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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 07/09/2024 08:39 AM (AKT) Announced: No 07/09/2024 02:07 PM (AKT) Access: Granted Resource Conservation and Recovery Act (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 Alaska Railroad Corporation Alaska Railroad Corporation AKD981767403 327 W Ship Creek Ave Anchorage, AK 99501 N/A Small Quantity Generator (SQG) 482112 - Short Line Railroads Transportation, railroads 61.221744, -149.87957 Matt Kelzenberg, Manager Environmental Operations/ Alaska Railroad PO Box 107500 Anchorage, AK 99510-7500 (907) 265-2384 kelzenbergm@akrr.com City, State, Zip Code Anchorage, AK 99510-7500 Permit Number (If Applicable) N/A Lead Inspector: Jon Jones Jones, Jon EPA Region 10 Digitally signed by Jones, Jon Date: 2024.10.11 12:13:18 -08'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Matthew Quarterman MATTHEW QUARTERMAN Date: 2024.10.11 14:06:28 -07'00' 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: CEI EPA Region 10 Lead Inspector, Jon Jones, arrived at the Alaska Railroad Corp Facility (the "Site" or "Facility"), located at 327 W Ship Creek Ave, Anchorage, AK 99501, at 08:39 AM (AKT) on 07/09/2024 for an unannounced 1 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 inspection. EPA Region 10 Lead Inspector presented credentials to and informed Matt Kelzenberg (Manager Environmental Operations) that this was an EPA Region 10 inspection to determine compliance with 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 Alaska Railroad Corp 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 Phone Lead Inspector/EPA REGION 10 Jon Jones (907) 2716329 Inspector/Enforcement Xiangyu Chu Officer/EPA REGION 10 (206) 5532859 RCRA Inspector-intraining/ Alaska Department of Environmental Conservation (ADEC) Vanessa Schmidt (907) 2694581 RCRA Inspector-intraining/ADEC Sable McGovern (907) 2694556 RCRA Inspector-intraining/ADEC Emily (907) 269- Vannortwick 4580 Field Safety Officer/ Alaska Railroad Erick White (907) 2652691 Hazardous Materials Specialist/ Alaska Railroad Demario Jones (907) 2652435 Manager Environmental Operations/ Alaska Railroad Matt Kelzenberg (907) 2652384 Email Jones.Jon@epa.gov Opening Conf. Yes Chu.xiangyu@epa.gov Yes Vanessa.schmidt@alaska.gov Yes Sable.mcgovern@alaska.gov Yes Emily.vannortwick@alaska.gov Yes Whitee@akrr.com No Jonesd@akrr.com No Kelzenbergm@akrr.com Yes Closing Conf. Yes Yes Yes Yes Yes Yes Yes Yes Opening Conference After arriving at the facility, Xiangyu Chu (EPA Inspector), Vanessa Schmidt (ADEC Inspector-in-training), Sable McGovern (ADEC Inspector-in-training), Emily Vannortwick (ADEC Inspector-in-training), and I were met by Matt Kelzenberg (Manager Environmental Operations). I presented him with my credentials, provided him with my 2 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 business card, and informed him of the purpose of the inspection. He brought us to a conference room within his office building and we began the opening conference. During the opening conference, Mr. Kelzenberg explained the facility's operations and described the facility's waste streams. He stated that the facility is generally a very small quantity generator (VSQG), despite the SQG status listed in RCRAInfo. He reported that the only instances in which they reach SQG status is during changeouts. Because of this VSQG status and the small amounts of hazardous waste they generate, he reported that most of their waste goes to the landfill. I inquired on the process for sending waste to the landfill. Mr. Kelzenberg stated that to his knowledge this was applicable only to aerosol cans and paints, but he requested that we speak to Demario Jones (Hazardous Materials Specialist) to get more details. He also stated that there had not been many process changes within the facility since the last inspection in 2018. A change that he did note is that they had switched out the use of Ni-Cad batteries, so these were no longer present in large quantities at the facility. When asked about the "transporter" status listed in RCRAInfo, Mr. Kelzenberg stated that they are not a transporter. He reported that they use Clean Harbors or Republic Services for large shipments of waste or send their waste to the landfill as mentioned prior. I asked about the two EPA ID numbers listed in RCRAInfo, one based at the facility address and another for a location on Viking Road. Mr. Kelzenberg stated that the Viking Road address is a completed cleanup site from 20 years ago in which sludge was being removed from retention ponds. He reported that there is nothing at that site currently. In relation to multiple EPA IDs, Mr. Kelzenberg also noted that they will occasionally lease a section of track within their yard to contractors that need to clean out their rail cars. He stated that to do this, companies will get their own EPA ID numbers but perform the cleaning itself on Alaska Railroad property. He noted that rail cars handling hazardous materials must be recertified every 25 years and this is done by the rail car owners. To re-certify, owners cut into the rail car and inspect it, but they first must clean out the car by scrubbing it. He stated that the last time this was done at the facility was last summer. He noted that this does not occur yearly and that generally there is an average of 10 rail cars being cleaned at a time. He reported that Republic Services is a company that often does this. I requested records on this, and he stated that he would ask their real estate department for the track leases with EPA ID numbers. Mr. Kelzenberg provided us with a facility map. We discussed the records we would need to review at the end of this inspection which included manifests, training, and weekly inspections. We were accompanied throughout the inspection by Mr. Kelzenberg, Mr. Jones, and Erick White (Field Safety Officer). We were not denied access to any part of the facility, and we were allowed to take photographs. Facility/Site Information What type of generator facility verified as? SQG occasionally, VSQG more regularly What type of SQG generator facility notified? Size of Facility 100 acres Length of Facility at Location 100 years Number of employees 700 during the summer, 500 year-round 3 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Process Description The Alaska Railroad Corp is a freight and passenger railroad company. Hazardous waste generated at this facility comes from the maintenance of locomotives, equipment, and facilities. Waste streams generated at this facility include aerosol cans, used oil, diesel, absorbent pads, batteries, petroleum products, contaminated debris from clean ups, and lamps. During the inspection we examined the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representative had not yet identified or designated as hazardous. We also observed the facility's universal waste management. Specifically, we inspected the areas of the facility listed below. Building(s) Building/Area/Sub-area 5K Used Oil Tank Building Satellite Accumulation Area (SAA) Boiler Plant BLDG 29 Outside Bldg 29 SAA Central Accumulation Area (CAA) General Repair Shop BLDG 27 SAA Car Shop BLDG 28 SAA Diesel Shop Center Aisle SAA Oil Filter Crushing Electric Rewind Shop SAA Heavy Equipment Shop SAA Wheelhouse SAA Process Description Area of Concern N/A Yes Used Oil Yes N/A Yes Miscellaneous waste containers Yes Lamps, batteries, paints, aerosol cans, Yes miscellaneous items awaiting waste determinations N/A Yes Used oil Yes N/A Yes Aerosol cans Yes N/A Yes Used oil, aerosol cans Yes Used oil, oil filters Yes N/A Yes Aerosol cans, used oil Yes N/A Yes Aerosol cans Yes N/A Yes Aerosol cans, parts washer solvent Yes SECTION II - OBSERVATIONS Building: Boiler Plant BLDG 29/ CAA Observation #: JJ1-OB-001 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer This building contains the facility's CAA and is also where their records are stored. Upon arriving, we reviewed some of the facility's paperwork, specifically their waste tracking, and were introduced to Mr. Jones. Mr. Jones stated that he handles the hazardous waste generated at the facility exclusively. He reported that the month prior to the inspection the facility generated less than 150 pounds of hazardous waste and that the only 4 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 hazardous waste on site at the time of the inspection was waste aerosol cans, of which he stated they had ~88 pounds. When asked how waste is disposed of, he stated that he brings it to the Eagle River Landfill. He stated that waste streams brought to the landfill for disposal includes aerosol cans, mini fridges and freezers, and asbestos. He had receipts for these drop offs which he presented to us. He reported that his last drop off to the landfill was last month. When asked about how waste batteries are handled, he stated that batteries, e-waste, ballasts, and bulbs go to Total Reclaim, and some batteries also go to Battery Plus and Batteries Specialists. He stated that Republic Services takes the facility's solvents, used oil, and absorbents, and that Clean Harbors takes their sludge and antifreeze. He reported that they do not have waste from pesticides because they use these materials in totality whenever possible. He stated that they use an internal manifest system to track waste streams and that they keep logs of containers and wastes present in the CAA. We were also introduced to Mr. White, who was in Mr. Jones's position prior. At the time of the inspection, we observed two containers of used lamps that were not closed. We also observed that the universal waste labels associated with these containers were attached to the container stands, instead of the containers themselves. Mr. Jones closed these containers during the inspection and made note that they are normally kept closed. He stated he would attach the labels to the containers. At the time of the inspection, we observed two used lamps sitting out on top of a used lamps container. Mr. Jones placed these lamps in the appropriate universal waste container and closed it. He noted that normally lamps go into the appropriate containers immediately and are not left out. At the time of the inspection, we observed a used bulb in a container of batteries. Mr. Jones removed this bulb and placed it in the appropriate universal waste container. At the time of the inspection, we observed one broken lamp in a trash can. At the time of the inspection, we observed 10 containers stacked in a pile. These containers appeared to be waste paints based on the product label. We also observed two containers of lubricant and two containers of `black cement". I asked Mr. Jones if these were waste. He stated that these materials arrived at the CAA two weeks ago and were waste, but he noted that he had yet to make a hazardous waste determination. We requested the waste determinations and safety data sheets (SDS) for these waste streams. At the time of the inspection, we observed waste aerosol cans in an open wheeling cart labeled as "nonhazardous". This container was not labeled as "hazardous waste", nor did it have a hazard indicator, or an accumulation start date. We also observed a blue container with waste aerosol cans that was closed and labeled "empty aerosol cans". This container was not labeled as "hazardous waste", nor did it have a hazard indicator, or an accumulation start date. Mr. Jones stated that the blue container is used to place waste aerosol cans into the wheeling cart and is not meant to accumulate waste aerosol cans. At the time of the inspection, we observed two waste aerosol cans sitting out on top of a bucket. Mr. Jones placed these into the appropriate hazardous waste container. At the time of the inspection, we observed a container of NiCad batteries and a container of lithium batteries each with an accumulation start date of 3/20/23. This was over one year of accumulation at the time of the inspection. Mr. Jones reported that he believed these dates to be incorrect and he stated that the actual accumulation start dates were February 2024. Building: Boiler Plant BLDG 29/ Outside BLDG 29 SAA Observation #: JJ1-OB-002 Date: 07/09/2024 Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Erick White Contains AOC: Yes Contains CBI: No Title(s): Manager Environmental Operations, Hazardous Materials Specialist, Field Safety Officer 5 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 At the time of the inspection, we observed several miscellaneous containers of unknown materials outside of the CAA. This included a full 55-gallon container labeled "PF solvent used" and a tote labeled "bad", as well as an unlabeled blue container. Mr. Jones stated that he believed one of these containers to be a mix of oil and water and another to be a mix of diesel and water. He was unsure what the "PF solvent" was. Mr. Jones stated that he believed these materials to be wastes, but he noted that he had not yet made a hazardous waste determination. We requested the waste determinations and safety data sheets (SDS) for these waste streams. Building: Car Shop BLDG 28/ SAA Observation #: JJ1-OB-003 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed a waste aerosol can in a container labeled "hazardous material". This container was closed but it was not labeled as "hazardous waste", nor did it have a hazard indicator. Mr. Jones showed us a flammable locker in this building. He stated that these lockers are used to hold aerosol cans when they are a product. He reported that shop personnel decide when an aerosol can is empty and place it in the SAA container. This is then brought to the CAA where Mr. Jones makes the final determination on if they are a waste. He stated that often materials brought to him are indeed wastes. Building: Wheelhouse/ SAA Observation #: JJ1-OB-004 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed a bucket and Mr. White told me it contained parts washer solvent sediment. This container was labeled with the words "hazardous waste" but was not marked with a hazard indicator. The log associated with this bucket stated that it had been onsite since 2/9/16. Building: General Repair Shop BLDG 27/ SAA Observation #: JJ1-OB-005 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed two buckets and were told by Mr. Jones that they contained used oil but were not labeled with the words "used oil". We also observed two jugs and were told by Mr. Jones that they contained used oil but were not labeled with the words "used oil". Mr. Jones reported that these containers were likely waiting to be transferred to the main used oil container for storage. At the time of the inspection, we observed a parts washer with used oil in a collection container that was not labeled with the words "used oil". This machine was not running at the time of the inspection. Shop personnel reported that they take sludge and used oil from the parts washer, but they were unclear of where the sludge from this machine was sent. We requested additional information on this process, specifically where the sludge is sent for disposal. At the time of the inspection, we observed what appeared to be an old oil spill on the floor by the parts washer that had not been cleaned. 6 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Mr. Jones stated that he would label all of the containers holding used oil with the words "used oil" and that they would clean the oil spill. Building: Electric Rewind Shop/ SAA Observation #: JJ1-OB-006 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed multiple waste aerosol cans in a container that was labeled "hazardous material". This container was closed but it was not labeled as "hazardous waste", nor did it have a hazard indicator. This container had a pre-made label stating that it was emptied daily. Upon inquiring about this, Mr. Jones confirmed that these containers are indeed emptied every 24-32 hours and that the amount present in this container represented an average accumulation over 24 hours for an SAA in the facility. At the time of the inspection, we observed, and were told by Mr. White, that the two drip containers held used oil, but were not labeled with the words "used oil". At the time of the inspection, we observed a paint sprayer in this building. I inquired about the product used in this machine and Mr. Jones stated that he was unsure. Mr. White reported that this product was analyzed five years prior and was determined to be nonhazardous. He stated that he would send these analytical results. Building: Diesel Shop/ Center Aisle SAA Observation #: JJ1-OB-007 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed a shelving unit with a container of oily waste at the bottom. This container was not labeled with the words "used oil". At the time of the inspection, we observed a container of what appeared to be a mix of sludge, water, and oil. This container was not labeled with the words "used oil". Mr. Jones stated that this material was from cleaning tracks, but he was unsure of what exactly the sludge was composed of. Mr. White stated that he believed the sludge to be dirt and that the container likely contained dirt, water, and a small amount of oil. We requested that they determine what this container contained and provide us with the results. At the time of the inspection, we observed two containers and were told by Mr. Jones that they contained used oil, but they were not labeled with the words "used oil". At the time of the inspection, we observed waste aerosol cans in a container labeled "hazardous material". This container was closed but it was not labeled as "hazardous waste", nor did it have a hazard indictor. Building: Diesel Shop/ Oil Filter Crushing SAA Observation #: JJ1-OB-008 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer This area of the Diesel Shop is where used oil filters are crushed. Mr. Jones stated that the process to crush oil filters is as such: oil filters are placed in a cart to drain and then crushed in the oil filter crusher. When crushed, oil drains into a bucket which is then emptied into one of two carts that are then taken to the CAA. 7 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 At the time of the inspection, we observed three carts labeled with the words "waste oil". One cart contained draining oil filters and the other two contained used oil. We also observed a bucket collecting used oil from the filter crusher which was not labeled with the words "used oil". Building: Heavy Equipment Shop/ SAA Observation #: JJ1-OB-009 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed waste aerosol cans in a container labeled "hazardous material". This container was closed but it was not labeled as "hazardous waste", nor did it have a hazard indicator. Building: 5K Oil Tank/ SAA Observation #: JJ1-OB-010 Date: 07/09/2024 Contains AOC: Yes Contains CBI: No Person(s) Interviewed: Matt Kelzenberg, Demario Jones, Title(s): Manager Environmental Operations, Erick White Hazardous Materials Specialist, Field Safety Officer At the time of the inspection, we observed a bucket containing what appeared to be used oil. Mr. Jones told us that this was a used oil container, but it was not labeled with the words "used oil". 8 of 68 Alaska Railroad Corp Inspection Date(s): SECTION III - RECORDS REVIEW 07/09/2024 - 07/09/2024 Record: Inspections Ref #: N/A Reviewed By: Vanessa Scmidt AOC: Yes Reviewed Date: 07/09/24 At the time of the inspection, three years (2021-2024) of weekly inspections of the CAA were reviewed. There were found to be 29 missing inspections for the following weeks: 2021: 2022: 2023: 7/25/21-7/31/21 8/8/21-8/14/21 8/22/21-8/28/21 8/29/21-9/4/21 9/12/21-9/18/21 9/26/21-10/2/21 10/3/21-10/9/21 11/21/21-11/27/21 4/17/22-4/23/22 4/24/22-4/30/22 6/5/22-6/11/22 6/12/22-6/18/22 6/19/22-6/25/22 6/26/22-7/2/22 7/3/22-7/9/22 8/7/22-8/13/22 9/11/22-9/17/22 10/23/22-10/29/22 11/6/22-11/12/22 11/20/22-11/26/22 12/25/22-12/31/22 5/14/23-5/20/23 7/2/23-7/8/23 7/9/23-7/15/23 10/8/23-10/14/23 10/15/23-10/21/23 10/22/23-10/28/23 10/29/23-11/4/23 12/24/23-12/30/23 Mr. Jones reported that missing these inspections was not deliberate. He stated that he is the only employee who can conduct the weekly inspections so when he is unavailable or out of office, they do not get done. Mr. White confirmed that this was the case when he was in this position as well. I recommended that they find an alternate who could perform these inspections in situations where the Hazardous Materials Specialist is unavailable to ensure that they are completed weekly as required. They were both amenable to this idea. Record: Manifests Ref #: N/A Reviewed By: Vanessa Schmidt AOC: No Reviewed Date: 07/09/24 At the time of the inspection, manifests were reviewed. Mr. Jones stated that there was only one manifest for the last three years (2021-2024) and this was in January 2024. He reiterated that waste is otherwise disposed of at the Eagle River landfill, and he provided receipts of this. All documents reviewed appeared to support a generator status of a VSQG. Record: Training Records Ref #: N/A Reviewed By: Vanessa Schmidt AOC: No Reviewed Date: 07/09/24 At the time of the inspection, we requested that Mr. Jones send us copies of facility training plans and the log for training received by facility personnel. He stated that he would send this following the inspection. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA Sub-area: 9 of 68 Alaska Railroad Corp Inspection Date(s): Two waste lamp containers not closed Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Two waste lamps containers with universal waste labels not affixed to containers Area: CAA Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA Two waste lamps not contained in appropriate universal waste container Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA One waste bulb in a container of batteries, not contained in appropriate universal waste container Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA One broken lamp in a trash can, not Regulation: contained in appropriate universal waste container Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA Two containers of waste batteries Regulation: with greater than 1 year in storage Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA Waste aerosol cans managed as non-hazardous waste Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA 10 of 68 07/09/2024 - 07/09/2024 Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Alaska Railroad Corp Inspection Date(s): Waste aerosol can container not closed Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Two waste aerosol can containers not labeled with words "hazardous waste", a hazard indictor, nor an accumulation start date. Area: CAA Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA Several waste containers without a hazardous waste determination made at the point of generation Regulation: Building: Boiler Plant BLDG 29 JJ1-OB-001 Area: CAA Two waste aerosol cans not Regulation: contained in appropriate hazardous waste container Building: Boiler Plant BLDG 29 JJ1-OB-002 Area: Outside Bldg 29 SAA Several waste containers without a hazardous waste determination made at the point of generation Regulation: Building: Car Shop BLDG 28 JJ1-OB-003 Area: SAA One container of waste aerosol cans Regulation: not labeled with words "hazardous waste" nor a hazard indictor Building: General Repair Shop BLDG Area: SAA 27 JJ1-OB-005 Five containers of used oil, not labeled "used oil" Regulation: Building: General Repair Shop BLDG Area: SAA 27 11 of 68 07/09/2024 - 07/09/2024 Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Alaska Railroad Corp Inspection Date(s): JJ1-OB-005 Oil spill observed on floor, not cleaned up Regulation: Building: Electric Rewind Shop JJ1-OB-006 Area: SAA One container of waste aerosol cans Regulation: not labeled with words "hazardous waste" nor a hazard indictor Building: Electric Rewind Shop JJ1-OB-006 Area: SAA Two containers of used oil, not labeled "used oil" Regulation: Building: Diesel Shop JJ1-OB-007 Area: Center Aisle SAA Four containers of used oil, not labeled "used oil" Regulation: Building: Diesel Shop JJ1-OB-008 Area: Center Aisle SAA One container of waste aerosol cans Regulation: not labeled with words "hazardous waste" nor a hazard indictor Building: Diesel Shop JJ1-OB-008 Area: Oil Filter Crushing SAA Four containers of used oil, not labeled "used oil" Regulation: Building: Heavy Equipment Shop JJ1-OB-009 Area: SAA One container of waste aerosol cans Regulation: not labeled with words "hazardous waste" nor a hazard indictor Building: 5K Oil Tank JJ1-OB-010 Area: SAA 07/09/2024 - 07/09/2024 Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sub-area: 12 of 68 Alaska Railroad Corp Inspection Date(s): One container of used oil, not labeled "used oil" Regulation: Building: Wheelhouse JJ1-OB-004 Area: SAA One container of hazardous waste, Regulation: not marked with a hazard indicator Record: Inspections N/A Missing 29 weekly inspections Regulation: 07/09/2024 - 07/09/2024 Sections: Sub-area: Sections: Sections: SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference Following the review of paperwork, I held a closing conference to discuss the findings of my inspection. This was attended by Matt Kelzenberg, Erick White, and Demario Jones I reiterated that the purpose of the inspection was to perform a routine hazardous waste compliance inspection and I thanked the facility staff for their time and cooperation. I reviewed the areas of concern that were identified during the inspection. This included: Universal waste containers not properly closed Universal waste labels not affixed to universal waste containers Universal waste not contained in universal waste containers Failure to make a hazardous waste determination made at the point of generation Hazardous waste managed as non-hazardous waste Hazardous waste containers without appropriate hazardous waste labeling in CAA ("hazardous waste", hazard indictor, accumulation start date) Hazardous waste containers not properly closed Hazardous waste not contained in hazardous waste containers Universal waste accumulated for over a year Hazardous waste containers without labels including words "hazardous waste" and a hazard indicator in SAAs Used oil containers not labeled with words "used oil" An oil spill not being cleaned up Missing weekly inspections The ability to address the areas of concern described and send photos was discussed. I also reiterated the information requested as follow up during the inspection. I answered any questions they had and explained the follow up process. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 13 of 68 Alaska Railroad Corp Inspection Date(s): 1. Photo Log 2. Document Log 07/09/2024 - 07/09/2024 14 of 68 Alaska Railroad Corp Inspection Date(s): APPENDIX 1: PHOTO LOG 07/09/2024 - 07/09/2024 Closed waste lamp container in CAA 07/09/24 No CBI Boiler Plant BLDG 29/ CAA Waste lamp container after being closed. No PII IMG-20240709095350535073413.jpg N/A N/A Open waste lamp container in CAA IMG-20240709093431343166406.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Open waste lamp container with lamps inside and label affixed to stand, not container. 15 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Open waste lamp container in CAA IMG-20240709093431343167507.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Open waste lamp container with lamps inside and label affixed to stand, not container. Waste lamps not in container in CAA IMG-20240709093543354348819.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste lamps sitting in the lid of the waste lamp container, not properly contained. 16 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Open waste lamp container in CAA 07/09/24 No CBI No PII Boiler Plant BLDG 29/ CAA Lamps inside of an open waste lamp container. IMG-20240709093925392538512.jpg N/A N/A Broken lamp in a trash can in CAA 07/09/24 No CBI No PII Boiler Plant BLDG 29/ CAA Broken lamp in a trash can, not properly contained. IMG-20240709095022502269968.jpg N/A N/A 17 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Open waste lamp container in CAA IMG-20240709095334533471072.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Open waste lamp container with lamps inside and label affixed to stand, not container. Open waste lamp container in CAA IMG-20240709095337533782175.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Open waste lamp container with lamps inside and lid sitting nearby. 18 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Universal waste lithium batteries in CAA with accumulation over one year IMG-202407091004064666326.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Universal waste lithium batteries accumulated for over one year. Open waste lamp container in CAA IMG-20240709095431543168403.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Open waste lamp container with lamps inside and lid hanging off. 19 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Closed waste lamp container in CAA 07/09/24 No CBI No PII Boiler Plant BLDG 29/ CAA Waste lamp container with lamps inside, closed. IMG-20240709095449544994993.jpg N/A N/A Waste bulb in container of batteries in CAA IMG-20240709095728572834723.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste bulb in a container of batteries, not properly contained. 20 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste bulb in container of batteries in CAA IMG-20240709095731573137486.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste bulb in a container of batteries, not properly contained. Universal waste NiCad batteries in CAA with accumulation over one year IMG-2024070910015115150328.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Universal waste NiCad batteries accumulated for over one year. 21 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Universal waste NiCad batteries in CAA with accumulation over one year IMG-2024070910022922958057.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Universal waste NiCad batteries accumulated for over one year. Universal waste NiCad batteries in CAA with accumulation over one year IMG-2024070910023523559299.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Universal waste NiCad batteries accumulated for over one year. 22 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown containers in CAA IMG-20240709101558155869381.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. Universal waste NiCad batteries in CAA with accumulation over one year IMG-2024070910043843859674.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Universal waste Ni-Cad batteries accumulated for over one year. 23 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Universal waste lithium batteries in CAA with accumulation over one year IMG-2024070910044344361174.jpg 07/09/24 07/09/24 07/09/24 N/A Boiler Plant BLDG 29/ CAA N/A Universal waste lithium batteries accumulated for over one year. Waste aerosol can accumulation in containers in CAA 07/09/24 No CBI No PII Boiler Plant BLDG 29/ CAA Waste aerosol can accumulation in CAA IMG-2024070910091491473678.jpg N/A N/A 24 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol can accumulation in open container in CAA IMG-2024070910091791761667.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste aerosol can container labeled as non-hazardous waste. Waste aerosol can accumulation in open container in CAA IMG-2024070910092092089391.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste aerosol cans in bag, in an open container labeled as "non-hazardous". 25 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol can accumulation in open container in CAA IMG-20240709101220122055279.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste aerosol cans in open container labeled "non-hazardous waste". Waste aerosol can accumulation in container in CAA IMG-20240709101223122358898.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Waste aerosol can accumulation in container labeled "empty aerosol cans". 26 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 "Black cement" containers in CAA IMG-2024070910220322384129.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Two containers of "black cement" in unknown materials pile without a hazardous waste determination. Unknown containers in CAA IMG-20240709101618161875285.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. 27 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown containers in CAA IMG-202407091016231623101017.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. Unknown containers in CAA IMG-20240709101630163069358.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. 28 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol cans not contained in CAA 07/09/24 No CBI No PII Boiler Plant BLDG 29/ CAA Two waste aerosol cans not in appropriate container. IMG-2024070910170717791964.jpg N/A N/A Waste aerosol cans not contained in CAA 07/09/24 No CBI No PII Boiler Plant BLDG 29/ CAA Two waste aerosol cans not in appropriate container. IMG-20240709101754175461182.jpg N/A N/A 29 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown containers in CAA IMG-20240709102031203180944.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. Unknown containers in CAA IMG-2024070910210321394717.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. 30 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown containers outside of CAA IMG-20240709103009309101190.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown containers outside of CAA without hazardous waste determinations. "Black cement" containers in CAA IMG-20240709102234223481031.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Two containers of "black cement" in unknown materials pile without a hazardous waste determination. 31 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown containers in CAA IMG-20240709102258225872482.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ CAA N/A Containers of unknown materials without hazardous waste determinations. Unknown containers outside of CAA IMG-202407091026432643117435.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown containers outside of CAA without hazardous waste determinations. 32 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown containers outside of CAA IMG-202407091026502650106465.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown containers outside of CAA without hazardous waste determinations. Container of PF Solvent outside of CAA IMG-20240709102653265376271.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Container of PF Solvent outside of CAA without a hazardous waste determination. 33 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Label on container of PF Solvent outside of CAA IMG-202407091027482748140039.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Label on container of PF Solvent outside of CAA without a hazardous waste determination. Unknown container outside of CAA IMG-20240709103002302101814.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown container outside of CAA without a hazardous waste determination. 34 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol cans in container in CAA 07/09/24 No CBI Boiler Plant BLDG 29/ CAA Waste aerosol cans in container in CAA. No PII IMG-20240709104810481081433.jpg N/A N/A Unknown containers outside of CAA IMG-20240709103024302492162.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown containers outside of CAA without hazardous waste determinations. 35 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Unknown container outside of CAA IMG-202407091033343334118344.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown container outside of CAA labeled with word "BAD" without a hazardous waste determination. Unknown container outside of CAA IMG-202407091033373337120164.jpg 07/09/24 No CBI No PII N/A Boiler Plant BLDG 29/ Outside BLDG 29 SAA N/A Unknown container outside of CAA labeled with word "BAD" without a hazardous waste determination. 36 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Car Shop SAA IMG-20240709104024402497162.jpg 07/09/24 No CBI No PII N/A Car Shop BLDG 28/ SAA N/A Waste aerosol accumulation container labeled "hazardous material". Waste aerosol accumulation container in Car Shop SAA IMG-20240709104031403193496.jpg 07/09/24 No CBI No PII N/A Car Shop BLDG 28/ SAA N/A Waste aerosol accumulation container with a waste aerosol can present inside, labeled "hazardous material". 37 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Car Shop SAA IMG-20240709104036403689454.jpg 07/09/24 No CBI No PII N/A Car Shop BLDG 28/ SAA N/A Waste aerosol accumulation container labeled "hazardous material". Waste aerosol accumulation container in Car Shop SAA IMG-20240709104040404078313.jpg 07/09/24 No CBI No PII N/A Car Shop BLDG 28/ SAA N/A Waste aerosol accumulation container labeled "hazardous material". 38 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Bucket of hazardous waste in Wheelhouse SAA 07/09/24 No CBI No PII Wheelhouse/ SAA Bucket of hazardous waste without a hazard indicator. IMG-202407091100000092062.jpg N/A N/A Waste aerosol accumulation container in Car Shop SAA IMG-20240709104813481388584.jpg 07/09/24 No CBI No PII N/A Car Shop BLDG 28/ SAA N/A Waste aerosol accumulation container labeled "hazardous material"; however, no waste aerosol cans present in container at time of inspection. 39 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Car Shop SAA IMG-20240709104930493078773.jpg 07/09/24 No CBI No PII N/A Car Shop BLDG 28/ SAA N/A Waste aerosol accumulation container labeled "hazardous material"; however, no waste aerosol cans present in container at time of inspection. Bucket of hazardous waste in Wheelhouse SAA 07/09/24 No CBI No PII Wheelhouse/ SAA Bucket of hazardous waste without a hazard indicator. IMG-20240709105912591265309.jpg N/A N/A 40 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Log for bucket of hazardous waste in Wheelhouse SAA IMG-20240709105948594861670.jpg 07/09/24 No CBI No PII N/A Wheelhouse/ SAA N/A Log for bucket of hazardous waste without a hazard indicator. Log for bucket of hazardous waste in Wheelhouse SAA IMG-20240709105948594871328.jpg 07/09/24 No CBI No PII N/A Wheelhouse/ SAA N/A Log for bucket of hazardous waste without a hazard indicator. 41 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Log for bucket of hazardous waste in Wheelhouse SAA IMG-20240709105949594973171.jpg 07/09/24 No CBI No PII N/A Wheelhouse/ SAA N/A Log for bucket of hazardous waste without a hazard indicator. Bucket of hazardous waste in Wheelhouse SAA 07/09/24 No CBI No PII Wheelhouse/ SAA Bucket of hazardous waste without a hazard indicator. IMG-20240709105957595787475.jpg N/A N/A 42 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Parts washer used oil collection container in General Repair Shop SAA IMG-202407091112441244111583.jpg 07/09/24 No CBI No PII N/A General Repair Shop BLDG 27/ SAA N/A Used oil collection container on parts washer, not labeled "used oil". Log for bucket of hazardous waste in Wheelhouse SAA IMG-2024070911001601673356.jpg 07/09/24 No CBI No PII N/A Wheelhouse/ SAA N/A Log for bucket of hazardous waste without a hazard indicator. 43 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Buckets of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two buckets of used oil, not labeled "used oil". IMG-2024070911083983999988.jpg N/A N/A Buckets of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two buckets of used oil, not labeled "used oil". IMG-2024070911084784775541.jpg N/A N/A 44 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Buckets of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two buckets of used oil, not labeled "used oil". IMG-2024070911085585583517.jpg N/A N/A Buckets of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two buckets of used oil, not labeled "used oil". IMG-20240709111032103295383.jpg N/A N/A 45 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Jugs of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two jugs of used oil, not labeled "used oil". IMG-20240709111111111191032.jpg N/A N/A Jugs of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two jugs of used oil, not labeled "used oil". IMG-202407091111151115105608.jpg N/A N/A 46 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil drip pan in Electric Rewind Shop SAA 07/09/24 No CBI No PII Electric Rewind Shop/ SAA Drip pan of used oil, not labeled "used oil". IMG-20240709113121312180696.jpg N/A N/A Parts washer used oil collection container in General Repair Shop SAA IMG-202407091112511251103717.jpg 07/09/24 No CBI No PII N/A General Repair Shop BLDG 27/ SAA N/A Used oil collection container on parts washer, not labeled "used oil". 47 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Buckets of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two buckets of used oil, not labeled "used oil". IMG-202407091113161316100224.jpg N/A N/A Buckets of used oil in General Repair Shop SAA 07/09/24 No CBI No PII General Repair Shop BLDG 27/ SAA Two buckets of used oil, not labeled "used oil". IMG-202407091113171317102617.jpg N/A N/A 48 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Electric Rewind Shop SAA IMG-20240709111752175285018.jpg 07/09/24 No CBI No PII N/A Electric Rewind Shop/ SAA N/A Waste aerosol accumulation container labeled "hazardous material". Waste aerosol accumulation container in Electric Rewind Shop SAA IMG-2024070911180318373870.jpg 07/09/24 No CBI No PII N/A Electric Rewind Shop/ SAA N/A Waste aerosol accumulation container labeled "hazardous material" with multiple waste aerosol cans inside. 49 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Electric Rewind Shop SAA IMG-20240709111821182187816.jpg 07/09/24 No CBI No PII N/A Electric Rewind Shop/ SAA N/A Waste aerosol accumulation container labeled "hazardous material". Waste aerosol accumulation container in Electric Rewind Shop SAA IMG-20240709111826182684428.jpg 07/09/24 No CBI No PII N/A Electric Rewind Shop/ SAA N/A Waste aerosol accumulation container labeled "hazardous material" with multiple waste aerosol cans inside. 50 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Shelving unit with oily waste at bottom in Diesel Shop IMG-20240709113723372388463.jpg Center Aisle SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Shelving unit with oily waste at bottom, not labeled "used oil". Used oil drip pan in Electric Rewind Shop SAA 07/09/24 No CBI No PII Electric Rewind Shop/ SAA Drip pan of used oil, not labeled "used oil". IMG-20240709113149314988767.jpg N/A N/A 51 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil drip pan in Electric Rewind Shop SAA 07/09/24 No CBI No PII Electric Rewind Shop/ SAA Drip pan of used oil, not labeled "used oil". IMG-202407091133493349101388.jpg N/A N/A Used oil drip pan in Electric Rewind Shop SAA 07/09/24 No CBI No PII Electric Rewind Shop/ SAA Drip pan of used oil, not labeled "used oil". IMG-20240709113350335098142.jpg N/A N/A 52 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Shelving unit with oily waste at bottom in Diesel Shop IMG-20240709113639363983050.jpg Center Aisle SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Shelving unit with oily waste at bottom, not labeled "used oil". Shelving unit with oily waste at bottom in Diesel Shop IMG-20240709113640364089811.jpg Center Aisle SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Shelving unit with oily waste at bottom, not labeled "used oil". 53 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Shelving unit with oily waste at bottom in Diesel Shop IMG-20240709113643364376899.jpg Center Aisle SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Shelving unit with oily waste at bottom, not labeled "used oil". Shelving unit with oily waste at bottom in Diesel Shop IMG-20240709113644364481298.jpg Center Aisle SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Shelving unit with oily waste at bottom, not labeled "used oil". 54 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil container in Diesel Shop Center Aisle SAA 07/09/24 No CBI No PII Diesel Shop/ Center Aisle SAA Used oil container, not labeled "used oil". IMG-20240709114604464108815.jpg N/A N/A Waste aerosol accumulation container in Diesel Shop Center Aisle SAA IMG-2024070911380538563998.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Waste aerosol accumulation container labeled as "hazardous material". 55 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Diesel Shop Center Aisle SAA IMG-2024070911380938977968.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Waste aerosol accumulation container labeled as "hazardous material". Waste aerosol accumulation container in Diesel Shop Center Aisle SAA IMG-20240709113819381979970.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Waste aerosol accumulation container labeled "hazardous material" with multiple waste aerosol cans inside. 56 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Container of sludge, oil, and water in Diesel Shop Center Aisle SAA IMG-202407091143354335102422.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Container of sludge, water, and oil, not labeled "used oil". Container of sludge, oil, and water in Diesel Shop Center Aisle SAA IMG-2024070911440044063979.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Container of sludge, water, and oil, not labeled "used oil". 57 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Container of sludge, oil, and water in Diesel Shop Center Aisle SAA IMG-20240709114406446857100.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Center Aisle SAA N/A Container of sludge, water, and oil, not labeled "used oil". Used oil container in Diesel Shop Center Aisle SAA 07/09/24 No CBI No PII Diesel Shop/ Center Aisle SAA Used oil container, not labeled "used oil". IMG-20240709114559455995999.jpg N/A N/A 58 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Carts of used oil from oil filter crushing in Diesel Shop IMG-20240709115539553991931.jpg SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA N/A Carts used to remove used oil after oil filters are crushed, labeled "waste oil". Used oil container in Diesel Shop Center Aisle SAA 07/09/24 No CBI No PII Diesel Shop/ Center Aisle SAA Used oil container, not labeled "used oil". IMG-202407091146124612116236.jpg N/A N/A 59 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil collection container in Diesel Shop Oil Filter Crushing SAA IMG-20240709115216521684351.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA N/A Container used to collect used oil when crushing used oil filters, not labeled "used oil". Used oil collection container in Diesel Shop Oil Filter Crushing SAA IMG-20240709115219521999265.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA N/A Container used to collect used oil when crushing used oil filters, not labeled "used oil". 60 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil container in Diesel Shop Center Aisle SAA 07/09/24 No CBI No PII Diesel Shop/ Center Aisle SAA Used oil container, not labeled "used oil". IMG-2024070911461046101424127.jpg N/A N/A Used oil collection container in Diesel Shop Oil Filter Crushing SAA IMG-20240709115223522394047.jpg 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA NA Container used to collect used oil when crushing used oil filters, not labeled "used oil". 61 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil filter crushing machine in Diesel Shop Oil Filter IMG-202407091152285228107485.jpg Crushing SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA N/A Machine used to crush used oil filters. Carts of used oil from oil filter crushing in Diesel Shop IMG-202407091155365536113918.jpg SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA N/A Carts used to drain oil filters and remove used oil after oil filters are crushed, labeled "waste oil". 62 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Heavy Equipment Shop SAA IMG-202407091205145141072249.jpg 07/09/24 No CBI No PII N/A Heavy Equipment Shop/ SAA N/A Waste aerosol accumulation container labeled "hazardous material". Carts of used oil from oil filter crushing in Diesel Shop IMG-202407091155415541104019.jpg SAA 07/09/24 No CBI No PII N/A Diesel Shop/ Oil Filter Crushing SAA N/A Carts used to remove used oil after oil filters are crushed, labeled "waste oil". 63 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Cart of used oil filters in Diesel Shop Oil Filter Crushing SAA 07/09/24 No CBI No PII Diesel Shop/ Oil Filter Crushing SAA Cart of draining used oil filters, labeled "waste oil". IMG-20240709115543554389953.jpg N/A N/A Used oil filters in Diesel Shop Oil Filter Crushing SAA 07/09/24 No CBI No PII Diesel Shop/ Oil Filter Crushing SAA Container of used oil filters. IMG-202407091155475547105351.jpg N/A N/A 64 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Used oil filters in Diesel Shop Oil Filter Crushing SAA 07/09/24 No CBI No PII Diesel Shop/ Oil Filter Crushing SAA Container of used oil filters. IMG-20240709115554555487644.jpg N/A N/A Bucket of used oil in 5K Oil Tank SAA 07/09/24 No CBI 5K Oil Tank/ SAA Bucket of used oil, not labeled "used oil". No PII IMG-2024070911580458480521.jpg N/A N/A 65 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Bucket of used oil in 5K Oil Tank SAA 07/09/24 No CBI 5K Oil Tank/ SAA Bucket of used oil, not labeled "used oil". No PII IMG-2024070911580758780759.jpg N/A N/A Bucket of used oil in 5K Oil Tank SAA 07/09/24 No CBI 5K Oil Tank/ SAA Bucket of used oil, not labeled "used oil". No PII IMG-20240709115812581279777.jpg N/A N/A 66 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 Waste aerosol accumulation container in Heavy Equipment Shop SAA IMG-202407091205225221284665.jpg 07/09/24 No CBI No PII N/A Heavy Equipment Shop/ SAA N/A Waste aerosol accumulation container labeled "hazardous material", with multiple waste aerosol cans inside. 67 of 68 Alaska Railroad Corp Inspection Date(s): 07/09/2024 - 07/09/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Facility Map AK Railroad Map .pdf No No Jon Jones 08/01/2024 68 of 68