Document ZJq4mpwdxwmXJqk7jGK7N6qzO

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 04/13/2021 - 04/13/2021 Announced: No Entry: 10:36 AM (AKT) Exit: 02:39 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) Costco Wholesale Corporation COSTCO WHOLESALE #107 5225 COMMERCIAL BOULEVARD JUNEAU, AK 99801 Warehouse Club and Supercenter 80,871 sq. Ft. Since 1993 58.359013, -134.482656 Costco Wholesale Corporation Attn: Ms. Jessica Stapleton, Environmental Compliance Manager 999 Lake Drive jstapleton@costco.com CC: Mr. Gene Waters, General Manager w107mgr@costco.com (city, state, zip code) County: Mr. Mark Pincikowski, Assistant General Manager w107mgr3@costco.com Issaquah, WA 98027 King Facility/Site Identifier: Media Number: NAICS: AKR000003764 Unpermitted Facility 452311 - Warehouse Clubs and Supercenters Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.06.29 08:23:05 -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 12:25:14 -07'00' Sullivan.Jennifer.A@epa.gov 1 of 12 (206) 553-6978 COSTCO WHOLESALE #107 Inspection Date(s): SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection 04/13/2021 - 04/13/2021 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 Lead Inspector Merchandise Manager General Manager Assistant General Manager Name Jon Jones Brent Mattson Gene Waters Mark Pincikowski Phone Email (907) 271-6329 Jones.Jon@epa.gov Present in Opening Conf. Yes (907) 780-6740 w107mer@costco.com Yes Present in Closing Conf. Yes No (907) 780-6740 w107mgr@costco.com Yes Yes w107mgr3@costco.com No Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the Costco Wholesale #107 at 10:36 AM (AKT) on 04/13/2021 for an inspection. I presented my credentials to Brent Mattson, Merchandise Manager and informed him that I was here to conduct an EPA RCRA inspection. Mr. Mattson had me follow him to the administrative offices, on the second floor, where he introduced me to Mr. Gene Waters, General Manager. I explained the purpose of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. The table above presents all the opening and closing conference participants. Facility/Site Description Costco Wholesale #107 (hereafter referred to as Costco, store or facility) is located in a business area in northwestern Juneau, Alaska. The facility is a Warehouse Club and Supercenter. The facility has been at it's current location since 1993. The 80,871 square foot facility has approximately 112 employees and is open Monday through Friday from 10:00 am to 8:30 pm. Saturday from 9:30 am to 6:00 pm and Sunday from 10:00 am to 6:00 pm. The store also has an onsite pharmacy operated by Costco personnel. Facility Info Number of employees Approximately 112 Weather Conditions Cool and rainy Operating Hours 10 am to 8:30 pm, Monday through Friday. 9:30 am to 6 pm, Saturday and Sunday Safety Training No 2 of 12 COSTCO WHOLESALE #107 Inspection Date(s): Provided to Inspector(s)? What type of SQG generator facility notified? What type of generator facility verified as? SQG verified by Mr. Waters Process Description 04/13/2021 - 04/13/2021 The following information was obtained from Messrs. Gene Waters, General Manager and Brent Mattson, Merchandise Manager, during the inspection. Wastes generated at the facility include waste aerosol cans, used batteries and fluorescent light tubes that are managed as universal waste, and pharmaceutical waste that is managed through a reverse distributor. Automotive batteries and small lead weights, used for tire balancing, in the automotive department are also recycled. 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. Only those areas in which I observed areas of concern or noted other pertinent issues are discussed in this inspection report. Building(s) Building/Area Store Floor Pharmacy Return to Vendor (RTV) Central Accumulation Area (CAA) Tire Center Process Description SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Area of Concern Yes Yes Yes Yes No Building: Store Floor/Pharmacy Contains CBI: No Observation #: JJ1-OB-001 Date/Time: 04/13/2021 While inspecting the pharmacy, I observed a container used to accumulate hazardous waste pharmaceuticals (HWPharms). At the time of the inspection, the container was closed and labeled with the words "Hazardous Waste Pharmaceuticals." 3 of 12 COSTCO WHOLESALE #107 Inspection Date(s): 04/13/2021 - 04/13/2021 While there, I was introduced to Mr. Robert Baars, Pharmacist. Mr. Baar told me that Costco uses Inmar as their reverse distributor for the return of waste pharmaceuticals for which they expect to receive credit. I asked Mr. Baar for documentation of the last three shipments to Inmar. I explained that I was wanted to get documentation of what pharmaceuticals Costco was returning to Inmar for credit as well as pharmaceuticals for which they did not receive credit. Mr. Baar said that it would take him a while to gather the documentation and I asked him if two weeks would be enough time. It was determined, during the inspection, that Mr. Baar would get the requested paperwork to Mr. Waters and Mr. Waters would then forward the paperwork on to me within two weeks. Mr. Baar stated that they usually receive credit for everything they send to Inmar; however, he said that most of the time they don't receive credit back on pet medications. Mr. Baar stated that even though they don't receive credit back on pet medications, they keep sending them to Inmar. Mr. Waters sent copies of the last three shipments to Inmar in four separate emails dated 04/15/2021. Photo(s) 1. Observation_Image-20210413110745745304995.jpg 2. Observation_Image-2021041311080686210992.jpg 3. Observation_Image-20210413110828828258229.jpg Building: Store Floor/RTV/Central Accumulation Area (CAA) Contains CBI: No Observation #: JJ1-OB-002 Date/Time: 04/13/2021 While inspecting the Central Accumulation Area (CAA), in the Return to Vendor (RTV) area, I saw a black, fivegallon container that contained waste Sporax. The container was dated "3/4/21." The container was labeled with the word "Corrosive" as the hazard indicator. According to Ben Roguska, RTV Clerk, the Sporax waste is generated in the hearing center and is managed as hazardous waste. At the time of the inspection, the container was not labeled with the words "Hazardous Waste." Mr. Roguska, labeled the container with the words "Hazardous Waste" during the inspection. While inspecting the facility's weekly hazardous waste storage checklists at the facility, I saw that this unlabeled container of hazardous waste was not caught during the weekly inspection that was conducted and documented on 04/06/2021. The first item listed on the checklist, under the heading "RTV Area - HW Storage Management" states, "For each bucket the "Hazardous Waste" label is visible and filled out correctly for your state?" The 04/06/2021 checklist is marked "Yes" while the bucket was found to be not labeled "Hazardous Waste" during the 04/13/2021 RCRA CEI. During my review of the data following the inspection, while writing the report, I noticed that I had not obtained a copy of the weekly inspection while at the facility. I sent Mr. Waters an email on 06/24/2021 requesting a copy of the weekly inspection which was provided to me on the same day. Document(s) 1. Re_ Copy of weekly inspection.pdf 2. 04-06-2021 weekly inspection.docx Photo(s) 1. Observation_Image-202104131138453845350216.jpg 2. Observation_Image-202104131138543854246409.jpg 3. Observation_Image-202104131139113911293971.jpg 4 of 12 COSTCO WHOLESALE #107 Inspection Date(s): 4. Observation_Image-202104131140344034275378.jpg 5. Observation_Image-202104131140414041261346.jpg 04/13/2021 - 04/13/2021 Building: Store Floor/Tire Center Contains CBI: No Observation #: JJ1-OB-003 Date/Time: 04/13/2021 While inspecting the Costco Tire Center I met Mason Morris, Tire Center Manager. According to Mr. Morris, Tire Center shop personnel use aerosol cans of Brakleen on automotive wheels. He said they puncture the aerosol cans, when empty, and recycle the empty aerosol cans. I observed a 15-gallon container with drum top can popper. At the time of the inspection the container was closed and labeled with the words "Hazardous Waste" and marked with a hazard indicator. Mr. Mason said lead-acid batteries and lead wheel weights get shipped down to Sumner, WA. where they are recycled. Mr. Mason said the batteries go to Interstate Battery. He said he wasn't sure about the wheel weights, but thought they were recycled through a company called Wegman. Records Review Record: Manifests Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/13/2021 I reviewed the facility's hazardous waste manifests for the period, April 2018 through April 2021. During this review, I saw that manifest #000384258 JJK was used to ship HWPharms; however, block 13 of the manifest did not contain "PHARMS." Block 13 contained "PHRM." Document(s) 1. 000384258 JJK.pdf Record: Inspections Ref #: JJ1-RR-002 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 04/13/2021 While reviewing CAA weekly inspection documentation, I saw that documentation for the following four weekly CAA inspections was missing: August 12 - 18,2018 September 15 - 21, 2019 November 10 - 16, 2019 July 26 - August 1, 2020 Record: Shipping Documents Ref #: JJ1-RR-003 Reviewed By: Jon Jones AOC: No Reviewed Date: 06/24/2021 On 4/15/2021, I received four emails from Mr. Gene Waters that included scanned copies of the paperwork 5 of 12 COSTCO WHOLESALE #107 Inspection Date(s): 04/13/2021 - 04/13/2021 documenting the return of waste pharmaceuticals from the pharmacy to Inmar, Costco's reverse distributor. During the inspection, Robert Baars, Costco Pharmacist, said that most of the time they don't receive credit back on pet medications, although he did say they keep sending them to Inmar. Document(s) 1. Scan2021-04-15-163304.pdf 2. Scan2021-04-15-163805.pdf 3. Scan2021-04-15-163919 part 1.pdf 4. Scan2021-04-15-163919 part 2.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 I reviewed the facility's hazardous waste manifests for the period, April 2018 through April 2021. During this review, I saw that manifest #000384258 JJK was used to ship HWPharms; however, block 13 of the manifest did not contain "PHARMS." Block 13 contained "PHRM." Citation: Sub-area: Section: JJ1-RR-002 While reviewing documentation of the CAA Weekly Inspections, I saw that there were four weekly inspections with no documentation . Those week are: Citation: August 12 -18, 2018 September 15 - 21, 2019 November 10 - 16, 2019 July 26 - August 1, 2020 Section: Building: Store Floor JJ1-OB-001 Costco uses Inmar as their reverse distributor. Pharmacist Area: Pharmacy Citation: Sub-area: Section: 6 of 12 COSTCO WHOLESALE #107 Inspection Date(s): Robert Baar said that most of the time they don't receive credit back on pet medications, but said they keep sending them to Inmar. Building: Store Floor Area: RTV JJ1-OB-002 While inspecting the CAA, in the RTV, I saw a black, five-gallon container of waste Sporax that was not labeled with the words "Hazardous Waste." The RTV clerk labeled the container with the words "Hazardous Waste" during the inspection. Citation: 04/13/2021 - 04/13/2021 Sub-area: Central accumulation area (CAA) 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. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. 7 of 12 COSTCO WHOLESALE #107 Inspection Date(s): SECTION VI - LIST OF APPENDICES Photo Log [Title] Observation_Image202104131138453845350216.jpg 04/13/2021 11:38 AM (AKT) Jon Jones RTV/Central Accumulation Area (CAA) No CBI No PII Black, 5-gallon container of waste Sporax, seen here on the floor is not labeled with the words, "Hazardous Waste." [Title] Observation_Image202104131138543854246409.jpg 04/13/2021 11:38 AM (AKT) Jon Jones RTV/Central Accumulation Area (CAA) No CBI No PII Close-up view of the black, 5-gallon container of waste Sporax showing that it is not labeled with the words, "Hazardous Waste." It also shows the container is marked with an Accumulation Start Date (ASD) of 3/4/21. 04/13/2021 - 04/13/2021 8 of 12 COSTCO WHOLESALE #107 Inspection Date(s): [Title] Observation_Image202104131139113911293971.jpg 04/13/2021 11:39 AM (AKT) Jon Jones RTV/Central Accumulation Area (CAA) No CBI No PII Close-up view of the black, 5-gallon container of waste Sporax showing that it is not labeled with the words, "Hazardous Waste." It also shows the container is marked with a hazard indicator "corrosive." [Title] Observation_Image202104131140344034275378.jpg 04/13/2021 11:40 AM (AKT) Jon Jones RTV/Central Accumulation Area (CAA) No CBI No PII The RTV clerk labeled the container during the inspection. 04/13/2021 - 04/13/2021 9 of 12 COSTCO WHOLESALE #107 Inspection Date(s): [Title] Observation_Image202104131140414041261346.jpg 04/13/2021 11:40 AM (AKT) Jon Jones RTV/Central Accumulation Area (CAA) No CBI No PII Close-up view showing that the container was labeled with the words "Hazardous Waste" during the inspection. [Title] Observation_Image20210413110745745304995.jpg 04/13/2021 11:07 AM (AKT) Jon Jones Store Floor/Pharmacy No CBI No PII I observed a container being used to accumulate HWPharms. The container was closed and properly labeled "Hazardous Waste Pharmaceuticals." 04/13/2021 - 04/13/2021 10 of 12 COSTCO WHOLESALE #107 Inspection Date(s): [Title] Observation_Image2021041311080686210992.jpg 04/13/2021 11:08 AM (AKT) Jon Jones Store Floor/Pharmacy No CBI No PII This is a view of the pharmacy hazardous waste inventory log that was on top of the container of HWPharms. 04/13/2021 - 04/13/2021 [Title] Observation_Image20210413110828828258229.jpg 04/13/2021 11:08 AM (AKT) Jon Jones Store Floor/Pharmacy No CBI No PII I observed a container being used to accumulate HWPharms. The container was closed and properly labeled "Hazardous Waste Pharmaceuticals." Document Log Document Type Records Review Facility Map Records Review Records Review Records Review Records Review Document Name Contains Contains Uploaded By CBI PII 000384258 JJK.pdf No No Jon Jones 107 Juneau Site Map 4.13.21 - Apr No No Jon Jones 13 2021 - 12-17 PM.pdf Scan2021-04-15-163304.pdf No No Jon Jones Scan2021-04-15-163805.pdf No No Jon Jones Scan2021-04-15-163919 part 1.pdf No No Jon Jones Scan2021-04-15-163919 part 2.pdf No No Jon Jones 11 of 12 Date Received 06/24/2021 06/24/2021 06/24/2021 06/24/2021 06/24/2021 06/24/2021 COSTCO WHOLESALE #107 Inspection Date(s): 04/13/2021 - 04/13/2021 Communications Re_ Copy of weekly inspection.pdf No No Jon Jones 06/24/2021 Weekly Inspections 04-06-2021 weekly inspection.docx No No Jon Jones 06/24/2021 Inspection Reports Field_Notes_AKR000003764v1.0.pdf No No Jon Jones 06/24/2021 12 of 12