Document Qgy7wNkOOE53vk6dRMEJLoODL

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 04/12/2021 - 04/12/2021 Announced: No Entry: 08:48 AM (AKT) Exit: 03:05 PM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) (city, state, zip code) County: State of Alaska ALASKA DOT & PF 6860 GLACIER HWY 6860 GLACIER HWY JUNEAU, AK 99801 Maintenance and operations (M&O) maintains highways and makes pavement repairs and the State Equipment Fleet (SEF) performs vehicle maintenance 10 acres Since the 1960's 58.35886, -134.5277 Mr. Michael A. Tunley michael.tunley@alaska.gov Safety Officer, State of Alaska DOT&PF, Southcoast Region 6860 Glacier Hwy. Box 112506 Juneau, AK 99811-2506 Facility/Site Identifier: Media Number: NAICS: AKD983066366 Unpermitted Facility 92119 - Other General Government Support Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.06.29 09:04:15 -08'00' Jones.Jon@epa.gov (907) 271-6329 Additional Persons Participating in Inspection: Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2021.06.30 11:33:17 -07'00' Sullivan.Jennifer.A@epa.gov SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection (206) 553-6978 1 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2021. Attendees Title Name Lead Inspector Jon Jones Safety Officer Mike Tunley Southeast District Equipment Manager, State Equipment Fleet Tim Wolfe Phone 9072716329 Email Jones.Jon@epa.gov Present in Opening Conf. Yes Present in Closing Conf. Yes (907) 465-8991 michael.tunley@alaska.gov No Yes (907) 465-1792 tim.wolfe@alaska.gov Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the Alaska DOT & PF 6860 Glacier Hwy facility at 08:48 AM (AKT) on 04/12/2021 for an inspection. I presented my credentials to Mr. Tim Wolfe and informed him that this was an EPA RCRA inspection. The table above presents all the opening and closing conference participants. During the inspection I looked at the facility's processes, in addition to 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 and used oil management. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. I was accompanied for the entirety of the inspection by Mr. Wolfe. At the point when I inspected the M&O Tool room, we were joined by Mr. Spencer Gates, M&O Equipment Operator Foreman. At the point when I inspected the Cold Shed, we were joined by Mr. Mike Tunley, Safety Officer. Facility/Site Description Alaska Department of Transportation (DOT) & Public Facilities (PF) has been at its present location (6860 Glacier Highway) in Juneau since the 1960's. One side of the facility houses ADOT&PF Maintenance & Operations (M&O), which maintains highways and makes pavement repairs, and the other side of the facility houses the State Equipment Fleet (SEF), which maintains approximately 419 state owned vehicles that belong to between 10 and 15 different state agencies. Facility Info What type of generator facility verified as? Verified by Mr. Wolfe as a VSQG; however, there were some wastes identified during the inspection in amounts that were indicative of the facility being a Small Quantity Generator (SQG) of hazardous waste. 2 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 What type of generator facility notified? Large Quantity Generator (LQG) of hazardous waste Safety Training No Provided to Inspector(s)? Operating Hours 8am to 4pm, Monday through Friday Weather Conditions Cold and snowy Number of employees 6 State Equipment Fleet personnel and 12 Maintenance and Operations personnel Process Description During the opening conference Mr. Wolfe told me about the following wastes that were generated and how the wastes were being managed. He also discussed changes since the last inspection. SEF wastes: Used antifreeze - Sent to recycle center at the household hazardous waste (HHW) facility in Juneau. Used oil - oil, hydraulic fluids, all burned in an onsite used oil burning space heater in the SEF Shop. Paint - aerosol and can for touch ups on vehicles Oil filters - crushed onsite. Aqueous parts washer. Waste fluorescent lamps are managed by ADOT&PF's Division of Facilities Services. Facilities personnel go to State of Alaska buildings, on an on-call basis, replacing burnt out fluorescent lamps. The waste fluorescent lamps are taken back to the Facilities location where they are crushed. Their department was established a couple of years ago. Mr. Wolfe told me that Ms. Anna Harrison is the Facilities Director and Mr. Bill Campbell is the Building Maintenance Foreman. Lead acid automotive batteries are turned in on a one-for-one basis to either Petro Marine or the local NAPA store. Tool batteries get accumulated and are then taken to the HHW facility for disposal. M&O wastes: Waste paint - Traffic paints and coatings Aerosol cans - paints and lubricants Changes since the 2012 RCRA CEI include: Salt tent and brine making equipment was put in approximately three years ago. Alaska Marine Highway warehouse was transferred to M&O approximately 1.5 years ago. Newer buildings added for construction/engineering projects. 3 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 Building(s) Building/Area Cold Shed Electricians Bay Equipment Shop Boiler room Maintenance and Operations Tool room SEF Welding room Vehicle Maintenance The Hill Process Description M&O equipment and vehicle storage. Shop with three roll-up doors. Storage for electrical supplies and electricians' vehicles. Tire work and light maintenance on road equipment. Area of Concern Yes Yes Yes Yes Yes Yes Yes Yes Yes SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Cold Shed Contains CBI: No Observation #: JJ1-OB-009 Date/Time: 04/12/2021 While inspecting the Cold Shed, I saw two 55-gallon containers on a pallet. One container was open and more than half full of solid, hardened, white traffic paint. The label on the container indicated that the ingredients of the paint included Methyl Ethyl Ketone (2-Butanone). The label also contained an ignitable hazard indicator. The container that held hardened white traffic paint was open and I saw two small wooden boards that were sticking out of the container. The other container felt as though it was full when I pushed on it, looked old and rusty and according to the label, contained Toluene. While inspecting these containers, we were joined onsite by Mr. Tunley, Safety officer. Mr. Spencer Gates, M&O Equipment Operator Foreman, told me they got rid of approximately 12 containers of paint last spring and said I should talk to Marcus Zimmerman, M&O Specialist, for more information. I asked Mr. Gates for a safety data sheet for the white traffic paint and toluene. SDS's for both were provided by the facility either during or shortly following the inspection. Mr. Gates said the vendor (Clean Harbors) they used to pick up the 12 containers of waste paint last spring would not take two additional containers in the shipment of waste because the contents of those containers was unknown to Clean Harbors. At the time of the inspection, there seemed to be some confusion as to which two containers Mr. Gates was referring to that were not picked up by Clean Harbors. At the time of the inspection, no one had any information regarding how long either of the 55-gallon containers had been onsite. Just prior to leaving the area where these containers were located, Mr. Gates told me that the container of Toluene was good product and not a waste. Photo(s) 1. Observation_Image-202104121259565956271225.jpg 2. Observation_Image-20210412130041041289380.jpg 3. Observation_Image-2021041213010616296971.jpg 4 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 4. Observation_Image-20210412130226226259617.jpg 5. Observation_Image-20210412130244244272723.jpg 04/12/2021 - 04/12/2021 Building: Cold Shed Contains CBI: No Observation #: JJ1-OB-010 Date/Time: 04/12/2021 While in the same area where the containers of hardened white traffic paint and toluene were observed, I also saw an 85-gallon overpack salvage drum that contained something. I asked Mr. Gates what the salvage drum contained and he said he wasn't sure. I explained that a waste determination would need to be made regarding the contents of the overpack salvage drum. Mr. Gates indicated that this was one of the two containers that was not picked up by Clean Harbors originally referenced in JJ1-OB-009. Photo(s) 1. Observation_Image-20210412130658658300321.jpg 2. Observation_Image-20210412130711711313229.jpg 3. Observation_Image-20210412130720720278022.jpg Building: Cold Shed Contains CBI: No Observation #: JJ1-OB-011 Date/Time: 04/12/2021 While continuing to inspect the Cold Shed, I saw a 55-gallon container that was on the lower level of a large steel shelf. The container was in a dark and hard to reach area, as there was a large vehicle that was parked inside the shed, adjacent to and blocking access to the container. I positioned myself as close to the container as possible and saw that the manufacturer's label indicated the contents were "Reclamite." Following the inspection, I was provided with two SDS's for the Reclamite. One from Tricor Refining, LLC and the other from Ergon Asphalt & Emulsions, Inc. I conducted a cursory review of the SDS's, which appeared to be identical, each indicating the contents were non-hazardous. Photo(s) 1. Observation_Image-20210412132005205236946.jpg 2. Observation_Image-202104121320252025205606.jpg 3. Observation_Image-202104121320572057210307.jpg Building: Cold Shed Contains CBI: No Observation #: JJ1-OB-012 Date/Time: 04/12/2021 While inspecting another area of the cold shed, I saw a pallet containing various one-gallon cans of a resin and a road penetrating sealer, as well as other miscellaneous containers. Writing on the resin container read, "Do not allow to freeze." In addition to the containers that were sitting loose on the pallet, there were also approximately 22 boxes of one-gallon cans on the pallet. During the inspection I asked for an inventory and SDS's for the items on the pallet. Mr. Tunley provided the information to me following the inspection. A cursory review of the inventory indicated that there were fifty, one-gallon containers containing Sitka Pronto 19TF Modified Methacrylate Crack Sealer Part A with a DOT Category of 3 (Flammable). According to the SDS, the Crack Sealer has a flashpoint of 135F. At the time of the inspection, this pallet and its contents were located in 5 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 the facility's Cold Shed where it had been stored over the winter months allowing the contents of the various containers to freeze and thaw. Photo(s) 1. Observation_Image-202104121332173217299027.jpg 2. Observation_Image-202104121332403240322846.jpg 3. Observation_Image-202104121332583258283627.jpg Building: Cold Shed Contains CBI: No Observation #: JJ1-OB-013 Date/Time: 04/12/2021 While in the same general area as the pallet discussed in Observation JJ1-OB-012, I saw an unlabeled black, 55gallon container that was next to the pallet of resin. The container did not appear to have any labeling. I asked what the container held and no one knew what was in the container. Mr. Gates opened the container during the inspection and said that it contained white paint. Mr. Gates said it contained good usable paint and was not a waste. Photo(s) 1. Observation_Image-202104121337553755265440.jpg 2. Observation_Image-20210412133807387275125.jpg 3. Observation_Image-202104121338263826256841.jpg Building: Electricians Bay Contains CBI: No Observation #: JJ1-OB-008 Date/Time: 04/12/2021 During the inspection I saw two small cardboard boxes that contained waste high-pressure sodium light bulbs. I saw approximately 36+ waste bulbs and one of the bulbs was broken. Mr. Gates asked me how the lamps should be managed and I told him that his facility would need to make a hazardous waste determination and at that point they could determine how to manage the bulbs. At that point, I was told that the lamps and bulbs that were generated at State of Alaska facilities were being managed by the Division of Facility Services. I was told that when lamps and bulbs burn out, Facility Services sends someone out to replace the waste lamps/bulbs with new lamps/bulbs. Facility Services then takes all the waste lamps and bulbs to their shop and puts them through their bulb crusher. Following the inspection, I received an email from Mr. Tunley with an updated inventory, dated 4/15/2021. In that email, Mr. Tunley told me, "I've updated the inventory we provided to you. I've revised the counts: - 47 High-pressure sodium bulbs - 10 fluorescent light tubes Also note that these bulbs were crushed by the Division of Facility Services in their bulb crusher." Photo(s) 1. Observation_Image-202104121234503450306488.jpg 2. Observation_Image-20210412123501351330491.jpg 3. Observation_Image-202104121235253525270533.jpg Building: Equipment Shop/Boiler room Observation #: JJ1-OB-006 Contains CBI: No Date/Time: 04/12/2021 6 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 While in the boiler room, I saw a five-gallon container that was marked with the words "Caution Hazardous Waste" and the date 9-17-02. I picked up the container and estimated it was one third full of an unknown waste. Mr. Wolfe told me that the ADOT&PF Facilities group was maintaining the equipment in the boiler room. Mr. Wolfe said he would check with Mr. Bill Campbell, Building Maintenance Foreman, to see if he knew what was in the container. At the time this inspection report was written, the contents of the container were still unknown. Photo(s) 1. Observation_Image-202104121145564556273913.jpg 2. Observation_Image-202104121146104610270717.jpg 3. Observation_Image-202104121146284628193661.jpg Building: Equipment Shop/Maintenance and Operations Contains CBI: No Observation #: JJ1-OB-001 Date/Time: 04/12/2021 During the inspection of the facility, I viewed the Maintenance and Operations (M&O) side of the Equipment Shop from the mezzanine above. Photo(s) 1. Observation_Image-202104121020532053327871.jpg Building: Equipment Shop/Maintenance and Operations/Tool room Contains CBI: No Observation #: JJ1-OB-007 Date/Time: 04/12/2021 While in the Tool room on the M&O side of the Equipment Shop, I inspected the contents of a trash receptacle and saw a punctured aerosol can in the trash. Upon further inspection, I noticed that the puncture hole was different from the other punctured cans I had seen at the facility. While in the Tool room, Mr. Wolfe introduced me to Mr. Spencer Gates, M&O Equipment Operator Foreman. I asked Mr. Gates if there was an aerosol can puncturing device on the M&O side of the Equipment Shop. He said there was not. I then asked if someone was puncturing the aerosols with something else and he said, "That's what it looks like." I told both gentlemen that the inappropriate puncturing of waste aerosol cans was not deemed proper waste management regardless of generator category. Photo(s) 1. Observation_Image-202104121211131113337325.jpg 2. Observation_Image-202104121211301130349579.jpg 3. Observation_Image-202104121211441144321589.jpg Building: Equipment Shop/SEF Welding room Observation #: JJ1-OB-002 Contains CBI: No Date/Time: 04/12/2021 7 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 At the time of the inspection, while in the SEF Welding room, I saw a 15-gallon container being used as a trash receptacle. Upon inspection of the contents, I saw a couple of aerosol cans in the trash. I asked Mr. Wolfe about the aerosol cans, and he told me they were waste aerosol cans. Mr. Wolfe told me that there was a waste aerosol can drum-top puncturing device located in the SEF shop. Mr. Wolfe took the waste aerosol cans to the area where waste aerosol cans get punctured. I asked Mr. Wolfe how the punctured aerosol cans were being managed and he told me he thought the punctured aerosol cans were disposed of in the trash as solid waste, but he said we should check with Mr. Martin to be sure. Mr. Martin confirmed that punctured aerosol cans were disposed of as solid waste. I explained to Mr. Wolfe that R10 EPA allowed generators to puncture waste aerosol cans into SAA containers, as long as they recycle the aerosol cans. Photo(s) 1. Observation_Image-20210412103906396342749.jpg 2. Observation_Image-202104121039183918314798.jpg 3. Observation_Image-202104121039333933307138.jpg 4. Observation_Image-202104121042164216308559.jpg 5. Observation_Image-202104121042504250352205.jpg Building: Equipment Shop/Vehicle Maintenance Contains CBI: No Observation #: JJ1-OB-003 Date/Time: 04/12/2021 While in the SEF vehicle maintenance shop, I saw a 55-gallon container with an aerosol can puncturing device and filter system attached. The container was marked with the date they began puncturing aerosols, 4-27-18. There were no visible markings or labeling on the container to indicate its contents other than the date they began filling the container. There was no cap on the puncturing device and the container was not closed, so the contents would have been able to evaporate. Upon further inspection, I saw that the lid to the puncturing device was on top of the container, next to the puncturing device. Mr. Wolfe closed the container during the inspection. Photo(s) 1. Observation_Image-20210412110541541296478.jpg 2. Observation_Image-20210412110551551314213.jpg 3. Observation_Image-2021041211060262315074.jpg 4. Observation_Image-202104121111341134299659.jpg 5. Observation_Image-202104121111411141342068.jpg 6. Observation_Image-202104121114541454328060.jpg Building: Equipment Shop/Vehicle Maintenance Contains CBI: No Observation #: JJ1-OB-004 Date/Time: 04/12/2021 View of a punctured aerosol can in the trash. Photo(s) 1. Observation_Image-202104121126232623244724.jpg 2. Observation_Image-202104121126302630229247.jpg 8 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): Building: Equipment Shop/Vehicle Maintenance Contains CBI: No 04/12/2021 - 04/12/2021 Observation #: JJ1-OB-005 Date/Time: 04/12/2021 15-gallon used oil receiver, containing approximately 10 gallons of used oil, is not labeled with the words "Used Oil." Following the inspection, I received an email from Mr. Wolfe, dated 4/12/2021, with a photo of the 15gallon used oil receiver labeled with the words, "Used Oil." Photo(s) 1. Observation_Image-20210412113203323257203.jpg 2. Observation_Image-202104121132193219276286.jpg 3. Observation_Image-202104121132333233284307.jpg Building: The Hill Contains CBI: No Observation #: JJ1-OB-014 Date/Time: 04/12/2021 While inspecting the area west of the Cold Shed, referred to as "The Hill," I saw a lone rusty and dented 55gallon container on a pallet that was located northwest of the Cold Shed. Mr. Gates told me the facility disposed of approximately 12 containers of hazardous waste through Clean Harbors during the spring 2020 (March/April). Mr. Gates stated that they intended to ship this container too, but Clean Harbors would not take it because it was an unknown waste. According to Mr. Gates, no weekly inspections were being conducted for this container. The container was not labeled and had no hazard indicator. Photo(s) 1. Observation_Image-202104121345184518224573.jpg 2. Observation_Image-202104121345514551183368.jpg Building: The Hill Contains CBI: No Observation #: JJ1-OB-015 Date/Time: 04/12/2021 Prior to leaving "The Hill", I saw an old rusty container by the edge of the roadway. I noticed that the container was not closed, and I asked what the container held. Mr. Gates spoke up and said that it was full of chains. I went over to get a closer look and it appeared to be half full of something with water, possibly snowmelt filling the rest of the container. At first glance I was unable to determine what the container held beneath the water. I poked at the material with a stick and found it to be hard and thought it might be full of chains. I returned to the office to conduct the closing conference and after the closing conference I decided to go back out with Messrs. Wolfe, Gates, and Tunley to remove some of the water in the container in order to get a better look at the contents of the container. After Mr. Wolfe removed some of the standing water in the container, I could see that it contained dried yellow traffic paint. I asked for a copy of the Material Safety Data Sheet (MSDS) for the paint and I was provided with a copy during the inspection. According to the MSDS, the waste paint contained the following constituents: Lead (3% by weight) and Chromium (Hexavalent Chromium 0.69 % by weight) 9 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 Based on those levels, the lead (30,000 ppm) and chromium (>6,000 ppm) would exceed the maximum concentration regulatory level of 5.0 (mg/L) or 5 ppm for each constituent. There was no clear indication of how long the waste had been onsite. Photo(s) 1. Observation_Image-202104121456575657228624.jpg 2. Observation_Image-20210412145708578210354.jpg 3. Observation_Image-202104121457255725296743.jpg 4. Observation_Image-202104121458135813224202.jpg 5. Observation_Image-202104121458275827220063.jpg Records Review A At the time of the inspection, the facility had no records to review. SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. Building: Cold Shed JJ1-OB-009 While in the Cold Shed, I saw two 55-gallon containers on a pallet. One container was halffull of hardened, white traffic paint. The other container felt as though it were full, looked old and rusty and according to the label, contained Toluene. Area: Citation: Sub-area: Section: JJ1-OB-010 While in the Cold Shed, I saw a salvage drum that contained something. I asked Mr. Gates what the salvage drum held and he said he wasn't sure. Citation: Section: JJ1-OB-011 While in the Cold Shed, I saw 55-gallon container of unknown contents. This container was later determined to contain Reclamite. Citation: Section: 10 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): JJ1-OB-012 While inspecting another area of the cold shed, I saw a pallet containing various one-gallon cans of a resin and a road penetrating sealer. Writing on the resin container says do not allow to freeze. Approximately 22 boxes on pallet with additional miscellaneous containers requiring a waste determination. Citation: JJ1-OB-013 While in the Cold Shed, I saw an unlabeled 55-gallon container next to the pallet of resin. The container was opened during the inspection and determined to be white paint. Citation: Building: Electricians Bay Area: JJ1-OB-008 During the inspection I saw two small cardboard boxes that contained waste high-pressure sodium light bulbs. I saw 36+ waste lamps and one was broken. Mr. Gates asked how the lamps should be managed and I told him that his facility would need to make a hazardous waste determination. Following the inspection, the facility updated the inventory, indicating that there were 47 High-pressure sodium bulbs and 10 fluorescent light tubes. The bulbs and lamps were not labeled and there was no indication of when the bulbs/lamps first became a waste. Citation: Building: Equipment Shop JJ1-OB-006 Area: Boiler room 11 of 43 04/12/2021 - 04/12/2021 Section: Section: Sub-area: Section: Sub-area: ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): While in the boiler room, I saw a five-gallon container that was marked with the words "Caution Hazardous Waste" and the date 9-17-02. At the time of the inspection there was no other information available regarding the container or its contents. The container was not marked with a hazard indicator. Citation: Section: 04/12/2021 - 04/12/2021 Building: Equipment Shop Area: Maintenance and Operations JJ1-OB-007 While in the tool room, I inspected the contents of a trash receptacle and saw a punctured aerosol can in the trash. Upon further inspection, I noticed that the puncture hole was different from the other punctured cans I had seen at the facility. Citation: I asked Mr. Gates if there was an aerosol can puncturing device on this end of the building. He said there was not. I then asked if someone was puncturing the aerosols with something else and he said, That's what it looks like." Sub-area: Tool room Section: Building: Equipment Shop Area: SEF Welding room JJ1-OB-002 There were two waste aerosol Citation: cans inside a trash receptacle, in the welding room. Sub-area: Section: Building: Equipment Shop Area: Vehicle Maintenance JJ1-OB-003 There was no cap on the aerosol can puncturing device that was attached to the SAA container being used to accumulate waste aerosol can residue. Since the container was Citation: Sub-area: Section: 12 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): not closed, the contents would have been able to evaporate. JJ1-OB-004 View of a punctured aerosol can Citation: in the trash, showing that the facility is not recycling the can. JJ1-OB-005 15-gallon used oil receiver, containing approximately 10 gallons of used oil, is not labeled with the words "Used Oil." Citation: Building: The Hill JJ1-OB-014 55-gallon container identified with unknown contents. Area: Citation: JJ1-OB-015 Container of dried waste traffic paint was identified. The container was not closed, not labeled with the words Hazardous Waste, a hazard indicator, or accumulation start date. According to the MSDS, the waste paint contains lead and chromium. Citation: SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection. 04/12/2021 - 04/12/2021 Section: Section: Sub-area: Section: Section: Closing Conference I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern that I observed during my walk-through inspection and paperwork review while at the facility. I answered any questions they had and explained the follow-up process that would take place after the inspection. 13 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 Following the inspection, I received an email from Mr. Tunley, dated 4/14/2021. In that email, Mr. Tunley referenced the following attachments, providing the following information: 200077596 8122 Clean Harbors - Represents three years of Juneau M&O's paint disposal. SEF Antifreeze shipping and disposal - Represents the last three years of Juneau SEF's antifreeze disposal. 12APR2021 RCRA Insp Inventory - Preliminary inventory of materials and containers identified during your inspection of our facility. Blank 1st Floor and 2nd Floor... - simple schematics of our different facility areas, excluding our outbuildings and outdoor areas. 7-Mile overview...- overhead images of our facility, outbuildings and outdoor areas captured from Google Earth (APR and SEP 2020). The Remaining attachments are SDS's for most of the products identified during your inspection. We will forward the remaining SDSs when they become available to us. The email continued, with Mr. Tunley stating the following: "We have initiated the process for getting drums and containers with unknown content sampled, identified, overpacked, shipped and disposed of. We will provide the results of sampling once we receive them. We will also provide the other documents associated with the shipping and disposal once we have those." Mr. Tunley followed up with another email, dated 5/12/2021, after a recent phone conversation I had with him. In that email, Mr. Tunley provided some of the following information: SDS's for paints that were disposed of via Clean Harbors in 2020 (Ennis-Flint paints and Flush Solvent) A synopsis of the process used for the Bulb Crusher and filters "Regarding the 12 drums that were disposed of in 2020, via Clean Harbors, it is believed that these were from roadway and airfield marking projects in the Southeast District of the Southcoast Region; we are still trying to determine exactly which stations. That said, our roadway and airfield marking projects have been using Ennis-Flint products for more than 10 years. It is unknown how many of the drums disposed of in 2020 were paint vs paint related materials and, unfortunately, the additional information we were able to get from Clean Harbors was rather vague (see attachment IMG_1167)." "Regarding the drums you identified during your inspection, we have had them sampled by a local environmental company and are awaiting their results." "As for training records for Hazardous/Universal Waste training, we were not able to locate any training records. That said, our team is developing training modules for the various workgroups that generate and handle RCRA wastes." At the time this inspection report was completed, no other outstanding information has been received from the facility. 14 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VI - LIST OF APPENDICES Photo Log [Title] Observation_Image202104121259565956271225.jpg 04/12/2021 12:59 PM (AKT) Jon Jones Cold Shed No CBI No PII View of open container that was half full of hardened, white traffic paint. 04/12/2021 - 04/12/2021 [Title] Observation_Image20210412130041041289380.jpg 04/12/2021 01:00 PM (AKT) Jon Jones Cold Shed No CBI No PII Close-up view of the label on the open container that was half full of hardened, white traffic paint. 15 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image2021041213010616296971.jpg 04/12/2021 01:01 PM (AKT) Jon Jones Cold Shed No CBI No PII Close-up view looking down into the open container that was half full of hardened, white traffic paint. [Title] Observation_Image20210412130226226259617.jpg 04/12/2021 01:02 PM (AKT) Jon Jones Cold Shed No CBI No PII Another view of the open container that was half full of hardened, white traffic paint, and next to a 55-gallon container labeled as Toluene. 04/12/2021 - 04/12/2021 16 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412130244244272723.jpg 04/12/2021 01:02 PM (AKT) Jon Jones Cold Shed No CBI No PII Close-up view of the label on the container of Toluene. [Title] Observation_Image20210412130658658300321.jpg 04/12/2021 01:06 PM (AKT) Jon Jones Cold Shed No CBI No PII View of an 85-gallon salvage drum that held unknown contents. I asked Mr. Gates what the salvage drum held and he said he wasn't sure. 04/12/2021 - 04/12/2021 17 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412130711711313229.jpg 04/12/2021 01:07 PM (AKT) Jon Jones Cold Shed No CBI No PII Another view of the 85-gallon salvage container with unknown contents. [Title] Observation_Image20210412130720720278022.jpg 04/12/2021 01:07 PM (AKT) Jon Jones Cold Shed No CBI No PII Another view of the 85-gallon salvage container with unknown contents. 04/12/2021 - 04/12/2021 18 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412132005205236946.jpg 04/12/2021 01:20 PM (AKT) Jon Jones Cold Shed No CBI No PII View of 55-gallon container of unknown contents. [Title] Observation_Image202104121320252025205606.jpg 04/12/2021 01:20 PM (AKT) Jon Jones Cold Shed No CBI No PII Closer view of 55-gallon container label marked as being Reclamite. 04/12/2021 - 04/12/2021 19 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121320572057210307.jpg 04/12/2021 01:20 PM (AKT) Jon Jones Cold Shed No CBI No PII Another view of 55-gallon container label marked as being Reclamite. [Title] Observation_Image202104121332173217299027.jpg 04/12/2021 01:32 PM (AKT) Jon Jones Cold Shed No CBI No PII Various one-gallon cans of a resin and a road penetrating sealer observed on a pallet. Writing on the resin container says do not allow to freeze. Approximately 22 boxes on pallet. 04/12/2021 - 04/12/2021 20 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121332403240322846.jpg 04/12/2021 01:32 PM (AKT) Jon Jones Cold Shed No CBI No PII Close-up view of the labels on various onegallon cans of a resin and a road penetrating sealer. Writing on the resin container says do not allow to freeze. Approximately 22 boxes on pallet. [Title] Observation_Image202104121332583258283627.jpg 04/12/2021 01:32 PM (AKT) Jon Jones Cold Shed No CBI No PII View of the pallet containing various onegallon cans of a resin and a road penetrating sealer. Approximately 22 boxes on pallet along with other miscellaneous containers. 04/12/2021 - 04/12/2021 21 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121337553755265440.jpg 04/12/2021 01:37 PM (AKT) Jon Jones Cold Shed No CBI No PII View of unlabeled 55-gallon container, that was next to pallet of resin beneath the steel shelving. [Title] Observation_Image20210412133807387275125.jpg 04/12/2021 01:38 PM (AKT) Jon Jones Cold Shed No CBI No PII Close-up view of the contents of the pallet. 04/12/2021 - 04/12/2021 22 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121338263826256841.jpg 04/12/2021 01:38 PM (AKT) Jon Jones Cold Shed No CBI No PII Close-up view of the contents of the pallet. [Title] Observation_Image202104121234503450306488.jpg 04/12/2021 12:34 PM (AKT) Jon Jones Electricians Bay No CBI No PII View of 47 waste high-pressure sodium bulbs. The waste bulbs were in containers that were not closed, labeled, and there was no indication as to when the bulbs became a waste. 04/12/2021 - 04/12/2021 23 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412123501351330491.jpg 04/12/2021 12:35 PM (AKT) Jon Jones Electricians Bay No CBI No PII Close-up view of the waste high-pressure sodium bulbs. A broken bulb can be seen in the bottom right-hand corner of the box on the left. [Title] Observation_Image202104121235253525270533.jpg 04/12/2021 12:35 PM (AKT) Jon Jones Electricians Bay No CBI No PII Close-up view of a high-pressure sodium bulb sleeve, showing the manufacturer information. 04/12/2021 - 04/12/2021 24 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121145564556273913.jpg 04/12/2021 11:45 AM (AKT) Jon Jones Equipment Shop/Boiler room No CBI No PII View of a five-gallon container that was marked with the words "Caution Hazardous Waste" and the date 9-17-02. The container is seen here with the blue lid. [Title] Observation_Image202104121146104610270717.jpg 04/12/2021 11:46 AM (AKT) Jon Jones Equipment Shop/Boiler room No CBI No PII Close-up view of the five-gallon container that was marked with the words "Caution Hazardous Waste" and the date 9-17-02. 04/12/2021 - 04/12/2021 25 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121146284628193661.jpg 04/12/2021 11:46 AM (AKT) Jon Jones Equipment Shop/Boiler room No CBI No PII Another close-up view of the five-gallon container that was marked with the words "Caution Hazardous Waste" and the date 917-02. [Title] Observation_Image202104121020532053327871.jpg 04/12/2021 10:20 AM (AKT) Jon Jones Equipment Shop/Maintenance and Operations No CBI No PII View of the M&O side of the Equipment Shop, as seen from the mezzanine above. 04/12/2021 - 04/12/2021 26 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412103906396342749.jpg 04/12/2021 10:39 AM (AKT) Jon Jones Equipment Shop/SEF Welding room No CBI No PII View of waste aerosol can inside a trash receptacle, in the welding room. [Title] Observation_Image202104121039183918314798.jpg 04/12/2021 10:39 AM (AKT) Jon Jones Equipment Shop/SEF Welding room No CBI No PII Close-up view of same waste aerosol can inside a trash receptacle, in the welding room. 04/12/2021 - 04/12/2021 27 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121039333933307138.jpg 04/12/2021 10:39 AM (AKT) Jon Jones Equipment Shop/SEF Welding room No CBI No PII View of second waste aerosol can in the bottom of the trash receptacle, in the welding room. [Title] Observation_Image202104121042164216308559.jpg 04/12/2021 10:42 AM (AKT) Jon Jones Equipment Shop/SEF Welding room No CBI No PII Close-up view of both waste aerosol cans inside a trash receptacle, in the welding room. 04/12/2021 - 04/12/2021 28 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121042504250352205.jpg 04/12/2021 10:42 AM (AKT) Jon Jones Equipment Shop/SEF Welding room No CBI No PII Close-up view of the labeling on the waste aerosol cans inside a trash receptacle, in the welding room. [Title] Observation_Image20210412110541541296478.jpg 04/12/2021 11:05 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII View of the SAA container with attached aerosol can popper. 04/12/2021 - 04/12/2021 29 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412110551551314213.jpg 04/12/2021 11:05 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Close-up view of the SAA container with attached aerosol can popper. [Title] Observation_Image2021041211060262315074.jpg 04/12/2021 11:06 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Close-up view of the top of the aerosol can popper, showing that the lid is not attached and the container is not closed. 04/12/2021 - 04/12/2021 30 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121111341134299659.jpg 04/12/2021 11:11 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Another view of the same SAA container showing that the aerosol can popper lid is not attached and laying on top of the container. [Title] Observation_Image202104121111411141342068.jpg 04/12/2021 11:11 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Close-up view of the aerosol can popper lid laying on the top of the SAA container. 04/12/2021 - 04/12/2021 31 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121114541454328060.jpg 04/12/2021 11:14 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Mr. Wolfe closed the container during the inspection by placing the lid back on the aerosol can popper. [Title] Observation_Image202104121126232623244724.jpg 04/12/2021 11:26 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII View of a punctured aerosol can in the trash. 04/12/2021 - 04/12/2021 32 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121126302630229247.jpg 04/12/2021 11:26 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Close-up view of a punctured aerosol can in the trash. [Title] Observation_Image20210412113203323257203.jpg 04/12/2021 11:32 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII View of 15-gallon used oil receiver, containing approximately 10 gallons of used oil, that is not labeled with the words "Used Oil." 04/12/2021 - 04/12/2021 33 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121132193219276286.jpg 04/12/2021 11:32 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Another view of 15-gallon used oil receiver, containing approximately 10 gallons of used oil, that is not labeled with the words "Used Oil." [Title] Observation_Image202104121132333233284307.jpg 04/12/2021 11:32 AM (AKT) Jon Jones Equipment Shop/Vehicle Maintenance No CBI No PII Another view of 15-gallon used oil receiver, containing approximately 10 gallons of used oil, that is not labeled with the words "Used Oil." 04/12/2021 - 04/12/2021 34 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121211131113337325.jpg 04/12/2021 12:11 PM (AKT) Jon Jones Maintenance and Operations/Tool room No CBI No PII View of the tool room, where I inspected the contents of a trash receptacle and saw a punctured aerosol can in the trash. Upon further inspection, I noticed that the puncture hole was different from the other punctured cans I had seen at the facility. I asked Mr. Gates if there was an aerosol can puncturing device on this end of the building. He said there was not. I then asked if someone was puncturing the aerosols with something else and he said, "That's what it looks like." [Title] Observation_Image202104121211301130349579.jpg 04/12/2021 12:11 PM (AKT) Jon Jones Maintenance and Operations/Tool room No CBI No PII View of the punctured aerosol can in the trash receptacle. 04/12/2021 - 04/12/2021 35 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121211441144321589.jpg 04/12/2021 12:11 PM (AKT) Jon Jones Maintenance and Operations/Tool room No CBI No PII View of the punctured aerosol can in the trash receptacle. [Title] Observation_Image202104121345184518224573.jpg 04/12/2021 01:45 PM (AKT) Jon Jones The Hill No CBI No PII Rusty and dented 55-gallon container holding unknown contents. 04/12/2021 - 04/12/2021 36 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121345514551183368.jpg 04/12/2021 01:45 PM (AKT) Jon Jones The Hill No CBI No PII Another view of the rusty and dented 55gallon container holding unknown contents. [Title] Observation_Image202104121456575657228624.jpg 04/12/2021 02:56 PM (AKT) Jon Jones The Hill No CBI No PII Open 55-gallon container half full of dried waste yellow traffic paint. 04/12/2021 - 04/12/2021 37 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image20210412145708578210354.jpg 04/12/2021 02:57 PM (AKT) Jon Jones The Hill No CBI No PII View of the bottom of the container, showing that at one point in time, the waste paint was leaking from the bottom of the container. [Title] Observation_Image202104121457255725296743.jpg 04/12/2021 02:57 PM (AKT) Jon Jones The Hill No CBI No PII View of the contents of the container holding the dried yellow waste traffic paint. 04/12/2021 - 04/12/2021 38 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): [Title] Observation_Image202104121458135813224202.jpg 04/12/2021 02:58 PM (AKT) Jon Jones The Hill No CBI No PII View of the container, half full of waste traffic paint, as seen from the roadway leading into the area known as "The Hill." [Title] Observation_Image202104121458275827220063.jpg 04/12/2021 02:58 PM (AKT) Jon Jones The Hill No CBI No PII Another view of the container, half full of waste traffic paint, as seen from the roadway leading into the area known as "The Hill." This view shows the Cold Shed to the far left and the Equipment shop straight ahead. Document Log 04/12/2021 - 04/12/2021 39 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): Document Type Document Name 04/12/2021 - 04/12/2021 Contains Contains Uploaded By CBI PII Date Received Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Burke 3200 Useal Part A.pdf No No Jon Jones 06/10/2021 Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed SikaPronto19TF part B.pdf No No Jon Jones 06/10/2021 Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Permagile Part B.pdf No No Jon Jones 06/10/2021 Other - Material Safety Power_Steering_Fluid_AC_Delco_10- No No Jon Jones 06/10/2021 Data Sheets (MSDS) / 5073_SDS_EN.pdf Safety Data Sheets (SDS) for waste identified in the Cold Shed Other - Material Safety Bondo traffic sensor seal 7084 pt A No No Jon Jones 06/11/2021 Data Sheets (MSDS) / and B.pdf Safety Data Sheets (SDS) for waste identified in the Cold Shed Other - Material Safety Chemsearch ChromaTite ptA.pdf No No Jon Jones 06/11/2021 Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Other - Material Safety Chemsearch ChromaTite ptB.pdf No No Jon Jones 06/11/2021 Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Other - Material Safety Chemsearch GripTite ptA, B, C.pdf No No Jon Jones 06/11/2021 Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste 40 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 identified in the Cold Shed Other - Material Safety Chevron Supreme Motor Oil SAE 5W- No No Jon Jones 06/11/2021 Data Sheets (MSDS) / 30 MSDS - Chevron-Supreme-Motor- Safety Data Sheets Oil-SAE-5W-30-MSDS.pdf (SDS) for waste identified in the Cold Shed Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed CITGO 500 15W40.pdf No No Jon Jones 06/11/2021 Other - Material Safety PARKS DENATURED ALCOHOL _2122- No No Jon Jones 06/11/2021 Data Sheets (MSDS) / 2123-2125-2127_.doc - MSDS - Safety Data Sheets Parks.pdf (SDS) for waste identified in the Cold Shed Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Sika Pronto 19TF ptA.pdf No No Jon Jones 06/11/2021 Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Tricor Asphalt Rejuvenating Agent.pdf No No Jon Jones 06/11/2021 Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed Toluene.pdf No No Jon Jones 06/11/2021 Other - Material Safety Data Sheets (MSDS) / Safety Data Sheets (SDS) for waste identified in the Cold Shed MORTON INTL INC SPECIALTY CHEMICALS GROUP.pdf No No Jon Jones 06/11/2021 Other - Material Safety EF SB LowVOC White.pdf Data Sheets (MSDS) / Safety Data Sheets (SDS) for traffic paint No No Jon Jones 06/11/2021 41 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 Other - Material Safety EF SB LowVOC Yello.pdf Data Sheets (MSDS) / Safety Data Sheets (SDS) for traffic paint No No Jon Jones 06/11/2021 Other - Material Safety EF SB FlushSolvent.pdf Data Sheets (MSDS) / Safety Data Sheets (SDS) for traffic paint No No Jon Jones 06/11/2021 Other - Material Safety EF WB White.pdf Data Sheets (MSDS) / Safety Data Sheets (SDS) for traffic paint No No Jon Jones 06/11/2021 Other - Material Safety EF WB Yello.pdf Data Sheets (MSDS) / Safety Data Sheets (SDS) for traffic paint No No Jon Jones 06/11/2021 Other - Material Safety MSDS from 2012 CEI for Morline No No Jon Jones 06/11/2021 Data Sheets (MSDS) / Yellow Traffic Paint.PDF Safety Data Sheets (SDS) for traffic paint Other - Inventory of 12APR2021 RCRA Insp Inventory.pdf No No Jon Jones 06/11/2021 RCRA Waste identified12APR2021 Other - Edited edit15APR2021 RCRA Insp Inventory RCRA Waste Inventory.pdf identified 12APR2021 No No Jon Jones 06/11/2021 Other - Bulb crushing Regarding Bulb Crusher.pdf information No No Jon Jones 06/11/2021 Facility Map 7-Mile overview-high.jpg No No Jon Jones 06/11/2021 Facility Map 7-Mile overview-low.jpg No No Jon Jones 06/11/2021 Facility Map 7-Mile overview-mid.jpg No No Jon Jones 06/11/2021 Facility Map Blank 1st Floor M&OnSEF.pdf No No Jon Jones 06/11/2021 Facility Map Blank 1st Floor Offices.pdf No No Jon Jones 06/11/2021 Facility Map Blank 2nd Floor M&OnSEF.pdf No No Jon Jones 06/11/2021 Facility Map Blank 2nd Floor Offices w Mez.pdf No No Jon Jones 06/11/2021 Other - Receipt and 200077596 8122 Clean Harbors No No Jon Jones 06/11/2021 Clean Harbors Waste $8,141.97.pdf Inventory sheet for 12, 55-gallon containers of Paint Related Material (PRM) totaling 6,411 pounds Communications SEF Antifreeze shiping and disposal No No Jon Jones 06/11/2021 for EPA .pdf Communications FW_ Oil can photo SEF.pdf No No Jon Jones 06/11/2021 42 of 43 ALASKA DOT & PF 6860 GLACIER HWY Inspection Date(s): 04/12/2021 - 04/12/2021 Communications 4.15.21 email rearding lamp-bulb No No Jon Jones 06/11/2021 management and inventory.pdf Communications 5.12.21 email from facility.pdf No No Jon Jones 06/11/2021 Inspection Reports Field_Notes_AKD983066366v1.0.pdf No No Jon Jones 06/11/2021 43 of 43