Area (SAA) Pole Barn WS1b WS2b WS3a WS3b Contaminated Soil Stockpile East Tank Farm Emergency Response Building (ERB) Environmental Office Process Description Area of Concern Yes Outdoor concrete slab near sludge tank with a few Yes hazardous waste barrels. One 55-gal container of strainer sludge and a 55-gal Yes container of non-hazardous diesel contaminated soil. Ballast water treatment building, location of Yes strainer waste SAA. 55-gal hazardous waste container of strainer waste Yes SAA. Hazardous waste central accumulation area (CAA). Yes Universal waste accumulation area for aerosols and No compressed gas cylinders. None currently accumulated. Aerosol cans and compressed gas cylinders. No Universal waste accumulation area for batteries. No CAA for smaller waste paint containers, held in "Red Yes Box". Used for petroleum and lubricants that are non- No hazardous. Houses tanks, last tank clean out was May/June Yes 2023. Houses firetrucks and fire team for VMT. UW Yes accumulation of batteries and waste aerosol cans. Universal waste accumulation of batteries and No lamps. 4 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Environmental Office UW Batteries and lamps. No Accumulation Equipment shop Area where used oil tank is stored. Yes Area next to oil tank Catch pan for hoses transferring used oil from Yes containers to large tank. Lab Where testing is conducted, Lab SAA located here. Yes Lab SAA BTEX and oil and grease waste SAA. Yes Maintenance Shop Repairs of VMT trucks and equipment done here. No SAA for waste leather gloves. Universal waste accumulation of bulbs, batteries, and aerosol cans. Maintenance Shop SAA Waste leather gloves. No Medical Clinic Where they handle prescription drugs and No administer medical care. Operations Office SAA for waste leather gloves and universal waste No accumulation of batteries. Operations Office SAA Waste leather gloves. No Oil Spill Building (OSB) Oil spill containment equipment is stored here. No Partner Industrial (Connex) Storage area of Connex box. No Connex Storage Connex, contained pallet of Part-A No Hardener. Power Vapor Universal accumulation of batteries, aerosol cans, No lamps, and SAA of leather gloves. Power Vapor UW Accumulation Batteries, aerosol cans, lamps. No Safety Office SAA for waste leather gloves. No Safety Office SAA Waste Leather gloves. No Valdez Fabrication Facility (VFF) Shop Houses metal, paint, and wood shop. No Metal Shop Repairs for VMT done here. Accumulation of Bra- No kleen rags and aerosol cans. Paint shop Generation point for waste paint. Yes Tatitlek Chenega Corporation (TCC) Boom Repair Warehouse used by Oil Spill Response No contractor, SAA that contained waste Trichloroethylene. Wood Shop Construction for VMT done here. SAA of leather No gloves. Universal waste accumulation point for batteries and aerosol cans. SECTION II - OBSERVATIONS Building: Valdez Marine Terminal/Central Accumulation Area (CAA)/Pole Barn Observation #: JJ1-OB-001 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed four, 55-gallon containers marked "hazardous waste" with no hazard indicators at the Pole Barn. There were two barrels of Isocyanates, one barrel of amines, and one barrel of C-Boiler refractory debris. Dan Gilson informed us that this barrel of C-Boiler refractory debris was awaiting a hazardous waste determination, 5 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 and they were hoping to add it to their contaminated soil stockpile. The missing hazard indicators for these barrels were added at time of the inspection by Dan Gilson. Additionally, there was one 55-gallon drum of recovered crude strainer waste that was labeled hazardous waste but was missing the hazard indicator. The hazard indicator was added at the time of the inspection by Dan Gilson. Photo(s) 1. IMG-20240806095002502137897.jpg 2. IMG-2024080609500850869111.jpg 3. IMG-20240806095015501585344.jpg 4. IMG-202408060950485048100511.jpg 5. IMG-2024080609510651678956.jpg 6. IMG-202408060955535553129449.jpg 7. IMG-20240806095600560107089.jpg 8. IMG-20240806095609569119898.jpg 9. IMG-202408060957445744111643.jpg 10. IMG-20240806095838583874527.jpg 11. IMG-20240806095846584680151.jpg 12. IMG-20240806095855585582992.jpg 13. IMG-20240806095957595797457.jpg Building: Valdez Marine Terminal/Central Accumulation Area (CAA)/WS3b Observation #: JJ1-OB-002 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator Dan Gilson led us to three waste storage containers. In Waste Storage 03b (WS3b) unit there was a large "Red Box" where all the hazardous waste is stored. The box was labeled "hazardous waste" and contained waste paint cans. The box was missing a hazard indicator. Dan Gilson marked the hazard indicator at the time of the inspection. Photo(s) 1. IMG-2024080610034434493087.jpg 2. IMG-2024080610035035086710.jpg 3. IMG-2024080610035635691139.jpg 4. IMG-2024080610090999102366.jpg Building: Valdez Marine Terminal/Central Accumulation Area (CAA)/WS1b Observation #: JJ1-OB-003 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator In Waste Storage 01b (WST1b) there was no hazardous or universal waste currently accumulated. There were no AOC's identified. 6 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Building: Valdez Marine Terminal/Central Accumulation Area (CAA)/WS2b Observation #: JJ1-OB-004 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator In Waste Storage 02b (WST2b) we observed waste aerosol cans and compressed gas cylinders. There were no AOC's identified. Building: Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank/CAA Observation #: JJ1-OB-005 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed a 55-gallon hazardous waste storage container of Stripper Sludge was not marked with a hazard indicator. Dan Gilson added the hazard indicator at the time of the inspection. Additionally, we observed a 55-gallon drum that was marked with a hazardous waste label. Dan Gilson stated that this drum was not hazardous waste, but rather diesel contaminated soil that was going to be put into the contaminated soil stockpile per allowance from ADEC. Photo(s) 1. IMG-202408061024332433113802.jpg 2. IMG-20240806102441244187972.jpg 3. IMG-20240806102540254086306.jpg 4. IMG-2024080610260126186861.jpg 5. IMG-202408061029462946106801.jpg 6. IMG-20240806102950295098246.jpg Building: Valdez Marine Terminal/Power Vapor/UW Accumulation Observation #: JJ1-OB-006 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed the Universal Waste storage areas which included batteries, aerosol cans, bulbs, and an SAA container of waste leather gloves. There were no AOCs observed. Building: Valdez Marine Terminal/Contaminated soil stockpile Observation #: JJ1-OB-007 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed the contaminated soil stockpile. Dan Gilson informed us that it is used for petroleum oils and lubricates that are non-hazardous. Additionally, Dan Gilson stated that the area's water runoff goes through their wastewater treatment facility. There were no AOCs observed. Photo(s) 1. IMG-202408061105015197774.jpg Building: Valdez Marine Terminal/East Tank Farm 7 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Observation #: JJ1-OB-008 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator During the inspection, while driving around the facility, I had Mr. Gilson stop the vehicle while we were in the area of last tank clean out, at Tank #8, that occurred back in May or June of 2023. While there, I told Mr. Gilson that I was aware of an EPA CID visit to the VMT regarding a complaint. Mr. Gilson told me that CID came out to investigate a complaint earlier in April of 2024. While I was viewing the area around Tank #8, from the vehicle, I asked Mr. Gilson to describe the tanks cleanout process. Mr. Gilson told me the following: Crude oil is pumped from the storage tank, drawing the oil level down as low as possible, and sent to an oil tanker vessel. 5 - 8K are sucked out of the storage tank with hoses and put into a couple of frac tanks where it is mixed with diesel and put into a slurry. The slurry then goes through a centrifuge with crude oil and diesel During my conversation with Mr. Gilson, I was told that no waste determination was made on the waste tank bottoms prior to going into the TBPU dryer. After the solids go through the TBPU dryer, a waste ash is generated. The waste ash is then shipped offsite to the Republic Moose Creek landfill. Mr. Gilson said that Alyeska made a waste determination for the waste ash and that the waste ash is not hazardous. Mr. Gilson said that 80 to 90 drums of waste tank bottoms was generated in either 2019 or 2020 due to issues with their contractor and the TBPU dryer being down. He said the waste tank bottoms were tested and determined to be a hazardous waste and were shipped offsite as hazardous waste. At the time of the inspection, Mr. Gilson said that the facility has been using the TBPU dryer since 2010. During the inspection, I asked for documentation (Manifests/LDRs) related to the 2019/2020 event when the waste tank bottoms was shipped out as well as analytical data for both the waste tanks bottoms and the waste ash. Mr. Gilson emailed the information to me on the day of the inspection which is included in the document log of this report. Document(s) 1. VMT HWR 8.28.19 012645739FLE.pdf 2. VMT HWR 8.17.19 012645731 FLE.pdf 3. VMT HWR 8.15.19 012645730 FLE.pdf 4. VMT HWR 8.13.19 012645729 FLE.pdf 5. 141351 Crude Tank Bottoms D018.docx 6. V19-079 TK8 TBP Haz Waste Char ALS Final Report 1194134.pdf 7. Profile 141351 Crude Tank Bottoms.pdf 8. V19-100 Tank 8 TBP Carbon Haz Waste Characterization ALS Final Report 1194201.pdf Photo(s) 1. IMG-2024080611134513452422587.jpg Building: Valdez Marine Terminal/Maintenance shop/SAA Observation #: JJ1-OB-009 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed the SAA for waste leather gloves, as well as their universal waste areas for batteries, bulbs, and aerosol cans. There were no AOCs. 8 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Building: Valdez Marine Terminal/Equipment shop/Area next to oil tank Observation #: JJ1-OB-010 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed a pan that catches used oil from a hose used to transfer the used oil from one container to their used oil tank. This pan contained used oil but was not labeled with the words "used oil". Dan Gilson had the pan marked with the words "Used Oil" at the time of the inspection. Photo(s) 1. IMG-20240806115512551293714.jpg 2. IMG-202408061155185518107964.jpg 3. IMG-20240806115523552380039.jpg 4. IMG-2024080611582358231742580.jpg Building: Valdez Marine Terminal/BWT/SAA Observation #: JJ1-OB-011 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed a 55-gallon hazardous waste storage container of strainer waste that was not marked with a hazard indicator for toxicity. Dan Gilson marked the hazard indicator at the time of the inspection. Photo(s) 1. IMG-20240806131314131485224.jpg 2. IMG-20240806131321132171008.jpg 3. IMG-20240806131344134469635.jpg Building: Valdez Marine Terminal/Lab/SAA Observation #: JJ1-OB-012 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator Upon entering the laboratory building we observed a 5-gallon bucket of hazardous waste leather gloves. The bucket was labeled with the words "hazardous waste" but was missing a hazard indicator. Dan Gilson added the hazard indicator at the time of the inspection. In the lab we observed a 2-gallon container of "BTEX" waste that was labeled "hazardous waste" but was missing a hazard indicator. Additionally, we found a 5-gallon container of "oil and grease waste" that was labeled "hazardous waste" but was missing a hazard indicator. Dan Gilson added hazard indicators to both containers at the time of the inspection. Dan Gilson clarified that the waste oil here was a hazardous waste and was not a used oil. 9 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): Photo(s) 1. IMG-20240806132829282971636.jpg 2. IMG-20240806132837283761176.jpg 3. IMG-20240806132853285363158.jpg 4. IMG-20240806133322332262542.jpg 5. IMG-2024080613350435498722.jpg 6. IMG-2024080613350835860902.jpg 7. IMG-20240806133513351364805.jpg 8. IMG-20240806133519351963684.jpg 9. IMG-20240806133556355670527.jpg 08/06/2024 - 08/06/2024 Building: Valdez Marine Terminal/Emergency Response Building (ERB) Observation #: JJ1-OB-013 Date: 08/06/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator When entering this part of the building we observed a 15-gallon container that held waste aerosol cans. The container was not labeled or marked clearly with any of the following phrases: "Universal Waste-Aerosol Can(s)," "Waste Aerosol Can(s)," or "Used Aerosol Can(s)." Dan Gilson added a "Universal Waste Aerosol Cans" label at the time of the inspection. Additionally, in the "fire team area", an upstairs office, we observed a small bucket that contained two NickleCadmium (NiCad) batteries labeled "universal waste" and had been in accumulation for greater than one year from the date the universal waste was generated of 7/23/23. Dan Gilson removed the batteries at the time of the inspection to be taken to the CAA where they would be picked up by their universal waste contractor. Photo(s) 1. IMG-20240806134023402373008.jpg 2. IMG-20240806134028402863672.jpg 3. IMG-20240806134034403457606.jpg 4. IMG-20240806134544454472410.jpg 5. IMG-20240806134551455165687.jpg 6. IMG-20240806135141514154868.jpg 7. IMG-20240806135150515060802.jpg 8. IMG-2024080613520052052010.jpg Building: Valdez Marine Terminal/Oil Spill Building (OSB) Observation #: JJ1-OB-014 Date: 08/06/2024 Person Interviewed: Dan Gilson No AOCs were identified. Contains AOC: No Contains CBI: No Title: VMT Environmental Coordinator Building: Valdez Marine Terminal/Valdez Fabrication Facility (VFF) Shop/Wood shop Observation #: JJ1-OB-015 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator 10 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 We walked through their wood shop, looking at their SAA for waste leather gloves, and universal waste accumulation of batteries and aerosol cans. We did not identify any AOCs. Building: Valdez Marine Terminal/Valdez Fabrication Facility (VFF) Shop/Metal shop Observation #: JJ1-OB-016 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed their SAA for Brakleen rags and aerosol cans, no AOCs identified. Building: Valdez Marine Terminal/Valdez Fabrication Facility (VFF) Shop/TCC Observation #: JJ1-OB-017 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed the SAA that contained waste Trichloroethylene, there were no AOCs. Dan Gilson also informed us that they have a contractor who handles their oil spill work at the facility. Building: Valdez Marine Terminal/Valdez Fabrication Facility (VFF) Shop/Paint shop Observation #: JJ1-OB-018 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator As we walked through the paint shop, we came upon two 5-gallon buckets of paint that Dan Gilson could not identify whether they were waste or not. Dan Gilson then reached out to the operator of the paint shop who identified the paint as still being utilized and not waste. Therefore, no AOCs were identified. Photo(s) 1. IMG-2024080614330833898491.jpg 2. IMG-2024080614332233222061089.jpg Building: Valdez Marine Terminal/Partner Industrial /Connex Observation #: JJ1-OB-019 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator In the Connex we saw a pallet of part A-hardener. There were no AOCs observed. Photo(s) 1. IMG-202408061443044341821535.jpg Building: Valdez Marine Terminal/Operations Office/SAA Observation #: JJ1-OB-020 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed waste leather gloves and UW batteries. There were no AOCs. Building: Valdez Marine Terminal/Environmental Office/UW accumulation 11 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Observation #: JJ1-OB-021 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We walked through the environmental office and observed their UW including batteries, and bulbs. There were no AOCs identified. Building: Valdez Marine Terminal/Safety office/SAA Observation #: JJ1-OB-022 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We observed a 5-gallon SAA bucket for waste leather gloves. There were no AOCs observed. Building: Valdez Marine Terminal/Medical clinic Observation #: JJ1-OB-023 Date: 08/06/2024 Contains AOC: No Contains CBI: No Person Interviewed: Dan Gilson Title: VMT Environmental Coordinator We inspected the onsite clinic at the facility. According to facility personnel, they do not generate hazardous waste pharmaceuticals. Non-hazardous waste drugs are placed into a drug deactivation container. No AOCs were observed. SECTION III - RECORDS REVIEW Record: Inspections AOC: Yes Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 08/06/2024 After inspecting the last three years of weekly inspections (8/6/21 through 8/6/24), the log was found to be complete with no weeks missed. However, based on the repetitive AOCs identified throughout the inspection, with regard to missing hazard indicators, there is concern that the facility is not conducting adequate inspections due to not catching this issue. We requested that Dan Gilson send us the last five weeks of inspections by email following the inspection. Mr. Gilson emailed the last five inspection logs to me on the day of the inspection. Document(s) 1. 7.7.24 VMT WCIL DG.pdf 2. 7.14.24 VMT WCIL DG.pdf 3. 7.21.24 VMT WCIL MK.pdf 4. 7.28.24 VMT WCIL AB.pdf 5. 8.4.24 VMT WCIL AJ.pdf Record: Waste Determination Documents AOC: No Ref #: JJ1-RR-002 Reviewed By: Jon Jones Reviewed Date: 08/06/2024 During the inspection, I asked Mr. Gilson to send me analytical data for both the waste ash generated in the TBPU dryer and the tank bottoms waste that was generated when the TBPU was not operating. Mr. Gilson emailed the analytical results to me on the day of the inspection. Record: Manifests 12 of 45 AOC: Yes Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Ref #: JJ1-RR-003 Reviewed By: Jon Jones Reviewed Date: 08/06/2024 During the inspection, I asked Mr. Gilson for copies of the manifests for the shipment of waste tank bottoms that were generated back in 2019/2020 when the TBPU was down. Mr. Gilson emailed those manifests to me on the day of the inspection. Following the inspection, I emailed Ms. Gretchen Stoddard, SME, and requested copies of records which is routine, as the bulk of documentation required for LQGs is maintained at their office in Anchorage, AK. My request for these manifests (8/6/21 through 8/6/24), along with other documentation, was sent to the facility on September 19, 2024. In that email, I asked for the documents to be provided on or before October 4, 2024. My request for documents was followed by an email from Alyeska requesting an extension to provide the requested documentation on or before October 18, 2024. I approved the extension. The requested documentation was received from the facility in two batches. Documents were received on October 18, 2024, and additional documentation was received on October 24, 2024. While inspecting the documentation received on October 24, 2024, hazardous waste manifest 013166999FLE, dated 03-21-2022, had not been signed or dated by the designated facility. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Valdez Marine Terminal JJ1-OB-001 Four, 55-gallon containers were not marked with hazard indicators. Area: Central Accumulation Area (CAA) Regulation: Sub-area: Pole Barn Sections: Building: Valdez Marine Terminal JJ1-OB-001 Area: Central Accumulation Area (CAA) Sub-area: Pole Barn One, 55-gallon container of Regulation: recovered crude strainer waste was not marked with a hazard indicator. Sections: Building: Valdez Marine Terminal JJ1-OB-002 Area: Central Accumulation Area (CAA) Sub-area: WS3b Large "Red Box" containing hazardous waste paint was not marked with a hazard indicator. Regulation: Sections: Building: Valdez Marine Terminal JJ1-OB-005 Area: Ballast Water Treatment (BWT) Sludge tank Sub-area: CAA 13 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 A 55-gallon hazardous waste storage Regulation: container of Stripper Sludge was not marked with a hazard indicator. Sections: Dan Gilson marked the container with hazard indicator at the time of the inspection. Building: Valdez Marine Terminal JJ1-OB-010 Area: Equipment shop Sub-area: Area next to oil tank Catch pan that held used oil was not Regulation: labeled with the words "used oil". Sections: Building: Valdez Marine Terminal JJ1-OB-011 Area: BWT Sub-area: SAA 55-gallon hazardous waste storage container of strainer waste was not marked with a hazard indicator for toxicity. Regulation: Sections: Building: Valdez Marine Terminal JJ1-OB-012 Area: Lab Sub-area: SAA 5-gallon bucket of hazardous waste Regulation: leather gloves was not marked with a hazard indicator. Sections: Building: Valdez Marine Terminal JJ1-OB-012 Area: Lab Sub-area: SAA 2-gallon container of "BTEX" waste that was not marked with a hazard indicator. Regulation: Sections: Building: Valdez Marine Terminal JJ1-OB-012 Area: Lab Sub-area: 5-gallon container of "oil and grease Regulation: waste" was not marked with a hazard indicator. Sections: Building: Valdez Marine Terminal JJ1-OB-013 Area: Emergency Response Building Sub-area: (ERB) 14 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 15-gallon container that held waste aerosol cans was not labeled or marked clearly with any of the following phrases: "Universal Waste-Aerosol Can(s)," "Waste Aerosol Can(s)," or "Used Aerosol Can(s)." Regulation: Sections: Building: Valdez Marine Terminal JJ1-OB-013 Area: Emergency Response Building Sub-area: Upstairs Office (ERB) Small bucket that contained two waste NiCad batteries and was labeled "Universal Waste" and dated 7/23/23 had been in accumulation for greater than one year from the date the universal waste was generated. Regulation: Sections: Building: Valdez Marine Terminal JJ1-OB-008 Possible treatment of hazardous waste without a permit. Area: East Tank Farm Regulation: Sub-area: Sections: Record: Inspections JJ1-RR-001 Not conducting adequate inspections. Regulation: Sections: Record: Inspections JJ1-RR-003 Manifest 013166999FLE was not signed or dated by the designated facility. Regulation: Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP 15 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Closing Conference At the close of the inspection, we reconvened with Dan Gilson VMT Environmental Coordinator, Klint VanWingerden VMT Director, Weston Branshaw Operations Manager, and were joined by Gretchen Stoddard Waste Management SME to conduct the closing conference. I thanked them for their time and cooperation during the inspection and began the review of the areas of concern identified during the inspection which are included in Section IV of this report. Additionally, I told Ms. Stoddard that I would send her an email requesting documents. I explained the process that would take place once the final report was finished and submitted. Finally, I explained that they would receive a copy of the report, as would a case officer. We answered any questions they had and departed the facility at 4:45 pm. Follow Up I sent a request for documentation email, via the Go Anywhere platform, to Ms. Stoddard on 9/16/24 requesting the following information: 1. Copies of hazardous waste manifests, LDRs, and any applicable exception reports for the last three years, covering the period from August 6, 2021, through August 6, 2024. 2. A copy of the facility's Training Plan and/or training provided to VMT personnel and training records for VMT personnel that manage hazardous and universal waste. 3. Copies of job titles for positions related to hazardous waste management and the name of the employee filling each job, written job description for each position, and written description of type and amount of both introductory and continuing training. 4. Copies of any emergency responder agreements. 5. A copy of the VMT Hazardous Waste Contingency Plan and Quick Reference Guide. 6. A map and/or drawing of the tanks located at your facility where tank bottoms are generated during periodic tank clean-outs. 7. A list of those tanks, their identification number, as well as each tanks capacity and clean-out schedule. 8. For the tanks identified in question 7, please provide information on each tank's clean-out since the VMT started processing tank bottoms to include: - Dates of each tank clean-out and quantity of tank bottoms generated during each clean-out. - Total amount of tank bottoms generated and/or processed on-site. - Name of Contractor, contact information, and name of contractor point-of-contact that processed the tank bottoms on-site. - Total amount of ash generated as a result of processing as well as disposal paperwork associated with the ash. Please also include copies of manifests and/or bill of lading, waste profiles and/or analytical results, and shipping company and disposal location contact information. 9. Please also provide the following information regarding the VMT's Tank Bottoms Processing: - The date that Alyeska's VMT commenced on-site Tank Bottoms Processing. - Documentation and records of Alyeska's decision to initiate Tank Bottoms Processing at the VMT, and at what level was this decision made? Please also provide copies of any internal email traffic regarding the decision to initiate Tank Bottoms Processing at the VMT. Please provide this documentation and/or information on or before October 4, 2024. Please contact me if you have any questions or require additional time to provide the requested information. 16 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 This was followed by a Teams meeting requested by Ms. Stoddard and Mr. Jan Shifflett, Alyeska Environmental Manager, to discuss the requested information in items #8 and #9 listed above. During the Teams meeting, Mr. Shifflett talked about the TBPU and its operation. During the discussion, Mr. Shifflett said that the operation of the TBPU actually started around 2002. He said that an EPA inspection was conducted in 2004 and following the inspection, an EPA information request was sent to the Alyeska VMT. Mr. Shifflett and Ms. Stoddard indicated that my requests in #8 and #9 above would be labor intensive and that some of the requested information may no longer exist. Mr. Shifflett asked if they could provide the information from the 2005 information request in lieu of the information requested in items #8 and #9. Mr. Shifflett said he thought their response to the previous information request contained most of the information that I was requesting. I told them that I would be willing to do that, but indicated that after the review of the information, the items in #8 and #9 may still need to be provided. The information requested was provided by the facility in emails dated October 18, 2024, and October 24, 2024. This requested information was received after this inspection report was completed and is not included in the Document Log of this report. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 17 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): APPENDIX 1: PHOTO LOG 08/06/2024 - 08/06/2024 Pole Barn: Four 55-gal Drums Missing Hazard Indicators IMG-20240806095002502137897.jpg 08/06/2024 09:50 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458709, -146.35951232 No hazard indicators on these four 55-gallon drums of hazardous waste, located at the Pole Barn. Drum 1: 55-gal Drum of Isocyanates IMG-2024080609500850869111.jpg 08/06/2024 09:50 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458709, -146.35951232 No hazard indicator on 55-gallon Drum 1 of Isocyanates. 18 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Drum 2: 55-gal Drum of Isocyanates IMG-20240806095015501585344.jpg 08/06/2024 09:50 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458421, -146.35950731 No hazard indicator on 55-gallon Drum 2 of Isocyanates. 55-gal Drum of C-Boiler Refractory Debris IMG-202408060950485048100511.jpg 08/06/2024 09:50 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458456, -146.35950835 No hazard indicator on 55-gallon drum of C- Boiler Refractory Debris. Holding for test results. 19 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 55-gal Drum of Amines 08/06/2024 09:51 AM (AKT) No CBI No PII Valdez Marine Terminal/Central Accumulation Area (CAA) No hazard indicator on 55-gallon drum of Amines. IMG-2024080609510651678956.jpg Photographer: Jon Jones 61.08458456, -146.35950835 55-gal Drum of Crude Strainer Waste IMG-202408060955535553129449.jpg 08/06/2024 09:55 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458388, -146.359508 No hazard indicator for one 55-gallon drum of crude strainer waste. 20 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Crude Strainer Waste Label: Missing Hazard Indicator IMG-20240806095600560107089.jpg 08/06/2024 09:56 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458388, -146.359508 No hazard indicator on label of 55-gallon drum of crude strainer waste. Back of 55-gal Drum of Crude Strainer Waste IMG-20240806095609569119898.jpg 08/06/2024 09:56 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458388, -146.359508 Additional picture showing that there was no hazard indicator on the 55-gallon drum of crude strainer waste. 21 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Hazard Indicator for Crude Strainer Waste Drum Marked IMG-202408060957445744111643.jpg 08/06/2024 09:57 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458414, -146.35950806 Missing hazard indicator marked at time of inspection by Dan Gilson. Hazard Indicator for Drum 1 of Isocyanates Marked IMG-20240806095838583874527.jpg 08/06/2024 09:58 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458414, -146.35950806 Missing hazard indicator added at time of inspection by Dan Gilson. 22 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Hazard Indicator for Drum 2 of Isocyanates Marked IMG-20240806095846584680151.jpg 08/06/2024 09:58 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458414, -146.35950806 Missing hazard indicator added at time of inspection by Dan Gilson. Hazard Indicator for Amines Drum Marked IMG-20240806095855585582992.jpg 08/06/2024 09:58 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458414, -146.35950806 Missing hazard indicator added at time of inspection by Dan Gilson. 23 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Hazard indicator for C-Boiler Refractory Debris Drum Marked IMG-20240806095957595797457.jpg 08/06/2024 09:59 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.0845782, -146.35950308 Missing hazard indicator added at time of inspection by Dan Gilson. Red Box in Waste Storage 03 IMG-2024080610034434493087.jpg 08/06/2024 10:03 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458964, -146.35951232 Hazardous waste storage box in with no hazard indicator. 24 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Label on Red Box in Waste Storage 03 IMG-2024080610035035086710.jpg 08/06/2024 10:03 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458964, -146.35951232 Hazard indicator missing on Red Box in Waste Storage 03. Hazardous Waste Label on Red Box IMG-2024080610035635691139.jpg 08/06/2024 10:03 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458964, -146.35951232 Label on Red Box in Waste Storage 03 missing hazard indicator. 25 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Hazardous Waste Indication on Red Box Marked IMG-2024080610090999102366.jpg 08/06/2024 10:09 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458964, -146.35951232 Hazard indicator on Red Box in Waste Storage 03 added at time of inspection. Organization Photo of Waste Storage Containers IMG-2024080610095595556382.jpg 08/06/2024 10:09 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Central Accumulation Area (CAA) 61.08458964, -146.35951232 Photo of the organization and labeling of the Waste Storage Containers Located at the CAA. 26 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 55-gal Drum of Stripper Sludge IMG-202408061024332433113802.jpg 08/06/2024 10:24 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank 61.08458963, -146.35951232 55-gallon hazardous waste storage container of stripper sludge was not marked with a hazard indicator. Stripper Sludge Label Missing Hazard Indicator IMG-20240806102441244187972.jpg 08/06/2024 10:24 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank 61.08458963, -146.35951232 55-gallon hazardous waste storage container of stripper sludge was not marked with a hazard indicator. 27 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Stripper Sludge Label with Hazard Indicator 08/06/2024 10:25 AM (AKT) No CBI No PII Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank Hazard Indicator added at time of inspection. IMG-20240806102540254086306.jpg Photographer: Jon Jones 61.08458963, -146.35951232 Stripper Sludge Label with Hazard Indicator Marked 08/06/2024 10:26 AM (AKT) No CBI No PII Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank Hazard indicator added at time of the inspection. IMG-2024080610260126186861.jpg Photographer: Jon Jones 61.08458963, -146.35951232 28 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 55-gal Container of Non-Hazardous Waste IMG-202408061029462946106801.jpg 08/06/2024 10:29 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank 61.08458963, -146.35951232 55-gallon container of non-hazardous, diesel contaminated soil. Mislabeled as hazardous waste. 55-gal Container of Non-Hazardous Waste Label IMG-20240806102950295098246.jpg 08/06/2024 10:29 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Ballast Water Treatment (BWT) Sludge tank 61.08458963, -146.35951232 55-gallon container of non-hazardous, diesel contaminated soil. Mislabeled as hazardous waste. 29 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Contaminated Soil Stockpile IMG-202408061105015197774.jpg 08/06/2024 11:05 AM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Contaminated soil stockpile 61.08154551, -146.39286804 Photo of the contaminated soil stockpile that ADEC approved. East Tank Farm, Tank 18 08/06/2024 11:13 AM (AKT) No CBI No PII Valdez Marine Terminal/East Tank Farm Area of last tank clean out back in May/ June of 2023. IMG-2024080611134513452422587.jpg Photographer: Jon Jones 61.0815455, -146.39286804 30 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Unlabeled Catch Pan Containing Used Oil 08/06/2024 11:55 AM (AKT) No CBI Valdez Marine Terminal/Equipment shop Pan not labeled with the words "used oil". No PII IMG-20240806115512551293714.jpg Photographer: Jon Jones 61.08456474, -146.35956195 Unlabeled Catch Pan Containing Used Oil 08/06/2024 11:55 AM (AKT) No CBI Valdez Marine Terminal/Equipment shop No PII Pan not labeled with the words "used oil". IMG-202408061155185518107964.jpg Photographer: Jon Jones 61.08456412, -146.35956421 31 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Unlabeled Catch Pan Containing Used Oil 08/06/2024 11:55 AM (AKT) No CBI Valdez Marine Terminal/Equipment shop Pan not labeled with the words "used oil". No PII IMG-20240806115523552380039.jpg Photographer: Jon Jones 61.08456698, -146.35954904 Used Oil Pan with Label 08/06/2024 11:58 AM (AKT) No CBI No PII Valdez Marine Terminal/Equipment shop Used oil label added at the time of the inspection. IMG-2024080611582358231742580.jpg Photographer: Jon Jones 61.08456423, -146.35956523 32 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Strainer Waste Label Missing Hazard Indicator IMG-20240806131314131485224.jpg 08/06/2024 01:13 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/BWT 61.08458158, -146.35950666 55-gallon hazardous waste storage container of strainer waste was not marked with a hazard indicator for toxicity. Strainer Waste Label Missing Hazard Indicator IMG-20240806131321132171008.jpg 08/06/2024 01:13 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/BWT 61.08458158, -146.35950666 55-gallon hazardous waste storage container of strainer waste was not marked with a hazard indicator for toxicity. 33 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Strainer Waste Label with Hazard Indicator IMG-20240806131344134469635.jpg 08/06/2024 01:13 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/BWT 61.08458158, -146.35950666 55-gallon hazardous waste storage container of strainer waste now marked with a hazard indicator for toxicity. Waste Leather Gloves Label Missing Hazard Indicator IMG-20240806132829282971636.jpg 08/06/2024 01:28 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458975, -146.39194729 5-gallon hazardous waste storage container of leather gloves was not marked with a hazard indicator. 34 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Waste Leather Gloves Label Missing Hazard Indicator IMG-20240806132837283761176.jpg 08/06/2024 01:28 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458965, -146.39194742 5-gallon hazardous waste storage container of leather gloves was not marked with a hazard indicator. Waste Leather Gloves Label Missing Hazard Indicator IMG-20240806132853285363158.jpg 08/06/2024 01:28 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458072, -146.39152947 5-gallon hazardous waste storage container of leather gloves was not marked with a hazard indicator. 35 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Waste Leather Gloves Label with Hazard Indicator IMG-20240806133322332262542.jpg 08/06/2024 01:33 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458976, -146.39195025 5-gallon hazardous waste SAA container of leather gloves labeled with a hazard indicator at time of the inspection. BTEX and Waste Oil Labels Missing Hazard Indicators IMG-2024080613350435498722.jpg 08/06/2024 01:35 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458963, -146.39194742 2-gallon container of "BTEX" waste that was labeled "hazardous waste" but was missing a hazard indicator. 5gallon container of "oil and grease waste" that was labeled "hazardous waste" but was missing a hazard indicator. 36 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 BTEX and Waste Oil Labels Missing Hazard Indicators IMG-2024080613350835860902.jpg 08/06/2024 01:35 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458963, -146.39194743 2-gallon container of "BTEX" waste that was labeled "hazardous waste" but was missing a hazard indicator. 5gallon container of "oil and grease waste" that was labeled "hazardous waste" but was missing a hazard indicator. Waste Oil and Grease Label Missing Hazard Indicator IMG-20240806133513351364805.jpg 08/06/2024 01:35 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458964, -146.39194745 5-gallon container of "oil and grease waste" that was labeled "hazardous waste" but was missing a hazard indicator. 37 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 BTEX Label Missing Hazard Indicator IMG-20240806133519351963684.jpg 08/06/2024 01:35 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458964, -146.39194744 2-gallon container of "BTEX" waste that was labeled "hazardous waste" but was missing a hazard indicator. BTEX and Waste Oil Labels with Hazard Indicators IMG-20240806133556355670527.jpg 08/06/2024 01:35 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Lab 61.08458964, -146.39194744 2-gallon container of "BTEX" waste that was labeled "hazardous waste" with added hazard indicator. 5-gallon container of "oil and grease waste" that was labeled "hazardous waste" with added hazard indicator. Hazard Indicators added at time of the inspection. 38 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Unlabeled 15-gal Container of Waste Aerosol Cans IMG-20240806134023402373008.jpg 08/06/2024 01:40 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.08458905, -146.39195369 (ERB) Waste aerosol step-can in which the aerosol cans are contained was not labeled or marked clearly with any of the following phrases: "Universal Waste-Aerosol Can(s)," "Waste Aerosol Can(s)," or "Used Aerosol Can(s)." Unlabeled 15-gal Container of Waste Aerosol Cans IMG-20240806134028402863672.jpg 08/06/2024 01:40 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.0845897, -146.39194758 (ERB) Top-down view of waste aerosol step-can in which the aerosol cans are contained was not labeled or marked clearly with any of the following phrases: "Universal Waste-Aerosol Can(s)," "Waste Aerosol Can(s)," or "Used Aerosol Can(s)." 39 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Waste Aerosol Cans in 15-gal Container 08/06/2024 01:40 PM (AKT) No CBI No PII Valdez Marine Terminal/Emergency Response Building (ERB) View of the waste aerosol cans in the step-can. IMG-20240806134034403457606.jpg Photographer: Jon Jones 61.0845897, -146.39194758 Universal Waste Aerosol Cans with Label IMG-20240806134544454472410.jpg 08/06/2024 01:45 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.084589, -146.39195261 (ERB) Universal Waste Label added by Dan Gilson at time of the inspection. 40 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Universal Waste Aerosol Cans with Label IMG-20240806134551455165687.jpg 08/06/2024 01:45 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.084589, -146.39195261 (ERB) Close-up view of Universal Waste Label added by Dan Gilson at time of the inspection. UW Battery container > One Year Accumulation IMG-20240806135141514154868.jpg 08/06/2024 01:51 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.08456326, -146.39081432 (ERB) A small container that held two universal waste NiCad batteries has been in accumulation for greater than one year from the date the universal waste was generated on 7/23/23. 41 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 UW Battery container > One Year Accumulation IMG-20240806135150515060802.jpg 08/06/2024 01:51 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.08456326, -146.39081432 (ERB) Close-up view of container that held two universal waste NiCad batteries has been in accumulation for greater than one year from the date the universal waste was generated on 7/23/23. UW Battery container > One Year Accumulation IMG-2024080613520052052010.jpg 08/06/2024 01:52 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Emergency Response Building 61.08456326, -146.39081432 (ERB) A small container that held two universal waste NiCad batteries has been in accumulation for greater than one year from the date the universal waste was generated on 7/23/23. 42 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Two, 5-gal Buckets of Paint IMG-2024080614330833898491.jpg 08/06/2024 02:33 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Valdez Fabrication Facility (VFF) Shop 61.0803426, -146.36400856 View of two, 5-gallon buckets of paint that were still being utilized by the paint crew and were not waste. Two, 5-gal Buckets of Paint IMG-2024080614332233222061089.jpg 08/06/2024 02:33 PM (AKT) No CBI No PII Photographer: Jon Jones Valdez Marine Terminal/Valdez Fabrication Facility (VFF) Shop 61.0803426, -146.36400856 Close-up view of two, 5-gallon buckets of paint that were still being utilized by the paint crew and were not waste. 43 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 Pallet of Part-A Hardner 08/06/2024 02:43 PM (AKT) No CBI Valdez Marine Terminal/Partner Industrial View of the pallet of part-A hardener. No PII IMG-202408061443044341821535.jpg Photographer: Jon Jones 61.0803426, -146.36400858 44 of 45 Alyeska Taps Valdez Marine Terminal Inspection Date(s): 08/06/2024 - 08/06/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Manifests VMT HWR 8.28.19 No No Jon Jones 012645739FLE.pdf Manifests VMT HWR 8.17.19 No No Jon Jones 012645731 FLE.pdf Manifests VMT HWR 8.15.19 No No Jon Jones 012645730 FLE.pdf Manifests VMT HWR 8.13.19 No No Jon Jones 012645729 FLE.pdf Land Disposal Restriction 141351 Crude Tank No No Jon Jones Bottoms D018.docx Sampling Results V19-079 TK8 TBP Haz No No Jon Jones Waste Char ALS Final Report 1194134.pdf Waste Determinations Profile 141351 Crude No No Jon Jones Tank Bottoms.pdf Waste Determinations V19-100 Tank 8 TBP No No Jon Jones Carbon Haz Waste Characterization ALS Final Report 1194201.pdf Records Review 7.7.24 VMT WCIL No No Jon Jones DG.pdf Records Review 7.14.24 VMT WCIL No No Jon Jones DG.pdf Records Review 7.21.24 VMT WCIL No No Jon Jones MK.pdf Records Review 7.28.24 VMT WCIL No No Jon Jones AB.pdf Records Review 8.4.24 VMT WCIL AJ.pdf No No Jon Jones Communications RCRA Waste Inspection No No Jon Jones Documents Request - 8- 6-24.msg 08/06/2024 08/06/2024 08/062024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 08/06/2024 45 of 45