Document ev2DyOG8QkQZ8V84Myma3ZMKq

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 04/12/2022 - 04/12/2022 Announced: No Entry: 08:43 AM (AKT) Exit: 04:05 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) University of Alaska University of Alaska SE Auke Lake Campus 11066 Auke Lake Way Juneau, AK 99801 University Unknown Since late 60's, when it began as a community college 58.384125, -134.638331 Daniel J. Garcia, Facility Services Health and Safety Manager 11066 Auke Lake Way Juneau, AK 99801 (907) 796-6077 djgarcia@alaska.edu (City, state, zip code) County: Juneau, AK 99801 City and Borough of Juneau Facility/Site Identifier: Media Number: NAICS: AKD983069626 N/A 611310 - Colleges, Universities, and Professional Schools Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2022.05.19 12:44:52 -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: 2022.05.19 14:49:14 -07'00' Sullivan.Jennifer.A@epa.gov 1 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): 04/12/2022 - 04/12/2022 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection 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 2022. Attendees Title Name Phone Lead Inspector Maintenance and Operations Manager Health and Safety Manager Jon Jones Adam Zenger Daniel J. Garcia 9072716329 (907) 796-6511 (907) 796-6077 Email Present in Opening Conf. Jones.Jon@epa.gov Yes azenger@alaska.edu Yes djgarcia@alaska.edu Yes Present in Closing Conf. Yes No Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the University of Alaska SE Auke Lake Campus at 08:43 AM (AKT) on 04/12/2022 for an inspection. I presented my credentials to Daniel Garcia and informed him that this was an EPA RCRA inspection. The table above presents all the opening and closing conference inspection participants. Facility/Site Description The facility is a branch of the University of Alaska located northwest of downtown Juneau, AK. Additional information about the facility can be found at https://uas.alaska.edu/ Facility Info Safety Training No Provided to Inspector(s)? Operating Hours 8:00 a.m. to 5:00 p.m., Monday through Friday Weather Conditions Sunny and cool Number of employees ~290 What type of generator facility notified? Very Small Quantity Generator (VSQG) What type of generator facility verified as? Verified VSQG by Daniel Garcia 2 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): 04/12/2022 - 04/12/2022 Process Description According to Messrs. Garcia and Zenger wastes generated on campus consist of the following: Waste fluorescent lamps (mix of four-foot lamps, eight-foot lamps and compact fluorescents- CFLs) Waste batteries - NiCad, Lithium, Lead-acid (both automotive and small power back-up batteries) Waste aerosols Waste acids & bases Waste solvents Toxic aqueous wastes Used oil Used antifreeze Absorbents contaminated with used oil - every other year-based on the number of spills. Occasional spill clean-ups (used oil in parking lots) Parts washer solvent- using Citrisolv - very rarely used According to Messrs. Garcia and Zenger, they make an appointment at the local Household Hazardous Waste (HHW) facility and prior to the appointment they gather the waste from all the generation points. All the waste is taken to the HHW facility at the landfill with the exception of lead-acid batteries and used oil. Used oil goes to businesses that burn used oil in their shops. Area businesses will contact the university to see if they have any used oil that they're willing to get rid of. Lead-acid batteries are recycled through D&S recycling. During the inspection of the facility, I was accompanied by Mr. Garcia. 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. At the time of the inspection the facility was not managing any waste as universal waste. Specifically, I inspected the following areas of the facility listed below. Building(s) Building/Area/Sub-area Anderson Building #15 Hazardous Materials Storage Shed Room 309 Egan Classroom Wing Room 300U1 Storage 118 Stover House Process Description Biology and chemistry classes. Wastes generated in the labs are accumulated here prior to being taken to the local HHW facility. Chemistry Lab Accumulation area for waste fluorescent lamps. Secondary location where waste fluorescent lamps and CFLs are accumulated. Accumulation of waste fluorescent lamps. Automotive shop/garage Area of Concern No No No No No No No SECTION II - OBSERVATIONS AND RECORDS REVIEW 3 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): 04/12/2022 - 04/12/2022 Observations Building: Anderson Building #15/Hazardous Materials Storage Shed Observation #: JJ1-OB-004 Contains CBI: No Date: 04/12/2022 During the inspection, I inspected the waste being accumulated in the Hazardous Material shed. Photo(s) 1. IMG-20220412151808188856482.jpg 2. IMG-202204121519391939923883.jpg 3. IMG-202204121520172017973786.jpg 4. IMG-202204121520282028901597.jpg 5. IMG-202204121520342034807559.jpg Building: Anderson Building #15/Room 309 Contains CBI: No Observation #: JJ1-OB-003 Date: 04/12/2022 While inspecting the Anderson Building, I met Ms. Honalee Elkan, Chemistry Lab Technician. Ms. Elkan showed me the waste accumulation areas, as well as the lab chemical storage areas. Photo(s) 1. IMG-20220412110054054725546.jpg 2. IMG-20220412110114114595926.jpg 3. IMG-20220412110122122649473.jpg 4. IMG-20220412110144144714134.jpg 5. IMG-2022041211040545648666.jpg 6. IMG-20220412110523523710468.jpg 7. IMG-2022041211070171785325.jpg 8. IMG-20220412110743743658762.jpg 9. IMG-20220412110810810752626.jpg Building: Egan Classroom Wing /Room 300U1 Observation #: JJ1-OB-002 Contains CBI: No Date: 04/12/2022 While in Room 300U1, I inspected the area where waste fluorescent lamps and CFLs were being accumulated. The university does not manage waste lamps as universal waste. Photo(s) 1. IMG-202204121035243524909230.jpg 2. IMG-202204121035423542799447.jpg 3. IMG-202204121038333833797666.jpg Building: Egan Classroom Wing /Storage 118 Observation #: JJ1-OB-001 Contains CBI: No Date: 04/12/2022 While inspecting Storage Room 118, I saw the area where the facility was accumulating waste fluorescent 4 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): 04/12/2022 - 04/12/2022 lamps. Mr. Garcia told me that the university does not manage the waste fluorescent lamps as universal waste. During the inspection, I saw 16 waste fluorescent lamps. At least some of the waste lamps were labeled in a green font, which is indicative of lamps that contain a low level of mercury that will pass TCLP testing. Photo(s) 1. IMG-202204121023472347935712.jpg 2. IMG-202204121023592359770349.jpg 3. IMG-202204121024332433752460.jpg Records Review I obtained copies of disposal paperwork for the waste that was disposed at the HHW facility. These documents are included in the Document Log of this inspection report. SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. I observed no areas of concern at the time of the inspection. SECTION IV - FOLLOW UP N/A Closing Conference At the conclusion of the inspection, I conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. I thanked Mr. Garcia for his time and cooperation during the inspection and reiterated that I observed no areas of concern at the time of the inspection. 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. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. 5 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): SECTION VI - LIST OF APPENDICES Photo Log [Title] IMG-20220412151808188856482.jpg 04/12/2022 03:18 PM (AKT) Jon Jones Anderson Building #15/Hazardous Materials Storage Shed No CBI No PII View of the Hazmat shed. [Title] IMG-202204121519391939923883.jpg 04/12/2022 03:19 PM (AKT) Jon Jones Anderson Building #15/Hazardous Materials Storage Shed No CBI No PII View of the waste in the Hazmat shed. 04/12/2022 - 04/12/2022 6 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): [Title] IMG-202204121520172017973786.jpg 04/12/2022 03:20 PM (AKT) Jon Jones Anderson Building #15/Hazardous Materials Storage Shed No CBI No PII View of the waste in the Hazmat shed. [Title] IMG-202204121520282028901597.jpg 04/12/2022 03:20 PM (AKT) Jon Jones Anderson Building #15/Hazardous Materials Storage Shed No CBI No PII View of the waste in the Hazmat shed. [Title] IMG-202204121520342034807559.jpg 04/12/2022 03:20 PM (AKT) Jon Jones Anderson Building #15/Hazardous Materials Storage Shed No CBI No PII View of the waste in the Hazmat shed. 7 of 13 04/12/2022 - 04/12/2022 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): [Title] IMG-20220412110054054725546.jpg 04/12/2022 11:00 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII view of the SAA beneath fume hood. [Title] IMG-20220412110114114595926.jpg 04/12/2022 11:01 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII view of the SAA beneath fume hood. [Title] IMG-20220412110122122649473.jpg 04/12/2022 11:01 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII view of the SAA beneath fume hood. 04/12/2022 - 04/12/2022 8 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): [Title] IMG-20220412110144144714134.jpg 04/12/2022 11:01 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII view of the SAA beneath fume hood. [Title] IMG-2022041211040545648666.jpg 04/12/2022 11:04 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII View of waste in fume hood. [Title] IMG-20220412110523523710468.jpg 04/12/2022 11:05 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII View of waste in fume hood. 04/12/2022 - 04/12/2022 9 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): [Title] IMG-2022041211070171785325.jpg 04/12/2022 11:07 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII View of the chemical storage cabinets. [Title] IMG-20220412110743743658762.jpg 04/12/2022 11:07 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII View of the chemical storage cabinets. [Title] IMG-20220412110810810752626.jpg 04/12/2022 11:08 AM (AKT) Jon Jones Anderson Building #15/Room 309 No CBI No PII View of the chemical storage cabinets. 04/12/2022 - 04/12/2022 10 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): [Title] IMG-202204121035243524909230.jpg 04/12/2022 10:35 AM (AKT) Jon Jones Egan Classroom Wing /Room 300U1 No CBI No PII Accumulation of waste fluorescent lamps and CFLs. [Title] IMG-202204121035423542799447.jpg 04/12/2022 10:35 AM (AKT) Jon Jones Egan Classroom Wing /Room 300U1 No CBI No PII Accumulation of waste fluorescent lamps and CFLs. [Title] IMG-202204121038333833797666.jpg 04/12/2022 10:38 AM (AKT) Jon Jones Egan Classroom Wing /Room 300U1 No CBI No PII Accumulation of waste fluorescent lamps and CFLs. 04/12/2022 - 04/12/2022 11 of 13 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): [Title] IMG-202204121023472347935712.jpg 04/12/2022 10:23 AM (AKT) Jon Jones Egan Classroom Wing /Storage 118 No CBI No PII During the inspection, I saw 16 waste fluorescent lamps. 04/12/2022 - 04/12/2022 [Title] IMG-202204121023592359770349.jpg 04/12/2022 10:23 AM (AKT) Jon Jones Egan Classroom Wing /Storage 118 No CBI No PII During the inspection, I saw 16 waste fluorescent lamps. [Title] IMG-202204121024332433752460.jpg 04/12/2022 10:24 AM (AKT) Jon Jones Egan Classroom Wing /Storage 118 No CBI No PII During the inspection, I saw 16 waste fluorescent lamps. Document Log Document Type Document Name Facility Map Facility Map.pdf Contains Contains Uploaded By CBI PII No No Jon Jones 12 of 13 Date Received 04/21/2022 UNIVERSITY OF ALASKA SE AUKE LK CAMPUS Inspection Date(s): Other - Waste Inventory for HHW facility Other - Waste Inventory for HHW facility Other - Waste Inventory for HHW facility Other - Waste Inventory for HHW facility Other - Waste Inventory for HHW facility Other - Waste Inventory for HHW facility Other - Application for CESQG at HHW facility Waste Inv. 3-7-2019.pdf Waste Inv. 5-2-2019.pdf Waste Inv. 5-30-2019.pdf Waste Inv. 11-14-2019.pdf Waste Inv. 4-16-2020.pdf Waste Inv. 10-22-2020.pdf App for CESQG.pdf 04/12/2022 - 04/12/2022 No No Jon Jones 04/21/2022 No No Jon Jones 04/21/2022 No No Jon Jones 04/21/2022 No No Jon Jones 04/21/2022 No No Jon Jones 04/21/2022 No No Jon Jones 04/21/2022 No No Jon Jones 04/21/2022 13 of 13