Document 7MgwaD7J7oY13EEG3vp1gqNLj

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 03/09/2023 08:30 AM (AKT) Announced: No 03/09/2023 11:39 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 City, State, Zip Code Walmart, Inc. Walmart Supercenter #2722 AKR000200808 537 Johansen Expressway Fairbanks, AK 99701 Fairbanks North Star Borough Small Quantity Generator (SQG) 452311 Warehouse Clubs and Supercenters 64.85813, -147.6915 Mr. Andrew Mierek, Store Manager admiere.s02722.us@wal-mart.com 537 Johansen Expressway Fairbanks, AK 99701 Cc: Mr. Sean Schoephoerster, Asset Protection Operations Coach sps0045.s02722.us@wal-mart.com Mr. Neil Walters, Senior EH&S Manager neil.walters@walmart.com Jamie Huens jamie.huens@walmart.com Mr. Derek Warren, Senior Manager II, EH&S Compliance (Supply Chain) derek.warren@walmart.com Fairbanks, AK 99701 Permit Number (If Applicable) Not Applicable 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 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) 1 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Walmart Supercenter #2722 Facility (the "Site" or "Facility"), located at 537 Johansen Expressway, Fairbanks, AK 99701, at 08:30 AM (AKT) on 03/09/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials and informed Andrew Mierek 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 2023. This report is based on information supplied by Walmart Supercenter #2722 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 Jon Jones REGION 10 Store Andrew Mierek Manager/Walmart, Inc. Hazardous Waste Program Specialist/Alaska Department of Environmental Conservation (ADEC) Ashley Streveler Asset Protection Operations Coach/Walmart, Inc. Sean Schoephoerster Store #4359 Mike Morris Manager/Walmart, Inc. Phone (907) 2716329 (907) 4519900 (907) 2694556 (907) 4519900 Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes admiere.s02722.us@wal- Yes Yes mart.com ashley.streveler@alaska.gov Yes Yes sps0045.s02722.us@wal- No Yes mart.com No Yes Opening Conference Shortly after arriving at Walmart Supercenter #2722, Mr. Andrew Mierek, Store Manager, took me to his office where I held the opening conference. During the opening conference, I explained that the focus of the RCRA inspection was to identify types of wastes 2 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 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 discussed in Section III of this inspection report. Facility/Site Information Number of employees Approximately 350 employees Length of Facility at Location Since 2004 Operating Hours 6:00 am to 11:00 pm, 7 days a week Safety Training No Provided to Inspector(s)? Size of Facility Unknown What type of generator facility notified? Small Quantity Generator (SQG) What type of generator facility verified as? Small Quantity Generator (SQG) verified by facility personnel Weather Conditions Cold and snowy Process Description During the opening conference, Mr. Mierek told me 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. The facility also generates waste aerosol cans and used oil in the Automotive shop. There is an on-site pharmacy that generates hazardous waste pharmaceuticals (HWPharms) and ships potentially creditable pharmaceuticals to a reverse distributor. I was accompanied during the inspection by Mr. Mierek. I looked at the facility's processes, hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. Building(s) Building/Area/Sub-area Main Store Building Automotive Service Basement/Pit Service Bays Pharmacy Receiving Area Central Accumulation Area (CAA) Process Description Area of Concern Yes Generation of waste aerosol cans and used oil Yes Used oil collection from the crushing of used oil Yes filters Waste aerosol can satellite accumulation area (SAA) Yes Generation of hazardous waste pharmaceuticals No Central Accumulation Area (CAA) Yes Accumulation of hazardous wastes and universal Yes wastes 3 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 SECTION II - OBSERVATIONS Building: Main Store Building/Automotive Service/Basement/Pit Observation #: JJ1-OB-001 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While in the Automotive Service area I met with Mr. Paul Woodard, Service Technician. According to Mr. Woodard, he has been employed with Walmart for 12+ years. We went down into the basement/pit beneath the Automotive Service area, and while there, I saw a five-gallon container of used oil that was beneath an oil filter crusher. The container held approximately four to four and a half gallons of used oil. Mr. Woodard also verified the amount of used oil in the container was between four and four and a half gallons. At the time of the inspection, the five-gallon container that held used oil was not labeled with the words, "Used Oil." Mr. Woodard labeled the container with the words "Used Oil" during the inspection. Photo(s) 1. IMG_0629.jpg 2. IMG_0630.jpg Building: Main Store Building/Automotive Service/Basement/Pit Observation #: JJ1-OB-002 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While still inspecting the basement/pit beneath the Automotive Service area, I saw a used oil tank with an attached hydraulic filter crusher. The tank was approximately 50 gallons in size and according to the site gauge on the tank it held a few gallons of used oil. Mr. Woodard stated that it held approximately two gallons of used oil. At the time of the inspection, the tank was not labeled with the words "Used Oil." Mr. Woodard labeled the tank with the words "Used Oil" during the inspection. Photo(s) 1. IMG_0631.jpg 2. IMG_0632.jpg Building: Main Store Building/Automotive Service/Service Bays Observation #: JJ1-OB-003 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While inspecting the service bays in the Automotive Service Department, I saw a cloth hamper that was being used to accumulate aerosol cans. I asked about the aerosol cans and Mr. Woodard told me that they were waste aerosol cans. At the time of the inspection, the waste aerosol cans were not in a closed container, and they were not labeled with the words "Hazardous Waste" or a hazard indicator. At the time of the inspection, waste aerosol cans were being managed as hazardous waste in the facility's CAA. 4 of 25 Walmart Supercenter #2722 Inspection Date(s): Photo(s) 1. IMG_0633.jpg 2. IMG_0634.jpg 3. IMG_0635.jpg 4. IMG_0638.jpg 03/09/2023 - 03/09/2023 Building: Main Store Building/Automotive Service/Service Bays Observation #: JJ1-OB-004 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While I continued to inspect the service bays in the Automotive Service Department, I saw a waste aerosol can of WD-40 lubricant in a trash receptacle. Mr. Woodard removed the waste aerosol can from the trash receptacle and placed it in the cloth hamper with the other waste aerosol cans that had been observed earlier. Photo(s) 1. IMG_0639.jpg Building: Main Store Building/Receiving Area/Central Accumulation Area (CAA) Observation #: JJ1-OB-005 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No I went to the facility's Central Accumulation Area (CAA) and while there I met Ms. Kelly Meeks, Asset Protection Team Lead. While inspecting the wastes being accumulated in the CAA, I saw a small box that was labeled with the words "Lithium Batteries." I asked about the batteries in the box, and I was told by store associates that the box held waste batteries. At the time of the inspection, I saw at least two waste lithium batteries inside of the container. At the time of the inspection, the box containing the waste lithium batteries was not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." Photo(s) 1. IMG_0640.jpg 2. IMG_0641.jpg Building: Main Store Building/Receiving Area/Central Accumulation Area (CAA) Observation #: JJ1-OB-006 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While still in the CAA, I also saw a box that was labeled with the words "Alkaline Batteries." I looked inside the container and saw that there was a button style (Lithium) battery and an AA, Ni-MH (Nickel Metal Hydride) battery mixed in with the alkaline batteries. At the time of the inspection, the container was not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." Photo(s) 1. IMG_0642.jpg 5 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 Building: Main Store Building/Receiving Area/Central Accumulation Area (CAA) Observation #: JJ1-OB-007 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While still inspecting the facility's CAA, I observed several boxes being used to accumulate four-foot and eightfoot waste fluorescent lamps. The waste lamp boxes I observed during the inspection were marked with hazardous waste labels and accumulation start dates. I inquired as to why they were managing the lamps as a hazardous waste and the response I received from store associates was, "How are they supposed to be managed?" I told them that the majority of generators manage their waste lamps as universal waste. I also told them that they were being managed as universal waste during the last inspection that I conducted on 6/20/2013. I explained that they could be managed either as hazardous waste or universal waste. After speaking with Ms. Meeks and the others, regarding the management of waste lamps, I was not convinced that they had a good understanding of either hazardous waste or universal waste management practices. I explained the differences between management as a hazardous waste versus universal waste and then indicated that a waste determination might be required. At the time of the inspection, the box containing the four-foot waste lamps was labeled with the words "Hazardous Waste" and was marked with an accumulation start date of 12/7/22. The box was not marked with a hazard indicator. Due to the lack of a hazard indicator, it was apparent to me that the facility was either not conducting weekly inspections of the CAA or thorough inspections were not being conducted. Store associates marked the box with a hazard indicator of "TOXIC" during the inspection. The eight-foot box being used to accumulate waste lamps was also labeled with the words "Hazardous Waste," but was empty. Photo(s) 1. IMG_0643.jpg 2. IMG_0644.jpg 3. IMG_0645.jpg 4. IMG_0646.jpg 5. IMG_0655.jpg Building: Main Store Building/Receiving Area/Central Accumulation Area (CAA) Observation #: JJ1-OB-008 Date: 03/09/2023 Contains AOC: Yes Person Interviewed: Andrew Mierek Title: Store Manager Contains CBI: No While still inspecting the facility's CAA, I saw a yellow flammable storage cabinet. I opened the cabinet and saw five containers that were being used to accumulate ignitable wastes. Each container had an approximate capacity of five gallons. There were two containers on the top shelf of the cabinet and three containers on the bottom shelf. One of the containers on the bottom shelf was empty. At the time of the inspection, a five-gallon container on the top shelf, being used to accumulate waste alcohol, was not marked with a hazard indicator and a five-gallon container on the bottom shelf, being used to accumulate waste heating oil, was also not marked with a hazard indicator. Due to the lack of a hazard indicator, it was apparent to me that the facility was either not conducting weekly inspections of the CAA or thorough inspections were not being conducted. Store associates marked each of the two containers with the hazard indicator "Ignitable" during the inspection. 6 of 25 Walmart Supercenter #2722 Inspection Date(s): Photo(s) 1. IMG_0650.jpg 2. IMG_0651.jpg 3. IMG_0652.jpg 4. IMG_0653.jpg 5. IMG_0654.jpg 03/09/2023 - 03/09/2023 Building: Main Store Building/Receiving Area Observation #: JJ1-OB-010 Date: 07/21/2023 Person Interviewed: Andrew Mierek Contains AOC: Yes Title: Store Manager Contains CBI: No While viewing the photos taken during the inspection, I saw a black, five-gallon container, holding hazardous waste pharmaceuticals in photo IMG_0647.jpg. The container was marked with a hazardous waste label and the words "Pharmaceutical Hazardous Waste" were written on the label. The container was marked with the date 2/1/23. At the time of the inspection, the container was not labeled with the words "Hazardous Waste Pharmaceuticals." Photo(s) 1. IMG_0647.jpg SECTION III - RECORDS REVIEW Record: Inspections Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/09/2023 During the records review portion of the inspection, I asked to see the facility's weekly hazardous waste inspection logs for the last three years, covering the period from 3/9/20 through 3/9/23. According to Messrs. Mierek and Schoephoerster the inspections logs were in an electronic format. Due to time constraints on the day of the inspection, I asked Messrs. Mierek and Schoephoerster is they could just email the inspection logs to me. Mr. Schoephoerster said that he could send me a copy of the inspection log and said that it was approximately three pages, showing the inspectors name and the date and time of the inspection. I told Messrs. Mierek and Schoephoerster that I would send them an email through a platform that would allow them to drag and drop all of the requested information into a file that could be emailed back to me. On 3/24/23, I sent an email to Mr. Mierek. In that email, I stated "Our email platform for sending/receiving documents is currently not working. So, in the meantime, can you please just email the weekly inspections covering the period of 3/9/23 through 3/9/20. I will figure something out for getting the manifests and get back with you. Let me know if you have any questions. Thank you for your patience." Mr. Mierek responded to my email on 3/24/23, stating "All of this is in the system. The problem I have is the time and size of the file to collect all these. I was hoping you would have a better way of getting this together." The inspection logs were never sent. 7 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 Record: Manifests Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 07/06/2023 On 7/6/23, I emailed the facility's RCRAInfo site contact, Mr. Neil Walters, in an attempt to acquire documentation that I had requested during the 3/9/23 inspection. In that email I expanded that document request to include a copy of the disposal paperwork for the last shipment of waste fluorescent lamps that left facility #2722. In that request, I asked that the information be provided on or before 7/20/23. At the time this inspection report was completed, a copy of the requested disposal paperwork for the last shipment of waste fluorescent lamps that left facility #2722 has not been received. Record: Ensure applicable employees are trained - SQG Ref #: JJ1-RR-003 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 07/06/2023 On 7/6/23, I emailed the facility's site contact, Mr. Neil Walters, in an attempt to acquire documentation that I had requested during the 3/9/23 inspection. In that email I expanded that document request to include copies of training records or training certificates for store associates that manage hazardous waste, universal waste, and hazardous waste pharmaceuticals. In that request, I asked that the information be provided on or before 7/20/23. At the time this inspection report was completed, copies of training records or training certificates for store associates that manage hazardous waste, universal waste, and hazardous waste pharmaceuticals has not been received. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Main Store Building JJ1-OB-001 Area: Automotive Service Sub-area: Basement/Pit Five-gallon container that held used Regulation: oil was not labeled with the words, "Used Oil." Sections: Building: Main Store Building JJ1-OB-002 Area: Automotive Service Sub-area: Basement/Pit Tank containing approximately two- Regulation: gallon of used oil was not labeled with the words "Used Oil." Sections: Building: Main Store Building JJ1-OB-003 Area: Automotive Service Sub-area: Service Bays Waste aerosol cans were not in a Regulation: closed container, and they were not labeled with the words "Hazardous 8 of 25 Sections: Walmart Supercenter #2722 Inspection Date(s): Waste" or a hazard indicator. Building: Main Store Building JJ1-OB-004 Area: Automotive Service Waste aerosol can of WD-40 lubricant was in a trash receptacle. Mr. Woodard removed the waste aerosol can from the trash receptacle and placed it in the cloth hamper with the other waste aerosol cans that had been observed earlier. Regulation: Building: Main Store Building Area: Receiving Area JJ1-OB-005 A box containing waste lithium Regulation: batteries was not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." Building: Main Store Building Area: Receiving Area JJ1-OB-006 A box that was labeled with the words "Alkaline Batteries" also contained a button style (Lithium) battery and an AA, Ni-MH (Nickel Metal Hydride) battery mixed in with the alkaline batteries. The container was not labeled with either the phrase "Universal Waste Batteries," "Waste Batteries," or "Used Batteries." Regulation: Building: Main Store Building Area: Receiving Area JJ1-OB-007 I was not convinced that facility associates had a good understanding of either hazardous waste or universal waste management practices. I explained the differences between Regulation: 9 of 25 03/09/2023 - 03/09/2023 Sub-area: Service Bays Sections: Sub-area: Central Accumulation Area (CAA) Sections: Sub-area: Central Accumulation Area (CAA) Sections: Sub-area: Central Accumulation Area (CAA) Sections: Walmart Supercenter #2722 Inspection Date(s): management as a hazardous waste versus universal waste and then indicated that a waste determination was required for the waste fluorescent lamps. Building: Main Store Building Area: Receiving Area JJ1-OB-008 A five-gallon container on the top shelf of the yellow flammable storage cabinet, being used to accumulate waste alcohol, was not marked with a hazard indicator and a five-gallon container on the bottom shelf, being used to accumulate waste heating oil, was also not marked with a hazard indicator. Regulation: Building: Main Store Building JJ1-OB-010 Area: Receiving Area A black, five-gallon container, holding hazardous waste pharmaceuticals was marked with a hazardous waste label and the words "Pharmaceutical Hazardous Waste" were written on the label. The container was marked with the date 2/1/23. Regulation: At the time of the inspection, the container was not labeled with the words "Hazardous Waste Pharmaceuticals." Record: Inspections JJ1-RR-001 At the time this report was completed, the requested hazardous waste inspection logs for the last three years, covering the period from 3/9/20 through 3/9/23 were not provided. Regulation: Record: Manifests 10 of 25 03/09/2023 - 03/09/2023 Sub-area: Central Accumulation Area (CAA) Sections: Sub-area: Sections: Sections: Walmart Supercenter #2722 Inspection Date(s): JJ1-RR-002 At the time this inspection report was completed, a copy of the requested disposal paperwork for the last shipment of waste fluorescent lamps that left facility #2722 has not been received. Regulation: Record: Ensure Applicable Employees are Trained - SQG JJ1-RR-003 At the time this inspection report was completed, copies of training records or training certificates for store associates that manage hazardous waste, universal waste, and hazardous waste pharmaceuticals has not been received. Regulation: 03/09/2023 - 03/09/2023 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 resulted in determinations of violation. 11 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 Following the Inspection On 7/6/23, I checked RCRAInfo to get the site contact information. I saw that Mr. Neil Walters, Senior EH&S Manager, was the new site contact for the facility. On 7/6/23 I sent an email to Mr. Walters. In that email, I made the following request: "I tried calling you, but a message indicated that you were not receiving calls at this time. I conducted a routine hazardous waste compliance inspection at your #2722 facility in Fairbanks, AK back on 3/9/23. During the inspection, I asked for copies of hazardous waste manifests and weekly hazardous waste inspections logs for the last three years, covering the date range from 3/9/23 back to 3/9/20. As of today, I have still not received this information. Since the inspection, I have reviewed your facility's hazardous waste manifests on EPA's EManifest system in RCRAInfo and no longer need copies of them. I do still need to get copies of the weekly inspection logs as well as some additional documentation. Would you please send me the following documentation: Copies of the weekly hazardous waste inspection logs for the last three years, covering the period from 3/9/23 back to 3/9/20, for facility #2722. A copy of the disposal paperwork for the last shipment of waste fluorescent lamps that left facility #2722. Copies of training records or training certificates for store associates that manage hazardous waste, universal waste, and hazardous waste pharmaceuticals. If the universal waste, and hazardous waste pharmaceuticals training is included in your facility's hazardous waste management training, please include a complete copy of your facility's hazardous waste management training module/slides for review. (Please DO NOT include any Personal Identifiable Information (PII) in this request) Just the name, training, and date of training. Please provide the requested documentation on or before 7/20/23. If you have any questions about the requested documents or if you would like for me to review the areas of concern that were identified on the day of the inspection with you, please contact me at (907) 227-4316." Mr. Walters responded on 7/6/23, stating "Hi Jon, Apologies for the missed call. Adding Jamie Huens to address the ask on our behalf. " On 7/18/23, I received an email from Mr. Derek Warren, Senior Manager II, EH&S Compliance (Supply Chain). In the email he states, "Back on 3-9-2023 you performed an inspection of Walmart facility 2722. I wanted to confirm if all your requests have been met and if you are still waiting on any information. Could you please send me all paperwork related to this, including any reports you issued the store. I responded to his email on 7/18/23, forwarding the email from Mr. Walters which stated, "Adding Jamie Huens to address the ask on our behalf." At the time this report was completed, the requested hazardous waste inspection logs for the last three years, covering the period from 3/9/20 through 3/9/23 as well as the training records and disposal paperwork for waste fluorescent lamps has not been provided. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 12 of 25 Walmart Supercenter #2722 Inspection Date(s): APPENDIX 1: PHOTO LOG 03/09/2023 - 03/09/2023 [Title] IMG_0629.jpg 03/09/2023 08:51 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85624722, -147.68691944 View of a five-gallon container beneath a used oil filter crusher that is being used to accumulate used oil. The container is not labeled with the words "Used Oil." [Title] IMG_0630.jpg 03/09/2023 08:51 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85625555, -147.68710277 Close-up view of the same five-gallon container seen in photo IMG_0629.jpg, showing that it is not labeled with the words "Used Oil." 13 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0631.jpg 03/09/2023 08:53 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85624722, -147.68647777 View of a ~50-gallon used oil storage tank that is attached to a hydraulic used oil filter crusher. The tank is not labeled with the words "Used Oil." [Title] IMG_0632.jpg 03/09/2023 08:53 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85625555, -147.68672222 View of the site glass on the tank seen in photo IMG_0631, showing that the tank contains approximately 2 gallons of used oil. 14 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0633.jpg 03/09/2023 09:07 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85628611, -147.68740833 View of a laundry hamper that is being used to accumulate waste aerosol cans. This view shows that the hamper is not labeled with the words "Hazardous Waste" or a hazard indicator. The hamper is also not closed. [Title] 03/09/2023 09:07 AM No CBI No PII Main Store Building/Automotive Service View of the waste aerosol cans in the laundry hamper. IMG_0634.jpg Photographer: Jon Jones 64.85629166, -147.68736388 15 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0635.jpg 03/09/2023 09:07 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85636944, -147.68745555 Another view of the hamper being used to accumulate waste aerosol cans, showing that it is not closed and labeled with the words "Hazardous Waste" or a hazard indicator. [Title] IMG_0638.jpg 03/09/2023 09:12 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85633055, -147.68748611 View of one of the waste aerosol cans that was being accumulated in the laundry hamper. 16 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0639.jpg 03/09/2023 09:13 AM No CBI No PII Photographer: Jon Jones Main Store Building/Automotive Service 64.85631666, -147.68743888 View of a waste aerosol can in a trash receptacle that held WD-40. [Title] IMG_0640.jpg 03/09/2023 09:29 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85653055, -147.689025 View of the facility's CAA, Showing two cardboard boxes on the shelf above the yellow flammable storage cabinet. 17 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0641.jpg 03/09/2023 09:29 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85636944, -147.68890277 View of the box on the left that is marked with the words "Lithium Batteries." The box seen here is not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." The box of Lithium batteries is also not dated. [Title] IMG_0642.jpg 03/09/2023 09:30 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85665833, -147.68956111 This is a view of the inside of the box that was labeled "Alkaline Batteries" and dated 5/9/22. This view shows that there is also a green AA, Nickel-Metal Hydride battery as well as a button style battery inside the box and it is not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." 18 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0643.jpg 03/09/2023 09:37 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85668055, -147.68975833 View of a box of four-foot waste fluorescent lamps that is labeled with the words "Hazardous Waste" as opposed to being managed as a universal waste. [Title] IMG_0644.jpg 03/09/2023 09:37 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85668055, -147.68975833 Close-up view of the label on the box of four-foot waste fluorescent lamps. 19 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0645.jpg 03/09/2023 09:37 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85658888, -147.68896388 View of the label on a box to be used to accumulate eight-foot waste fluorescent lamps. The box seen here is empty. [Title] IMG_0646.jpg 03/09/2023 09:37 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85658888, -147.68896388 Close-up view of the label on the box for eight-foot waste fluorescent lamps. 20 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0647.jpg 03/09/2023 09:39 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85673611, -147.689225 View of a black, five-gallon container seen at the back, top right of the photo that is marked with a hazardous waste label that contains the words "Pharmaceutical Hazardous Waste" instead of the words "Hazardous Waste Pharmaceuticals." [Title] IMG_0650.jpg 03/09/2023 09:50 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85671111, -147.68946944 View of waste containers seen here inside of the yellow, flammable storage cabinet. 21 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0651.jpg 03/09/2023 09:50 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85661388, -147.68888888 View of a waste container holding Waste alcohol that is not marked with a hazard indicator. [Title] IMG_0652.jpg 03/09/2023 09:50 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85658888, -147.68871944 View of a waste container holding waste heating fuel that is not marked with a hazard indicator. 22 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0653.jpg 03/09/2023 09:54 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85644444, -147.68893333 View of the containers after being marked with the hazard indicator. [Title] IMG_0654.jpg 03/09/2023 09:54 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85644444, -147.68893333 View of the containers after being marked with the hazard indicator. 23 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 [Title] IMG_0655.jpg 03/09/2023 10:01 AM No CBI No PII Photographer: Jon Jones Main Store Building/Receiving Area 64.85656111, -147.68917777 View of the four-foot waste lamp container after facility associates added the word "TOXIC" for a hazard indicator. 24 of 25 Walmart Supercenter #2722 Inspection Date(s): 03/09/2023 - 03/09/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Communications Communications Communications Communications Communications Communications Email from Andrew No No Jon Jones Mierek 3.24.23.msg Email to Neil Walters No No Jon Jones 7.6.23.msg Email from Neil Walters No No Jon Jones 7.6.23.msg Email from Derek No No Jon Jones Warren 7.18.23.msg Email to Andrew No No Jon Jones Mierek 3.24.23.msg Email to Derek Warren No No Jon Jones 7.18.23.msg 07/21/2023 07/21/2023 07/21/2023 07/21/2023 07/21/2023 07/21/2023 25 of 25