Document XGRQE7rNBpmq7avyo0pprnmJ
Inspection Date(s): Facility or Site Name: Facility/Site Physical Location:
(city, state, zip code) Mailing address (if different from above): Facility/Site Contacts:
Website: RCRA ID Number:
Latitude, Longitude:
HOME DEPOT #0975 INSPECTION REPORT
18-19 April 2024
Inspection Announced: No
Home Depot Store #0975 421 Absecon Blvd.
Absecon, NJ 08201
Christina Quigley Manager Christina_M_Quigley@homedepot.com (609) 484-3511 x500 https://www.homedepot.com/l/Absecon/NJ/Absecon/08201/975
NJR000048009
39.415740, -74.493461
Facility/Site Personnel Participating in Inspection:
Christina Quigley
Manager
Facility/Site Personnel Unavailable During Inspection:
Inspector(s):
Carl F. Plssl
US EPA, Enforcement Officer/Engineer
Plossl.Carl@epa.gov (212) 637-4088
Additional Inspection Report Elements:
HOME DEPOT #0975 (ABSECON, NJ) INSPECTION PHOTO ALBUM.pptx Chemical-Strategy-PFAS-update-Aug-2023-FINAL
Inspection Report Author:
Carl F. Plssl
CARL PLOSSL
Digitally signed by CARL PLOSSL Date: 2024.06.26 16:29:01 -04'00'
Supervisor Leonard Grossman
LEONARD GROSSMAN
Digitally signed by LEONARD GROSSMAN Date: 2024.06.26 16:44:09 -04'00'
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RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
SECTION I - INTRODUCTION
Purpose of the Inspection Objective
A Compliance Evaluation Inspection (CEI) was conducted to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management.
Background
The facility has been previously inspected for RCRA compliance in 2020 by the state, with a finding of no action, and has had a notification history as a small and very small quantity generator (last notification on 9 Feb 2023 as a SQG). A review of the facility's waste manifest records shows a consistent generator status as a SQG with some limited variation from VSQG to SQG (on a monthly basis). The facility is in an environmental justice area and within an extreme flood risk area.
Opening Conference
18 April 2024. I, EPA Region 2 RCRA inspector Plssl, arrived at the main entrance to the Home Depot at ~4:40 pm for an unannounced inspection of the store. I announced and identified myself at the customer counter and was connected to an associate manager. The associate manager was unfamiliar with the nature of compliance inspections and asked if I would return the next morning. I agreed if she would conduct me on a quick inspection of their hazardous waste storage area.
We then began a walk through and inspection of the main back operations area.
19 April 2024. I arrived at the main entrance to the Home Depot at ~9 am for an announced inspection of the store. I announced and identified myself at the customer counter and was connected to the store manager Christina Quigley. Ms. Warren was somewhat familiar with the nature of compliance inspections but not those
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RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
conducted pursuant to RCRA federal and state hazardous waste regulations. We discussed the facility past and current operations, waste management and disposal practices, and the nature of RCRA inspections and ran through the SQG checklist.
We then began a walk through and inspection of the main back operations area and the rental equipment management area.
Facility/Site Description https://www.homedepot.com/l/Absecon/NJ/Absecon/08201/975
From Home Depot: Recycling at The Home Depot Did you know?
Our store diverts waste from landfills by accepting lead acid batteries, rechargeable batteries, plastic plant pots, and CFLs for recycling.
Our stores sent approximately 5.3M pounds of shredded paper for recycling in 2022. This helped the planet by preserving over 63.5K trees. It kept over 16K trash bags of solid waste out of landfills, saved over 50M gallons of water, and conserved 7.8M kilowatt hours of electricity.
Since 2010, we have decreased electricity consumption by over 52% in our U.S. stores.
The Home Depot's core values are based on doing the right thing for our associates and customers. This commitment extends beyond our stores to the environment, as well as our communities. We are your partners in environmental sustainability. Learn more about our eco actions.
According to Ms. Quigley: General o Facility has been operating since 2002 o Manager Quigley is primary emergency coordinator The Fire Department conducts regular inspections and it the facility's primary emergency responder o ~149 employees work at this location, 24-hours per day, Monday-Friday, 5 am until midnight, Saturday and Sunday, along with 24-hour security Facility operates as a small quantity generator Small quantities of generated hazardous wastes primarily consist of aerosol cans, other ignitable wastes, and various commercial products that have been determined to be waste as spill clean-up, damaged container, out-of-date, and returns. Also, contaminated oil and fuel from the equipment rental operations: o Most common waste codes from manifests (in order of frequency): D001, D035, D008, D007, D005, D002, and D039: D001 Ignitable Waste, D002 Corrosive Waste, D003 Reactive Waste, D005 Barium, D006 Cadmium, D007
Chromium, D008 Lead, D016 2,4-D Or 2,4-Dichlorophenoxyacetic Acid, D018 Benzene, D028 1,2-
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RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
Dichloroethane, D035 Methyl Ethyl Ketone, D039 Tetrachloroethylene, D043 Vinyl Chloride, U112 Acetic Acid, Ethyl Ester Or Ethyl Acetate, U159 2-Butanone Or Methyl Ethyl Ketone, U220 Benzene, Methyl Or Toluene, U239 Benzene, Dimethyl- Or Xylene, U240 2,4-D, Salts And Esters Or 2,4-Dichlorophenoxyacetic Acid, Salts And Esters, U279 Carbanyl
Other specific hazardous waste generation o Spent fluorescent lamps (LED lamp replacement program several years ago) o Spent high intensity lamps o Old paints and spent cleaning and painting solvents o Spent aerosol cans o Spent lead acid, NiCd, and lithium batteries o E-wastes
Other regulated wastes o Used oil
Waste dispositions o Hazardous waste determinations generally via a Home Depot proprietary "HHM" smart phone application o Universal waste disposal records were available o Manifests and LDR forms were available
Facility is operating as a small quantity generator. From 2019 to 2024, the facility averaged 296lbs/month.
Additional records requested during inspection: o None
Additional records/information requested by phone/email after inspection: o None yet
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Home Depot #0975
Waste Manifest Date Qty
Units
3/12/2024 29 Pounds
3/12/2024 40 Pounds
3/12/2024 125 Pounds
3/12/2024 125 Pounds
3/12/2024 143 Pounds
3/12/2024 34 Pounds
1/15/2024
4 Pounds
1/15/2024 112 Pounds
1/15/2024 143 Pounds
1/15/2024 165 Pounds
1/15/2024 32 Pounds
12/18/2023 132 Pounds
12/18/2023 124 Pounds
11/28/2023 89 Pounds
11/28/2023 77 Pounds
10/23/2023 20 Pounds
10/23/2023 39 Pounds
10/23/2023 40 Pounds
9/26/2023 91 Pounds
9/26/2023 112 Pounds
9/26/2023 125 Pounds
9/26/2023 98 Pounds
8/28/2023 55 Pounds
8/28/2023 197 Pounds
8/28/2023 50 Pounds
8/28/2023 68 Pounds
7/31/2023 100 Pounds
7/31/2023 15 Pounds
7/31/2023 75 Pounds
7/3/2023 45 Pounds
7/3/2023 107 Pounds
7/3/2023 69 Pounds
7/3/2023 26 Pounds
7/3/2023 76 Pounds
6/5/2023 120 Pounds
6/5/2023 132 Pounds
6/5/2023 99 Pounds
6/5/2023 110 Pounds
6/5/2023 27 Pounds
5/8/2023 35 Pounds
5/8/2023 13 Pounds
5/8/2023 127 Pounds
5/8/2023 5/8/2023
68 Pounds 23 Pounds
5/8/2023 30 Pounds
4/14/2023 98 Pounds
4/14/2023 12 Pounds
4/14/2023 96 Pounds
4/14/2023 76 Pounds
3/13/2023 47 Pounds
3/13/2023 3/13/2023 3/13/2023 1/16/2023 1/16/2023
80 Pounds 16 Pounds 211 Pounds 67 Pounds 67 Pounds
RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
Waste (kg)
Waste Codes
13 D001
18 D001 D003 D006 D007 D035
57 D001 D005 D007 D008 D035 D039
57 D001 D018
65 D001 D018 D035
15 D002
2 D001 D003 D008
51 D001 D018
65 D001 D018 D035
75 D002
15 D008
60 D001 D018
56 D001 D018 D035
40 D001 D005 D007 D008 D035 D039
35 D001 D018 D035
9 D001 D018
18 D001 D035 U112 U159 U220 U239
18 D018 D028 D043
41 D001 D005 D007 D008 D035 D039
51 D001 D018 D035
57 D001 D035 U112 U159 U220 U239
44 D002
25 D001 D005 D007 D008 D035 D039
89 D001 D018
23 D016
31 D016 U240
45 D001 D018 D035
7 D008
34 D016 U240
20 D001 D003 D006 D007 D035
49 D001 D005 D007 D008 D035 D039
31 D001 D018 D035
12 D002
34 D016
54 D001 D005 D007 D008 D035 D039
60 D001 D018
45 D001 D018 D035
50 D016
12 D018 D028 D043
16 D001
6 D001 D005 D007 D008 D035 D039
58 D001 D018
31 D001 D035 U112 U159 U220 U239 10 D016
14 D018
44 D001 D005 D007 D008 D035 D039
5 D001 D018 D035
44 D016
34 D016 U240 U279
21 D001 D005 D007 D008 D035 D039
36 D001 D018 D035 7 D002
96 D016 30 D001 D018 30 D001 D018 D035
TSDF ID
MTN*
PAD085690592 200739409CLE
PAD085690592 200739409CLE
PAD085690592 200739409CLE
PAD085690592 200739409CLE
PAD085690592 200739409CLE
PAD085690592 200739409CLE
RID040098352 200682348CLE
PAD085690592 200682347CLE
PAD085690592 200682347CLE
PAD085690592 200682347CLE
PAD085690592 200682347CLE
PAD085690592 200658927CLE
PAD085690592 200658927CLE
PAD085690592 200506619CLE
PAD085690592 200506619CLE
PAD085690592 200608442CLE
PAD085690592 200608442CLE
PAD085690592 200608442CLE
PAD085690592 200583929CLE
PAD085690592 200583929CLE
PAD085690592 200583929CLE
PAD085690592 200583929CLE
PAD085690592 200558025CLE
PAD085690592 200558025CLE
PAD085690592 200558025CLE
PAD085690592 200558025CLE
PAD085690592 200530694CLE
PAD085690592 200530694CLE
PAD085690592 200530694CLE
PAD085690592 200506126CLE
PAD085690592 200506126CLE
PAD085690592 200506126CLE
PAD085690592 200506126CLE
PAD085690592 200506126CLE
PAD085690592 200480148CLE
PAD085690592 200480148CLE
PAD085690592 200480148CLE
PAD085690592 200480148CLE
PAD085690592 200480148CLE
PAD085690592 200455394CLE
PAD085690592 200455394CLE
PAD085690592 200455394CLE
PAD085690592 200455394CLE PAD085690592 200455394CLE
PAD085690592 200455394CLE
PAD085690592 200435055CLE
PAD085690592 200435055CLE
PAD085690592 200435055CLE
PAD085690592 200435055CLE
PAD085690592 200405024CLE
PAD085690592 PAD085690592 PAD085690592 PAD085690592 PAD085690592
200405024CLE 200405024CLE 200405024CLE 200352650CLE 200352650CLE
Total
Waste/ship
ment
Units
496 lbs
456 lbs 256 lbs 166 lbs
99 lbs 426 lbs 370 lbs 190 lbs
323 lbs
488 lbs
296 lbs 282 lbs
lbs/month
264.9 lbs
289.2 lbs 389.6 lbs 140.4 lbs 111.6 lbs 447.1 lbs 402.2 lbs 206.5 lbs
351.1 lbs
530.5 lbs
375.4 lbs 268.2 lbs
SQG
SQG SQG VSQG VSQG SQG SQG VSQG
SQG
SQG
SQG SQG
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RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
SECTION II - OBSERVATIONS
The accompanying HOME DEPOT #0975 (ABSECON, NJ) INSPECTION PHOTO ALBUM.pptx document is the complete set of inspection observations made during the facility walkthrough with both the associate and primary store managers.
SECTION III - AREAS OF CONCERN
Concerns Container Accumulation Area issues: o SQG posting requirements: Did not post emergency coordinator's name and phone number, fire department's phone number, and locations of fire extinguishers and spill control equipment near the phone o Hazardous waste containers: All labels were not both visible and affixed to containers Labels lacked accumulation start dates o Weekly inspections lacked sufficiency as noted herein Universal Waste issues: o All containers were not closed (to protect from potential breakage) o A container was not labeled as "Universal Waste-Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)" o A container was not labeled as "Universal Waste-Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)" o must inform all employees who handle or have responsibility for managing universal waste were apparently not sufficiently informed on the proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility Equipment Rental and Maintenance Area: o No labeled distinction between hazardous waste, i.e., contaminated gasoline/oil, and still usable product, i.e., uncontaminated gasoline, and used oil o Ignitable, D001/D018, containers not labeled as hazardous waste or with accumulation start dates o Used oil containers not labeled as "used oil" o Area needs to be included in weekly inspections o Did not post emergency coordinator's name and phone number, fire department's phone number, and locations of fire extinguishers and spill control equipment near the phone
Closing Conference
Ms. Quigley and I reviewed my findings and we discussed any follow up. We agreed that we would correspond by email regarding any additional records that I needed to complete the evaluation.
INSPECTION PHOTOGRAPHS: See HOME DEPOT #0975 (ABSECON, NJ) INSPECTION PHOTO ALBUM.pptx
UNIVERSAL WASTE REGULATIONS: See Appendix 1 6|Page
RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
FOLLOW UP EMAILS: None yet
PROVIDED RECORDS: None yet
Appendix 1: Certain, Applicable Universal Waste Regulations
Title 40 Chapter I Subchapter I Part 273 Small quantity handler of universal means a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time.
A small quantity handler of universal waste is: (a) Prohibited from disposing of universal waste; and (b) Prohibited from diluting or treating universal waste, except by responding to releases as provided in 40 CFR 273.17; or by managing specific wastes as provided in 40 CFR 273.13.
Lamps. A small quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows:
(1) A small quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.
(2) A small quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions.
A small quantity handler of universal waste must label or mark the universal waste to identify the type of universal waste as specified below:
(a) Universal waste batteries (i.e., each battery), or a container in which the batteries are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste-- Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies);"
(e) Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)".
A small quantity handler of universal waste may accumulate universal waste for no longer than one year from the date the universal waste is generated, or received from another handler, unless the requirements of paragraph (b) of this section are met.
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HOME DEPOT #0975 INSPECTION REPORT
A small quantity handler of universal waste who accumulates universal waste must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. The handler may make this demonstration by:
(1) Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received; (2) Marking or labeling each individual item of universal waste (e.g., each battery or thermostat) with the date it became a waste or was received; (3) Maintaining an inventory system on-site that identifies the date each universal waste became a waste or was received; (4) Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received; (5) Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or (6) Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. A small quantity handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility.
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RCRA Compliance Branch
HOME DEPOT #0975 INSPECTION REPORT
Appendix 2: Follow Up Email Chain Appendix 3: Additional Records Provided Post Inspection Appendix 4: Post Inspection Facility Reports
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