Document Lo8en9G2wL63XRDoxEw857K4d

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA Region 10 Enforcement Division INSPECTION REPORT 03/07/2023 08:20 AM (AKT) Announced: No 03/07/2023 11:04 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 Lowe's Home Center, LLC Lowes Of Fairbanks #1985 AKR000207159 425 Merhar Avenue Fairbanks, AK 99701 Fairbanks North Star Borough Small Quantity Generator (SQG) 444110 - Home Centers Do-it-yourself Home Center 64.858023, -147.701529 Corey Proulx, Assistant Store Manager 425 Merhar Avenue Fairbanks, AK 99701 Fairbanks, AK 99701 corey.j.proulx@store.lowes.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 14:17:59 -08'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan EPA Region 10 Digitally signed by Jennifer A Sullivan Date: 2023.04.28 10:00:29 -07'00' 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 Lowes of Fairbanks #1985 Facility (the "Site" or "Facility"), located at 425 Merhar Avenue, Fairbanks, AK 99701, at 08:20 AM (AKT) on 03/07/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Kyle Olson that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 1 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 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. This report is based on information supplied by Lowes Of Fairbanks #1985 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 Lead Inspector/EPA Region 10 Name Jon Jones Back End Kyle Olson Supervisor/Lowe's of Fairbanks #1985 Hazardous Waste Program Specialist/ADEC Ashley Streveler Assistant Store Corey Proulx Manager/Lowe's of Fairbanks #1985 Phone (907) 2716329 (907) 2694556 (907) 4514700 Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes 1278292@store.lowes.com Yes Yes ashley.streveler@alaska.gov Yes Yes corey.j.proulx@store.lowes.com No Yes Opening Conference Shortly after arriving at Lowe's, we were taken to the facility backroom where I held the opening conference. I presented my inspector credentials to and informed Mr. Kyle Olson, Back End Supervisor, 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 Approximately 160 to 180 employees Length of Facility at Location Since 2008 Operating Hours 6:00 am to 10:00 pm, Monday through Saturday and 7:00 am to 8:00 pm on Sunday Safety Training No Provided to 2 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 Inspector(s)? Size of Facility What type of generator facility notified? What type of generator facility verified as? Weather Conditions 115, 400 square feet Small Quantity Generator (SQG) Small Quantity Generator (SQG) verified by facility personnel Cold and cloudy Process Description During the opening conference, Mr. Olson 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. Olson. 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 Building Central Accumulation Area (CAA) Return to Manufacturing Area (RTM) Process Description Hazardous waste accumulation Accumulation of universal waste lamps and batteries and waste aerosol satellite area Area of Concern Yes No Yes SECTION II - OBSERVATIONS Building: Main Building/Return to Manufacturing Area (RTM) Observation #: JJ1-OB-001 Date: 03/07/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Kyle Olson Title: Back End Supervisor While inspecting the RTM area, I saw one sealed waste lead-acid battery and six waste Lithium batteries. At the time of the inspection, the seven waste batteries were not labeled with either the words "Universal Waste Batteries," "Waste Batteries," or "Used Batteries." Photo(s) 1. IMG_0517.jpg 2. IMG_0518.jpg 3. IMG_0538.jpg Building: Main Building/Return to Manufacturing Area (RTM) Observation #: JJ1-OB-002 Date: 03/07/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Kyle Olson Title: Back End Supervisor While still inspecting the RTM, I saw four boxes that held eight-foot waste fluorescent lamps. At the time of the 3 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 inspection, the four boxes of eight-foot waste fluorescent lamps were not labeled with either the words "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." One of the four boxes of waste fluorescent lamps was also not closed. Photo(s) 1. IMG_0519.jpg 2. IMG_0520.jpg Building: Main Building/Return to Manufacturing Area (RTM) Observation #: JJ1-OB-003 Date: 03/07/2023 Contains AOC: Yes Person Interviewed: Kyle Olson Title: Back End Manager Contains CBI: No While still in the RTM area, I saw three boxes that held four-foot waste fluorescent lamps. Two of the three boxes were not labeled, and one was labeled "Universal Waste - Light Bulbs." I also saw a small plastic tub that held waste fluorescent "U -shaped" lamps and CFL's that was also labeled "Universal Waste - Light Bulbs." I saw an additional three boxes of waste lamps that had been returned by a customer. The three boxes were labeled with the word "Trash." At the time of the inspection, all seven four containers that held four-foot waste fluorescent lamps, "U -shaped" lamps, and CFL's were not labeled with either the phrase "Universal Waste Lamps," "Waste Lamps," or "Used Lamps." Photo(s) 1. IMG_0521.jpg 2. IMG_0522.jpg 3. IMG_0523.jpg 4. IMG_0524.jpg 5. IMG_0525.jpg 6. IMG_0526.jpg 7. IMG_0527.jpg 8. IMG_0528.jpg 9. IMG_0529.jpg 10. IMG_0530.jpg 11. IMG_0539.jpg 12. IMG_0540.jpg 13. IMG_0541.jpg 14. IMG_0542.jpg Building: Main Building/Return to Manufacturing Area (RTM) Observation #: JJ1-OB-004 Date: 03/07/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Kyle Olson Title: Back End Supervisor While still in the RTM area, I saw a plastic trash receptacle that was being used as a satellite accumulation container to collect waste aerosol cans. The container was labeled as "Non - RCRA Regulated Waste" and marked with a hazard indicator of "Flammable." The container was dated 1/31/2023, but after a discussion with Mr. Olson it was determined that the container was being used as a satellite container. At the time of the 4 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 inspection, the satellite container of waste aerosol cans was not closed, as the lid was not attached or snapped down onto the container. The satellite container was also not labeled with the words "Hazardous Waste." Photo(s) 1. IMG_0533.jpg 2. IMG_0534.jpg 3. IMG_0535.jpg 4. IMG_0536.jpg 5. IMG_0537.jpg Building: Main Building/Central Accumulation Area (CAA) Observation #: JJ1-OB-005 Date: 03/07/2023 Contains AOC: No Contains CBI: No Person Interviewed: Kyle Olson Title: Back End Supervisor The facility's CAA is located outside, behind the RTM area. I inspected the waste in accumulation and did not identify any areas of concern while at the CAA. SECTION III - RECORDS REVIEW Record: Manifests Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/07/2023 During the inspection, I reviewed the facility's hazardous waste manifests covering the period from September 2020 through the end of January 2023. During my inspection of these manifests, I saw five manifests for hazardous waste that was shipped from the facility without being signed by the generator or their designated representative. The following hazardous waste manifests were not signed by the generator or their designated representative: Manifest # Date of shipment 004899344FLE 12/14/21 004899349FLE 12/14/21 004899348FLE 12/14/21 004899345FLE 12/14/21 004899278FLE 12/14/21 I downloaded a copy of the manifests, listed above, except for 004899278FLE, from RCRAInfo, showing that they had not been signed by the generator or their designated representative. Manifest 004899278FLE was not available in RCRAInfo. The facility also did not have the copy of these manifests on-site, listed above, that had been signed by the designated facility. Document(s) 5 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 1. 004899344FLE-2-8-2022-6-16-10-PM.pdf 2. 004899345FLE-2-8-2022-6-25-12-PM.pdf 3. 004899348FLE-2-7-2022-6-58-22-PM.pdf 4. 004899349FLE-2-7-2022-7-24-14-PM.pdf Photo(s) 1. IMG_0543.jpg 2. IMG_0544.jpg 3. IMG_0545.jpg 4. IMG_0546.jpg 5. IMG_0547.jpg 6. IMG_0548.jpg 7. IMG_0549.jpg 8. IMG_0550.jpg 9. IMG_0551.jpg 10. IMG_0552.jpg 11. IMG_0553.jpg 12. IMG_0554.jpg 13. IMG_0555.jpg 14. IMG_0556.jpg 15. IMG_0557.jpg Record: Preparedness and Prevention Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/07/2023 At the time of the inspection, the facility did not have emergency information posted next to a phone. Following the inspection, I sent a sample emergency information sheet to Mr. Olson to post at the facility. I asked him to follow-up with a photo of this posted emergency information. At the time this inspection report was written, this information had not been received. Record: Inspections Ref #: JJ1-RR-003 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/07/2023 At the time of the inspection, the facility was unable to provide documentation of weekly hazardous waste inspections for the 3-year period of March 2020 through March 2023. At the end of the inspection, I requested that these inspection logs be sent to me for review. At the time this inspection report was completed, this information had not been received. Record: Ensure applicable employees are trained - SQG Ref #: JJ1-RR-004 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/07/2023 At the time of the inspection, Mr. Olson said that there were approximately 11 Lowe's employees that required training. During the inspection, training records for these employees was not available for inspection. The content of the training was also not available for review. 6 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 At the end of the inspection, I asked Mr. Olson to provide this information. At the time this inspection report was completed, this information had not been received. Record: Manifests Ref #: JJ1-RR-005 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 03/07/2023 During my inspection of the facility's hazardous waste manifests, I saw that the facility did not have a copy of the following manifests on-site that had been signed by the designated facility: Manifest # Date of shipment 004899335FLE 9/10/21 004899333FLE 9/10/21 004899332FLE 9/10/21 004899331FLE 9/10/21 004899334FLE 9/10/21 004899347FLE 9/10/21 000384263JJK 9/4/20 000384264JJK 9/4/20 000384265JJK 9/4/20 000384266JJK 9/4/20 002636067PSC 1/21/20 Photo(s) 1. IMG_0558.jpg 2. IMG_0559.jpg SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Main Building JJ1-OB-001 Area: Return to Manufacturing Area Sub-area: (RTM) Seven waste batteries were not labeled with either the words "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." Regulation: Sections: Building: Main Building Area: Return to Manufacturing Area Sub-area: (RTM) 7 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 JJ1-OB-002 Four boxes of eight-foot waste fluorescent lamps were not labeled with either the words "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." One of the four boxes of waste fluorescent lamps was also not closed. Regulation: Sections: Building: Main Building JJ1-OB-003 Area: Return to Manufacturing Area Sub-area: (RTM) Four containers that held four-foot waste fluorescent lamps, "U shaped" lamps, and CFL's were not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." Regulation: Sections: Building: Main Building JJ1-OB-004 Area: Return to Manufacturing Area Sub-area: (RTM) A satellite container of waste aerosol cans was not closed, as the lid was not attached or snapped down onto the container. The satellite container was also not labeled with the words "Hazardous Waste." Regulation: Sections: Record: Manifests JJ1-RR-001 The following hazardous waste manifests were not signed by the generator or their designated representative: Manifest # Date of shipment 004899344FLE 12/14/21 004899349FLE 12/14/21 004899348FLE 12/14/21 004899345FLE 12/14/21 Regulation: 8 of 32 Sections: Lowes Of Fairbanks #1985 Inspection Date(s): 004899278FLE 12/14/21 The facility also did not have the copy of these manifests, listed above, that had been signed by the designated facility. Record: Preparedness and Prevention JJ1-RR-002 The facility did not have emergency Regulation: information posted next to a phone. Record: Inspections JJ1-RR-003 The facility was unable to provide Regulation: documentation of weekly hazardous waste inspections for the 3-year period of March 2020 through March 2023. Record: Ensure applicable employees are trained - SQG JJ1-RR-004 During the inspection, training records for these employees was not available for inspection. The content of the training was also not available for review. Regulation: Record: Manifests JJ1-RR-005 During my inspection of the facility's hazardous waste manifests, I saw that the facility did not have a copy of the following manifests on-site that had been signed by the designated facility: Regulation: Manifest # Date of shipment 004899335FLE 9/10/21 004899333FLE 9/10/21 004899332FLE 9/10/21 004899331FLE 9/10/21 9 of 32 03/07/2023 - 03/07/2023 Sections: Sections: Sections: Sections: Lowes Of Fairbanks #1985 Inspection Date(s): 004899334FLE 9/10/21 004899347FLE 9/10/21 000384263JJK 9/4/20 000384264JJK 9/4/20 000384265JJK 9/4/20 000384266JJK 9/4/20 002636067PSC 1/21/20 03/07/2023 - 03/07/2023 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 10 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): APPENDIX 1: PHOTO LOG 03/07/2023 - 03/07/2023 [Title] IMG_0517.jpg 03/07/2023 08:55 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.856225, -147.69589166 View of a sealed lead-acid battery that is seen here not labeled with either the phrase "Universal Waste Battery," "Waste Battery," or "Used Battery." [Title] IMG_0518.jpg 03/07/2023 08:55 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85616944, -147.69590833 View of six waste Lithium batteries that are not labeled with either the phrase "Universal Waste - Battery," "Waste Battery," or "Used Battery." 11 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0519.jpg 03/07/2023 09:09 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85599444, -147.696075 View of three boxes, containing eight-foot waste fluorescent lamps that are seen here not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." [Title] IMG_0520.jpg 03/07/2023 09:09 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85584999, -147.69578611 View of a fourth box containing eight-foot waste fluorescent lamps that is not closed or labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." 12 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0521.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85581111, -147.6958 View of a box containing four-foot waste fluorescent lamps that is not closed and not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." [Title] IMG_0522.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85575, -147.69589166 Close-up view of the waste fluorescent lamps seen in the container from the previous photo (IMG_0521). 13 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0523.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85572777, -147.69589166 Close-up view of the label on the open container of waste lamps seen in photo IMG_0521. [Title] IMG_0524.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85574444, -147.69587777 View of container, holding waste lamps, that is not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." 14 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0525.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85574444, -147.69587777 Close-up view of the label on the container of waste lamps seen in the previous photo (IMG_0524). [Title] IMG_0526.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85573611, -147.69590833 View of two additional boxes, containing four-foot waste fluorescent lamps, that are not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or :Used Lamps." 15 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0527.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85575, -147.69598333 Another view of the two boxes, seen in the previous photo (IMG_0526), that are not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." [Title] IMG_0528.jpg 03/07/2023 09:10 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85574444, -147.696 View of three additional boxes of waste lamps that were brought back to the store by a customer. The boxes are seen here not labeled with either the phrase "Universal Waste - Lamps," "Waste Lamps," or "Used Lamps." 16 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0529.jpg 03/07/2023 09:11 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85574444, -147.696 Another view of the same unlabeled boxes of waste lamps seen in the previous photo (IMG_0528). [Title] IMG_0530.jpg 03/07/2023 09:11 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85570555, -147.69595277 Another view of the same unlabeled boxes of waste lamps seen in the previous two photos (IMG_0528 and IMG_0529). 17 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0533.jpg 03/07/2023 09:11 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85576666, -147.696 View of a lined trash can, being used as a satellite container to accumulate waste aerosol cans. The container held waste aerosol cans and was labeled with the words "Non-RCRA Regulated Waste" and marked with a hazard indicator of "Flammable." [Title] IMG_0534.jpg 03/07/2023 09:11 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85575833, -147.69604444 Another view of the same container seen in the previous photo (IMG_0533), showing the labeling on the container. 18 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0535.jpg 03/07/2023 09:11 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85571388, -147.696 View of the labeling on the top of the satellite container being used to accumulate waste aerosol cans. [Title] IMG_0536.jpg 03/07/2023 09:11 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85572777, -147.69586111 A close-up view of the label on the waste aerosol satellite container, showing that it is not labeled with the words, "Hazardous Waste." 19 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0537.jpg 03/07/2023 09:12 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85574444, -147.69589166 Another view of the waste aerosol can satellite container. [Title] IMG_0538.jpg 03/07/2023 09:12 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85571944, -147.69587777 View of the labeling for waste batteries, on the shelving in the RTM area. 20 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0539.jpg 03/07/2023 09:12 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85616388, -147.69598333 View of the labeling for waste lamps and flow chart on the shelving in the RTM area. [Title] IMG_0540.jpg 03/07/2023 09:12 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85619444, -147.69593888 Close-up view of the Hazardous Material flow chart posted on the shelving in the RTM area. 21 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0541.jpg 03/07/2023 09:12 AM No CBI No PII Photographer: Jon Jones Main Building/Return to Manufacturing Area (RTM) 64.85578055, -147.69603055 Additional view of labeling on the shelving in the RTM area. [Title] 03/07/2023 09:13 AM No CBI No PII Main Building/Return to Manufacturing Area (RTM) Close-up view of labeling in the RTM area. IMG_0542.jpg Photographer: Jon Jones 64.85573611, -147.69596944 22 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0543.jpg 03/07/2023 09:45 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85620833, -147.69589166 View of the generator copy of Manifest 004899344FLE, showing that it was not signed by either the Generator or their designated representative. [Title] IMG_0544.jpg 03/07/2023 09:46 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85571944, -147.69590833 Close-up view of the Generator signature block on Manifest 004899344FLE. 23 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0545.jpg 03/07/2023 09:46 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85573611, -147.69586111 Close-up view of the Generator signature block on Manifest 004899344FLE. [Title] IMG_0546.jpg 03/07/2023 09:47 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85616944, -147.69590833 View of the generator copy of Manifest 004899349FLE, showing that it was not signed by either the Generator or their designated representative. 24 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0547.jpg 03/07/2023 09:47 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85625555, -147.69587777 Close-up view of the Generator signature block on Manifest 004899349FLE. [Title] IMG_0548.jpg 03/07/2023 09:47 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85621666, -147.69590833 Close-up view of the Generator signature block on Manifest 004899349FLE. 25 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0549.jpg 03/07/2023 09:48 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85613888, -147.69598333 View of the generator copy of Manifest 004899348FLE, showing that it was not signed by either the Generator or their designated representative. [Title] IMG_0550.jpg 03/07/2023 09:48 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85613888, -147.69598333 Close-up view of the Generator signature block on Manifest 004899348FLE. 26 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0551.jpg 03/07/2023 09:48 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85623055, -147.69601388 Close-up view of the Generator signature block on Manifest 004899348FLE. [Title] IMG_0552.jpg 03/07/2023 09:49 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.855775, -147.69609166 View of the generator copy of Manifest 004899345FLE, showing that it was not signed by either the Generator or their designated representative. 27 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0553.jpg 03/07/2023 09:49 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85575, -147.69606111 Close-up view of the Generator signature block on Manifest 004899345FLE. [Title] IMG_0554.jpg 03/07/2023 09:50 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85572777, -147.69604444 Close-up view of the Generator signature block on Manifest 004899345FLE. 28 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0555.jpg 03/07/2023 09:53 AM No CBI No PII Photographer: Jon Jones [Building/Area] [Geographic Coordinates] View of the generator copy of Manifest 004899278FLE, showing that it was not signed by either the Generator or their designated representative. [Title] IMG_0556.jpg 03/07/2023 09:53 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85620833, -147.69592222 Close-up view of the Generator signature block on Manifest 004899278FLE. 29 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0557.jpg 03/07/2023 09:53 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85620833, -147.69592222 Close-up view of the Generator signature block on Manifest 004899278FLE. [Title] IMG_0558.jpg 03/07/2023 10:12 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85591111, -147.69531388 View of Manifests for which there was no copy available that had been signed by the designated facility. 30 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 [Title] IMG_0559.jpg 03/07/2023 10:12 AM No CBI No PII Photographer: Jon Jones [Building/Area] 64.85616388, -147.69586111 Close-up view of the manifest seen in the previous photo (IMG_0558). 31 of 32 Lowes Of Fairbanks #1985 Inspection Date(s): 03/07/2023 - 03/07/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Records Review Records Review Records Review Records Review 004899344FLE-2-8- No No Jon Jones 2022-6-16-10-PM.pdf 004899345FLE-2-8- No No Jon Jones 2022-6-25-12-PM.pdf 004899348FLE-2-7- No No Jon Jones 2022-6-58-22-PM.pdf 004899349FLE-2-7- No No Jon Jones 2022-7-24-14-PM.pdf Date Received 04/26/2023 04/26/2023 04/26/2023 04/26/2023 32 of 32