Document N2jZzwBQr3JGR7va2VpK0xyGw

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 11/06/2023 07:56 AM (PT) Announced: No 11/06/2023 09:56 AM (PT) 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 Home Depot USA, Inc. Home Depot #4726 XJW000024252 (Former Facility/Site Identifier: WAH000024252) 9310 Quil Ceda Blvd Tulalip, WA 98271 Snohomish Small Quantity Generator 444110 Home Centers 48.097305, -122.18728 Mr. Brett Amstuz, Home Depot #4726 Store Manager 9310 Quil Ceda Blvd Tulalip, WA 98271 brett_g_amstuz@homedepot.com Michelle O'Brien, Manager-Regulatory Compliance 2455 Paces Ferry Road, D-4 Atlanta, GA 30339 michelle_a_obrien@homedepot.com City, State, Zip Code Tulalip, WA 98271 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones Jones, Jon EPA Region 10 Digitally signed by Jones, Jon Date: 2023.11.16 07:48:34 -09'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Matt Quarterman MATTHEW QUARTERMAN Date: 2023.12.14 13:30:21 -08'00' 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: Compliance Evaluation Inspection (CEI) 1 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Home Depot #4726 Facility (the "Site" or "Facility"), located at 9310 Quil Ceda Blvd, Tulalip, WA 98271, at 07:56 AM (PT) on 11/06/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Ms. Gale Smith, Customer Experience Manager, that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273). The inspection was conducted as part of a Core Program requirement for FY 2024. This report is based on information supplied by Home Depot #4726 Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility including, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Lead Inspector/EPA REGION 10 Store Manager/Home Depot Receiving /Home Depot Customer Experience Manager (CXM)/Home Depot Jon Jones (907) 2716329 Brett Amstuz (360) 6575762 Ext. 500 Danyiel Vane Gale Smith (360) 6575762 Ext. 299 Email Jones.Jon@epa.gov Opening Conf. Yes brett_g_amstuz@homedepot.com No No cxm_4726@homedepot.com Yes Closing Conf. Yes Yes Yes Yes Opening Conference Shortly after arriving at Home Depot #4726, I was taken to the facility breakroom where I held the opening conference. I presented my inspector credentials to and informed Ms. Gale Smith, Customer Experience Manager, that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). During the opening conference, I explained that the focus of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. Only those areas in which I observed potential compliance concerns or noted other pertinent issues are discussed in Section III of this inspection report. 2 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 Facility/Site Information Number of employees ~134 Length of Facility at Location 22 years Operating Hours 6:00 am to 9:00 pm, Monday through Saturday. Sunday, 7:00 am to 8:00 pm. Safety Training No Provided to Inspector(s)? Size of Facility Approximately 115,000 square feet What type of generator facility notified? Small Quantity Generator What type of generator facility verified as? Verified by Ms. Smith and Ms. Vane to be a Small Quantity Generator Weather Conditions Rainy Process Description During the opening conference, Ms. Smith told me 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. I was accompanied during the inspection by Ms. Smith. 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 Store Receiving CAA Process Description Area where facility receives merchandise 180-day area where the facility accumulates hazardous and universal waste Area of Concern Yes Yes Yes SECTION II - OBSERVATIONS Building: Store/Receiving/CAA Observation #: JJ1-OB-001 Date: 11/06/2023 Person Interviewed: Ms. Danyiel Vane Contains AOC: Yes Title: Receiving Contains CBI: No While in the facility's receiving area, I inspected the central accumulation area (CAA). While in this area, I met with two facility receiving personnel, Ms. Danyiel Vane, and Mr. Miguel Ortiz. As I began inspecting the waste in the CAA, Ms. Vane provided me with a current inventory log of the waste in accumulation. This Hazmat Waste Log is included in the document log. At the time of the inspection, I saw five containers that were not closed. There were two red plastic containers. One was a five-gallon container labeled as containing "Toxic" hazardous waste and the other was a ~two-and-a-half-gallon container that was labeled as containing 3 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 "Toxic/Reactive" hazardous waste. There was also a five-gallon container, inside of a red flammable storage cabinet, that was labeled as containing "Ignitable/Toxic" hazardous waste. There was also another ~two-and-ahalf-gallon black container that was labeled "Toxic/Ignitable" hazardous waste and another black, five-gallon container that was labeled as containing "Toxic/Corrosive" hazardous waste. The container lids on these hazardous waste containers were not completely snapped down onto the container. I explained to Ms. Vane that the lid needed to make a complete seal with the container in order for it to be considered closed. Ms. Vane closed each of the five containers during the inspection. Document(s) 1. Hazmat Waste Log_Part1.pdf 2. Hazmat Waste Log_Part2.pdf Photo(s) 1. IMG-2023110608244024401866994.jpg 2. IMG-2023110608245224521727171.jpg 3. IMG-202311060825042542109414.jpg 4. IMG-2023110608252025201980867.jpg 5. IMG-2023110608305330531890571.jpg 6. IMG-202311060831033131912192.jpg 7. IMG-2023110608311431142056399.jpg 8. IMG-2023110608312131212075553.jpg SECTION III - RECORDS REVIEW Record: Manifests AOC: Yes Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 11/06/2023 During the records review, I inspected the facility's hazardous waste manifests covering the period of 11/06/2020 through 11/06/2023. During this manifest inspection, I saw the following 13 hazardous waste manifests for which there was no original returned copy that had been signed and dated by the designated facility: Manifest # Date of Shipment 200282182CLE 200056596CLE 200034266CLE 000406359DAT 003271887CLE 003242794CLE 003189650CLE 000344184DAT 000343467DAT 003093592CLE 000343071DAT 003020610CLE 000343982DAT 10/19/22 1/15/22 12/15/21 10/19/21 8/26/21 8/2/21 6/1/21 5/3/21 4/6/21 3/8/21 2/10/21 1/14/21 11/17/20 During the inspection, Ms. Vane took the opportunity to log onto her personal computer and after opening her 4 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 hazardous waste vendors website, she was able to print a copy of each manifest listed above that had the signature and date from the designated facility. Ms. Vane then filed these copies with the manifests she had onsite. Document(s) 1. 000343071DAT 2.10.21.pdf 2. 000343467DAT 4.6.21.pdf 3. 000343982DAT 11.17.20.pdf 4. 000344184DAT 5.3.21.pdf 5. 000406359DAT 10.19.21.pdf 6. 003020610CLE 1.14.21.pdf 7. 003093592CLE 3.8.21.pdf 8. 003189650CLE 6.1.21.pdf 9. 003242794CLE 8.2.21.pdf 10. 003271887CLE 8.26.21.pdf 11. 200034266CLE 12.15.21.pdf 12. 200056596CLE 1.15.22.pdf 13. 200282182CLE 10.19.22.pdf SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Store JJ1-OB-001 Area: Receiving Sub-area: CAA During the inspection, I saw five hazardous waste containers that were not closed. The container lids on these hazardous waste containers were not completely snapped down onto the container making a complete seal. Regulation: Ms. Vane closed each of the five containers during the inspection. Sections: Record: Manifests JJ1-RR-001 During the manifest inspection, I saw 13 hazardous waste manifests for which there was no original returned copy that had been signed and dated by the designated facility. Regulation: During the inspection, Ms. Vane printed a copy of each manifest that had the signature and date from the designated facility. Ms. Vane then 5 of 11 Sections: Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 filed these copies with the manifests she had onsite. 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. Follow Up N/A Communication Log N/A SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 6 of 11 Home Depot #4726 Inspection Date(s): APPENDIX 1: PHOTO LOG 11/06/2023 - 11/06/2023 [Title] IMG-2023110608244024401866994.jpg 11/06/2023 08:24 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08139123, -122.18826522 View of two red plastic containers that were not closed. A five-gallon container labeled "Toxic" hazardous waste and a ~two-and-a-half-gallon container that was labeled "Toxic/Reactive" hazardous waste. [Title] IMG-2023110608245224521727171.jpg 11/06/2023 08:24 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08139124, -122.18826493 View of five-gallon container, inside of a red flammable storage cabinet, that was labeled as containing "Ignitable/Toxic" hazardous waste and not closed. 7 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 [Title] IMG-202311060825042542109414.jpg 11/06/2023 08:25 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08138867, -122.18828571 View of another ~two-and-a-half-gallon black container that was labeled "Toxic/Ignitable" hazardous waste and not closed. [Title] IMG-2023110608252025201980867.jpg 11/06/2023 08:25 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08138242, -122.18833714 View of another black, five-gallon container that was labeled as containing "Toxic/Corrosive" hazardous waste and not closed. 8 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 [Title] IMG-2023110608305330531890571.jpg 11/06/2023 08:30 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.0813856, -122.18832365 View of the containers, seen in IMG-2023110608244024401866994.jpg, after being closed. [Title] IMG-202311060831033131912192.jpg 11/06/2023 08:31 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08138892, -122.18835414 View of the container, seen in IMG-2023110608245224521727171.jpg, after being closed. 9 of 11 Home Depot #4726 Inspection Date(s): 11/06/2023 - 11/06/2023 [Title] IMG-2023110608311431142056399.jpg 11/06/2023 08:31 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08139434, -122.18825233 View of the container, seen in IMG-202311060825042542109414.jpg, after being closed. [Title] IMG-2023110608312131212075553.jpg 11/06/2023 08:31 AM (PT) No CBI No PII Photographer: Jon Jones Store/Receiving/CAA 48.08139555, -122.18832347 View of container, seen in IMG-2023110608252025201980867.jpg, after being closed. 10 of 11 Home Depot #4726 Inspection Date(s): APPENDIX 2: DOCUMENT LOG Document Type Document Name Hazardous Waste Manifest 000343071DAT 2.10.21.pdf Hazardous Waste Manifest 000343467DAT 4.6.21.pdf Hazardous Waste Manifest 000343982DAT 11.17.20.pdf Hazardous Waste Manifest 000344184DAT 5.3.21.pdf Hazardous Waste Manifest 000406359DAT 10.19.21.pdf Hazardous Waste Manifest 003020610CLE 1.14.21.pdf Hazardous Waste Manifest 003093592CLE 3.8.21.pdf Hazardous Waste Manifest 003189650CLE 6.1.21.pdf Hazardous Waste Manifest 003242794CLE 8.2.21.pdf Hazardous Waste Manifest 003271887CLE 8.26.21.pdf Hazardous Waste Manifest 200034266CLE 12.15.21.pdf Hazardous Waste Manifest 200056596CLE 1.15.22.pdf Hazardous Waste Manifest 200282182CLE 10.19.22.pdf Other - Hazmat Waste Log Hazmat Waste Log_Part1.pdf Other - Hazmat Waste Log Hazmat Waste Log_Part2.pdf 11/06/2023 - 11/06/2023 Contains Contains Uploaded By CBI PII No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones No No Jon Jones Date Received 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11/09/2023 11 of 11