Document 7R8Ln8BMxK2yV1rg1B3jxeve8
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA Region 10 Enforcement Division INSPECTION REPORT
10/19/2022 09:44 AM (PT)
Announced: No
10/19/2022 01:00 PM (PT)
Access: Granted
RCRA
CEI - Compliance Evaluation Inspection
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
Western Washington University (WWU)
WWU Physical Plant WAD981763030
915 26Th St
Bellingham, WA 98225 Whatcom
Very Small Quantity Generator (VSQG)
611310 - Colleges, Universities, and Professional Schools
University 48.72492, -122.48354
Grant Whitman, MPH whitmag2@wwu.edu Laboratory Safety Consultant, Interim Hazardous Waste Contact Environmental Health and Safety Western Washington University CS132A, MS 9070 2001 Bill McDonald Parkway, Bellingham, WA 98225 (360) 650-4064 Bellingham, WA 98225
Permit Number (If Applicable) Not Applicable
Lead Inspector: Jon Jones
JONATHAN JONES
EPA Region 10
Digitally signed by JONATHAN JONES Date: 2023.02.07 12:17:32 -09'00'
Jones.Jon@epa.gov
(907) 271-6329
Supervisor Review: Jen Sullivan
Jennifer A Sullivan EPA Region 10
Digitally signed by Jennifer A Sullivan Date: 2023.02.08 08:54:38 -08'00'
Sullivan.Jennifer.A@epa.gov
(206) 553-6978
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI - Compliance Evaluation Inspection
This report is based on information supplied by WWU Physical Plant 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 and/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
Hazardous Waste Manager/WWU /WWU
Gary Carlton
Laboratory Safety Grant Whitman Consultant, Interim Hazardous Waste Contact/WWU /WWU
Inspector/Ecology Chris Teske /Ecology
Phone (907) 271-6329 (360) 650-6527 (360) 650-4064
(360) 255-4384
Email
Opening Conf.
Jones.Jon@epa.gov Yes
carltog@wwu.edu Yes
whitmag2@wwu.edu Yes
ctes461@ecy.wa.gov Yes
Closing Conf. Yes Yes No
Yes
Opening Conference
EPA Region 10 Lead Inspector, Jon Jones, arrived at the WWU Physical Plant Facility (the "Site" or "Facility"), located at 915 26Th St, Bellingham, WA 98225, at 09:44 AM (PT) on 10/19/2022 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Gary Carlton that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA).
Facility/Site Information
Weather Conditions Cloudy and gray
Safety Training
No
Provided to
Inspector(s)?
What type of generator facility notified?
Very Small Quantity Generator (VSQG)
What type of generator facility verified as?
Verified VSQG by Mr. Carlton
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
Weather Conditions Day 1 - Cloudy and gray
Process Description During the opening conference, Mr. Carlton provided the following information:
Universal waste lamps and batteries generated on the main campus are taken to WWUs off-site Physical Plant.
The Paint Shop generates waste paints, thinners, and aerosol can waste.
Building(s) Building/Area/Sub-area Marshaling Yard Universal waste accumulation area Physical Plant
Loading dock area adjacent to the Physical Plant Room 203A - Paint Shop
Process Description Universal waste lamp accumulation Accumulation of universal waste lamps Maintenance operations that include painting and a paint booth. Waste aerosol can popping area.
Area of Concern Yes Yes Yes
Yes
Painting operations and paint booth
No
SECTION II - OBSERVATIONS
Building: Marshaling Yard/Universal waste accumulation area
Observation #: JJ1-OB-001 Date: 01/25/2023
Contains AOC: Yes
Contains CBI: No
Person Interviewed: Gary Carlton
Title: Hazardous Waste Manager/WWU
While inspecting the universal waste lamp accumulation area, we observed the following:
A container, of universal waste lamps, dated 11/25/19, that had been in accumulation for greater than one year.
A container of four-foot universal waste lamps that was not closed. The container was also dated 7/8/21 and had been in accumulation for greater than one year.
There were approximately 13 containers of universal waste lamps, among approximately 65+ containers, that were not closed and at least one of the 13 containers was not labeled with either the words "Universal Waste - Lamp(s)," "Waste - Lamp(s)," or "Used - Lamp(s)."
Several of the universal waste lamp containers were buried beneath other containers and we were unable to see if they were closed and dated. Training provided to WWU personnel that manage universal waste states that universal waste containers will be dated.
The facility responded with information and photo documentation by way of SharePoint on 11/2/22. The information received indicated that universal waste lamp containers were closed, labeled, and shipped for disposal on 11/9/22.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
Photo(s) 1. IMG_0361.jpg 2. IMG_0362.jpg 3. IMG_0363.jpg 4. IMG_0364.jpg 5. IMG_0365.jpg 6. IMG_0366.jpg 7. IMG_0367.jpg 8. IMG_0368.jpg 9. IMG_0369.jpg
10. IMG_0370.jpg 11. IMG_0371.jpg 12. IMG_0372.jpg 13. IMG_0373.jpg 14. IMG_0374.jpg 15. IMG_0375.jpg 16. IMG_0376.jpg 17. IMG_0377.jpg 18. IMG_0378.jpg 19. IMG_0379.jpg 20. IMG_0380.jpg
Building: Physical Plant/Loading dock area adjacent to the Physical Plant
Observation #: JJ1-OB-002 Date: 10/19/2022
Contains AOC: Yes
Contains CBI: No
Person Interviewed: Gary Carlton
Title: Hazardous Waste Manager
At the time of the inspection, we observed that the waste aerosol can popping process was not capturing all the waste aerosol can residue as there was evidence of overspray on both the dock area and the outside wall of the Physical Plant, adjacent to and around the bottom of the waste container that was equipped with the attached aerosol can popping device. It was unclear as to whether the overspray was due to improper use of the can popping device or lack of maintenance on the device.
Photo(s) 1. IMG_0333.jpg 2. IMG_0334.jpg 3. IMG_0335.jpg 4. IMG_0346.jpg 5. IMG_0347.jpg
SECTION III - RECORDS REVIEW Record: Personnel Training
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AOC: No
Western Washington University Physical Plant Inspection Date(s): 10/19/2022
Ref #: JJ1-RR-001
Reviewed By: Jon Jones
Reviewed Date: 10/19/2022
A review of the training records indicated that WWU personnel managing universal waste lamps had received both hazardous waste and universal waste training.
No other records were reviewed, as the WWU Physical Plant is a VSQG.
SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation.
Building: Marshaling Yard JJ1-OB-001
Area: Universal waste accumulation Sub-area: area
While inspecting the universal waste Citations: lamp accumulation area, we observed the following:
Sections:
A container, of universal waste lamps, dated 11/25/19, that had been in accumulation for greater than one year.
A container of four-foot universal waste lamps that was not closed. The container was also dated 7/8/21 and had been in accumulation for greater than one year.
There were approximately 13 containers of universal waste lamps, among approximately 65+ containers, that were not closed and at least one of the 13 containers was not labeled with either the words "Universal Waste Lamp(s)," "Waste - Lamp(s)," or "Used - Lamp(s)."
Building: Physical Plant
Area: Loading dock area adjacent to Sub-area: the Physical Plant
JJ1-OB-002
At the time of the inspection, we observed that the waste aerosol can popping process was not capturing all the waste aerosol can residue as there was evidence of overspray on both the dock area and the outside
Citations:
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Sections:
Western Washington University Physical Plant Inspection Date(s): 10/19/2022
wall of the Physical Plant, adjacent to and around the bottom of the waste container that was equipped with the attached aerosol can popping device.
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 are determined to be violations. Following the inspection, Mr. Carlton emailed his facility's response to the areas of concern on 11/2/22. The documentation included photos of the corrective action and will be reviewed by an EPA Compliance Officer.
Follow Up N/A
SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted.
SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
APPENDIX 1: PHOTO LOG
[Title]
IMG_0333.jpg
10/19/2022 09:49 AM (PT) No CBI
No PII Photographer: Jon Jones
Physical Plant/Loading dock area adjacent to the Physical Plant
48.7248, -122.48311666
View of the area adjacent to and around the container with the attached waste aerosol can popping device, showing the overspray of waste paints/coatings.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0334.jpg
10/19/2022 09:49 AM (PT) No CBI
No PII Photographer: Jon Jones
Physical Plant/Loading dock area adjacent to the Physical Plant
48.72478888, -122.48313888
Another view of the area adjacent to and around the container with the attached waste aerosol can popping device, showing the overspray of waste paints/coatings.
[Title]
IMG_0335.jpg
10/19/2022 09:49 AM (PT) No CBI
No PII Photographer: Jon Jones
Physical Plant/Loading dock area adjacent to the Physical Plant
48.72475833, -122.48326944
Another view of the area adjacent to and around the container with the attached waste aerosol can popping device, showing the overspray of waste paints/coatings.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0346.jpg
10/19/2022 09:54 AM (PT) No CBI
No PII Photographer: Jon Jones
Physical Plant/Loading dock area adjacent to the Physical Plant
48.72473611, -122.48326111
Another view of the area adjacent to and around the container with the attached waste aerosol can popping device, showing the overspray of waste paints/coatings.
[Title]
IMG_0347.jpg
10/19/2022 09:54 AM (PT) No CBI
No PII Photographer: Jon Jones
Physical Plant/Loading dock area adjacent to the Physical Plant
48.72473888, -122.4832
Another view of the area adjacent to and around the container with the attached waste aerosol can popping device, showing the overspray of waste paints/coatings.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0361.jpg
10/19/2022 10:27 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48162777
View of the universal waste lamp accumulation area, showing that several universal waste lamp containers are not closed.
[Title]
IMG_0362.jpg
10/19/2022 10:27 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72538055, -122.48161944
Another view of the universal waste lamp accumulation area, showing that at least six universal waste lamp containers are not closed.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0363.jpg
10/19/2022 10:33 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72534444, -122.48164444
View of a four-foot universal waste lamp container, seen on the left, that is not closed and an eight-foot universal waste lamp container that has been in accumulation for greater than a year.
[Title]
IMG_0364.jpg
10/19/2022 10:33 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72536944, -122.48164444
Close-up view of the labeling on the universal waste lamp container, showing that the date the first waste lamp went into the container was 11/25/19.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0365.jpg
10/19/2022 10:33 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.725375, -122.48163611
Another close-up view of the label showing the date of 11/25/19.
[Title]
IMG_0366.jpg
10/19/2022 10:33 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.725375, -122.48163611
Another view of the four-foot universal waste lamp container, seen in IMG_0363.jpg, that is not closed.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0367.jpg
10/19/2022 10:33 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72534166, -122.48165
Another close-up view of the same container seen in IMG_0366.jpg.
[Title]
IMG_0368.jpg
10/19/2022 10:34 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48163611
View of the waste lamps in the container seen in IMH_0367.jpg.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0369.jpg
10/19/2022 10:34 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72539166, -122.48161944
Close-up view of the same waste lamps seen in IMG_0368.jpg.
[Title]
IMG_0370.jpg
10/19/2022 10:35 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
View of a four-foot container of universal waste lamps, seen here on the far right of the bottom shelf, that has been in accumulation for greater than a year.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0371.jpg
10/19/2022 10:35 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
A close-up view of the same container seen in IMG_0370.jpg.
[Title]
10/19/2022 10:35 AM (PT) No CBI
No PII
Marshaling Yard/Universal waste accumulation area
Close-up view of the label, showing the date of 7/8/21.
IMG_0372.jpg Photographer: Jon Jones 48.72537222, -122.48164444
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0373.jpg
10/19/2022 10:35 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
Another close-up view of the same container seen in IMG_0372.jpg.
[Title]
IMG_0374.jpg
10/19/2022 10:36 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72534444, -122.48165
Another view of several universal waste lamp containers, first seen in IMG_0361.jpg, that are not closed.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0375.jpg
10/19/2022 10:36 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
View of a universal waste lamp container that is not closed.
[Title]
IMG_0376.jpg
10/19/2022 10:36 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
View of the waste lamps seen inside of the container, first shown in IMG_0375.jpg, that is not closed.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0377.jpg
10/19/2022 10:38 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
View of another universal waste lamp container that is not closed.
[Title]
IMG_0378.jpg
10/19/2022 10:38 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
View of another universal waste lamp container that is not closed.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
[Title]
IMG_0379.jpg
10/19/2022 10:38 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48164444
View of another universal waste lamp container that is not closed.
[Title]
IMG_0380.jpg
10/19/2022 10:38 AM (PT) No CBI
No PII Photographer: Jon Jones
Marshaling Yard/Universal waste accumulation area 48.72537222, -122.48163611
Another view of the same open universal waste lamp container seen in IMG_0379.jpg.
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Western Washington University Physical Plant Inspection Date(s): 10/19/2022
APPENDIX 2: DOCUMENT LOG
Document Type
Document Name
Contains Contains Uploaded By
CBI
PII
Communications Communications Personnel Training
WWU Responses to No
No
Jon Jones
EPA Inspection Findings
11_1_22.pdf
10.19.22 G. Whitman No
No
Jon Jones
email content.docx
UW training slides.pptx No
No
Jon Jones
Date Received 02/01/2023 02/03/2023 02/03/2023
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