Document gE2b4GxjX54B2q0ZD48Y0145a
Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection
EPA Region 10 Enforcement Division INSPECTION REPORT
09/29/2022 09:39 AM (PT)
Announced: No
09/29/2022 02:22 PM (PT)
Access: Granted
RCRA
CEI - Compliance Evaluation Inspection
Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Identified by Generator Type of Operation Size of Facility Length of Facility at Location Geographic Coordinates Mailing Address/Secondary Address
King County DOT Department of Local Services - Road Services Division King County DOT Department of Local Services - Road Services Division WAD047476882 155 Monroe Avenue NE Bldg. P, G, and F Renton, WA 98056 King Large Quantity Generator 212319 - OTHER CRUSHED AND BROKEN STONE MINING AND QUARRYING Road Services 54.11 acres 20 years or more 47.483192, -122.17491 Mr. Brent Dhoore, Environmental Scientist 155 Monroe Avenue NE, Bldg. A Renton, WA 98056 brent.dhoore@kingcounty.gov
City, State, Zip Code
Renton, WA 98056
Permit Number (If Applicable) Not Applicable
Lead Inspector: Jon Jones
Supervisor Review: Jen Sullivan
JONATHAN JONES EPA Region 10
Jennifer A Sullivan EPA Region 10
Digitally signed by JONATHAN JONES Date: 2022.12.08 08:35:37 -09'00'
Jones.Jon@epa.gov
(907) 271-6329
Digitally signed by Jennifer A Sullivan Date: 2022.12.08 10:51:11 -08'00'
Sullivan.Jennifer.A@epa.gov (206) 553-6978
SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: CEI - Compliance Evaluation Inspection
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This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with Washington's federally authorized hazardous waste regulations found at Washington Administrative Code (WAC) 173-303. The facility was inspected to ensure compliance with standards for hazardous waste generators (WAC 173-303-170 through 230), universal waste management standards (WAC 173-303-573), and requirements for management of used oil (WAC 173-303-515). The inspection was conducted as a Core Program Requirement for FY 2022.
This report is based on information supplied by King County DOT Department of Local Services - Road Services Division facility representatives, observations made by the EPA Region 10 inspectors, and records and reports maintained by the facility, but not limited to: direct observations 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 or 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
Phone
Lead Inspector/EPA Region 10
Jon Jones
9072716329
Environmental Scientist II/King Co. Department of Local Services, Road Services Division
Jim Crawford (206) 2559598
Compliance
Katelynn
Inspector/Washington Piazza
Department of
Ecology
(206) 5183622
RCRA Inspector, EPA Jennifer
Region 10
Parker
(206) 5531900
Environmental Scientist/King Co. Department of Local Services, Road Services Division
Brent Dhoore (206) 4772606
Email Jones.Jon@epa.gov
Opening Conf.
Yes
jim.crawford@kingcounty.gov Yes
katelynn.piazza@ecy.wa.gov Yes
parker.jennifer@epa.gov
Yes
brent.dhoore@kingcounty.gov No
Closing Conf. Yes Yes
Yes
Yes Yes
Opening Conference
EPA Region 10 Lead Inspector, Jon Jones, arrived at the King County DOT Department of Local Services - Road Services Division Facility (the "Site" or "Facility"), located at 155 Monroe Avenue NE Bldg. P, G, and F, Renton, WA 98056, at 09:39 AM (PT) on 09/29/2022 for an unannounced inspection. Inspector Jones presented credentials to and informed Jim Crawford that this was an EPA Region 10 inspection to determine compliance with the Resource Conservation and Recovery Act (RCRA).
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King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
Facility/Site Information
Number of employees 150
Weather Conditions Cloudy
Operating Hours
24 hours a day, 7 days a week, 365 days a year. 6:00 am to 4:30 pm for the main crew.
Safety Training
No
Provided to
Inspector(s)?
What type of generator facility notified?
Large Quantity Generator (LQG)
What type of generator facility verified as?
LQG verified by Jim Crawford
Process Description
Mr. Crawford invited us into his office area while he canceled his meetings for the day. We held an opening conference. During the opening conference, Mr. Crawford told us that his facility generated the following wastes:
Used oil - uncontaminated used oil is recycled in an on-site burner at the facility Used antifreeze Fluorescent lamps and batteries that are managed as universal waste. Orphaned wastes that are picked up along the roadside within King County. Aerosols managed as hazardous waste E-waste Solvents Traffic paint
During the inspection of the facility, we were accompanied by Mr. Crawford. Shortly after the inspection began, we were joined by Mr. Brent Dhoore, Environmental Scientist.
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. Specifically, we inspected the following areas of the facility listed below.
Building(s)
Building/Area/Sub-area Building B Building F Building G Building J Building C Building P Traffic Striping Paint Area
Process Description Sign Shop Fleet Services Lube Shop Fleet Services - Main Fleet Vehicle Maintenance Administration Environmental office Traffic Striping Paint Area Storage of traffic paint totes
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Area of Concern No Yes Yes No No Yes Yes
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
Hazardous Waste Shed (CAA)
Central Accumulation Area
Yes
Planning Unit 9
SAA
No
Universal waste storage
Electronic waste storage
SECTION II - OBSERVATIONS
Building: Building G Observation #: JJ1-OB-001 Date: 09/29/2022 Person Interviewed: Brent Dhoore
Contains AOC: Yes
Contains CBI: No
Title: Environmental Scientist
While inspecting the Main Fleet Vehicle Maintenance shop we were introduced to one of the facility mechanics who identified himself as Blade. Blade accompanied us throughout the shop. During the inspection of the shop, I saw multiple (4+) oil pans throughout the shop that contained varying amounts of used oil, none of which were labeled with the words "Used Oil." I explained to both Blade and Mr. Dhoore that containers, including oil drain pans, used to store used oil were required to be labeled. I also saw multiple oil pans stacked up in different areas of the shop that did not contain used oil during the inspection. I suggested to Blade and Mr. Dhoore that if these were containers they routinely use for the accumulation of used oil, it would help to label them also to ensure compliance with the used oil regulations.
While still inspecting the shop, I saw a mop bucket that was full of dirty water. I asked Blade about the contents of the bucket, and he explained that it was just dirty water from mopping up spills on the floor. Mr. Dhoore explained that the mop water is dark because it is oily water, which has been determined based on knowledge of the process. Not knowing exactly what the contaminants in the mop water were, I suggested that a waste determination might be needed.
Following the inspection, I received an email from Mr. Dhoore dated 10/19/22 which addressed updates regarding some of the remaining areas of concern that were identified during the inspection on 9/29/22. In that email, Mr. Dhoore stated:
"We are coordinating with our contract lab to test the fleet mop bucket water for designation" and "I also dropped off some printed used oil labels yesterday to our Fleet office so they can label all of the used oil containers in the shops that currently are not labeled. We will be following up with them soon to ensure everything is properly labeled."
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Building: Building F
Observation #: JJ1-OB-002 Date: 09/29/2022
Contains AOC: Yes
Contains CBI: No
Person Interviewed: Brent Dhoore
Title: Environmental Scientist
While we inspected Building F, Isaac from facility services joined us and answered questions.
While inspecting the Fleet Services Lube Shop at Building F, I saw a black used oil drain pan on the floor beneath a used oil filter crusher. At the time of the inspection, this used oil pan was not labeled with the words "Used Oil."
Adjacent to the used oil filter crusher, I saw a large, elevated drain pan with a grate over the top. At the time of the inspection, there were multiple used oil filters on top of the grate and used oil was draining from the filters and being collected in the elevated drain pan. This elevated drain pan contained used oil and was not labeled with the words "Used Oil."
While still inspecting the Fleet Services Lube Shop building, I saw a spill pallet that contained oil. The facility representative confirmed it was used oil. At the time of the inspection, the spill pallet was not labeled with the words "Used Oil."
While still in the Fleet Services Lube Shop building, I inspected the contents of a couple of metal trash receptacles. During this inspection, I saw a waste aerosol can in each trash receptacle. I shook the contents of one of the waste aerosol cans and could hear and feel liquid sloshing around inside the aerosol can. According to the labeling on the waste aerosol cans, the aerosols contents were extremely flammable and under pressure. At the time of the inspection, facility personnel told me that waste aerosols generated at the facility were managed as solid waste and discarded into the trash.
While inspecting more trash receptacles in the Fleet Services Lube Shop building, I saw a waste leather glove inside a large plastic trash can. I explained to facility personnel that many waste leather gloves are known to fail TCLP for chromium (D007). I explained that a waste determination should be made on the waste leather glove.
Prior to leaving the Fleet Services Lube Shop building, I saw a large metal used oil drain pan connected to a lift that held used oil and was not labeled with the words "Used Oil."
I also saw another metal trash receptacle that held multiple waste aerosol cans. There were eight waste aerosol cans in the trash can. According to the labeling on the waste aerosol cans, the aerosols contents were extremely flammable and under pressure. I shook the contents of some of the waste aerosol cans and could hear and feel liquid sloshing around inside the aerosol cans.
As we finished walking through Building F, Mr. Dhoore told us that the facility ships out fully intact aerosol cans that still contain product as hazardous waste. He explained further that the facility representatives thought that if they fully sprayed out the contents, then the waste aerosol cans could just go in the trash cans for management as solid waste. I asked for safety data sheets (SDS's) for the waste aerosol cans we observed in the trash receptacles.
As we were leaving the Fleet Services Lube Shop building, I saw two more waste aerosol cans beneath and behind the used oil filter crusher that we first saw when we entered the building. At the time of the inspection, the facility was not managing their waste aerosol cans as hazardous waste Prior to leaving the area, I explained both methods of hazardous waste aerosol can management to facility personnel.
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Following the inspection, I received an email from Mr. Dhoore dated 10/19/22, which addressed updates regarding some of the remaining areas of concern that were identified during the inspection on 9/29/22. In that email, Mr. Dhoore stated:
"Hello good afternoon, Jon, I wanted to send you a few updates on things we are working through in response to the inspection of our facility on 9/29/2022. We are coordinating with our contract lab to test the leather gloves for designation that were found in the trash can. I also dropped off some printed used oil labels yesterday to our Fleet office so they can label all the used oil containers in the shops that currently are not labeled. We will be following up with them soon to ensure everything is properly labeled."
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Building: Building P/Traffic Striping Paint Area
Observation #: JJ1-OB-003 Date: 09/29/2022
Contains AOC: Yes
Contains CBI: No
Person Interviewed: Brent Dhoore
Title: Environmental Scientist
Wes Harvey, Traffic Supervisor, joined us as we inspected Building P.
While inspecting the striping paint storage area outside and adjacent to Building P, I saw multiple (12+) 5-gallon containers that used to contain ignitable paint and had been allowed to dry out/evaporate. I asked for SDS's for the traffic paint (White and yellow) during the inspection. I viewed the labeling on the paint totes and saw that the paint was ignitable (D001).
While in the striping paint storage area, I also observed five waste aerosol cans. Two of the five waste aerosol cans were in a pit, beneath some of the paint totes. The two waste aerosol cans were rusty and looked like that had been discarded in the pit a long time before the inspection. The contents of the two waste aerosols were unknown due to missing labeling. There were additional containers of waste paint-related materials in the
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same area. The contents of those containers were not identifiable and no information was provided regarding the results of a hazardous waste determination for these wastes.
In the traffic paint tote area, yellow paint had leaked out of one of the totes and had been allowed to solidify on the asphalt surface where it had leaked.
Following the inspection, I received SDS's, from Mr. Dhoore on 10-5-22, for both the white and yellow traffic paints used at the facility. I reviewed the SDS information for both traffic paints and saw that each was an ignitable (D001) paint. The flash point for each was -0.4 F. These SDS's are included as attachments and listed in the document log.
Document(s) 1. Traffic white paint 2020_current.pdf 2. TRAFFI 2.PDF
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Building: Building P Observation #: JJ1-OB-004 Date: 09/29/2022 Person Interviewed: Brent Dhoore
Contains AOC: Yes
Contains CBI: No
Title: Environmental Scientist
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While inspecting the interior of the building, I saw a waste aerosol can inside a trash receptacle. The aerosol was a can of marking paint, and the label identified the contents as extremely flammable liquid (D001) that were under pressure (D003). At the time of the inspection, the waste aerosol can was not being managed as a hazardous waste.
While still in the building, I also saw a 5-gallon bucket that was not closed and had contained what appeared to be an ignitable paint waste that had been allowed to dry/evaporate. This was verified by facility personnel as waste yellow traffic paint. The yellow traffic paint used at the facility is ignitable (D001) when in liquid form.
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Building: Hazardous Waste Shed (CAA) Observation #: JJ1-OB-005 Date: 09/29/2022 Person Interviewed: Brent Dhoore
Contains AOC: Yes
Contains CBI: No
Title: Environmental Scientist
We arrived at the facility's Hazardous Waste Shed (CAA) and prior to entering the gated CAA area, I saw a large, wheeled, trash receptacle with a hinged lid that was staged outside the fence. The trash receptacle had a capacity of 96 gallons and contained approximately 25 waste aerosol cans. At the time of the inspection, facility personnel stated that the container was being utilized as a satellite accumulation area (SAA) container. We explained that an SAA container could only accumulate up to a maximum of 55-gallons. During the inspection, I saw that the container was not labeled with the words "Hazardous Waste" and was not marked with a hazard indicator. Mr. Dhoore labeled the container with the words "Hazardous Waste" and a hazard indicator during the inspection.
Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation that showed the 96-gallon container, referenced above, had been replaced with a 55-gallon container.
Directly across from the CAA, we saw a black tote that was approximately one cubic yard in size. At the time of the inspection, the tote contained waste lamps and waste bulbs. The containers contents were being managed as universal waste and the tote was labeled as "Universal Waste - Bulbs." We explained that the tote was required to be labeled with the words "Universal Waste - Lamps."
Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation showing that the tote, referenced above, had been labeled with the words "Universal Waste - Lamps."
We also saw that there was a 5-gallon container on top of the tote that contained waste batteries that were not alkaline batteries. At the time of the inspection, the 5-gallon container was not labeled with the words "Universal Waste - Batteries." The container was labeled "Universal Waste - Button Batts." This area of concern has yet to be addressed.
We entered the fenced CAA and while there I saw two blue, 15-gallon containers. According to the labeling, the containers held waste epoxy resin and were brought into the CAA on 8/10/22. At the time of the inspection, both containers were not closed. The first one of the two was labeled with the words "Hazardous Waste" and marked with an accumulation start date (ASD) of 8/10/22 but had no hazard indicator. The second of the two was not labeled with the words "Hazardous Waste" or marked with a hazard indicator and ASD. The facility representatives told us the county's hazardous waste vendor had refused to take these containers off-site during the last quarterly pick up since they were open.
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Following the inspection, I received an email from Mr. Dhoore dated 10/19/22, which addressed updates regarding some of the remaining areas of concern that were identified during the inspection on 9/29/22. In that email, Mr. Dhoore stated:
"We also transferred the two open top blue containers of epoxy to 30 gal drums that are now closed with lids and rings."
While moving through the CAA, I saw a 5-gallon container that held waste flares. At the time of the inspection, the container was not labeled with the words "Hazardous Waste" and not marked with an ASD. The container was also not closed.
Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation showing that the 5-gallon container, referenced above, had been closed.
I also saw a blue, 55-gallon container that was labeled as "Pending Analysis." The container was also labeled with a hazardous waste marking, a hazard indicator, and marked as containing mixed automotive fluids. At the time of the inspection, the container was marked with an ASD of 12/1/21, indicating that it had been in accumulation for greater than 90-days. According to the date, the container had been in the CAA for 302 days.
Following the inspection, I received another email from Mr. Dhoore dated 10/19/22, which addresses updates regarding some of the remaining areas of concern that were identified during the inspection on 9/29/22. In that email, Mr. Dhoore stated:
"I've also coordinated with our disposal vendor to come out and pick up the remaining waste items in our cage. The earliest they could come out is November 9th, so I've scheduled for that day. If they can come sooner of course we will do that."
At the time this report was submitted, EPA has not received any information confirming that the waste has been shipped off-site.
While continuing my inspection of the facility's CAA, I saw a 5-gallon container that held waste Chlor-D-Tect kits. According to facility personnel, the waste container was being used as a SAA container. At the time of the inspection, the container was labeled with the words "Hazardous Waste" and marked with a hazard indicator; however, the container was not closed.
Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation showing that the 5-gallon container, referenced above, had been closed.
Adjacent to the container of Chlor-D-Tect kits, I saw a container that held waste mercury switches. The container held approximately 16 waste mercury switches. At the time of the inspection, the container was not closed, and it was not labeled with either the words "Universal Waste Mercury - Containing Equipment," Waste Mercury - Containing Equipment," or "Used Mercury - Containing Equipment." The container was labeled with a universal waste label and the words "Mercury Switches" was written on the label.
Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation that the 5-gallon container, referenced above, had been closed.
The facility takes in orphaned waste that is left on the roadside in King County and during my inspection of the CAA I saw a pallet that contained twenty 5-gallon containers of various wastes. During my inspection of these orphaned wastes, I saw that there were seventeen 5-gallon containers of waste that were not labeled with the words "Hazardous Waste" or marked with hazard indicators. There were two additional 5-gallon waste containers that were also not labeled with the words "Hazardous Waste" or marked with hazard indicators, and they were also not closed. There was also one 5-gallon container that was labeled with the words
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"Hazardous Waste" but was not marked with a hazard indicator. The ASD for these orphan waste containers was 9/13/22. Across from the pallets of orphaned waste, I saw a 55-gallon container that held 13 waste aerosol cans. The container was labeled with the words "Hazardous Waste" and marked with a hazard indicator; however, the container was not closed. The container lid was misshapen in a way that did not allow it to make a complete seal with the top of the container. The container was also marked with an ASD of 5/2/22. According to the ASD, the container had been in accumulation for greater than 90-days. At the time of the inspection, the container had been in accumulation for 150 days. Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation showing that the 55-gallon container, referenced above, had a drum ring attached, closing the container. Following the inspection, I received another email from Mr. Dhoore dated 10/19/22, which addresses updates regarding some of the remaining areas of concern that were identified during the inspection on 9/29/22. In that email, Mr. Dhoore stated: "I've also coordinated with our disposal vendor to come out and pick up the remaining waste items in our cage. The earliest they could come out is November 9th, so I've scheduled for that day. If they can come sooner of course we will do that." At the time this report was submitted, EPA has not received any information confirming that the waste has been shipped off-site.
A 1-gallon container was also found in a trash receptacle while inspecting the CAA. The container was removed from the trash during the inspection. The facility personnel explained to the EPA inspectors that it contained used oil. At the time of the inspection, the container of used oil was not labeled with the words "Used Oil." Following the inspection, I received an email from Mr. Dhoore on 10-5-22, that included photo documentation showing that the 1-gallon container, referenced above, had since been labeled with the words "Hazardous Waste" versus "Used Oil." However, there was no hazard indicator marked on the container and the ASD of 10/3/22 is not accurate since the waste container had already been generated and was in the trash during the 9/29/22 inspection.
Document(s) 1. AEROSO 1.JPG 2. AEROSO 2.JPG 3. FLAREA 1.JPG 4. OILCON 1.JPG 5. UNIVER 1.JPG
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SECTION III - RECORDS REVIEW
Record: Inspections
Ref #: JJ1-RR-001
Reviewed By: Jon Jones
AOC: Yes Reviewed Date: 09/29/2022
During the paperwork review at the facility, weekly hazardous waste inspection logs were inspected for the period from May 2019 through December 2021. During the inspection of these records, the following weeks
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were identified as a week in which a weekly hazardous waste inspection was not conducted by facility personnel at the facility's CAA:
August 11-17, 2019 December 29, 2019 - January 4, 2020 June 28 - July 4, 2020 December 6 - 12, 2020 March 28 - April 3, 2021 April 4 - 10, 2021 June 27 - July 3, 2021 December 26, 2021 - January 1, 2022*
*The December 2021 weekly inspection checklist states in the comments section, "Week of 12/27 no inspection due to snow event."
Copies of weekly hazardous waste inspections performed prior to and following weeks where no inspection was performed are included in this report.
At the time of the inspection, the weekly hazardous waste inspection logs for 2022 were documented electronically. During the inspection, I requested that the 2022 weekly inspection logs be emailed to me following the inspection. These inspection records were sent to me via email by Mr. Dhoore on 10-5-22. I reviewed the weekly inspections that ranged from January through September 2022. At the time of this review, I saw that there were no weekly inspection logs for the month of May 2022. Based on this information, there were no weekly hazardous waste inspections conducted during the following four weeks:
May 1 - 7, 2022 May 8 - 14, 2022 May 15 - 21, 2022 May 22 - 28, 2022
Document(s)
1. WklyHWchecklists.pdf 2. JANUAR 1.PDF 3. FEBRUA 1.PDF 4. MARCH2 1.PDF 5. APRIL2 1.PDF 6. June 2022_Renton_final.pdf 7. July 2022_Renton_final.pdf 8. AUGUST 1.PDF 9. SEPTEM 1.PDF
Record: Manifests
AOC: Yes
Ref #: JJ1-RR-002
Reviewed By: Jon Jones
Reviewed Date: 09/29/2022
During my review of the facility's hazardous waste manifests which covered the period of September 2019 through September 2022, I saw the following two hazardous waste manifests for which there was no original returned manifest that had been signed by the designated facility:
Manifest# Date 017187952FLE 6/2/22 017187953FLE 6/2/22
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Mr. Dhoore sent me an email on 10-5-22, following the inspection, that included copies of the above referenced hazardous waste manifests, and LDR's, that had been signed by the designated facility. These documents are included as attachments and are listed in this reports document log.
Document(s)
1. Mans-unsigned by Desfac.pdf 2. 017187952FLE.pdf 3. 017187953FLE.pdf
Record: Personnel Training
Ref #: JJ1-RR-003
Reviewed By: Jon Jones
AOC: Yes Reviewed Date: 09/29/2022
During my review of the facility's weekly hazardous waste inspections, I saw that while containers of hazardous waste in the facility's CAA we're not closed, not labeled with the words hazardous waste, and were being accumulated for greater than 90-days, these inspection discrepancies were not being noted in the weekly inspection logs. Based on these findings, facility personnel were either not actually conducting the weekly inspections and just continued to fill out the weekly inspection logs or they lack the training to recognize these types of discrepancies.
SECTION IV - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation.
Building: Building G JJ1-OB-001
Area:
Sub-area:
Multiple (4+) oil pans throughout Citations: the shop contained varying amounts of used oil, but were not labeled with the words "Used Oil."
Sections:
Building: Building G JJ1-OB-001
Area:
Sub-area:
While still inspecting the shop, I saw a mop bucket that was full of dirty water. Facility representatives explained the mop water was such a dark color because it is oily water. Not knowing exactly what had been mopped up in the vehicle maintenance area, I suggested that a waste determination might be needed.
Citations:
Sections:
Building: Building F JJ1-OB-002
Area:
Sub-area:
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I saw three used oil drain pans that contained used oil but were not labeled with the words "Used Oil."
Citations:
Building: Building F JJ1-OB-002
Area:
I saw a spill pallet that contained used oil. At the time of the inspection, the spill pallet was not labeled with the words "Used Oil."
Citations:
Building: Building F JJ1-OB-002
Area:
I inspected the contents of trash receptacles and discovered waste aerosol cans in three of the trash receptacles. I shook the contents of a number of the waste aerosol cans and could hear and feel liquid sloshing around inside the aerosol cans. According to the labeling on the waste aerosol cans, the aerosols contents were flammable and under pressure. At the time of the inspection, facility personnel told me that waste aerosols generated at the facility that were fully sprayed out were managed as solid waste and discarded into the trash.
Citations:
Building: Building F JJ1-OB-002
Area:
I saw a waste leather glove inside of a large plastic trash can. I explained to facility personnel that waste leather gloves are known to fail TCLP for chromium (D007). I explained that a waste determination should be made on the waste leather glove.
Citations:
Building: Building F JJ1-OB-002
Area:
I saw two more waste aerosol cans Citations: beneath and behind a used oil filter
14 of 64
Sections: Sub-area: Sections: Sub-area: Sections:
Sub-area: Sections:
Sub-area: Sections:
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
crusher. At the time of the inspection, the facility was not managing their waste aerosol cans as hazardous waste.
Building: Building P JJ1-OB-003
Area: Traffic Striping Paint Area
I saw multiple (12+) 5-gallon containers that used to contain ignitable paint and had been allowed to dry out/evaporate.
Citations:
Sub-area: Sections:
Building: Building P JJ1-OB-003
Area: Traffic Striping Paint Area
In the striping paint storage area, I observed that yellow paint had leaked out of a traffic paint tote and was allowed to dry in place on the asphalt where it had leaked.
Citations:
Sub-area: Sections:
Building: Building P JJ1-OB-003
Area: Traffic Striping Paint Area
I saw five waste aerosol cans. Two of the five waste aerosol cans were in a pit, beneath some of the paint totes. The two waste aerosol cans were rusty and looked like had been discarded in the pit a long time before the inspection. The contents of the two waste aerosols were unknown due to missing labeling.
Citations:
Building: Building P JJ1-OB-004
Area:
I saw a waste aerosol can inside a trash receptacle. The aerosol was a can of marking paint, and the contents were described on the label as extremely flammable liquid (D001) that were under pressure (D003). At the time of the inspection, the waste aerosol can
Citations:
15 of 64
Sub-area: Sections:
Sub-area: Sections:
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
was not being managed as a hazardous waste.
Building: Building P JJ1-OB-004
Area:
A 5-gallon bucket that had contained an ignitable paint waste had been left open and allowed to dry/evaporate. The yellow traffic paint used at the facility is ignitable (D001) when in liquid form.
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
A trash receptacle outside the fenced CAA had a capacity of 96 gallons and contained approximately 25 waste aerosol cans. Facility personnel stated that the container was being utilized as a satellite accumulation area (SAA) container. The SAA container was not labeled with the words "Hazardous Waste" and was not marked with a hazard indicator.. Mr. Dhoore labeled the container with the words "Hazardous Waste" and a hazard indicator during the inspection.
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
At the time of the inspection, a tote Citations: contained waste lamps and waste bulbs that were being managed as universal waste. The tote was labeled as "Universal Waste - Bulbs," rather than "Universal Waste - Lamps."
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
Sub-area: Sections: Sub-area: Sections:
Sub-area: Sections: Sub-area:
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King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
A 5-gallon container on top of the tote contained waste batteries but was not labeled with the words "Universal Waste - Batteries."
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
Two, blue, 15-gallon containers held waste epoxy resin and had been brought into the CAA on 8/10/22. At the time of the inspection, both containers were not closed. One of the two was labeled with the words "Hazardous Waste" and marked with an ASD of 8/10/22, but had no hazard indicator. The second of the two was not labeled with the words "Hazardous Waste" or marked with a hazard indicator and ASD.
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
A 5-gallon container held hazardous waste flares but at the time of the inspection, the container was not labeled with the words "Hazardous Waste" and not marked with an ASD. The container was also not closed.
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
I also saw a blue, 55-gallon container that was labeled as "Pending Analysis." The container was also labeled with a hazardous waste marking, a hazard indicator, and marked as containing mixed automotive fluids. At the time of the inspection, the container was marked with an ASD of 12/1/21 indicating that it had been in accumulation for greater than 90days. According to the date, the
Citations:
17 of 64
Sections: Sub-area: Sections:
Sub-area: Sections:
Sub-area: Sections:
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
container had been in the CAA for 302 days.
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
I saw a 5-gallon container that held waste Chlor-D-Tect kits. According to facility personnel, the waste container was being used as a SAA container. At the time of the inspection, the container was labeled with the words "Hazardous Waste" and marked with a hazard indicator however, the container was not closed.
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
The facility takes in orphaned waste that is left on the roadside in King County and during my inspection of the CAA I saw a pallet that contained twenty 5-gallon containers of various wastes. Seventeen of the containers were not labeled with the words "Hazardous Waste" or marked with hazard indicators. Two l 5-gallon waste containers that were also not labeled with the words "Hazardous Waste" or marked with hazard indicators, and they were also not closed. There was also one 5-gallon container that was labeled with the words "Hazardous Waste" but wasn't marked with a hazard indicator.
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
A 55-gallon container that held 13 Citations: waste aerosol cans was labeled with the words "Hazardous Waste" and marked with a hazard indicator;
18 of 64
Sub-area: Sections:
Sub-area: Sections:
Sub-area: Sections:
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
however, the container was not closed. The container lid was misshapen in a way that did not allow it to make a complete seal with the top of the container. The container was also marked with an ASD of 5/2/22. According to the ASD, the container had been in accumulation for greater than 90days. At the time of the inspection, the container had been in accumulation for 150 days.
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
A 1-gallon container was also found in a trash receptacle while inspecting the CAA. The container was removed from the trash during the inspection and to the facility representatives told the EPA inspectors it contained used oil,. At the time of the inspection, the container of used oil was not labeled with the words "Used Oil."
Citations:
Building: Hazardous Waste Shed (CAA)
JJ1-OB-005
Area:
I saw a container that held waste mercury switches. The container held approximately16 waste mercury switches. At the time of the inspection, the container was not closed, and it was not labeled with either the words "Universal Waste Mercury - Containing Equipment," Waste Mercury - Containing Equipment," or "Used Mercury Containing Equipment." The container was labeled with a universal waste label and the words "Mercury Switches" was written on the label.
Citations:
Sub-area: Sections:
Sub-area: Sections:
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King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
Record: Inspections JJ1-RR-001
During the inspection of these records, the following weeks were identified as a week in which a weekly hazardous waste inspection was not conducted by facility personnel at the facility's CAA:
Citations:
August 11-17, 2019 December 29, 2019 - January
4, 2020 June 28 - July 4, 2020 December 6 - 12, 2020 March 28 - April 3, 2021 April 4 - 10, 2021 June 27 - July 3, 2021 December 26, 2021 - January
1, 2022* May 1 - 7, 2022 May 8 - 14, 2022 May 15 - 21, 2022 May 22 - 28, 2022
*The December 2021 weekly inspection checklist states in the comments section, "Week of 12/27 no inspection due to snow event."
Record: Manifests JJ1-RR-002
During my review of the facility's hazardous waste manifests which covered the period of September 2019 through September 2022, I saw the following two hazardous waste manifests for which there was no original returned manifest that had been signed by the designated facility:
Citations:
Manifest# Date 017187952FLE 6/2/22 017187953FLE 6/2/22
Record: Personnel Training JJ1-RR-003
Sections: Sections:
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King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
During my review of the facility's weekly hazardous waste inspections, I saw that while containers of hazardous waste in the facility's CAA we're not closed, not labeled with the words hazardous waste, and were being accumulated for greater than 90days, these inspection discrepancies were not being noted in the weekly inspection logs. Based on these findings, facility personnel were either not actually conducting the weekly inspections and just continued to fill out the weekly inspection logs or they lack the training to recognize these types of discrepancies.
Citations:
Sections:
SECTION V - CLOSING CONFERENCE AND FOLLOW UP
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 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 I observed during my 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 are determined to be violations.
SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted.
SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log
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King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
APPENDIX 1: PHOTO LOG
[Title]
IMG_0015.jpg
09/29/2022 11:04 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of used oil drain pan beneath oil filter crusher that is not labeled with the words "Used Oil."
[Title]
IMG_0017.jpg
09/29/2022 11:04 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of an elevated used oil drain pan, seen here with used oil filters draining into the pan. The drain pan is not labeled with the words "Used Oil."
22 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0021.jpg
09/29/2022 11:06 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of a spill pallet that contains used oil that has accumulated in the pallet. The spill pallet is not labeled with the words "Used Oil."
[Title]
IMG_0020.jpg
09/29/2022 11:06 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of a waste aerosol can inside a trash receptacle.
23 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0016.jpg
09/29/2022 11:04 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Close-up view of the used oil drain pan beneath the oil filter crusher, which is not labeled with the words "Used Oil."
[Title]
IMG_0019.jpg
09/29/2022 11:06 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of a waste aerosol can inside a trash receptacle.
24 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0018.jpg
09/29/2022 11:04 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Close-up view of the elevated used oil drain pan that contains used oil and is not labeled with the words "Used Oil."
[Title]
IMG_0022.jpg
09/29/2022 11:07 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Another view of the same spill pallet that contains used oil and is not labeled with the words "Used Oil."
25 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0023.jpg
09/29/2022 11:07 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Close-up view of the same spill pallet showing that it contains used oil.
[Title]
IMG_0024.jpg
09/29/2022 11:08 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of a waste aerosol can inside another trash receptacle.
26 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0025.jpg
09/29/2022 11:08 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Close-up view of the same waste aerosol can in the trash receptacle.
[Title]
IMG_0026.jpg
09/29/2022 11:13 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of a waste leather glove seen here in a trash receptacle.
27 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0027.jpg
09/29/2022 11:15 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of another used oil drain pan that is not labeled with the words "Used Oil."
[Title]
IMG_0030.jpg
09/29/2022 11:17 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Another view of the drain pan collecting drips from a hydraulic oil tank.
28 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0034.jpg
09/29/2022 11:31 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of waste aerosol cans seen here on the floor behind the facility's oil filter crusher.
[Title]
IMG_0033.jpg
09/29/2022 11:31 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Another view of the same waste aerosol cans seen on the floor behind the oil filter crusher.
29 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0032.jpg
09/29/2022 11:27 AM
Photographer: Jon Jones
Building F
No CBI
No PII
View of additional waste aerosol cans seen in another trash receptacle.
[Title]
IMG_0028.jpg
09/29/2022 11:15 AM
Photographer: Jon Jones
Building F
No CBI
No PII
Close-up view of the used oil drain pan seen in an earlier photo that contains used oil and is not labeled with the words "Used Oil."
30 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0006.jpg
09/29/2022 10:39 AM
Photographer: Jon Jones
Building G
No CBI
No PII
View of an oil drain pan that contains used oil and is not labeled with the words "Used Oil."
[Title]
IMG_0007.jpg
09/29/2022 10:39 AM
Photographer: Jon Jones
Building G
No CBI
No PII
Another view of the same unlabeled used oil drain pan seen in IMG_0006.jpg
31 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0008.jpg
09/29/2022 10:40 AM
Photographer: Jon Jones
Building G
No CBI
No PII
Another view of the same unlabeled used oil drain pan seen in IMG_0006.jpg and IMG_0007.jpg
[Title]
IMG_0009.jpg
09/29/2022 10:40 AM
Photographer: Jon Jones
Building G
No CBI
No PII
View of another used oil drain pan seen here with used oil filters. The drain pan contains used oil and is not labeled with the words "Used Oil."
32 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0010.jpg
09/29/2022 10:40 AM
Photographer: Jon Jones
Building G
No CBI
No PII
Another view of the same used oil drain pan seen in IMG_0009.jpg
[Title]
IMG_0012.jpg
09/29/2022 10:42 AM
Photographer: Jon Jones
Building G
No CBI
No PII
View of an unlabeled used oil drain pan being actively used, beneath a vehicle, to collect used oil.
33 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title] 09/29/2022 10:42 AM Building G Another view of an unlabeled used oil drain pan.
IMG_0011.jpg
Photographer: Jon Jones
No CBI
No PII
[Title]
IMG_0013.jpg
09/29/2022 10:42 AM
Photographer: Jon Jones
Building G
No CBI
No PII
Another view of the same used oil drain pan seen in IMG_0011.jpg and IMG_0012.jpg
34 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0014.jpg
09/29/2022 10:48 AM
Photographer: Jon Jones
Building G
No CBI
No PII
View of a bucket of mop water that is a dark color and was described as oily water, leading to questions of whether a dangerous waste designation needs to be made.
[Title]
IMG_0062.jpg
09/29/2022 12:10 PM
Photographer: Jon Jones
Building P
No CBI
No PII
View of a 5-gallon container of waste yellow traffic paint that had been allowed to dry out.
35 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title] 09/29/2022 12:10 PM Building P View of a waste aerosol can in a trash receptacle.
IMG_0060.jpg
Photographer: Jon Jones
No CBI
No PII
[Title]
IMG_0061.jpg
09/29/2022 12:10 PM
Photographer: Jon Jones
Building P
No CBI
No PII
Close-up view of the same waste aerosol can seen in IMG_0060.jpg.
36 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0044.jpg
09/29/2022 11:50 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of damaged container of traffic paint that appears to need a waste determination.
[Title]
IMG_0046.jpg
09/29/2022 11:51 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of a waste aerosol can in the pit area beneath the traffic paint totes.
37 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0041.jpg
09/29/2022 11:49 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of a 5-gallon container holding dried waste white traffic paint.
[Title]
IMG_0048.jpg
09/29/2022 11:51 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of another waste aerosol can in the bottom of the pit beneath the traffic paint totes.
38 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0040.jpg
09/29/2022 11:49 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of another 5-gallon container that holds waste traffic paint that was allowed to dry out in the container.
[Title]
IMG_0037.jpg
09/29/2022 11:47 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of a 5-gallon container that holds waste yellow traffic paint that had been allowed to dry out in the container.
39 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0035.jpg
09/29/2022 11:47 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of three 5-gallon traffic paint containers that require a waste determination. Two of the three containers hold waste yellow traffic paint that had been allowed to dry out in the containers.
[Title]
IMG_0036.jpg
09/29/2022 11:47 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of one of the open 5-gallon containers, showing that waste yellow traffic paint had been allowed to dry out in the container.
40 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0038.jpg
09/29/2022 11:48 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of the closed container of traffic paint that requires a waste determination.
[Title]
IMG_0039.jpg
09/29/2022 11:48 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of the waste white traffic paint that had been allowed to dry out inside a 5-gallon container.
41 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0042.jpg
09/29/2022 11:50 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of waste yellow traffic paint that had been allowed to dry out in the container.
[Title]
IMG_0043.jpg
09/29/2022 11:50 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of a 5-gallon container of traffic paint that requires a waste determination.
42 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0045.jpg
09/29/2022 11:51 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
Another view of the waste aerosol can in the pit area beneath the traffic paint totes.
[Title]
IMG_0049.jpg
09/29/2022 11:53 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
Another view of the three 5-gallon containers of traffic paint. Two of the containers contain waste yellow traffic paint that had been allowed to dry out in the container.
43 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0047.jpg
09/29/2022 11:51 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
Another view of one of the waste aerosol cans in the pit beneath the traffic paint totes.
[Title]
IMG_0051.jpg
09/29/2022 11:55 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of additional 5-gallon container of waste yellow traffic paint that had been allowed to dry out in the container.
44 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0053.jpg
09/29/2022 11:55 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of another 5-gallon container of waste yellow traffic paint that had been allowed to dry out in the container.
[Title]
IMG_0050.jpg
09/29/2022 11:54 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of additional 5-gallon containers that hold waste paint related material and require a waste determination.
45 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title] 09/29/2022 11:59 AM Building P/Traffic Striping Paint Area View of traffic paint totes.
IMG_0054.jpg
Photographer: Jon jones
No CBI
No PII
[Title] 09/29/2022 11:59 AM Building P/Traffic Striping Paint Area View of additional traffic paint totes.
IMG_0055.jpg
Photographer: Jon Jones
No CBI
No PII
46 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title] 09/29/2022 11:59 AM Building P/Traffic Striping Paint Area Another view of the traffic paint totes.
IMG_0056.jpg
Photographer: Jon Jones
No CBI
No PII
[Title]
IMG_0057.jpg
09/29/2022 11:59 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of a spill of some yellow traffic paint that had not been cleaned up and had instead been allowed to dry out on the asphalt where it had leaked.
47 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0058.jpg
09/29/2022 11:59 AM
Photographer: Jon Jones
Building P/Traffic Striping Paint Area
No CBI
No PII
View of some additional aerosol cans that appeared to be waste-like and required a waste determination.
[Title]
IMG_0084.jpg
09/29/2022 12:43 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View inside of a container of universal waste mercury switches.
48 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0074.jpg
09/29/2022 12:34 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the contents of an open container of waste epoxy.
[Title]
IMG_0085.jpg
09/29/2022 12:43 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the label on a container of universal waste mercury switches.
49 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0091.jpg
09/29/2022 01:00 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the label on a container of waste aerosol cans, showing that the container has been in accumulation for more than 90 days.
[Title] 09/29/2022 12:29 PM Hazardous Waste Shed (CAA) View inside of a tote of universal waste lamps.
IMG_0069.jpg
Photographer: Jon Jones
No CBI
No PII
50 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0064.jpg
09/29/2022 12:25 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of a trash receptacle that is being used as a SAA container for the accumulation of waste aerosol cans.
[Title]
IMG_0063.jpg
09/29/2022 12:25 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Another view of the SAA container of waste aerosol cans seen in IMG_0064.jpg.
51 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0068.jpg
09/29/2022 12:29 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the label on the universal waste lamps tote, showing that it is improperly labeled as universal waste - bulbs.
[Title]
IMG_0065.jpg
09/29/2022 12:26 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the waste aerosol cans inside the waste aerosol SAA container.
52 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0066.jpg
09/29/2022 12:26 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Close-up view of the waste aerosol cans inside the waste aerosol SAA container.
[Title]
IMG_0073.jpg
09/29/2022 12:34 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the contents of the other open container of waste epoxy.
53 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0067.jpg
09/29/2022 12:28 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the labeling on the waste aerosol SAA container.
[Title]
IMG_0070.jpg
09/29/2022 12:30 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of a 5-gallon container of universal waste batteries, on top of the universal waste lamps tote, that is mislabeled as universal waste button batts.
54 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title] 09/29/2022 12:34 PM Hazardous Waste Shed (CAA) View of the two open containers of waste epoxy.
IMG_0072.jpg
Photographer: Jon Jones
No CBI
No PII
[Title]
IMG_0071.jpg
09/29/2022 12:34 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Another view of the open containers of waste epoxy. Only one of the containers is labeled with the words "Hazardous Waste", and marked with an ASD.
55 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0077.jpg
09/29/2022 12:36 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the open container of waste flares seen in the CAA.
[Title]
IMG_0078.jpg
09/29/2022 12:36 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the waste flares seen inside of the open container in the CAA.
56 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0075.jpg
09/29/2022 12:34 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Another view of the two open containers of waste epoxy in the CAA.
[Title]
IMG_0080.jpg
09/29/2022 12:41 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the label on a container of mixed auto fluids that is also marked as "Pending Analysis." The date on the container indicates that the waste has been in accumulation for greater than 90 days.
57 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0079.jpg
09/29/2022 12:41 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the container holding waste auto fluids that has been in accumulation at the CAA for greater than 90 days.
[Title]
IMG_0076.jpg
09/29/2022 12:36 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of an open container of waste Chlor-d-tect kits.
58 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0082.jpg
09/29/2022 12:43 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the waste Chlor-d-tect kits inside the open container.
[Title]
IMG_0081.jpg
09/29/2022 12:42 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Close-up view of the label on the container of waste chlor-d-tect kits.
59 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0083.jpg
09/29/2022 12:43 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Another view of the container of universal waste mercury switches.
[Title]
IMG_0087.jpg
09/29/2022 12:50 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of two containers of orphaned waste in the CAA, each with an open bung hole.
60 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0086.jpg
09/29/2022 12:50 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the orphaned waste containers inside the CAA.
[Title]
IMG_0090.jpg
09/29/2022 01:00 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the waste aerosol accumulation container inside the CAA that was not closed and had been in accumulation for greater than 90 days.
61 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0089.jpg
09/29/2022 12:51 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Another view of the orphaned waste containers in the CAA.
[Title]
IMG_0088.jpg
09/29/2022 12:50 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
View of the only orphaned waste container upon which a label with the words "Hazardous Waste" and an ASD had been placed.
62 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
[Title]
IMG_0092.jpg
09/29/2022 01:00 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Close-up view of the lid on the waste aerosol can accumulation container that is greater than 90 days old. This view shows that the container is not closed.
[Title]
IMG_0093.jpg
09/29/2022 01:05 PM
Photographer: Jon Jones
Hazardous Waste Shed (CAA)
No CBI
No PII
Close-up view of the marking on the waste aerosol SAA container. The markings seen here indicate that the container has a capacity of 96 gallons.
63 of 64
King County DOT Department of Local Services - Road Services Division Inspection Date(s): 09/29/2022
APPENDIX 2: DOCUMENT LOG
Document Type
Document Name
Contains Contains Uploaded By
CBI
PII
Records Review
Mans-unsigned by Desfac.pdf
No
No
Jon Jones
Records Review
WklyHWchecklists.pdf
No
No
Jon Jones
Records Review
JANUAR~1.PDF
No
No
Jon Jones
Records Review
FEBRUA~1.PDF
No
No
Jon Jones
Records Review
MARCH2~1.PDF
No
No
Jon Jones
Records Review
APRIL2~1.PDF
No
No
Jon Jones
Records Review
June
No
No
Jon Jones
2022_Renton_final.pdf
Records Review
July 2022_Renton_final.pdf No
No
Jon Jones
Records Review
AUGUST~1.PDF
No
No
Jon Jones
Records Review
SEPTEM~1.PDF
No
No
Jon Jones
Other - Safety Data Sheet
Traffic white paint 2020_current.pdf
No
No
Jon Jones
Other - Safety Data Sheet
TRAFFI~2.PDF
No
No
Jon Jones
Records Review
017187952FLE.pdf
No
No
Jon Jones
Records Review
017187953FLE.pdf
No
No
Jon Jones
Communications
Documents email 10-5- No
No
Jon Jones
22.pdf
Facility Map
Renton Site Plan_Figure No
No
Jon Jones
1..pdf
Communications
emailNarrative10.5.22.docx No
No
Jon Jones
Other - Photo of aerosol AEROSO~1.JPG accumulation drum
No
No
Jon Jones
Other - Photo of lid and AEROSO~2.JPG ring attached to drum
No
No
Jon Jones
Other - Photo of flare, chlordtect, and merc switch lids on
FLAREA~1.JPG
No
No
Jon Jones
Other - Photo of used oil OILCON~1.JPG container labeled as HW
No
No
Jon Jones
Other - Photo of relabeled UW tote
UNIVER~1.JPG
No
No
Jon Jones
Other - Photo of container with a newer haz ind. applied
PU9FLA~1.JPG
No
No
Jon Jones
Date Received
11/23/2022
11/23/2022 11/23/2022 11/23/2022 11/23/2022 11/23/2022 11/23/2022
11/23/2022 11/23/2022 11/23/2022 11/23/2022
11/23/2022
11/23/2022 11/23/2022 11/23/2022
11/23/2022
11/23/2022 11/23/2022
11/23/2022
11/23/2022
11/23/2022
11/23/2022
11/23/2022
64 of 64