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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 03/08/2024 09:03 AM (AKT) Announced: No 03/08/2024 10:32 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 BMW of Anchorage BMW of Anchorage AKD091746925 730 E 5Th Ave Anchorage, AK 99501 N/A Very Small Quantity Generator (VSQG), as determined at the time of the inspection. 811198 - All Other Automotive Repair and Maintenance 44111 - New Car Dealers 44112 - Used Car Dealers BMW Dealership and Service 61.217539, -149.869914 Mr. David Billman dbillman@lithia.com 730 E 5Th Ave Anchorage, AK 99501 Anchorage, AK 99501 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA Region 10 Jones.Jon@epa.gov (907) 227-4316 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) EPA Region 10 Lead Inspector, Jon Jones, arrived at the BMW of Anchorage Facility (the "Site" or "Facility"), located at 730 E 5Th Ave, Anchorage, AK 99501, at 09:03 AM (AKT) on 03/08/2024 for an unannounced 1 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 inspection. I was accompanied by RCRA Inspectors-in-training from the Alaska Department of Environmental Conservation (ADEC). After arriving at BMW, we spoke to a service representative that asked us to wait for the Service Manager. He called the Service Manager and then told us that he was Five minutes out and would get with us once he arrived. We waited in the reception area. After a short time, we were met by Mr. David Billman, General Manager. EPA Region 10 Lead Inspector presented credentials to and informed Mr. Billman 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). The inspection was conducted as part of a Core Program requirement for FY 2024. This report is based on information supplied by BMW of Anchorage Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its HQ including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Lead Inspector/EPA Jon Jones REGION 10 (907) 227-4316 RCRA Inspector-in- Alan Pefley training /ADEC RCRA Inspector-in- Vanessa Schmidt training /ADEC General Manager/BMW of Anchorage David Billman (907) 646-7595 Email Opening Conf. Jones.Jon@epa.g Yes ov Yes Yes dbillman@lithia.c Yes om Closing Conf. Yes Yes Yes Yes Opening Conference During the opening conference, Mr. Billman told us the wastes generated at the facility were primarily generated during the servicing of vehicles. The facility, a member of the Lithia Auto Group NA, is a retail dealer of new and used automobiles, primarily manufactured by Bavarian Motor Works (BMW). In addition to selling vehicles the facility operates a maintenance and repair area; this area that was the focus of the inspection as this is where most of the hazardous waste is generated. Mr. Billman told us the facility's paint and body shop portion of the business was discontinued approximately 20 years ago. 2 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 Facility/Site Information What type of generator facility verified as? Verified SQG by David Billman What type of generator facility notified? Small Quantity Generator (SQG) Size of Facility Approximately 50,000 square feet Safety Training No Provided to Inspector(s)? Operating Hours Monday through Friday, 9:00 a.m. to 8:00 p.m. Service Department 7:30 a.m. to 6:00 p.m. Length of Facility at Location Since the mid 1950's Number of employees 42 Weather Conditions Clear and cold Process Description Mr. Billman told us the following wastes were being generated: Waste aerosol cans Used oil Used Antifreeze Lead-acid batteries recycled locally for core charge Waste lamps We were accompanied during the inspection by Mr. Billman. 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. We also observed the facility's universal waste. Building(s) Building/Area/Sub-area BMW Parts Department BMW Service Department Bay 9 Bay 2/3 Bay 11/12 Bay 5 Special Tool Room Bay 7 BMW Showroom Process Description Used oil collection 3 of 12 Area of Concern No Yes No No No No No Yes No BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 SECTION II - OBSERVATIONS Building: BMW Service Department/ Bay 7 Observation #: JJ1-OB-001 Date: 03/08/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Randy Giddings Title: Used Car Technician While inspecting the various vehicle bays inside the Service Department we stopped at Bay 7. While there we observed a 20-gallon used oil receiver that contained used oil. The facility has many 20-gallon used oil receivers that they use to collect used oil drained from vehicles. The used oil in the receivers is periodically transferred to a larger tank with an approximate storage capacity of 500 gallons prior to being picked up for recycling. At the time of the inspection, that storage tank was labeled with the words, "Used Oil." During the inspection at Bay 7, we spoke with Mr. Randy Giddings, Service Technician, who happened to be working in the area. We asked Mr. Giddings how much used oil was in the receiver and he stated that it was full. At the time of the inspection, the 20-gallon used oil receiver was not labeled with the words "Used Oil." I explained that the used oil regulations required used oil storage containers to be labeled with the words "Used Oil." I explained that they could either label the container during the inspection or they could label it after the inspection and provide documentation that it had been labeled. Mr. Billman had Mr. Giddings label the 20-gallon used oil receiver during the inspection. Photo(s) 1. IMG-2024030809413641362406025.jpg 2. IMG-2024030809414441442537835.jpg 3. IMG-2024030809415641562649552.jpg 4. IMG-202403080943054352794961.jpg Building: BMW Service Department/Bay 9 Observation #: JJ1-OB-002 Date: 03/08/2024 Contains AOC: No Contains CBI: No Person Interviewed: David Billman Title: General Manager While inspecting the area around Bay 9, we saw an aerosol can on the floor. I picked up the aerosol can, shook it, and determined that the aerosol can was an empty waste aerosol can. I asked Mr. Billman how the facility managed waste aerosol cans. Mr. Billman found a Service technician nearby who stated that they probably get punctured and thrown away. When I asked where they were being punctured, the shop tech said he did not puncture them, he just threw them away. During the inspection we identified additional waste aerosol cans and didn't find any evidence that they were being punctured prior to being thrown into the trash. Based on the amount of waste aerosol cans that were being generated each month, considering the other wastes that were being generated at the facility, I told Mr. Billman that I didn't think his facility was an SQG. I told Mr. Billman that from everything I had seen during the inspection, his facility was a Very Small Quantity Generator (VSQG) of hazardous waste. Based on the VSQG determination, no area of concern was identified. I did tell Mr. Billman that taking the waste aerosol cans to the local Household Hazardous Waste (HHW) facility at the solid waste transfer station was also an option that was available. Photo(s) 1. IMG-2024030809503150311396780.jpg 2. IMG-2024030809504750471261787.jpg 3. IMG-202403080951015111255152.jpg 4 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 Building: BMW Service Department/Special Tool Room Observation #: JJ1-OB-003 Date: 03/08/2024 Contains AOC: No Contains CBI: No Person Interviewed: David Billman Title: General Manager While inspecting the Special Tool Room we saw a box that contained some four-foot fluorescent lamps. Upon closer inspection, we saw five of these lamps. I noticed that these lamps had darkened ends which are indicative of being waste lamps. I also saw that the lamps were marked with a manufacturer stamp on the end with green writing that is also indicative of an "Eco" lamp or low mercury lamp that will not fail TCLP for mercury. During the inspection, I explained to Mr. Billman that there were several ways that his facility could manage the lamps. I explained that he could manage the waste lamps as solid waste, but I encouraged him to manage the lamps through the local HHW facility at the solid waste transfer station. Photo(s) 1. IMG-2024030810115011501336228.jpg 2. IMG-2024030810115711571306737.jpg Building: BMW Service Department Observation #: JJ1-OB-006 Date: 03/08/2024 Person Interviewed: Contains AOC: No Title: Contains CBI: No During the inspection, we had questions about the facility's management of used oil, lead-acid batteries, and their parts washer. On 3/8/24 Mr. Billman followed up with an email and provided the requested information about his facility's parts washer and the solvent used. According to the information provided, the facility uses a high-flash (143F) solvent. The information is included in the document log. On 3/27/24 Mr. Billman followed up with another email and provided the requested information for his facility's lead-acid batteries and used oil. The information is included in the document log. Photo(s) 1. IMG-2024030810135613561317899.jpg SECTION III - RECORDS REVIEW During the inspection, it was determined that BMW of Anchorage 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. Building: BMW Service Department Area: Bay 7 JJ1-OB-001 Sub-area: 5 of 12 BMW of Anchorage Inspection Date(s): At the time of the inspection, a full 20-gallon used oil receiver was not labeled with the words "Used Oil." Regulation: The container was labeled, with the words "Used Oil," during the inspection. 03/08/2024 - 03/08/2024 Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the conclusion of the inspection, we conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. We thanked Mr. Billman for his time and cooperation during the inspection and began a review of the area of concern (listed in Section III - Areas of Concern) that we 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 2. Document Log 6 of 12 BMW of Anchorage Inspection Date(s): APPENDIX 1: PHOTO LOG 03/08/2024 - 03/08/2024 [Title] IMG-2024030809413641362406025.jpg 03/08/2024 09:41 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Bay 7 61.21690769, -149.86922003 View of the 20-gallon used oil receiver, at Bay 7, that is full of used oil, seen here not labeled with the words "Used Oil." [Title] IMG-2024030809414441442537835.jpg 03/08/2024 09:41 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Bay 7 61.21691747, -149.86944197 Close up view of the 20-gallon used oil receiver, at Bay 7, that is full of used oil, seen here not labeled with the words "Used Oil." 7 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 [Title] IMG-2024030809415641562649552.jpg 03/08/2024 09:41 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Bay 7 61.21691943, -149.8694493 Another view of the 20-gallon used oil receiver, at Bay 7, that is full of used oil, seen here not labeled with the words "Used Oil." [Title] IMG-202403080943054352794961.jpg 03/08/2024 09:43 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Bay 7 61.21693634, -149.86943613 View of the 20-gallon used oil receiver, at Bay 7, after being labeled with the words "Used Oil" during the inspection. 8 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 [Title] 03/08/2024 09:50 AM (AKT) No CBI BMW Service Department/Bay 9 View of waste aerosol can on the floor. No PII IMG-2024030809503150311396780.jpg Photographer: Jon Jones 61.21694573, -149.86943429 [Title] 03/08/2024 09:50 AM (AKT) No CBI No PII BMW Service Department/Bay 9 View of waste aerosol can that was found on the floor. IMG-2024030809504750471261787.jpg Photographer: Jon Jones 61.21694381, -149.86941558 9 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 [Title] IMG-202403080951015111255152.jpg 03/08/2024 09:51 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Adjacent to lift 9 61.21694995, -149.86946102 Another view of the waste aerosol can that was found on the floor. [Title] IMG-2024030810115011501336228.jpg 03/08/2024 10:11 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Special Tool Room 61.21692873, -149.86949992 View of four-foot waste fluorescent lamps in a box in the Special Tool Room. 10 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 [Title] IMG-2024030810115711571306737.jpg 03/08/2024 10:11 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department/Special Tool Room 61.21704442, -149.86971323 Close-up view of four-foot waste fluorescent lamps in a box in the Special Tool Room. [Title] IMG-2024030810135613561317899.jpg 03/08/2024 10:13 AM (AKT) No CBI No PII Photographer: Jon Jones BMW Service Department 61.21691002, -149.86930025 View of the facility's solvent parts washer that uses a high flash (143F) solvent. 11 of 12 BMW of Anchorage Inspection Date(s): 03/08/2024 - 03/08/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Used Oil Disposal Receipts Copy of Used Oil No No Jon Jones recycling Invoice_79903.pdf Other - Battery Recycling East Penn Battery Core No No Jon Jones Invoice Pick-up Slip.pdf Other - Parts washer Dyna Super Brute parts No No Jon Jones information washer Info.docx 03/27/2024 03/27/2024 03/08/2024 12 of 12