Document R2dzvmjMd4NzB378VaJwpy4yn
Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied:
REGION 10 Enforcement Division
INSPECTION REPORT
05/27/2021 - 05/27/2021 Announced: No
Entry: 07:53 AM (AKT)
Exit: 11:57 AM (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:
OBI Seafoods, LLC OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY 621 SHELIKOF ST KODIAK, AK 99615 Seafood Processor 127,000 square feet Since 1910 57.78498, -152.421253 Mr. Alex Thatcher, Environmental Compliance Manager OBI Seafoods, LLC 1100 West Ewing Street, Seattle, WA 98119 Phone: (206) 285-6800 Mobile: (206) 455-5488 alex.thatcher@obiseafoods.com
CC: Mr. James Turner, Plant Manager james.turner@obiseafoods.com Ocean Beauty Seafoods, Inc. - Kodiak Facility (907) 486-5791
Seattle, WA 98119 King
Facility/Site Identifier: Media Number: NAICS:
AKD063376974 Unpermitted Facility 311710 - Seafood Product Preparation and Packaging
Lead Inspector: Jon Jones
Jones, Jon REGION 10
Digitally signed by Jones, Jon Date: 2021.08.18 13:24:04 -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: 2021.08.18 14:34:33 -07'00'
Sullivan.Jennifer.A@epa.gov
(206) 553-6978
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection
05/27/2021 - 05/27/2021
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
Phone
Email
Lead Inspector Jon Jones 9072716329 Jones.Jon@epa.gov
Present in Opening Conf.
Yes
Plant Manager James Turner (907) 486-5791 james.turner@obiseafoods.com Yes
Director of
Don Dillon
Maintenance
and Engineering
(907) 486-5791 don.dillon@obiseafoods.com Yes
Environmental Compliance Manager
QA Manager
Alex Thatcher (206) 455-5488 alex.thatcher@obiseafoods.com Yes Ryan Musch (907) 486-5791 ryan.musch@obiseafoods.com Yes
Safety Manager Rome Kamai (907) 539-2412 rome.kamai@obiseafoods.com Yes
Present in Closing Conf. Yes Yes No
Yes
Yes No
Opening Conference
EPA Lead Inspector Jon Jones arrived at the Ocean Beauty Seafoods, Inc - Kodiak Facility at 07:53 AM (AKT) on 05/27/2021 for an inspection. I presented my credentials to James Turner and informed him that this was an EPA RCRA inspection. The table above presents all the opening and closing conference inspection participants.
During the opening conference, Mr. Turner told me that Ocean Beauty had recently acquired Icicle Seafoods and the company changed its name to OBI Seafoods, LLC. OBI is an abbreviation for Ocean Beauty Icicle.
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 used oil management.
Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in Section III of this inspection report.
I was accompanied for the entirety of the inspection by Messrs. Thatcher, Dillon, Musch and Kamai.
Facility/Site Description
Ocean Beauty Seafoods, Inc. - Kodiak Facility is a Seafood Processor located in Kodiak, AK. A copy of the facility's Notice of Intent, required as part of the facility's CWA/NPDES permit, was obtained during the inspection and contains additional information about the facility, including the types of seafood processed at
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): the facility.
Facility Info
Number of employees 50 to 350 seasonally, currently 287
Weather Conditions Clear and sunny
Safety Training
No
Provided to
Inspector(s)?
What type of generator facility notified?
Very Small Quantity Generator (VSQG)
What type of generator facility verified as?
Verified VSQG by Alex Thatcher
Operating Hours
24/7/365
05/27/2021 - 05/27/2021
Process Description According to OBI representatives, the following wastes are generated at the Kodiak facility:
Cooking oil - sent to Arlington, WA facility Used oil from forklifts - sent to Arlington, WA facility Used oil from refrigeration - sent to Arlington, WA facility LED lighting - sent to Arlington, WA facility Aerosol wastes, WD-40, paints, etc - disposed of locally as solid waste Latex paint - sent to Arlington, WA facility Diesel used as a solvent - sent to Arlington, WA facility Mineral Spirits - sent to Arlington, WA facility Rags/wipes contaminated with MEK - disposed of locally as solid waste Videojet makeup fluid (D001) - sent down to Arlington, WA facility
Building(s)
Building/Area Cannery Fabrication forklift shop Galley Trash dumpster located just to the left of the galley entrance
Process Description
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Area of Concern No Yes No Yes
OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY
Inspection Date(s):
05/27/2021 - 05/27/2021
Maintenance Shop
Yes
Oil Storage Van
Accumulation of used gasoline, used antifreeze, Yes used solvent (Stoddard solvent according to Mr. Dillon), and used oil.
South end warehouse
used oil and product storage
No
SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations
Building: Cannery
Contains CBI: No
Observation #: JJ1-OB-006
Date/Time: 05/27/2021
While in the Cannery I saw three additional quart size containers of waste ink on a table.
Photo(s)
1. Observation_Image-202105271019511951421272.jpg 2. Observation_Image-202105271019581958331812.jpg 3. Observation_Image-20210527102007207439341.jpg
Building: Fabrication forklift shop
Contains CBI: No
Observation #: JJ1-OB-002
Date/Time: 05/27/2021
While inspecting the contents of some flammable storage cabinets, I saw some containers of Methyl Ethyl Ketone (MEK). I asked what the MEK was used for and Mr. Dillon said it was used for thinning paint and clean up. I asked if rags/wipes were used with the MEK. Mr. Dillon told me that rags/wipes were used for clean-up. I then asked how the rags/wipes were being managed and he told me they were disposed of into the trash as solid waste.
Photo(s)
1. Observation_Image-202105270857185718495419.jpg 2. Observation_Image-202105270858105810433334.jpg 3. Observation_Image-202105270858165816434646.jpg
Building: Galley/Trash dumpster located just to the Contains CBI: No left of the galley entrance
Observation #: JJ1-OB-004
Date/Time: 05/27/2021
During the inspection, Mr. Dillon told me that the rags/wipes, contaminated with MEK, were disposed of into the trash dumpster just outside the galley. The trash is picked up by Alaska Waste and disposed of at the Kodiak Borough Landfill. The rags/wipes contaminated with MEK are an F-listed waste.
Photo(s)
1. Observation_Image-202105270927352735413791.jpg 2. Observation_Image-202105270928102810448006.jpg 3. Observation_Image-202105270928192819518973.jpg
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s):
05/27/2021 - 05/27/2021
Building: Maintenance Shop
Contains CBI: No
Observation #: JJ1-OB-005
Date/Time: 05/27/2021
During my inspection of the maintenance shop, I saw four, quart size, containers of what Mr. Dillon said was waste ink, along with nine boxes, each containing six waste ink cartridges. The ink and ink cartridges are used in product labeling. At the time of the inspection, the boxes of ink were labeled as waste and three of the quart size containers were leaking.
Mr. Dillon said the ink would be shipped down to their Arlington, WA facility for final disposal. Mr. Thatcher told me that the Arlington facility was a WA state SQG (federal VSQG). However, information contained in the facility's RCRA site detail report indicates the facility is not a generator. Information for the receiving facility is as follows:
Arlington, WA EPA I.D.# WAH 00005 7800 OBI Seafoods Arlington 19405 68th Drive NE (Bldg B) Arlington, WA 98223
During the inspection, I requested a copy of the Safety Data Sheet (SDS) for Videojet makeup fluid and cartridges, and one was provided.
Photo(s)
1. Observation_Image-20210527095505555441011.jpg 2. Observation_Image-202105270955175517448929.jpg 3. Observation_Image-202105270955315531450960.jpg 4. Observation_Image-202105270958545854429364.jpg
Building: Oil Storage Van
Contains CBI: No
Observation #: JJ1-OB-003
Date/Time: 05/27/2021
While inspecting the Oil Storage Van, I saw four 55-gallon containers being used to accumulate the following four wastes:
used gasoline used antifreeze used solvent used oil There was labeling on the wall behind and just above each container which indicated what each container held. However, at the time of the inspection, none of the 55-gal accumulation containers were labeled.
Specifically, the 55-gal container being used to accumulate used oil was not labeled with the words, "Used Oil."
Photo(s)
1. Observation_Image-20210527090930930407376.jpg 2. Observation_Image-20210527090959959356168.jpg 3. Observation_Image-202105270912141214337223.jpg 4. Observation_Image-202105270912261226338214.jpg 5. Observation_Image-202105270932323232357384.jpg
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s):
05/27/2021 - 05/27/2021
Building: South end warehouse
Contains CBI: No
Observation #: JJ1-OB-001
Date/Time: 05/27/2021
I saw four, 55-gallon containers on a pallet that were wrapped with a band of cellophane that was labeled with the words, "Galley Dirty Oil." According to Mr. Dillon they held used cooking oil.
Photo(s)
1. Observation_Image-202105270846464646289742.jpg 2. Observation_Image-202105270847294729253245.jpg 3. Observation_Image-202105270847584758309983.jpg
Records Review
Record: Shipping Documents/Tolling agreements
Ref #: JJ1-RR-001
Reviewed By: Jon Jones
AOC: Yes Reviewed Date: 07/26/2021
I reviewed the bills of lading for the facility for the last several years for wastes that were shipped down to their Arlington, WA facility. The OBI Seafoods Kodiak Division is self-transporting their waste, by vessel, to another OBI facility that is not a large quantity generator. The OBI seafoods, LLC Arlington, WA facility (WAH000057800) is listed on their site detail report as a non-generator.
Document(s)
1. 2.6.2018 BOL.pdf 2. 6.1.2018 BOL.pdf 3. 9.17.2017 BOL.pdf 4. 9.17.2017(2) BOL.pdf 5. 9.23.2019 BOL.pdf 6. 9.27.2019 BOL.pdf 7. 10.4.2019 BOL.pdf 8. 10.26.2020 BOL.pdf 9. 10.26.2020(2) BOL.pdf
SECTION III - AREAS OF CONCERN
The presentation of areas of concern does not constitute a formal compliance determination or violation.
Building:
Area:
JJ1-RR-001
The OBI Seafoods Kodiak Division is self-transporting their waste, by vessel, to another OBI facility that is not a large quantity generator. The OBI seafoods, LLC Arlington, WA facility (WAH000057800) is
Citation:
Sub-area:
Section:
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY
Inspection Date(s): listed on their site detail report as a non-generator.
Building: Fabrication forklift shop
Area:
JJ1-OB-002
While inspecting the contents of flammable storage cabinets, I saw some containers of MEK. I asked what the MEK was used for and Mr. Dillon said it was used for thinning paint and clean up. I asked if rags/wipes were used with the MEK and he told me they were, and the rags/wipes were disposed of as solid waste.
Citation:
Building: Galley
Area: Trash dumpster located just to the left of the galley entrance
JJ1-OB-004
During the inspection, Mr. Dillon told me that the rags/wipes contaminated with MEK were disposed of into the trash. The trash is picked up by Alaska Waste and disposed of at the Kodiak Borough Landfill. The rags/wipes contaminated with MEK are an F-listed waste.
Citation:
Building: Maintenance Shop
JJ1-OB-005
During my inspection of the maintenance shop, I saw four, quart size containers of what Mr. Dillon said was waste ink, along with nine boxes, each containing six waste ink cartridges. The ink and ink cartridges are used in product labeling. At the time of the inspection, three of the quart size containers were leaking.
Area: Citation:
Mr. Dillon said the ink would be
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05/27/2021 - 05/27/2021
Sub-area:
Section:
Sub-area: Section:
Sub-area: Section:
OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY
Inspection Date(s):
shipped down to their Arlington, WA facility for final disposal. Mr. Thatcher told me that the Arlington facility was a WA state SQG (federal VSQG).
05/27/2021 - 05/27/2021
Building: Oil Storage Van
Area:
JJ1-OB-003
At the time of the inspection, the 55-gal container being used to accumulate used oil was not labeled with the words, "Used Oil."
Citation:
Sub-area: Section:
SECTION IV - FOLLOW UP
Building: JJ1-AF-001
Area:
Sub-area:
Following the inspection, Mr. Thatcher sent me an email, dated 6/8/21, in which he provided photo documentation of containers that were labeled after the inspection. He also elaborated on the generation of off-spec gasoline and solvent at the facility.
Building: Maintenance Shop JJ1-OB-005
Area:
Sub-area:
I requested a copy of the SDS for the waste Videojet makeup fluid and cartridges. A copy of the SDS was provided during the inspection.
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 then explained the follow-up process that would take place after the inspection.
SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted.
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s):
SECTION VI - LIST OF APPENDICES Photo Log
[Title] Observation_Image202105271019511951421272.jpg 05/27/2021 10:19 AM (AKT) Jon Jones Cannery No CBI No PII View of three, quart size containers of waste ink seen here on a table in the cannery.
[Title] Observation_Image202105271019581958331812.jpg 05/27/2021 10:19 AM (AKT) Jon Jones Cannery No CBI No PII Close-up view of the three, quart size containers of waste ink on a table in the cannery.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image20210527102007207439341.jpg 05/27/2021 10:20 AM (AKT) Jon Jones Cannery No CBI No PII Another view of the same three, quart size containers of waste ink seen here on a table in the cannery.
[Title] Observation_Image202105270857185718495419.jpg 05/27/2021 08:57 AM (AKT) Jon Jones Fabrication forklift shop No CBI No PII View of the MEK containers inside the flammable storage locker.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270858105810433334.jpg 05/27/2021 08:58 AM (AKT) Jon Jones Fabrication forklift shop No CBI No PII View of the red step can, where the waste rags/wipes, contaminated with MEK, are disposed as solid waste.
[Title] Observation_Image202105270858165816434646.jpg 05/27/2021 08:58 AM (AKT) Jon Jones Fabrication forklift shop No CBI No PII View inside the red step can, showing that there were no rags/wipes in the step can at the time of the inspection.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270927352735413791.jpg 05/27/2021 09:27 AM (AKT) Jon Jones Galley/Trash dumpster located just to the left of the galley entrance No CBI No PII View of the trash dumpster, just outside of the galley, where the rags/wipes, contaminated with MEK, have been disposed.
[Title] Observation_Image202105270928102810448006.jpg 05/27/2021 09:28 AM (AKT) Jon Jones Galley/Trash dumpster located just to the left of the galley entrance No CBI No PII View of the labeling on the outside of the trash dumpster, indicating the only household garbage is acceptable.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270928192819518973.jpg 05/27/2021 09:28 AM (AKT) Jon Jones Galley/Trash dumpster located just to the left of the galley entrance No CBI No PII View inside the trash dumpster.
[Title] Observation_Image20210527095505555441011.jpg 05/27/2021 09:55 AM (AKT) Jon Jones Maintenance Shop No CBI No PII View of the containers and boxes of containers of waste ink.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270955175517448929.jpg 05/27/2021 09:55 AM (AKT) Jon Jones Maintenance Shop No CBI No PII View of the leaking waste ink containers.
[Title] Observation_Image202105270955315531450960.jpg 05/27/2021 09:55 AM (AKT) Jon Jones Maintenance Shop No CBI No PII Close-up view of the waste ink containers and cartridges.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270958545854429364.jpg 05/27/2021 09:58 AM (AKT) Jon Jones Maintenance Shop No CBI No PII View of the boxes that were labeled with the words, "Waste Ink."
[Title] Observation_Image20210527090930930407376.jpg 05/27/2021 09:09 AM (AKT) Jon Jones Oil Storage Van No CBI No PII View of the unlabeled containers inside the Oil Storage Van.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image20210527090959959356168.jpg 05/27/2021 09:09 AM (AKT) Jon Jones Oil Storage Van No CBI No PII View of the black, 55-gallon unlabeled used oil storage container.
[Title] Observation_Image202105270912141214337223.jpg 05/27/2021 09:12 AM (AKT) Jon Jones Oil Storage Van No CBI No PII Another view of the 55-gal container being used to accumulate used oil, showing that it was not labeled with the words, "Used Oil."
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270912261226338214.jpg 05/27/2021 09:12 AM (AKT) Jon Jones Oil Storage Van No CBI No PII Another view of the 55-gal container being used to accumulate used oil, showing that it was not labeled with the words, "Used Oil."
[Title] Observation_Image202105270932323232357384.jpg 05/27/2021 09:32 AM (AKT) Jon Jones Oil Storage Van No CBI No PII View of the Oil Storage Van.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270846464646289742.jpg 05/27/2021 08:46 AM (AKT) Jon Jones South end warehouse No CBI No PII View of containers holding used cooking oil.
[Title] Observation_Image202105270847294729253245.jpg 05/27/2021 08:47 AM (AKT) Jon Jones South end warehouse No CBI No PII Another view of the used cooking oil.
05/27/2021 - 05/27/2021
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OCEAN BEAUTY SEAFOODS INC KODIAK FACILITY Inspection Date(s): [Title] Observation_Image202105270847584758309983.jpg 05/27/2021 08:47 AM (AKT) Jon Jones South end warehouse No CBI No PII Another view of the used cooking oil.
05/27/2021 - 05/27/2021
Document Log
Document Type Document Name
Contains Contains Uploaded By
CBI
PII
Other - Safety Data Videojet Make-up Fluid SDS.pdf No
No
Jon Jones
Sheet
Other - Safety Data Mineral Spirits 365 SDS.pdf Sheet
No
No
Jon Jones
Other - Safety Data MEK SDS.pdf Sheet
No
No
Jon Jones
Records Review 2.6.2018 BOL.pdf
No
No
Jon Jones
Records Review 6.1.2018 BOL.pdf
No
No
Jon Jones
Records Review 9.17.2017 BOL.pdf
No
No
Jon Jones
Records Review 9.17.2017(2) BOL.pdf
No
No
Jon Jones
Records Review 9.23.2019 BOL.pdf
No
No
Jon Jones
Records Review 9.27.2019 BOL.pdf
No
No
Jon Jones
Records Review 10.4.2019 BOL.pdf
No
No
Jon Jones
Records Review 10.26.2020 BOL.pdf
No
No
Jon Jones
Records Review 10.26.2020(2) BOL.pdf
No
No
Jon Jones
Facility Map
Facility drawing.pdf
No
No
Jon Jones
Other - Seafood OBI Kodiak_NOI_Signed 4.23.21.pdf No
No
Jon Jones
Processor Notice of
Intent (NOI) form
Inspection Reports Field_Notes_AKD063376974v1.0.pdf No
No
Jon Jones
Date Received
07/26/2021
07/26/2021
07/26/2021
07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021 07/26/2021
07/26/2021
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