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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA Region 10 Enforcement Division INSPECTION REPORT 03/06/2023 08:58 AM (AKT) Announced: No 03/06/2023 11:33 AM (AKT) 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 Home Depot USA Home Depot USA Inc. HD 1303 AKR000201087 1301 Old Steese Highway Fairbanks, AK 99701 Fairbanks North Star Borough Small Quantity Generator 44411 - Home Centers Do-it-yourself Home Store 64.851493, -147.692253 Mr. Rod Person, HD 1303 Store Manager 1301 Old Steese Highway Fairbanks, AK 99701 Fairbanks, AK 99701 rod_t_person@homedepot.com Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones JONATHAN JONES EPA Region 10 Digitally signed by JONATHAN JONES Date: 2023.04.27 14:08:40 -08'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan Digitally signed by Jennifer A Sullivan Date: 2023.04.28 09:02:00 -07'00' EPA Region 10 Sullivan.Jennifer.A@epa.gov (206) 553-6978 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI - Compliance Evaluation Inspection EPA Region 10 Lead Inspector, Jon Jones, arrived at the Home Depot USA, Inc. HD 1303 Facility (the "Site" or "Facility"), located at 1301 Old Steese Highway, Fairbanks, AK 99701, at 08:58 AM (AKT) on 03/06/2023 for an unannounced inspection. This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273). The inspection was conducted as part of a Core Program requirement for FY 2023. 1 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 This report is based on information supplied by Home Depot USA, Inc. HD 1303 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 or subsequent to, the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/EPA Region 10 Name Jon Jones Phone (907) 2716329 Hazardous Waste Program Specialist/ADEC Ashley Streveler (907) 2694556 Store Manager/Home Depot Rod Person (907) 4519003 Customer Experience Manager/Home Depot Alethea Woeok Assistant Store Manager/Home Depot German VillaBonilla Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes ashley.streveler@alaska.gov Yes Yes rod_t_person@homedepot.com Yes Yes Yes Yes No Yes Opening Conference Shortly after arriving at Home Depot, we were taken to the facility breakroom where I held the opening conference. I presented my inspector credentials to and informed Mr. Rod Person, HD 1303 Store Manager, that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). During the opening conference, I explained that the focus of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. 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 ~130 Length of Facility at Location Since 2002 2 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 Operating Hours Safety Training Provided to Inspector(s)? Size of Facility What type of generator facility notified? What type of generator facility verified as? Weather Conditions Winter hours: 7:00 am to 8:00 pm, Monday through Saturday and 7:00 am to 6:00 pm on Sunday. Summer hours: 6:00 am to 10:00 pm, Monday through Saturday and 7:00 am to 8:00 pm on Sunday. No Approximately 115,000 square feet Small Quantity Generator (SQG) Small Quantity Generator (SQG) verified by store personnel Cold and cloudy Process Description During the opening conference, Mr. Person told us 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. We were accompanied during the inspection by Mr. Person and Ms. Woeok. 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. I also observed the facility's universal waste. Building(s) Building/Area/Sub-area Main Store Receiving Area Process Description Central Accumulation Area (CAA) Area of Concern Yes Yes SECTION II - OBSERVATIONS Building: Main Store /Receiving Area Observation #: JJ1-OB-001 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No While inspecting the facility's Central Accumulation Area (CAA) I saw a black, 5-gallon container that held three to four Lithium and/or Ni-Cad tool batteries. At the time of the inspection, the container was labeled with the word "Rechargeable." The container was not labeled as either hazardous waste or universal waste. A review of the facility's training at the end of the walk-through inspection indicated that waste batteries and lamps are managed as universal waste. Following the inspection, I received an email from Mr. Person and a second email from a Mr. Steven Lohry, Assistant Store Manager, providing the same photos showing that the container of waste batteries had been labeled with the words, "Hazardous Waste." The photo submitted did not show a hazard indicator on the container. 3 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): Document(s) 1. Corrective Actions.msg 2. Fw Corrective Actions.msg Photo(s) 1. IMG_0444.jpg 2. IMG_0445.jpg 3. IMG_0446.jpg 4. IMG_0447.jpg 5. Image1.jpeg 03/06/2023 - 03/06/2023 Building: Main Store /Receiving Area Observation #: JJ1-OB-002 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No While still in the facility's CAA, I saw a 5-gallon container that was labeled "Hazardous Waste," but was not labeled or marked with a hazard indicator. At the time of the inspection, the area on the container label where a hazard indicator is marked was labeled "None." Following the inspection, I received duplicate emails from Messrs. Person and Lohry, on 3/6/2023, providing photos showing that the container had been marked with the word "Corrosive" for the hazard indicator. Photo(s) 1. IMG_0448.jpg 2. IMG_0449.jpg Building: Main Store /Receiving Area Observation #: JJ1-OB-003 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No While still in the CAA, I saw a 2-gallon container of hazardous waste that was labeled with the words "Desechos Peligroso." We were able to determine that the labels printed by the facility were in English on one side and in Spanish on the reverse side. Facility personnel reversed the labeling so that the English side was showing. The lid on the container was not closed, as it was not making a complete seal with the container. Following the inspection, I received emails from Messrs. Person and Lohry, on 3/6/2023, providing photos showing that the container had been closed. Photo(s) 1. IMG_0450.jpg 2. IMG_0451.jpg 3. IMG_0452.jpg Building: Main Store /Receiving Area Observation #: JJ1-OB-004 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No 4 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 While still in the CAA, I saw a 35-gallon container that held waste aerosol cans. At the time of the inspection, the container held approximately eight waste aerosol cans and was not labeled or marked with the words "Hazardous Waste" or the hazard indicator. Following the inspection, I received emails from Messrs. Person and Lohry, on 3/6/2023, providing photos showing that the container of waste aerosol cans had been marked with a hazard indicator, but there was no indication in the photo that the container had been labeled with the words, "Hazardous Waste." Photo(s) 1. IMG_0453.jpg 2. IMG_0454.jpg 3. IMG_0455.jpg 4. IMG_0456.jpg Building: Main Store /Receiving Area Observation #: JJ1-OB-005 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No While still in the CAA, I saw a 15-gallon container that was labeled as containing waste oily paint rags. The container was not labeled with the words hazardous waste and only marked with half of a Flammable/Ignitable hazard indicator. While discussing this container with store personnel, it seemed as though they were unsure about the contents of the container. I explained that a waste determination was required for this waste. Following the inspection, I received emails from Messrs. Person and Lohry, on 3/6/2023, providing photos showing that the container of waste oily paint rags was marked with the hazard indicator of "Ignitable," but there was no indication that it had been labeled with the words "Hazardous Waste." Photo(s) 1. IMG_0457.jpg 2. IMG_0458.jpg 3. IMG_0459.jpg 4. Image2.jpeg Building: Main Store /Receiving Area Observation #: JJ1-OB-006 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No While still in the CAA, I inspected the contents of a flammable storage cabinet. When I opened the cabinet, I saw a 2-gallon container of hazardous waste that was not closed. At the time of the inspection the container lid was not making a complete seal with the container. The container was closed by facility personnel during the inspection. I also saw a black, 5-gallon container that had the Spanish language side of the label showing. The label was reversed during the inspection so that the words "Hazardous Waste" and the hazard indicator were visible in English. 5 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): Photo(s) 1. IMG_0460.jpg 2. IMG_0461.jpg 3. IMG_0462.jpg 4. IMG_0463.jpg 03/06/2023 - 03/06/2023 Building: Main Store /Receiving Area Observation #: JJ1-OB-007 Date: 03/06/2023 Person Interviewed: Rod Person Contains AOC: Yes Title: Store Manager Contains CBI: No While still at the CAA, I saw a cardboard box for the accumulation of 8-foot waste fluorescent lamps. The container of waste fluorescent lamps was on top of the flammable storage cabinet. The container held waste lamps and was preprinted with a label that was marked with the words "Universal Waste," but was not labeled as "Universal Waste - Lamps." At the time of the inspection the container of waste lamps was not closed. I also saw one loose, 4-foot waste fluorescent lamp on the shelf above the flammable storage cabinet. At the time of the inspection, the 4-foot waste lamp was not packaged and was not labeled as a universal waste lamp. Facility personnel placed the 4-foot waste fluorescent lamp in the 8-foot waste fluorescent lamp container during the inspection. Following the inspection, I received emails from Messrs. Person and Lohry, on 3/6/2023, providing photos showing that this 8-foot container of universal waste lamps had been closed. Photo(s) 1. IMG_0464.jpg 2. IMG_0465.jpg 3. IMG_0466.jpg 4. IMG_0467.jpg 5. IMG_0468.jpg 6. Image3.jpeg SECTION III - RECORDS REVIEW Record: Inspections Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/19/2023 I reviewed the facility's weekly inspections that were sent to me following the inspection and saw that the facility is conducting a weekly inspection almost daily with few exceptions. Based on the inspection frequency the facility is meeting the requirement of conducting weekly hazardous waste inspections of the hazardous waste in their CAA. Based on the areas of concern that I identified during the inspection of the CAA, it is apparent that personnel conducting these inspections are either not conducting adequate inspections or are not trained to recognize the areas of concern that were identified. A weekly inspection was conducted by the facility on the day of the inspection and the areas of concern noted in the inspection were not observed and/or addressed during the facility's weekly inspection. Document(s) 6 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 1. HHM Safety Checklist.pdf 2. 3.6.23 wkly pt1.pdf 3. 3.6.23 wkly pt2.pdf 4. 3.6.23 wkly pt3.pdf 5. 3.6.23 wkly pt4.pdf 6. 3.6.23 wkly pt5.pdf 7. 3.6.23 wkly pt6.pdf 8. 3.6.23 wkly pt7.pdf 9. 3.6.23 wkly pt8.pdf 10. 3.6.23 wkly pt9.pdf 11. 3.6.23 wkly pt10.pdf 12. 3.6.23 wkly pt11.pdf 13. 3.6.23 wkly pt12.pdf Record: Manifests Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/06/2023 During my review of the facility's hazardous waste manifests, I saw that the generators copy of manifest #200121243CLE, dated 5/10/22, was not signed by the generators designated representative or the first transporter. For this manifest, the first transporter was also the generators designated representative. At the time of the inspection the facility did not have any of the original manifests that had been signed and dated by the designated facility. The facility followed up with a request for these documents and provided them following the inspection. A review of the final signed copy of manifest #200121243CLE showed that transporter 1 had signed the manifest, on behalf of the generator, and signed in the transporter 1 box using what looked like a felt tipped marker. The use of a felt tipped marker did not transfer the signatures onto the generator copy and as such, the generator was not in possession of a generator copy that had been signed by the transporter. Document(s) 1. IMG_0469.jpg 2. 1303 - Manifest - 22-05-10.pdf Record: Personnel Training Ref #: JJ1-RR-003 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/06/2023 During the inspection, I asked for a copy of the training that is provided to facility personnel. It was explained to me that the training was a computer-based training and could not be printed, so I sat through the training with Mr. German Villa-Bonilla, Assistant Store Manager. While personally viewing the computer-based training, I saw that nothing was included related to labeling hazardous wastes with either the words, "Hazardous Waste" or a hazard indicator. Record: Personnel Training Ref #: JJ1-RR-004 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/06/2023 While watching the facility's computer-based training, I saw that it contained universal waste training, but it did not address the accounting of the time that universal waste is in accumulation. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. 7 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): Building: Main Store JJ1-OB-001 Area: Receiving Area A black, 5-gallon container that held three to four Lithium or Ni-Cad tool batteries. At the time of the inspection, the container was labeled with the word "Rechargeable." The container was not labeled as either hazardous waste or universal waste. Regulation: Building: Main Store JJ1-OB-002 Area: Receiving Area A 5-gallon container that was labeled as hazardous waste, but not labeled or marked with a hazard indicator. At the time of the inspection, the area on the container label where a hazard indicator is marked was labeled "None." Following the inspection, I received emails from the facility, on 3/6/2023, providing photos showing that the container had been marked with the word "Corrosive" for the hazard indicator. Regulation: Building: Main Store JJ1-OB-003 Area: Receiving Area A 2-gallon container of hazardous waste that was labeled with the words "Desechos Peligroso." The labels printed by the facility were in English on one side and in Spanish on the reverse side. Facility personnel reversed the labeling so that the English side was showing. The lid on the container was not closed, as it was not making a complete seal with the container. Following the inspection, I received emails from the facility, on 3/6/2023, providing photos showing that this container had been closed. Regulation: Building: Main Store JJ1-OB-004 Area: Receiving Area 8 of 29 03/06/2023 - 03/06/2023 Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Home Depot USA, Inc HD 1303 Inspection Date(s): A 35-gallon container, that held approximately eight waste aerosol cans, was not labeled, or marked with the words "Hazardous Waste" or the hazard indicator. Following the inspection, I received emails from the facility providing photos showing that the container of waste aerosol cans had been marked with a hazard indicator, but there was no indication in the photo that it had been labeled with the words, "Hazardous Waste." Regulation: Building: Main Store JJ1-OB-005 Area: Receiving Area A 15-gallon container that was labeled as containing waste oily paint rags was not labeled with the words hazardous waste and only marked with half of a Flammable/Ignitable hazard indicator. While discussing this container with store personnel, it seemed as though they were unsure about the contents of the container. I explained that a waste determination was required for this waste. Regulation: Building: Main Store JJ1-OB-006 Area: Receiving Area I inspected the contents of a flammable storage cabinet and saw a 2-gallon container of hazardous waste that was not closed. At the time of the inspection the container lid was not making a complete seal with the container. The container was closed by facility personnel during the inspection. Regulation: Building: Main Store JJ1-OB-007 Area: Receiving Area I saw a cardboard box for the accumulation of 8-foot waste Regulation: 9 of 29 03/06/2023 - 03/06/2023 Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Home Depot USA, Inc HD 1303 Inspection Date(s): fluorescent lamps. The container held waste lamps and was labeled with the words universal waste lamps. At the time of the inspection the container of waste lamps was not closed. I also saw one loose, 4-foot waste fluorescent lamp on the shelf above the flammable storage cabinet. At the time of the inspection, the 4foot waste lamp was not packaged and was not labeled with the words "Universal Waste - Lamps." Facility personnel placed the 4-foot waste fluorescent lamp in the 8-foot waste fluorescent lamp container during the inspection. Following the inspection, I received an email from the facility providing a photo showing that this 8-foot container of universal waste lamps had been closed. There was no indication it had been labeled with the words "Universal Waste - Lamps." Building: Main Store JJ1-OB-006 Area: Receiving Area A black, 5-gallon container that had the Spanish language side of the label showing, was not labeled with the words "Hazardous Waste." The label was reversed during the inspection so that the words "Hazardous Waste" and the hazard indicator were visible in English. Regulation: Record: Inspections JJ1-RR-001 I reviewed the facility's weekly inspections that were sent to me following the inspection and saw that the facility is conducting a weekly inspection almost daily with few exceptions. Based on the inspection frequency the facility is meeting the requirement of Regulation: 10 of 29 03/06/2023 - 03/06/2023 Sub-area: Sections: Sections: Home Depot USA, Inc HD 1303 Inspection Date(s): conducting weekly hazardous waste inspections in their CAA. Based on the areas of concern that I identified during the inspection of the CAA, it is apparent that personnel conducting these inspections are either not conducting adequate inspections or are not trained to recognize the areas of concern that were identified. An inspection was conducted on the day of the inspection and the areas of concern noted in the inspection were not observed and/or addressed during the facility's weekly inspection. Record: Manifests JJ1-RR-002 During my review of the facility's hazardous waste manifests, I saw that the generators copy of manifest #200121243CLE, dated 5/10/22, was not signed by the generators designated representative or the first transporter. For this manifest, the first transporter was also the generators designated representative. Regulation: At the time of the inspection the facility did not have any of the original manifests that had been signed and dated by the designated facility. The facility followed up with a request for these documents and provided them following the inspection. A review of the final signed copy of manifest #200121243CLE showed that transporter 1 had signed the manifest on behalf of the generator and also signed in the transporter 1 box using what looks like a felt tipped marker. The use of a felt tipped marker did not transfer the signatures onto the generator copy. Record: Personnel Training 11 of 29 03/06/2023 - 03/06/2023 Sections: Home Depot USA, Inc HD 1303 Inspection Date(s): JJ1-RR-003 While personally viewing the computer-based training, I saw that nothing was included related to labeling hazardous wastes with either the words, "Hazardous Waste" or a hazard indicator. Regulation: Record: Personnel Training JJ1-RR-004 While watching the facility's computer-based training, I saw that it contained universal waste training, but it did not address the accounting of the time that universal waste is in accumulation. Regulation: 03/06/2023 - 03/06/2023 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 documented violations. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 12 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): APPENDIX 1: PHOTO LOG 03/06/2023 - 03/06/2023 [Title] IMG_0444.jpg 03/06/2023 09:19 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85726944, -147.68281666 View of a black, poly bucket that contains 3 to 4 Lithium/Ni-Cad waste batteries. The container is seen here labeled "Rechargeable" and not labeled as either hazardous or universal waste. [Title] IMG_0445.jpg 03/06/2023 09:19 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85728333, -147.68284722 View of a black, poly bucket that contains 3 to 4 Lithium/Ni-Cad waste batteries. The container is seen here labeled "Rechargeable" and not labeled as either hazardous or universal waste. 13 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0446.jpg 03/06/2023 09:19 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85725277, -147.68272499 View of a black, poly bucket that contains 3 to 4 Lithium/Ni-Cad waste batteries. The container is seen here labeled "Rechargeable" and not labeled as either hazardous or universal waste. [Title] IMG_0447.jpg 03/06/2023 09:19 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85723055, -147.68273888 View of a black, poly bucket that contains 3 to 4 Lithium/Ni-Cad waste batteries. The container is seen here labeled "Rechargeable" and not labeled as either hazardous or universal waste. 14 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0448.jpg 03/06/2023 09:21 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85734444, -147.68290833 While still in the facility's CAA, I saw a 5-gallon container that was labeled as hazardous waste but was not labeled or marked with a hazard indicator. At the time of the inspection, the area on the container label where a hazard indicator is marked was labeled "None." Following the inspection, I received an email from Mr. Person and a second email from a Mr. Steven Lohry, on 3/6/2023, providing the same photos showing that this container had been marked with the word "Corrosive" for the hazard indicator. 15 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0449.jpg 03/06/2023 09:21 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85746111, -147.68305833 While still in the facility's CAA, I saw a 5-gallon container that was labeled as hazardous waste but was not labeled or marked with a hazard indicator. At the time of the inspection, the area on the container label where a hazard indicator is marked was labeled "None." Following the inspection, I received an email from Mr. Person and a second email from a Mr. Steven Lohry, on 3/6/2023, providing the same photos showing that this container had been marked with the word "Corrosive" for the hazard indicator. 16 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0450.jpg 03/06/2023 09:23 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85732222, -147.68286111 View of the open container, showing that the lid is not making a complete seal with the container. [Title] 03/06/2023 09:24 AM No CBI No PII Main Store /Receiving Area View of the label on the container that is not closed. IMG_0451.jpg Photographer: Jon Jones 64.85731388, -147.68278611 17 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0452.jpg 03/06/2023 09:24 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85728333, -147.68276944 View of the open container, showing that the lid is not making a complete seal with the container. [Title] IMG_0453.jpg 03/06/2023 09:31 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85733888, -147.68283055 View of 35-gallon container holding waste aerosol cans that is not labeled with the words hazardous waste or marked with a hazard indicator. 18 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0454.jpg 03/06/2023 09:32 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85729166, -147.68281666 View of 35-gallon container holding waste aerosol cans that is not labeled with the words hazardous waste or marked with a hazard indicator. [Title] IMG_0455.jpg 03/06/2023 09:32 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85692499, -147.68257222 View of 35-gallon container holding waste aerosol cans that is not labeled with the words hazardous waste or marked with a hazard indicator. 19 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0456.jpg 03/06/2023 09:32 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85682777, -147.68258611 View of 35-gallon container holding waste aerosol cans that is not labeled with the words hazardous waste or marked with a hazard indicator. [Title] IMG_0457.jpg 03/06/2023 09:32 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85728333, -147.68272499 View of a 15-gallon container that holds oily paint waste rags. The container is not labeled with the words hazardous waste and not marked with a complete hazard indicator. 20 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0458.jpg 03/06/2023 09:33 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85728333, -147.68276944 View of a 15-gallon container that holds oily paint waste rags. The container is not labeled with the words hazardous waste and not marked with a complete hazard indicator. [Title] IMG_0459.jpg 03/06/2023 09:33 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85733888, -147.6828 View of a 15-gallon container that holds oily paint waste rags. The container is not labeled with the words hazardous waste and not marked with a complete hazard indicator. 21 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0460.jpg 03/06/2023 09:41 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85731388, -147.68289166 View of the lid on the container, showing that it's not making a complete seal. [Title] IMG_0461.jpg 03/06/2023 09:41 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85743611, -147.68301388 Close-up view showing that the lid is not making a complete seal with the container. 22 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0462.jpg 03/06/2023 09:42 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.8573, -147.6828 View of the 5-gallon container in the flammable storage cabinet with the Spanish language side of the label showing. [Title] IMG_0463.jpg 03/06/2023 09:42 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85729166, -147.68281666 Close-up view of the label with the Spanish language side visible. 23 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0464.jpg 03/06/2023 09:49 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85730833, -147.68283055 View of the 8-foot universal waste lamp container, seen here on top of the flammable storage cabinet and not closed. [Title] IMG_0465.jpg 03/06/2023 09:51 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85726944, -147.68273888 Close-up view of the universal waste marking on the 8-foot container, without the actual words, "Universal Waste - Lamps." 24 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0466.jpg 03/06/2023 09:51 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85721666, -147.68275555 Close-up view inside the universal waste container, showing that it contains waste lamps. [Title] IMG_0467.jpg 03/06/2023 09:51 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85716944, -147.6828 Close-up view inside the universal waste container, showing that it contains waste lamps. 25 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 [Title] IMG_0468.jpg 03/06/2023 09:51 AM No CBI No PII Photographer: Jon Jones Main Store /Receiving Area 64.85704722, -147.68269444 View of the loose, 4-foot waste fluorescent lamp, on the shelf above the flammable storage cabinet, seen here not packaged or labeled with the words universal waste lamps. Facility Photo 1 Image1.jpeg [Image Capture Date] No CBI No PII Photographer: Unknown Main Store /Receiving Area [Geographic Coordinates] Photo shows corrective action taken by the facility following the inspection. 26 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 Facility photo 2 Image2.jpeg [Image Capture Date] No CBI No PII Photographer: Unknown Main Store /Receiving Area [Geographic Coordinates] Facility photo, showing that the container was marked with the hazard indicator "Ignitable." Facility Photo 3 Image3.jpeg [Image Capture Date] No CBI No PII Photographer: Unknown Main Store /Receiving Area [Geographic Coordinates] Photo provided by the facility showing that the universal waste lamp container was closed. 27 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Communications Communications Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Records Review Manifests Manifests Manifests Manifests Manifests Manifests Manifests Manifests Manifests Corrective Actions.msg No No Jon Jones Fw Corrective Actions.msg No No Jon Jones HHM Safety Checklist.pdf No No Jon Jones 3.6.23 wkly pt1.pdf No No Jon Jones 3.6.23 wkly pt2.pdf No No Jon Jones 3.6.23 wkly pt3.pdf No No Jon Jones 3.6.23 wkly pt4.pdf No No Jon Jones 3.6.23 wkly pt5.pdf No No Jon Jones 3.6.23 wkly pt6.pdf No No Jon Jones 3.6.23 wkly pt7.pdf No No Jon Jones 3.6.23 wkly pt8.pdf No No Jon Jones 3.6.23 wkly pt9.pdf No No Jon Jones 3.6.23 wkly pt10.pdf No No Jon Jones 3.6.23 wkly pt11.pdf No No Jon Jones 3.6.23 wkly pt12.pdf No No Jon Jones IMG_0469.jpg No No Jon Jones 1303 - Manifest - 22-05- No No Jon Jones 10.pdf 1303 - Manifest - 20-03- No No Jon Jones 16.pdf 1303 - Manifest - 20-05- No No Jon Jones 12.pdf 1303 - Manifest - 20-07- No No Jon Jones 07.pdf 1303 - Manifest - 20-09- No No Jon Jones 01.pdf 1303 - Manifest - 20-10- No No Jon Jones 26.pdf 1303 - Manifest - 20-12- No No Jon Jones 21.pdf 1303 - Manifest - 21-02- No No Jon Jones 16.pdf 1303 - Manifest - 21-04- No No Jon Jones 13.pdf 1303 - Manifest - 21-06- No No Jon Jones 07.pdf Date Received 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/19/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 28 of 29 Home Depot USA, Inc HD 1303 Inspection Date(s): 03/06/2023 - 03/06/2023 Manifests 1303 - Manifest - 21-08- No No Jon Jones 03.pdf Manifests 1303 - Manifest - 21-09- No No Jon Jones 21.pdf Manifests 1303 - Manifest - 21-11- No No Jon Jones 22.pdf Manifests 1303 - Manifest - 22-01- No No Jon Jones 17.pdf Manifests 1303 - Manifest - 22-03- No No Jon Jones 14.pdf Manifests 1303 - Manifest - 22-07- No No Jon Jones 06.pdf Manifests 1303 - Manifest - 22-08- No No Jon Jones 31.pdf Manifests 1303 - Manifest - 22-10- No No Jon Jones 25.pdf Manifests 1303 - Manifest - 22-12- No No Jon Jones 19.pdf Personnel Training Associate HHM Training.pdf No No Jon Jones Personnel Training Store 1303 SABA history for No No Jon Jones 4265_4266_4267_4260.xlsx Personnel Training Store 1303 Workday No No Jon Jones history for 4265_4266_4267_4260.xlsx Other - Photo, provided by facility, of label on a Non-hazardous waste container Image4.pdf No No Jon Jones 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 04/21/2023 29 of 29