Document 7Rb2yjGakO8J5VwzOKenJn8m6

3 Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 07/10/2024 09:03 AM (AKT) Announced: No 07/10/2024 11:31 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 State of Alaska Alaska Department of Environmental Conservation Environmental Health Laboratory (ADEC EHL) AKR000202069 5251 Dr. Martin Luther King Jr. Avenue Anchorage, AK 99507 Anchorage Municipality Small Quantity Generator (SQG) 54138- Testing Laboratory and Services 54194- Veterinary Services Laboratory 61.179085, -149.783761 Patryce McKinney, EHL Chief patryce.mckinney@alaska.gov 5251 Dr. Martin Luther King Jr. Avenue Anchorage, AK 99507 Anchorage, AK 99507 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones Jones, Jon EPA Region 10 Digitally signed by Jones, Jon Date: 2024.10.31 11:03:08 -08'00' Jones.Jon@epa.gov (907) 227-4316 Supervisor Review: Matthew Quarterman MATTHEW QUARTERMAN Date: 2024.12.17 14:39:16 -08'00' Digitally signed by MATTHEW 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) EPA Region 10 Lead Inspector, Jon Jones, arrived at the ADEC Environmental Health Laboratory Facility (the "Site" or "Facility"), located at 5251 Dr. Martin Luther King Jr. Avenue, Anchorage, AK 99507, at 09:03 AM (AKT) on 07/10/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and 1 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 3 07/10/2024 - 07/10/2024 informed Patryce McKinney 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 ADEC Environmental Health Laboratory Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Lead Inspector/EPA REGION 10 Jon Jones RCRA Xiangyu Chu Inspector/Enforcement Officer/EPA Region 10 RCRA Inspector-intraining/ADEC Sable McGovern RCRA Inspector-intraining/ADEC Grace Tapulgo RCRA Inspector-intraining/ADEC Alan Pefley Quality Systems Manager and Safety Officer/ADEC EHL Kelly Snyder Chemist V/ADEC EHL Jacqueline Knue Chief Environmental Health Laboratory/ADEC EHL Patryce McKinney Phone (907) 2716329 (206) 5532859 (907) 2694556 (907) 2697578 (907) 2696277 (907) 3757799 (907) 3758229 (907) 3758200 Email Jones.Jon@epa.gov chu.xiangyu@epa.gov Opening Conf. Yes Yes sable.mcgovern@alaska.gov Yes Grace.tapulgo@alaska.gov Yes Alan.pefley@alaska.gov Yes kelly.snyder@alaska.gov Yes jacqueline.knue@alaska.gov Yes patryce.mckinney@alaska.gov Yes Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Opening Conference After arriving at the facility, Xiangyu Chu, Sable McGovern, Grace Tapulgo, and Alan Pefley and I were met by Jacqueline Knue (Chemist V/ADEC EHL). We presented our credentials, provided Ms. Knue with our business cards, and informed her of the purpose of the inspection. She informed Kelly Snyder (Quality Systems Manager and Safety Officer) and Patryce McKinney (Chief Environmental Health Laboratory) of the inspection as they joined us in a conference room. Once introductions had been made, we began the opening conference. 2 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 3 07/10/2024 - 07/10/2024 During the opening conference, I explained the focus of the RCRA inspection was to identify hazardous waste(s) generated by the facility, as well as the methods of waste management. In addition, I would be reviewing relevant documentation regarding the storage and shipment of hazardous waste. The attendees of the opening conference believed the quantity of hazardous waste produced on site put them into the category of small quantity generator. The site was inspected as such. We were accompanied throughout the inspection by Snyder, Knue, and McKinney. We were not denied access to any part of the facility, and we were allowed to take photographs. Facility/Site Information Operating Hours Length of Facility at Location Number of employees Safety Training Provided to Inspector(s)? Size of Facility What type of generator facility notified? What type of generator facility verified as? Weather Conditions 8:00am-4:30pm Monday through Friday Since 2005 (19 yrs.) 25 No Approximately 23,000 sq. feet Small Quantity Generator (SQG) SQG Partially cloudy Process Description The ADEC Environmental Health Lab performs microbiological and chemical analyses for food, water, shellfish, soils, zoonotic diseases, etc. in support of environmental health programs in the state of Alaska. The site typically manifests two to four shipments of non-acute hazardous waste via US Ecology per year. At the time of the inspection, ADEC EHL employees believed the site was a small quantity generator. Based on our observations of waste generation and the amount of waste on site during the inspection, the facility appeared to be a very small quantity generator that was generating less than 100 kilograms (220 pounds) of hazardous waste during the month of the inspection. According to Ms. Knue, the EHL typically manifests two to four shipments of hazardous waste per year. Data retrieved from RCRAInfo confirms this claim, with no month exceeding 1,000 kg (2,200 pounds) of hazardous waste generation. Waste codes include D001, D002, and D009. Typical hazardous wastes generated include, but are not limited to used oil, waste corrosive liquids (including nitric acid and hydrochloric acid), and waste methanol (from centrifuge tubes). Building(s) Building/Area/Sub-area ADEC Environmental Health Lab Room 162 - Micro media Prep Room 169 - Instrumentation Room 170 - Wet Chemistry Room 177 - Chemical Preparation Room 179 - Chemical Storage (referred to as the Waste Room) Process Description Central Accumulation Area (CAA) - MP waste - Vial acid waste Area of Concern Yes No Yes Yes Yes Yes 3 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 3 - WPS waste - Methylene chloride waste 07/10/2024 - 07/10/2024 SECTION II - OBSERVATIONS Building: ADEC Environmental Health Lab/ Room 179/CAA Observation #: JJ1-OB-001 Date: 07/10/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Patryce McKinney Title: Chief Environmental Health Laboratory Ms. McKinney led us to the hazardous waste storage area in Room 179. She informed us that the site's liquid hazardous wastes were stored on the elevated platform in various container sizes. Several containers in Room 179 were labeled with an internal numerical label, of which the contents were documented in a hazardous waste binder provided by Patryce McKinney. This is how inspectors knew the contents of each container. I observed a partially filled 5-gallon bucket of liquids labeled "Mehg" with an accumulation start date of 8/30/2022. The container was labeled with the words "Hazardous Waste," but was not marked with an indication of the hazards of the contents. I observed a partially filled 55-gallon drum of liquid solvent waste. The drum was not marked with an accumulation start date (ASD). The drum's bunghole was open; therefore, the drum was not closed. Staff said they leave the bunghole open to eliminate pressure buildup. I observed a partially filled 55-gallon drum of liquid organic waste, determined to be a hazardous waste by the EHL staff. The container was not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. I observed two 55-gallon drum of liquid labeled with an internal label, determined to be a hazardous waste by EHL staff. The containers were not labeled with the words "Hazardous Waste," marked with an ASD, or with an indication of the hazards of the contents. I observed two plastic containers of used oil, 4 Liters and 1 Liter. Ms. McKinney informed us they contained used oil. The containers were nearly full and not labeled with the words "Used Oil." I observed a 5-gallon container of boiler treatment waste. The container was not labeled with the words "Hazardous Waste," marked with an ASD, or with an indication of the hazards of the contents. The contents were determined to be a hazardous waste by EHL staff. I observed a 1 Liter plastic container of waste methylene chloride. The container was not labeled with the words "Hazardous Waste," marked with an ASD, or with an indication of the hazards of the contents. The contents were determined to be a hazardous waste by EHL staff. I observed a cart of individually contained waste and/or expired materials, of which P. McKinney indicated had been stored for over ten years. P. McKinney indicated some substances would have come from their previous location in Palmer, AK, which operated from August 2001 to May 2004. This location operated under EPA ID# AKR000202028, last notifying as not a generator 05/02/2008. There is no record of these materials being transported from the previous location to the current location. Additional information regarding the contents of this cart was requested, as a quantity of P-listed wastes over 2.2 pounds would affect their generator status. Further communication from Ms. Snyder on 7/29/2024 included a comprehensive list of the substances determined to be acute hazardous waste. This included acute hazardous wastes such as sodium cyanide, strychnine, and arsenic oxide (P106, P108, P012, respectively.) 4 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 3 07/10/2024 - 07/10/2024 Building: ADEC Environmental Health Lab/Room 170/Wet Chemistry Observation #: JJ1-OB-002 Date: 07/10/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Patryce McKinney Title: Chief EHL I observed a partially filled 2 Liter SAA container of acid waste located in the fume hood not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. The contents were determined to be a hazardous waste by EHL staff. I observed two partially filled SAA containers of waste nitric acid located below the fume hood not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. The contents were determined to be a hazardous waste by EHL staff. Building: ADEC Environmental Health Lab/Room 169/Instrumentation Observation #: JJ1-OB-003 Date: 07/10/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Patryce McKinney Title: Chief EHL I observed a cubby of expired chemicals intended for disposal via trash (if determined to be non-hazardous) or awaiting logging prior to being moved to the CAA in Room 179 (if determined to be hazardous). The containers were not labeled with the words "Hazardous Waste" or with an indication of the hazards of their contents. The expired chemicals required a hazardous waste determination. Building: ADEC Environmental Health Lab/Room 177/Chemical Preparation Observation #: JJ1-OB-004 Date: 07/10/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Patryce McKinney Title: Chief EHL Room 177 houses multiple machines that excrete waste fluid via gravity fed hoses into bottles. Ms. McKinney informed us that the liquids collected from these machines are a hazardous waste. The bottles contained varying levels of liquids. I observed several partially filled containers of acid waste, determined to be a hazardous waste by ADEC EHL staff, not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. The contents were determined to be a hazardous waste by EHL staff. I observed a Gilson solid phase extraction (SPE) system collecting hazardous waste discharge from machinery via a plastic hose into a small open container. The containers were not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. The contents were determined to be a hazardous waste by EHL staff. The employee covered the top of the container with plastic wrap at the time of inspection. SECTION III - RECORDS REVIEW Record: Manifests AOC: No Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 07/10/2024 I did not find any areas of concern in my review of the last three years of manifests for the ADEC EHL. The facility typically manifests two to four shipments of hazardous waste per year, ranging from 10 to 500 pounds each. These wastes are historically D001 and D002. One manifest includes 25 pounds of D009 for the disposal of a broken mercury thermostat. The manifests do not include shipment of any acute hazardous wastes. 5 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 3 07/10/2024 - 07/10/2024 One paper manifest uploaded onto RCRAInfo does not match the e-Manifest it was filed under. For example, the uploaded paper manifest for e-Manifest 003477371FLE is the documentation for manifest tracking number 010997558FLE, via US Air Force ID# AK1570028646. It's clear that someone at the designated facility uploaded the wrong manifest to E-Manifest. Document(s) 1. 003476281FLE.pdf 2. 003476369FLE.pdf 3. 003477228FLE.pdf 4. 003477298FLE.pdf 5. 003477329FLE.pdf 6. 003477371FLE.pdf 7. 008742143FLE.pdf 8. 008742249FLE.pdf Record: Inspections AOC: No Ref #: JJ1-RR-002 Reviewed By: Jon Jones Reviewed Date: 07/10/2024 The site does not have any official hazardous waste inspections on record. The only regularly conducted inspection is a monthly safety check of Room 179 - Waste Storage. Communication from Ms. Snyder on 8/2/2024 confirms that the ADEC EHL Maintenance Team checks the hazardous waste storage area for leaks daily, however there is no written record of these inspections and as such, the facility is not conducting weekly hazardous waste inspections. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: ADEC Environmental Health Lab JJ1-OB-001 Area: Room 179/CAA Sub-area: Various containers in this area were Regulation: identified as having the following deficiencies: A ~1 Liter container of waste methylene chloride was not labeled "Hazardous Waste," marked with a hazard indicator or an ASD. A 1-gallon container of WPS waste was not labeled "Hazardous Waste," marked with a hazard indicator or an ASD. A 5-gallon container of Boiler Treatment waste was not labeled "Hazardous Waste," marked with a hazard indicator or an ASD. Sections: 6 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 3 07/10/2024 - 07/10/2024 A 5-gallon container of waste Mehg was not marked with a hazard indicator but was marked with an ASD of 8/30/22 indicating that it had been in accumulation for more than 270 days. A 55-gallon container of waste solvent was not closed or marked with an ASD. Three additional 55-gallon containers of liquid organic waste were not labeled "Hazardous Waste," marked with a hazard indicators or an ASDs. Failure to make a hazardous waste determination for a cart full of individually contained hazardous waste materials collected and stored over the last ten years. Building: ADEC Environmental Health Lab Area: Room 170/Wet Chemistry JJ1-OB-002 Three SAA containers were not labeled with the words "Hazardous Waste" or marked with a hazard indicator. Regulation: Building: ADEC Environmental Health Lab JJ1-OB-003 Area: Room 169/Instrumentation Failure to make a hazardous waste determination for containers of expired chemicals. Regulation: Building: ADEC Environmental Health Lab JJ1-OB-004 Area: Room 177/Chemical Preparation SAA containers collecting Gilson solid phase extraction (SPE) system waste discharge from machinery via a plastic hose were not closed, not labeled with the words "Hazardous Waste," or marked with a hazard indicator. Regulation: 7 of 32 Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: ADEC Environmental Health Laboratory Inspection Date(s): 3 EHL personnel closed the containers during the inspection. Record: Inspections JJ1-RR-002 No weekly hazardous waste inspections were being conducted for the last three years. Regulation: 07/10/2024 - 07/10/2024 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 ADEC EHL Staff 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 we 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 documented violations. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 8 of 32 ADEC Environmental Health Laboratory Inspection Date(s): APPENDIX 1: PHOTO LOG 07/10/2024 - 07/10/2024 55-gallon drum of solvent waste 07/10/2024 09:36 AM No CBI No PII Room 179 Drum not labeled with accumulation start date. IMG-20240710093650365078651.jpg Photographer: Jon Jones N/A 5-gallon bucket of Mehg waste IMG-20240710093721372195034.jpg 07/10/2024 09:37 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Container not labeled with an indication of the hazards of the contents. 9 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 55-gallon drum of organic waste 07/10/2024 09:40 AM No CBI Room 179 Bung not secured into container. No PII IMG-2024071009400640658618.jpg Photographer: Jon Jones N/A Central accumulation area 07/10/2024 09:41 AM No CBI No PII Room 179 Storage of hazardous waste and used oil containers. IMG-20240710094110411055416.jpg Photographer: Jon Jones N/A 10 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Central accumulation area 07/10/2024 09:44 AM No CBI No PII Room 179 Storage of hazardous waste and used oil containers. IMG-202407100944104410860907.jpg Photographer: Jon Jones N/A Central accumulation area 07/10/2024 09:44 AM No CBI Room 179 Bung not secured into container. No PII IMG-202407100944224422908461.jpg Photographer: Jon Jones N/A 11 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 PSCOA boiler treatment IMG-2024071009445444541366236.jpg 07/10/2024 09:44 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Container of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 5-gallon container labeled as "Mehg" 07/10/2024 09:45 AM No CBI Room 179 Accumulation start date of 8/30/2022. No PII IMG-2024071009451245121368435.jpg Photographer: Jon Jones N/A 12 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Hazardous waste container 07/10/2024 09:45 AM No CBI Room 179 Bung not secured into container. No PII IMG-20240710094534453471016.jpg Photographer: Jon Jones N/A Hazardous waste container IMG-202407100946454645828924.jpg 07/10/2024 09:46 AM No CBI No PII Photographer: Jon Jones Room 179 N/A WPS waste container not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 13 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Used oil containers IMG-202407100947284728967178.jpg 07/10/2024 09:47 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Containers of used oil, 4L and 1L, not labeled with the words "Used Oil." Used oil containers IMG-2024071009490249241349.jpg 07/10/2024 09:49 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Containers of used oil, 4L and 1L, not labeled with the words "Used Oil." 14 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Used oil container 07/10/2024 09:49 AM No CBI Room 179 Not labeled with the words "Used Oil." No PII IMG-20240710094905495517430.jpg Photographer: Jon Jones N/A Container of used oil 07/10/2024 09:49 AM No CBI Room 179 Not labeled with the words "Used Oil." No PII IMG-202407100949184918626854.jpg Photographer: Jon Jones N/A 15 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 55-gallon drum of labeled with an internal label IMG-20240710094951495130324.jpg 07/10/2024 09:49 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Container of hazardous waste not labeled with the words "Hazardous Waste", an indication of the hazards of the contents, or accumulation start date. 55-gallon drum of labeled with an internal label IMG-20240710094955495545878.jpg 07/10/2024 09:49 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Container of hazardous waste not labeled with the words "Hazardous Waste", an indication of the hazards of the contents, or accumulation start date. 16 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Container of methylene chloride IMG-20240710095435543567748.jpg 07/10/2024 09:54 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Container of hazardous waste not labeled with the words "Hazardous Waste", an indication of the hazards of the contents, or accumulation start date Expired and/or waste chemical storage IMG-2024071009584858481159253.jpg 07/10/2024 09:58 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. 17 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Expired and/or waste chemical storage IMG-202407100959005901293824.jpg 07/10/2024 09:59 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. Expired and/or waste chemical storage IMG-2024071009591659161094414.jpg 07/10/2024 09:59 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. 18 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Expired and/or waste chemical storage IMG-20240710095947594782375.jpg 07/10/2024 09:59 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. Expired and/or waste chemical storage IMG-2024071010014214277593.jpg 07/10/2024 10:01 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. 19 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Expired and/or waste chemical storage IMG-202407101001571571185490.jpg 07/10/2024 10:01 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. Expired and/or waste chemical storage IMG-2024071010022122160127.jpg 07/10/2024 10:02 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage, not labeled with the words "hazardous waste", or an indication of the hazards of the contents. 20 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Expired and/or waste chemical storage IMG-202407101003033377010.jpg 07/10/2024 10:03 AM No CBI No PII Photographer: Jon Jones Room 179 N/A Both acute and non-acute hazardous waste exceeding ten years of storage Container of acid waste in fume hood IMG-202407101011291129795151.jpg 07/10/2024 10:11 AM No CBI No PII Photographer: Jon Jones Room 170 N/A Container of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 21 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Container of acid waste in fume hood IMG-20240710101159115958986.jpg 07/10/2024 10:11 AM No CBI No PII Photographer: Jon Jones Room 170 N/A Container of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container of acid waste in fume hood storage cabinet IMG-202407101012311231827278.jpg 07/10/2024 10:12 AM No CBI No PII Photographer: Jon Jones Room 170 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 22 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Container of acid waste in fume hood storage cabinet IMG-20240710101237123741547.jpg 07/10/2024 10:12 AM No CBI No PII Photographer: Jon Jones Room 170 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Expired chemical storage cubby IMG-20240710101638163874265.jpg 07/10/2024 10:16 AM No CBI No PII Photographer: Jon Jones Room 169 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 23 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Expired chemical storage cubby IMG-20240710101826182666708.jpg 07/10/2024 10:18 AM No CBI No PII Photographer: Jon Jones Room 169 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Machinery liquid collection of HPLC waste IMG-2024071010212121211291952.jpg 07/10/2024 10:21 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 24 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Machinery liquid collection of HPLC waste IMG-20240710102218221886275.jpg 07/10/2024 10:22 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Machinery liquid collection of HPLC, acid waste IMG-202407101024262426995068.jpg 07/10/2024 10:24 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. 25 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Containers of acid waste IMG-2024071010244324431035095.jpg 07/10/2024 10:24 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. Machinery liquid collection of HPLC, acid waste IMG-20240710102738273864657.jpg 07/10/2024 10:27 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. 26 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Machinery liquid collection of acid waste IMG-20240710102744274444720.jpg 07/10/2024 10:27 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. Machinery liquid collection IMG-20240710102750275066977.jpg 07/10/2024 10:27 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. 27 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Containers of acid waste IMG-20240710103017301753253.jpg 07/10/2024 10:30 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Containers of acid waste IMG-20240710103018301843224.jpg 07/10/2024 10:30 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. 28 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Gilson solid phase extraction (SPE) liquid collection IMG-20240710103145314567283.jpg 07/10/2024 10:31 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. Gilson solid phase extraction (SPE) liquid collection IMG-2024071010315431541090812.jpg 07/10/2024 10:31 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Container(s) not closed. 29 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Container of acid waste IMG-20240710103205325901979.jpg 07/10/2024 10:32 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of hazardous waste not labeled with the words "Hazardous Waste" or with an indication of the hazards of the contents. Gilson solid phase extraction (SPE) liquid collection IMG-20240710103542354260666.jpg 07/10/2024 10:35 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of HPLC waste, closed by staff at time of inspection. 30 of 32 ADEC Environmental Health Laboratory Inspection Date(s): 07/10/2024 - 07/10/2024 Gilson solid phase extraction (SPE) liquid collection IMG-20240710103545354574718.jpg 07/10/2024 10:35 AM No CBI No PII Photographer: Jon Jones Room 177 N/A Containers of HPLC waste, closed by staff at time of inspection. 31 of 32 ADEC Environmental Health Laboratory Inspection Date(s): APPENDIX 2: DOCUMENT LOG Document Type Document Name 07/10/2024 - 07/10/2024 Contains Contains Uploaded By CBI PII Date Received Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Facility Map Communications Communications Communications 003476281FLE.pdf No No Jon Jones 003476369FLE.pdf No No Jon Jones 003477228FLE.pdf No No Jon Jones 003477298FLE.pdf No No Jon Jones 003477329FLE.pdf No No Jon Jones 003477371FLE.pdf No No Jon Jones 008742143FLE.pdf No No Jon Jones 008742249FLE.pdf No No Jon Jones EQ-A100 LayoutCropped.pdf No No Jon Jones Hazardous Waste and No No Jon Jones Hazard Indication Labels.docx PU listed waste No No Jon Jones amounts and ASDs.msg RE RCRA Compliance No No Jon Jones Evaluation Inspection on 71024.msg 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 07/30/2024 32 of 32