Document aJVn5GdOaxvGv8N6ejvmO9KNY

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 08/17/2023 09:03 AM (PT) Announced: No 08/17/2023 01:50 PM (PT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Mailing Address/Secondary Address City, State, Zip Code Bradken, Inc. Bradken Atlas WAD009241803 3021 S Wilkeson St Tacoma, WA 98409 Pierce County Large Quantity Generator (LQG) 331513 Steel Foundry 47.23238, -122.45875 Ms. Susan Wagner, EHS Coordinator swagner@bradken.com 3021 S Wilkeson Tacoma, WA 98409 Tacoma, WA 98409 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA Region 10 jones.jon@epa.gov (907) 227-4316 Supervisor Review: Matt Quarterman EPA Region 10 quarterman.matthew@epa.gov (206) 553-2146 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) EPA Region 10 Lead Inspector, Jon Jones, arrived at the Bradken Atlas Facility (the "Site" or "Facility"), located at 3021 S Wilkeson St, Tacoma, WA 98409, at 09:03 AM (PT) on 08/17/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Susan Wagner that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). This report is based on information supplied by Bradken Atlas representatives, observations made by the EPA Region 10 inspector, and records and reports maintained at the facility and its HQ including, but not limited to: direct observations 1 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or after the inspection from a review of USEPA, state, and public records may be included in this report. Attendees Title/Organization Name Lead Inspector/EPA Jon Jones REGION 10 Safety & Wellbeing Business Partner/Bradken Atlas Dale Spencer USEPA Matt Quarterman EHS Susan Wagner Coordinator/Bradken Atlas Phone (907) 2716329 (253) 3018935 (253) 4485692 Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes dspencer@bradken.com Yes Yes Yes Yes swagner@bradken.com Yes Yes Opening Conference We met with Bradken Atlas Security personnel in the office lobby upon arrival and explained the purpose of our visit and asked to see Ms. Susan Wagner, EHS Coordinator. While waiting for Ms. Wagner to arrive, Security personnel at the facility initially did not want to allow us in without providing a copy of a Driver's License and wanted to prevent our use of a camera during the inspection. Once Ms. Wagner arrived, we were allowed to enter the facility by showing our credentials and signing the visitor log. Ms. Wagner also said that the use of a camera during the inspection would be allowed. We were also met by Mr. Dale Spencer, Safety & Wellbeing Business Partner. I presented my credentials to Ms. Wagner and Mr. Spencer and informed them that this was an EPA RCRA inspection. The table above presents all the inspection opening and closing conference participants. During the inspection we looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. We 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. 2 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 Facility/Site Information What type of generator facility verified as? Ms. Wagner verified that the facility was an LQG What type of generator facility notified? Large Quantity Generator Size of Facility 15 acres Safety Training No Provided to Inspector(s)? Operating Hours Three shifts - 6:00 a.m. to 2:30 p.m., 3:30 p.m. to midnight, and 11:00 p.m. to 6:00 a.m. Length of Facility at Location Since 1899 Number of employees 220 Process Description According to Ms. Wagner and Mr. Spencer, Bradken Atlas produces steel castings for a wide variety of customers, including government agencies and private industry. The foundry has been located at this site for over a century. Facility processes include pouring metal, making steel castings, grinding, welding, and radiography. The radiography is to ensure that castings have no cracks. There's also a lab that conducts tensile testing and QA for their chemical process for pouring. During the opening conference we were told that there was one SAA and one CAA. During the walk-through portion of the inspection, we actually observed two SAAs and two active CAAs. The facility generates the following wastes: Waste furnace dust - D007 chromium baghouse dust managed as hazardous waste Waste aerosols cans - get punctured onsite Waste aerosol can residue - managed as hazardous waste Waste fixer - silver is recovered and recycled. Waste fluorescent lamps - managed as universal waste Waste batteries - managed as universal waste Used oil Building(s) Building/Area/Sub-area Cleaning Room SAA Maintenance CAA Connex Maintenance Wash Bay Process Description Accumulation of waste aerosol cans. Accumulation area for chromium dust generated in the furnace Area of Concern Yes Yes Yes Yes No 3 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 Oil Storage Universal Waste Area RE2 Area just outside entrance Storage Area (Butler Building) No Aerosol can popping SAA and accumulation of Yes universal waste lamps No Holding area for spent processor Fixer No Yes SECTION II - OBSERVATIONS Building: Maintenance/Maintenance Wash Bay Observation #: JJ1-OB-001 Date: 08/17/2023 Person Interviewed: Susan Wagner Contains AOC: No Title: EHS Coordinator Contains CBI: No While in the Wash Bay we saw a tote that held approximately 300 gallons of process water for testing. At the time of the inspection, the tote was labeled "Spent Processor Fixer - Waste Pending Analysis." According to Ms. Wagner, the spent fixer wastewater does not designate as hazardous waste/dangerous waste but will occasionally not meet the City of Tacoma discharge limits. According to Ms. Wagner, the spent processor fixer wastewater was sampled by the City of Tacoma on 7/5/23. Ms. Wagner told us that the results of the Bradken Atlas analytical showed that the wastewater met discharge limits and the City of Tacoma's test results indicated the wastewater did not meet discharge limits. Ms. Wagner stated that they would either reprocess the wastewater through their silver recovery system or dispose of the wastewater as a non-regulated waste. Photo(s) 1. IMG-2023081709474547453224107.jpg 2. IMG-2023081709475247523074728.jpg 3. IMG-202308170948004802439689.jpg Building: Maintenance/Universal Waste Area Observation #: JJ1-OB-002 Date: 08/17/2023 Person Interviewed: Susan Wagner Contains AOC: Yes Title: EHS Coordinator Contains CBI: No While we were in the Maintenance area, I inspected a small, fenced area that the facility was using as a universal waste area. While in this fenced universal waste area, I saw that the facility had a 55-gallon closedtop container that was being used as a satellite accumulation area (SAA) container for aerosol can waste residue, generated from puncturing waste aerosol cans in a drum-top aerosol can popper. At the time of the inspection the lid on the can popper was open, and the SAA container was not closed. I also saw that there was a hazard/risk indicator on the SAA container that was inaccurate. At the time of the inspection, there was a DOT Class 2 flammable gas hazard/risk label on the SAA container. Mr. Spencer closed the aerosol residue SAA container during the inspection. I asked how the punctured aerosol cans were being managed and Mr. Spencer said that the punctured aerosol cans are thrown away in the trash. Mr. Spencer then said they may get melted in the furnace. I asked Mr. Spencer to follow up with me regarding the management of the punctured aerosol cans. Following the inspection, I received an email from Mr. Spencer on 8/21/23. In that email, Mr. Spencer stated that, "Our empty paint cans (universal waste) will be recycled through our metal recycling vendor." I received another 4 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 email from Mr. Spencer on 8/21/23 and that email included a photo of the 55-gallon waste aerosol residue SAA container after it had been labeled with a DOT Class 3 flammable liquid hazard/risk indicator. Document(s) 1. Universal Waste (Flammable Liquid).docx Photo(s) 1. IMG-2023081709535153513801109.jpg 2. IMG-202308170954005402511532.jpg 3. IMG-202308170954085482906240.jpg 4. IMG-2023081709542454242950451.jpg 5. IMG-20230817100905953789338.jpg Building: Maintenance/Universal Waste Area Observation #: JJ1-OB-003 Date: 08/17/2023 Person Interviewed: Susan Wagner Contains AOC: Yes Title: EHS Coordinator Contains CBI: No While in the universal waste area, we saw four cardboard boxes that held four-foot waste fluorescent lamps and one cardboard box that held eight-foot waste fluorescent lamps. At the time of the inspection, none of the five cardboard boxes of waste fluorescent lamps were labeled with either the phrase "Universal Waste-Lamps, " "Used lamps," or "Waste Lamps." All five boxes were not closed. There were also three loose bulbs that were not packaged or labeled. Mr. Spencer had facility personnel package the loose bulbs, close the open boxes, and label each box with the words "Universal Waste-Lamps" during the inspection. Document(s) 1. Additional Signage added.docx Photo(s) 1. IMG-202308171002302303080216.jpg 2. IMG-202308171002402403453810.jpg 3. IMG-202308171002472473162521.jpg 4. IMG-202308171002552553252590.jpg 5. IMG-20230817100306362775253.jpg 6. IMG-202308171024032433173969.jpg 7. IMG-2023081710241524153006764.jpg 8. IMG-2023081710242124213466775.jpg Building: Maintenance/CAA Connex Observation #: JJ1-OB-004 Date: 08/17/2023 Person Interviewed: Susan Wagner Contains AOC: Yes Title: EHS Coordinator Contains CBI: No While in the central accumulation area (CAA) Connex, we saw five, cubic yard super sacks that, according to labeling, contained waste furnace dust with chromium (D007). At the time of the inspection, all five super sacks 5 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 were marked with hazardous waste labels and an accumulation start date (ASD), but none were marked with hazard/risk indicators. At the time of the inspection, all five waste super sacks had been in accumulation for less than 90 days. The words Class 9 N.O.S. were written on each of the hazardous waste labels and I explained to Ms. Wagner and Mr. Spencer that Class 9 N.O.S. was not specific to the hazard/risk. Mr. Spencer had facility personnel place stickers on each super sack, during the inspection, that contained the word "TOXIC." Photo(s) 1. IMG-202308171018061863617465.jpg 2. IMG-2023081710181418143778742.jpg 3. IMG-202308171019021922760351.jpg 4. IMG-2023081710191619162934502.jpg 5. IMG-2023081711101410143587245.jpg 6. IMG-2023081711102610263147834.jpg Building: Storage Area (Butler Building) Observation #: JJ1-OB-006 Date: 08/17/2023 Person Interviewed: SW Contains AOC: Yes Title: EHS Contains CBI: No While inspecting the contents of a flammable storage cabinet in the Butler Building, I saw two aerosol cans that were waste aerosol cans. Mr. Spencer verified that the aerosol cans were a waste and should go to the SAA can popper. Photo(s) 1. IMG-202308171100560562358569.jpg 2. IMG-20230817110103132142280.jpg 3. IMG-202308171101241242702261.jpg Building: Cleaning Room 1/SAA Observation #: JJ1-OB-008 Date: 08/17/2023 Person Interviewed: SW Contains AOC: Yes Title: EHS Contains CBI: No While in Cleaning Room 1, we saw a 55-gallon SAA container that was being used for the accumulation of waste aerosol cans. At the time of the inspection the container was not closed. There was a round hole in the container lid with a waste aerosol can protruding from the hole and four additional waste aerosol cans were on the top of the container. Photo(s) 1. IMG-2023081711472147212300436.jpg 2. IMG-2023081711473147312325177.jpg 6 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 SECTION III - RECORDS REVIEW Record: Inspections Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: Yes Reviewed Date: 08/17/2023 During the inspection, I requested weekly hazardous waste inspections for the period covering August 17, 2020, through August 17, 2023 (3 years). At the time of the inspection, Ms. Wagner printed copies of weekly inspections covering the period of January through May of 2023. She stated that she was having problems with the printer and was unable to provide copies of any other weekly inspections. I explained to Ms. Wagner that it was common for facilities to maintain weekly inspection logs electronically and I asked if I could visually inspect them on a company computer. Ms. Wagner told us that she would rather provide them to me following the inspection. I explained to Ms. Wagner that I looked at electronic records on facility computers during the majority of my RCRA inspections and again expressed my interest in viewing the facility's weekly hazardous waste inspection logs prior to leaving the facility. Ms. Wagner again reiterated that she would rather send them to me following the inspection. I told her that would be fine. On 8/21/2023, I received an email from Mr. Spencer that included weekly hazardous waste inspection logs covering the period of August 17, 2020, through July 29, 2023. Inspection logs for the first three weeks of August 2023 were not provided. During my inspection of these weekly logs, I saw that there was no weekly inspection conducted for the following 25 weeks: 12/27/2020 through 01/02/2021 01/23/2022 through 01/29/2022 02/13/2022 through 02/19/2022 02/20/2022 through 02/26/2022 04/03/2022 through 04/09/2022 04/10/2022 through 04/16/2022 04/17/2022 through 04/23/2022 04/24/2022 through 04/30/2022 05/01/2022 through 05/07/2022 05/08/2022 through 05/14/2022 05/15/2022 through 05/21/2022 05/22/2022 through 05/28/2022 05/29/2022 through 06/04/2022 06/19/2022 through 06/25/2022 06/26/2022 through 07/02/2022 07/03/2022 through 07/09/2022 07/10/2022 through 07/16/2022 07/17/2022 through 07/23/2022 07/24/2022 through 07/30/2022 03/05/2023 through 03/11/2023 03/12/2023 through 03/18/2023 03/19/2023 through 03/25/2023 03/26/2023 through 04/01/2023 04/02/2023 through 04/08/2023 04/09/2023 through 04/15/2023 Additional areas of concern were noted during the inspection of the weekly hazardous waste inspection logs that were provided following the facility inspection. These concerns are as follows: Lack of attention to detail 7 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 o Inspection log question, Are any drums leaking? The block for this question was continuously marked with a "Y" on almost all inspection logs indicating yes. o Inspection log question, Are all containers marked with appropriate labeling? The "Yes" block for this question was marked with a check mark for every week that waste super sacks were present in the CAA between 06/12/2023 and 08/17/2023. o Weekly inspections were also documented as occuring on holidays when the facility was not operating. Document(s) 1. Haz. Waste Inspection ~ 2020.pdf 2. Haz. Waste Inspection ~ 2021.pdf 3. Haz. Waste Inspection ~ 2022.pdf 4. Haz. Waste Inspection ~ 2022 (2).pdf 5. Haz. Waste Inspection ~ 2023.pdf 6. Haz. Waste Inspection ~ 2023 (2).pdf 7. 2023 ~ Haz Waste Weekly Inspection Checklist.docx 8. Logs obtained during CEI (1).pdf 9. Logs obtained during CEI (2).pdf 10. Logs obtained during CEI (3).pdf 11. Logs obtained during CEI (4).pdf 12. Logs obtained during CEI (5).pdf SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Maintenance JJ1-OB-002 Area: Universal Waste Area Sub-area: At the time of the inspection, the lid on the aerosol can popper was open, and the SAA container of waste aerosol can residue was not closed. Regulation: Sections: The hazard/risk indicator on the SAA container of waste aerosol can residue was not accurate. Building: Maintenance JJ1-OB-003 Area: Universal Waste Area Five cardboard boxes of waste fluorescent lamps were not labeled with either the phrase "Universal Waste-Lamps, " "Used Lamps," or "Waste Lamps." Regulation: All five boxes of waste fluorescent lamps were not closed. 8 of 27 Sub-area: Sections: Bradken Atlas Inspection Date(s): There were also three loose bulbs that were not packaged or labeled. Building: Maintenance JJ1-OB-004 Area: CAA Connex Five, cubic yard super sacks that contained waste furnace dust with chromium (D007) were not marked with hazard/risk indicators. Regulation: Building: Storage Area (Butler Building) JJ1-OB-006 Area: Two waste aerosol cans that were found inside of a flammable storage cabinet. The aerosol cans were not labeled with the words "Hazardous Waste." Mr. Spencer verified that the aerosol cans were a waste and should go to the SAA can popper. Regulation: Building: Cleaning Room JJ1-OB-008 Area: SAA A 55-gallon waste aerosol can SAA container was not closed, and four waste aerosol cans were accumulating on the top of the container. Regulation: The four waste aerosol cans on top of the SAA container were not labeled with the words, "Hazardous Waste." Record: Inspections JJ1-RR-001 There were no weekly hazardous Regulation: waste inspections conducted for the following 25 weeks: 12/27/2020 through 01/02/2021 01/23/2022 through 01/29/2022 9 of 27 08/17/2023 - 08/17/2023 Sub-area: Sections: Sub-area: Sections: Sub-area: Sections: Sections: Bradken Atlas Inspection Date(s): 02/13/2022 through 02/19/2022 02/20/2022 through 02/26/2022 04/03/2022 through 04/09/2022 04/10/2022 through 04/16/2022 04/17/2022 through 04/23/2022 04/24/2022 through 04/30/2022 05/01/2022 through 05/07/2022 05/08/2022 through 05/14/2022 05/15/2022 through 05/21/2022 05/22/2022 through 05/28/2022 05/29/2022 through 06/04/2022 06/19/2022 through 06/25/2022 06/26/2022 through 07/02/2022 07/03/2022 through 07/09/2022 07/10/2022 through 07/16/2022 07/17/2022 through 07/23/2022 07/24/2022 through 07/30/2022 03/05/2023 through 03/11/2023 03/12/2023 through 03/18/2023 03/19/2023 through 03/25/2023 03/26/2023 through 04/01/2023 04/02/2023 through 04/08/2023 04/09/2023 through 04/15/2023 10 of 27 08/17/2023 - 08/17/2023 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the conclusion of the inspection, we conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. We thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern (listed in Section III - Areas of Concern) that we observed during the inspection of the facility. I then explained the follow-up process that would take place once I finished the report. I explained they would receive a copy of the report as would a case officer. I told them the case officer would review the report to determine if any of my areas of concern documented violations. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 11 of 27 Bradken Atlas Inspection Date(s): APPENDIX 1: PHOTO LOG 08/17/2023 - 08/17/2023 [Title] 08/17/2023 09:47 AM (PT) No CBI Maintenance/Maintenance Wash Bay Tote labeled "Pending Analysis." No PII IMG-2023081709474547453224107.jpg Photographer: Jon Jones 47.23214896, -122.45949561 [Title] 08/17/2023 09:47 AM (PT) No CBI Maintenance/Maintenance Wash Bay Close-up view of the same tote. No PII IMG-2023081709475247523074728.jpg Photographer: Jon Jones 47.23219649, -122.45955898 12 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] 08/17/2023 09:48 AM (PT) No CBI Maintenance/Maintenance Wash Bay Another view of the same tote. No PII IMG-202308170948004802439689.jpg Photographer: Jon Jones 47.23217662, -122.45956837 [Title] IMG-2023081709535153513801109.jpg 08/17/2023 09:53 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23218807, -122.45938078 View of the SAA container holding waste aerosol residue. 13 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-202308170954005402511532.jpg 08/17/2023 09:54 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23220014, -122.45935102 Another view of the same waste aerosol residue SAA container, showing that it is not closed. [Title] IMG-202308170954085482906240.jpg 08/17/2023 09:54 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23221661, -122.45933694 Another view of the same waste aerosol residue SAA container, showing that it is not closed. 14 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-2023081709542454242950451.jpg 08/17/2023 09:54 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23220169, -122.45931909 View of the SAA container with a hazard/risk indicator that is not accurate. [Title] 08/17/2023 10:02 AM (PT) No CBI Maintenance/Universal Waste Area View of the universal waste containers No PII IMG-202308171002302303080216.jpg Photographer: Jon Jones 47.23231279, -122.4593144 15 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] 08/17/2023 10:02 AM (PT) No CBI No PII Maintenance/Universal Waste Area View of waste bulbs that are not packaged. IMG-202308171002402403453810.jpg Photographer: Jon Jones 47.23232884, -122.45932873 [Title] IMG-202308171002472473162521.jpg 08/17/2023 10:02 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23233718, -122.4592921 View of the universal waste containers that are not closed. 16 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-202308171002552553252590.jpg 08/17/2023 10:02 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23231744, -122.45928959 Another view of the universal waste containers that are not closed. [Title] IMG-20230817100306362775253.jpg 08/17/2023 10:03 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23231761, -122.45927752 Another view of the universal waste containers that are not closed. 17 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-20230817100905953789338.jpg 08/17/2023 10:09 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23245867, -122.45914894 View of the waste aerosol residue SAA container after being closed. [Title] IMG-202308171018061863617465.jpg 08/17/2023 10:18 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/CAA Connex 47.23262439, -122.4597039 View of supersacks containing waste furnace dust in the CAA, showing that they are not marked with hazard/risk labels. 18 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-2023081710181418143778742.jpg 08/17/2023 10:18 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/CAA Connex 47.23262497, -122.45967834 View of supersack containing waste furnace dust in the CAA, showing that it is not marked with a hazard/risk label. [Title] IMG-202308171019021922760351.jpg 08/17/2023 10:19 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/CAA Connex 47.23261978, -122.45967004 Another view of supersacks containing waste furnace dust in the CAA, showing that they are not marked with hazard/risk labels. 19 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-2023081710191619162934502.jpg 08/17/2023 10:19 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/CAA Connex 47.2326295, -122.45967845 Close-up view of the label, showing that it is marked as Class 9 N.O.S. Class 9 is not specific to the hazard and cannot be used as a hazard/risk indicator. [Title] IMG-202308171024032433173969.jpg 08/17/2023 10:24 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23234095, -122.45943769 View of the universal waste containers after being closed and labeled. 20 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-2023081710241524153006764.jpg 08/17/2023 10:24 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23232306, -122.45941565 View of the universal waste containers after being closed and labeled. [Title] IMG-2023081710242124213466775.jpg 08/17/2023 10:24 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/Universal Waste Area 47.23231069, -122.45938086 View of the universal waste containers after being closed and labeled. 21 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-202308171100560562358569.jpg 08/17/2023 11:00 AM (PT) No CBI No PII Photographer: Jon Jones Storage Area (Butler Building) 47.23330152, -122.46108977 View of two waste aerosol cans, seen here on the left, that were found inside the yellow flammable storage cabinet, seen here on the right. [Title] 08/17/2023 11:01 AM (PT) No CBI Storage Area (Butler Building) Close-up view of the waste aerosol cans. No PII IMG-20230817110103132142280.jpg Photographer: Jon Jones 47.23328718, -122.46118381 22 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] 08/17/2023 11:01 AM (PT) No CBI No PII Storage Area (Butler Building) Another close-up view of the waste aerosol cans. IMG-202308171101241242702261.jpg Photographer: Jon Jones 47.23327893, -122.46122363 [Title] IMG-2023081711101410143587245.jpg 08/17/2023 11:10 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/CAA Connex 47.23262535, -122.45974615 View of the supersacks in the CAA after being labeled with hazard/risk labels. 23 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-2023081711102610263147834.jpg 08/17/2023 11:10 AM (PT) No CBI No PII Photographer: Jon Jones Maintenance/CAA Connex 47.23261592, -122.45972075 View of the supersacks in the CAA after being labeled with hazard/risk labels. [Title] IMG-2023081711472147212300436.jpg 08/17/2023 11:47 AM (PT) No CBI No PII Photographer: Jon Jones Cleaning Room/SAA 47.23365335, -122.46004974 View of the waste aerosol SAA container showing that it is not closed with additional waste aerosol cans seen on top of the container. 24 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 [Title] IMG-2023081711473147312325177.jpg 08/17/2023 11:47 AM (PT) No CBI No PII Photographer: Jon Jones Cleaning Room/SAA 47.23371269, -122.45986199 Another view of the waste aerosol SAA container showing that it is not closed with additional waste aerosol cans seen on top of the container. 25 of 27 Bradken Atlas Inspection Date(s): 08/17/2023 - 08/17/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Records Review Haz. Waste Inspection ~ No No Jon Jones 2020.pdf Records Review Haz. Waste Inspection ~ No No Jon Jones 2021.pdf Records Review Haz. Waste Inspection ~ No No Jon Jones 2022.pdf Records Review Haz. Waste Inspection ~ No No Jon Jones 2022 (2).pdf Records Review Haz. Waste Inspection ~ No No Jon Jones 2023.pdf Records Review Haz. Waste Inspection ~ No No Jon Jones 2023 (2).pdf Communications RE Universal Waste No No Jon Jones .msg Communications RE Universal Waste(2) No No Jon Jones .msg Communications Universal Waste(3).msg No No Jon Jones Communications Re Universal Waste(4).msg No No Jon Jones Communications RE Universal Waste(5).msg No No Jon Jones Communications RE Universal Waste No No Jon Jones (6).msg Communications RE Universal Waste(7).msg No No Jon Jones Communications RE Universal Waste(8) No No Jon Jones .msg Communications Re Universal Waste(9) No No Jon Jones .msg Records Review 2023 ~ Haz Waste No No Jon Jones Weekly Inspection Checklist.docx Other - Updated signage Additional Signage No No Jon Jones added.docx Other - Updated container Universal Waste labeling (Flammable Liquid).docx No No Jon Jones Records Review Logs obtained during No No Jon Jones CEI (1).pdf 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 10/05/2023 26 of 27 Bradken Atlas Inspection Date(s): Records Review Records Review Records Review Records Review 08/17/2023 - 08/17/2023 Logs obtained during No No Jon Jones CEI (2).pdf Logs obtained during No No Jon Jones CEI (3).pdf Logs obtained during No No Jon Jones CEI (4).pdf Logs obtained during No No Jon Jones CEI (5).pdf 10/05/2023 10/05/2023 10/05/2023 10/05/2023 27 of 27