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
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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.
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Inspection Date(s):
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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.
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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
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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
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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
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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
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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
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Contains CBI: No
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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)
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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:
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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
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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:
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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.
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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.
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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