Document ExwNGGKyZy8M9wyeJaOJjMOag

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 07/12/2023 01:59 PM (AKT) Announced: No 07/12/2023 02:39 PM (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 North Slope Borough (NSB) North Slope Borough Sa 10 a.k.a. Vehicle Maintenance Shop (VMS) AKD983066028 Tracts 73B & 74 Prudhoe Bay, AK 99734 North Slope Borough Very Small Quantity Generator (VSQG) 811111 - General Automotive Repair Vehicle Maintenance 70.209761, -148.404393 Mr. Andrew Adams, Vehicle Maintenance Shop Manger 1234 Drill Site 12 Road, P.O. Box 340044, Drop Point 4 Prudhoe Bay, AK 99734 aadams@iceservices.net CC: Robert Scherer, VMS Manager rscherer@iceservices.net Rich Helinski, Projects/Operations Manager rhelinski@iceservices.net Patricia Brower, NSB Liaison patricia.brower@north-slope.org Cynthia Trapp, NSB, DPW, Environmental Official cynthia.trapp@north-slope.org Prudhoe Bay, AK 99734 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 8 North Slope Borough Sa 10 Inspection Date(s): 07/12/2023 - 07/12/2023 EPA Region 10 Lead Inspector, Jon Jones, arrived at the North Slope Borough (NSB) Sa 10 a.k.a. Vehicle Maintenance Shop (VMS) Facility (the "Site," "Facility," or "VMS"), located at Tracts 73B & 74, Prudhoe Bay, AK 99734, at 01:59 PM (AKT) on 07/12/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Justin Smith that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 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) 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 North Slope Borough VMS representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its HQ including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Lead Inspector/EPA REGION 10 Jon Jones (907) 2716329 RCRA Matt Inspector/USEPA Quarterman (206) 5532146 RCRA Inspector-in- Alan Pefley training/ADEC Light Duty Mechanic/Ice Services, Inc. Justin Smith (907) 6590107 Vehicle Andrew Adams (907) 448- Maintenance Shop 3053 Manager/Ice Services, Inc. Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes quarterman.matthew@epa.gov Yes Yes Yes Yes Yes Yes aadams@iceservices.net No Yes Opening Conference Shortly after arriving at the VMS, we were met outside by Mr. Justin Smith, Light Duty Mechanic and Moustapha Niang, Shop Mechanic. We entered the VMS, and I held the opening conference with Mr. Smith. Mr. Smith told us that the Shop Manager, Andrew Adams, was on the phone when we arrived. 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. Mr. Smith told us that the North Slope Borough owned the VMS. He told us that Ice Services, Inc. operated the facility. 2 of 8 North Slope Borough Sa 10 Inspection Date(s): 07/12/2023 - 07/12/2023 Facility/Site Information The NSB VMS is a small shop with four vehicle service bays. The shop maintains both Ice Services, Inc. and NSB vehicles. At the time of the inspection, there were three Shop Mechanics onsite and a Shop Manager. The shop operates seven days a week. The facility notified as a VSQG and Mr. Smith verified that the facility was a VSQG. Process Description According to Mr. Smith, the following wastes are generated at the VMS: Used oil - burned onsite in a used oil burning space heater. Used oil filters - hot drained, crushed and disposed of with the oily waste. Used antifreeze - managed through US Ecology. Waste aerosol cans - waste aerosol cans that last contained product (paints, lubricants, and solvents) are punctured onsite with the empty aerosol cans being managed with the oily waste. Waste aerosol can residue - not being collected during can puncturing. Lead-acid batteries - recycled through Brooks Supply in Deadhorse, AK. Waste tool and radio batteries - managed as solid waste and disposed of at the Oxbow Landfill. Waste lamps - lamps are changed out by another section of Ice Services and taken to the Ice Services camp site. Oily waste - (Absorbents/rags, oil filters, and punctured waste aerosol cans) disposed of at the Oxbow Landfill. We were accompanied during the inspection by Mr. Smith. We looked at the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. Building(s) Building/Area/Sub-area Vehicle Maintenance Shop Process Description Maintenance of Ice Services vehicles (Pick-ups) and NSB water and sewer trucks, generating: -Used oil -Used antifreeze -Oily waste rags/absorbents -Lead-acid automotive batteries -Waste aerosols (Paints, solvents, lubricants) -Tool/radio batteries Area of Concern Yes SECTION II - OBSERVATIONS Building: Vehicle Maintenance Shop Observation #: JJ1-OB-001 Date: 07/12/2023 Person Interviewed: Justin Smith Contains AOC: Yes Contains CBI: No Title: Light Duty Mechanic While in the Vehicle Maintenance shop, we saw a used oil storage tank with a storage capacity between 125 and 150 gallons. At the time of the inspection, the tank was not labeled with the words "Used Oil." I told Mr. Smith the used oil regulations required all used oil storage units to be labeled with the words "Used Oil." Mr. Smith labeled the storage tank with the words "Used Oil" during the inspection. 3 of 8 North Slope Borough Sa 10 Inspection Date(s): Photo(s) 1. IMG_1611.jpg 2. IMG_1610.jpg 3. IMG_1607.jpg 4. IMG_1608.jpg 5. IMG_1609.jpg 07/12/2023 - 07/12/2023 Building: Vehicle Maintenance Shop Observation #: JJ1-OB-002 Date: 07/12/2023 Person Interviewed: Justin Smith Contains AOC: Yes Contains CBI: No Title: Light Duty Mechanic While still in the VMS, I asked Mr. Smith to show me where they accumulate waste aerosol cans and how they are managed. Mr. Smith explained that as they generate waste aerosol cans, they are punctured over the used oil storage tank using a hammer punch. He then said the punctured cans go into an oily waste bag. Mr. Smith told us the bags of oily waste are taken to the Oxbow Landfill for disposal. I explained the regulations, requiring VSQGs to manage their waste properly. I told Mr. Smith that his facility's current method of puncturing the waste aerosol cans was not meeting that requirement. I suggested to Mr. Smith, that his facility might want to manage their waste aerosol cans as a universal waste and avoid the puncturing process. Photo(s) 1. IMG_1612.jpg Building: Vehicle Maintenance Shop Observation #: JJ1-OB-003 Date: 07/12/2023 Person Interviewed: Justin Smith Contains AOC: Yes Contains CBI: No Title: Light Duty Mechanic While still in the VMS, I asked Mr. Smith about the generation of waste batteries from power tools and handheld radios/communication devices. Mr. Smith told me those type of batteries are disposed of into the trash and taken to the Oxbow Landfill. I suggested to Mr. Smith that their facility manage the waste batteries as universal waste. SECTION III - RECORDS REVIEW At the time of the inspection, the facility was a VSQG of hazardous waste and no records were reviewed. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. 4 of 8 North Slope Borough Sa 10 Inspection Date(s): Building: Vehicle Maintenance Shop Area: JJ1-OB-001 Used oil storage tank was not Regulations: labeled with the words "Used Oil." Building: Vehicle Maintenance Shop Area: JJ1-OB-002 Waste aerosol cans they are punctured over the used oil storage tank using a hammer punch. The punctured cans go into an oily waste bag and are taken to the Oxbow Landfill for disposal. Regulations: Building: Vehicle Maintenance Shop Area: JJ1-OB-003 Waste batteries (Lithium/Ni-Cad) from power tools and hand-held radios/communication devices are disposed of into the trash and taken to the Oxbow Landfill. Regulations: 07/12/2023 - 07/12/2023 Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the conclusion of the inspection, I conducted a closing conference with Mr. Smith. After Mr. Adams, Shop Manager was done with his phone call, I went up to his office and conducted a second closing conference with him too. I thanked Mr. Smith and Mr. Adams 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 the 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 5 of 8 North Slope Borough Sa 10 Inspection Date(s): APPENDIX 1: PHOTO LOG 07/12/2023 - 07/12/2023 [Title] IMG_1607.jpg 07/12/2023 02:07 PM No CBI No PII Photographer: Jon Jones Vehicle Maintenance Shop 70.21313611, -148.403825 Another view of the used oil storage tank, showing that it is not labeled with the words "Used Oil." [Title] IMG_1608.jpg 07/12/2023 02:07 PM No CBI No PII Photographer: Jon Jones Vehicle Maintenance Shop 70.21308888, -148.40385555 Another view of the used oil storage tank, showing that it is not labeled with the words "Used Oil." 6 of 8 North Slope Borough Sa 10 Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1609.jpg 07/12/2023 02:07 PM No CBI No PII Photographer: Jon Jones Vehicle Maintenance Shop 70.213075, -148.40386944 Another view of the used oil storage tank, showing that it is not labeled with the words "Used Oil." [Title] IMG_1610.jpg 07/12/2023 02:07 PM No CBI No PII Photographer: Jon Jones Vehicle Maintenance Shop 70.21301388, -148.40402222 Another view of the used oil storage tank, showing that it is not labeled with the words "Used Oil." 7 of 8 North Slope Borough Sa 10 Inspection Date(s): 07/12/2023 - 07/12/2023 [Title] IMG_1611.jpg 07/12/2023 02:08 PM No CBI No PII Photographer: Jon Jones Vehicle Maintenance Shop 70.21321111, -148.40374722 View of the used oil storage tank after being labeled with the words "Used Oil' during the inspection. [Title] IMG_1612.jpg 07/12/2023 02:11 PM No CBI No PII Photographer: Jon Jones Vehicle Maintenance Shop 70.213075, -148.40394722 View of the hammer punch that is being used at the facility to puncture waste aerosol cans over the used oil tank. 8 of 8