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Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA Alaska Enforcement Division INSPECTION REPORT 07/08/2024 08:37 AM (AKT) Announced: No 07/08/2024 11:00 AM (AKT) Access: Granted Resource Conservation and Recovery Act (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 Sherwin-Williams Sherwin-Williams #708176 AKD983069709 245 Post Rd Anchorage, AK 99501-2802 N/A Very Small Quantity Generator (VSQG) 444120 Sale of paints, epoxies and solvents 61.219845, -149.858958 245 Post Rd Anchorage, Alaska, 00501 Permit Number (If Applicable) N/A Lead Inspector: Xiangyu Chu EPA Region 10 Supervisor Review: Matt Quarterman EPA Region 10 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) EPA Inspectors Xiangyu Chu and Jon Jones, and Alaska Department of Environmental Conservation (ADEC) Inspectors, Emily VanNortwick, and Grace Tapulgo arrived at the Sherwin-Williams #708176 Facility (the "Site" or "Facility"), located at 245 Post Rd, Anchorage, AK 99501-2802, at 08:37 AM (AKT) on 07/08/2024 for an 1 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 unannounced inspection. EPA Lead Inspector presented credentials to and informed store manager, Jaylee Trujillo that this was an EPA Region 10 inspection to determine compliance with RCRA. This report is based on information supplied by Sherwin-Williams #708176 Facility representatives, observations made by the EPA inspectors, and records and reports maintained by the facility and its Headquarters including, but not limited to: direct observations made by the EPA Inspectors , photographs taken by EPA inspectors, physical evidence collected by the EPA inspectors, measurements or samples taken by EPA inspectors, 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 inspectors by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector//EPA Region 10 Inspector/EPA Region 10 ADEC Inspector ADEC Inspector Sherwin Williams - Branch Manager Opening Conference Name Phone Xiangyu Chu (206) 5532859 Jon Jones (907) 2274316 Emily (907) 854- VanNortwick 5629 Grace Tapulgo (907) 2697578 JayLee Trujillo 907-2725550 Email Chu.xiangyu@epa.gov Opening Conf. Yes Jones.jon@epa.gov Yes emily.vannortwick@alaska.gov Yes grace.tapulgo@alaska.gov Yes Sw708176@sherwin.com Yes Closing Conf. Yes Yes Yes Yes Yes EPA Region 10 inspectors, Xiangyu Chu, Jon Jones and two ADEC inspectors, Emily VanNortwick and Grace Tapulgo, arrived at Sherwin Williams at 9:07am and met with the store manager, Ms. Trujillo, for the opening conference in the manager's office. Inspectors Chu presented her credentials and informed Ms. Trujillo that this was an EPA Region 10 inspection to determine compliance with RCRA. EPA inspectors then explained that the focus of this inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and a review of relevant documents, which would include three years of weekly inspections, manifests, and any employee hazardous waste training provided by Sherwin Williams. Ms. Trujillo and the inspectors on site opted to perform the walk-through portion of the inspection first and review relevant documents afterwards. Ms. Trujillo informed us that this location had never been inspected in the past, and that they did not count their hazardous waste, rather they disposed of it when they had time to. Sherwin Willams has one main hazardous waste accumulation area called the Hot Room. This area contains the Satellite Accumulation Area (SAA) and other pallets of expired material that are not yet identified as a waste. Ms. Trujillo explained that they do not count their hazardous waste each month, and only ship out waste as needed through Clean Earth. She does an inventory on expired items every few months but has no set schedule for it and has not inventoried the current expired items for a "long time". Once identified, expired products are then stored for several months longer as they await donation or discounted purchase. 2 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 Facility/Site Information Safety Training N/A Provided to Inspector(s)? Operating Hours 7AM to 5PM on weekdays and 8AM to 12PM weekends Length of Facility at Location 29 years Number of employees Seven at this location Size of Facility 13,000 square feet What type of SQG generator facility notified? What type of generator facility verified as? VSQG Weather Conditions Cloudy, average temperature 58 degrees Fahrenheit Process Description Sherwin Williams is a coatings manufacturer and distributor. The location we inspected is a sales and distribution facility for primarily architectural coatings. This location stocks and sells paints, acrylic coatings, and varnishes. The waste streams produced primarily consist of spilled paint cleanup rags, wastewater, and universal wastes including aerosol cans and lamps. The location also has a collection of expired products that will be donated or sold at a discounted price. At the time of the inspection, Ms. Trujillo told me that the facility doesn't count or keep records of the amount of waste generated on site. But she does not think they generate more than 220 pounds (100 kg) of hazardous waste per month. Based on our observations of waste generation and the amount of waste on site during the inspection, the facility appeared to be a very small quantity generator that was generating less than 220 pounds of hazardous waste during the month of the inspection. During the inspection we examined the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representative had not yet identified or designated as hazardous. We also observed the facility's universal waste management. Specifically, we inspected the areas of the facility listed below. Building(s) Building/Area/Sub-area Carpet Room Carpet area Hot Room Product shelf SAA Outside Process Description Waste water collection site Wastewater drum mixed with latex Hazardous Waste Storage Expired Acrolon coating Paint cleanup rags, aerosol cans, propane containers, lamps Expired Pallet Area of Concern No No Yes No Yes No 3 of 12 Sherwin-Williams #708176 Inspection Date(s): SECTION II - OBSERVATIONS 07/08/2024 - 07/08/2024 Building: Hot Room/SAA Observation #: EV3-OB-001 Date: 07/08/2024 Person Interviewed: JayLee Trujillo Contains AOC: Yes Title: Manager Contains CBI: No At the time of inspection, we observed two SAA accumulation drums: one 35-gallon drum had a "Hazardous Waste" label and an aerosol can inside but was not marked or labeled with an indication of the hazards of the contents. The second 55-gallon drum contains cleanup materials such as spilled paint and epoxy rags. Ms. Trujillo told us that this is a SAA hazardous waste container and is managed as such. This drum was not labeled with the words "Hazardous Waste" and an indication of the hazards of the content. A small propane tank was found on the floor next to the SAA, Ms. Trujillo placed it into the hazardous waste drum after we photographed and documented it. We also observed a closed cardboard cylindrical drum that contained two universal waste lamps. This drum was not labeled or marked with the words "Universal Waste Lamps" or "Used Lamps" and was not marked with an accumulation start date. This drum was labeled with the words "Universal Waste." Photo(s) IMG_2186.jpg Building: Hot Room/Product Shelf Observation #: EV3-OB-002 Date: 07/08/2024 Person Interviewed: JayLee Trujillo Contains AOC: No Title: Manager Contains CBI: No At the time of the inspection, we observed one shelf next to the SAA that contained new and full Acrolon gallon containers that were expired. We asked if Ms. Trujillo had a written inventory of these products indicating awareness and a plan for the expired items, and she did not. We found five that were confirmed expired. Ms. Trujillo told us that these expired products were not determined to be a waste because they can still be sold or donated via the Sherwin Williams program called "Ready To Go." Expired products are placed on a separate pallet when the manager has time, but there is no set review schedule to do this. Ms. Trujillo told me that the last inventory review was on October 22, 2023. We advised her to move forward in selling or donated this material to avoid it becoming a waste. Building: Carpet Room/Carpet area Observation #: EV3-OB-003 Date: 07/08/2024 Person Interviewed: JayLee Trujillo Contains AOC: Yes Title: Manager Contains CBI: No At the time of the inspection, we observed two drums containing wastewater from pump maintenance and Latex cleaning. The drums were not labeled with "Hazardous Waste" or a hazardous waste indicator. Ms. Trujillo told me that the water is sent out as hazardous waste by Clean Harbors. 4 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 SECTION III - RECORDS REVIEW Record: Manifests Ref #: EV3-RR-001 Reviewed By: Xiangyu Chu AOC: No Reviewed Date: 07/08/2024 At the time of the inspection, we examined the last three years of manifests, and found that all the manifests were signed and returned within 60 days. Record: Inspections Ref #: EV3-RR-002 Reviewed By: Xiangyu Chu AOC: Yes Reviewed Date: 07/08/2024 No weekly hazardous waste inspections of the Satellite Accumulation Area have been conducted at this Sherwin Williams location. Ms. Trujillo stated that the waste drums, when full, remain on site for "under a month" before they are sent out as waste on an as-needed basis. Ms. Trujillo was then informed by EPA inspectors on how and when to conduct hazardous waste inspections since they had not been conducted before. Record: Training Ref #: EV3-RR-003 Reviewed By: Xiangyu Chu AOC: No Reviewed Date: 07/08/2024 Sherwin Williams provides hazardous waste training, records indicate that all employees on site have received initial training within the last 5 years, with renewals coming up at the end of the year. Record: Preparedness and Prevention Ref #: EV3-RR-004 Reviewed By: Xiangyu Chu AOC: No Reviewed Date: 07/08/2024 Ms. Trujillo has an evacuation plan in the Manager's office, and it has been inspected by the fire department within the last year. Fire extinguishers get inspected yearly along with fire alarms. Record: Land Disposal Restrictions (LDR) Notices/Documents Ref #: EV3-RR-005 Reviewed By: Xiangyu Chu AOC: No Reviewed Date: 07/08/2024 SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. EV3-OB-001 Two hazardous waste accumulation drums improperly labeled. One had only a "Hazardous Waste" label, but no hazardous waste indicator or accumulation start date. One had no labeling at all. Citations: Sections: 5 of 12 Sherwin-Williams #708176 Inspection Date(s): A third cylindrical cardboard box contained lamps. It was labeled with "Universal Waste" but did not include "Lamps" in the label, or have an accumulation start date. Building: Hot Room EV3-OB-002 Area: SAA A Butane tank was sitting on the floor adjacent to the SAA, and this was an AOC. Ms. Trujillo put it in a sealed hazardous waste drum after this was pointed out. (Correction: the small tank was a propane tank). Citations: Building: Carpet Room EV3-OB-003 Area: Carpet area A drum was found that contained Citations: wastewater used for cleaning tools and pumps and may be mixed with latex. According to Ms. Trujillo, the water is sent out as hazardous waste when the drum fills up but is not counted appropriately. Building: N/A Area: Inspections 07/08/2024 - 07/08/2024 Sub-area: Sections: Sub-area: Sections: Sub-area: N/A SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference During the closing conference EPA inspectors reiterated that we would need to see training documents for the staff, and Ms. Trujillo made a note to send these records to Chu Xiangyu at a later date. Inspector Chu summarized the need for proper labeling of containers, as well as the use of checklists as tools for tracking and counting hazardous waste generation. Inspector Jones stated that he would send Ms. Trujillo some resources to help with this via email. Inspector Chu then covered the AOCs from the inspection. Additionally, she advised Ms. Trujillo to pursue donating or selling the expired materials that were found to avoid them becoming a hazardous waste. Inspector Chu also discussed the requirement for Ms. Trujillo to begin counting their hazardous waste so that they can notify correctly and have proper records for how much hazardous waste they are generating. 6 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 Finally, Inspector Chu informed Ms. Trujillo that she would send the report when it is complete. Inspector Jones asked if there were any questions and Ms. Trujillo had none. Follow Up Training records were sent via email to EPA on 7/9/2024. Communication Log No additional information was received. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 7 of 12 Sherwin-Williams #708176 Inspection Date(s): APPENDIX 1: PHOTO LOG 07/08/2024 - 07/08/2024 SAA 07/08/2024 08:58 AM Hot Room/SAA A photo of the SAA. No CBI No PII IMG_2186.jpg Photographer: Jon Jones 61.21983611, -149.85865833 Hazardous Waste Drum IMG-2024070808592059201125611.jpg 07/08/2024 08:59 AM (AKT) No CBI No PII Photographer: Grace Tapulgo Hot Room/SAA [Geographic Coordinates] This 55gal drum was not full, and it was missing a "hazardous waste" label and hazard indicator. The drum was closed. 8 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 55 Gallon drum 07/08/2024 08:59 AM (AKT) No CBI No PII Hot Room/SAA Closer photo of the label on the 55-gallon drum. IMG-2024070808595259521236339.jpg Photographer: Emily VanNortwick [Geographic Coordinates] 55 Gallon hazardous Waste drum IMG-20240708090009091196538.jpg 07/08/2024 09:00 AM (AKT) No CBI No PII Photographer: Emily VanNortwick Hot Room/SAA [Geographic Coordinates] This drum was not full and did not have a hazard indicator or accumulation start date. 9 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 Cardboard universal waste box IMG-202407080900550551082801.jpg 07/08/2024 09:00 AM (AKT) No CBI No PII Photographer: Emily VanNortwick Hot Room/SAA [Geographic Coordinates] This photo shows the interior to the cylindrical cardboard box containing lamps within the SAA. Cardboard universal waste box IMG-20240708090104141174780.jpg 07/08/2024 09:01 AM (AKT) No CBI No PII Photographer: Emily VanNortwick Hot Room/SAA [Geographic Coordinates] This photo shows the "universal waste" label on the cardboard box, but it lacks a "lamp" label and accumulation start date. 10 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 Propane tank on the floor IMG_2189.jpg 07/08/2024 09:01 AM No CBI No PII Photographer: Jon Jones Hot Room/SAA 61.21987777, -149.85858055 Propane tank as it was found before being placed in the drum. Expired Acrolon IMG_2191.jpg 07/08/2024 09:05 AM No CBI No PII Photographer: Jon Jones Hot Room/SAA 61.21982222, -149.85887222 This is a photo of one of the expired Acrolon containers. It is unopened and unused. 11 of 12 Sherwin-Williams #708176 Inspection Date(s): 07/08/2024 - 07/08/2024 Expired Acrolon Date 07/08/2024 09:07 AM (AKT) No CBI No PII Hot Room/SAA The expiration date on a container of Acrolon IMG-20240708090704741348324.jpg Photographer: Emily VanNortwick [Geographic Coordinates] Expired Paint 07/08/2024 09:25 AM No CBI Hot Room/SAA Expired cans of paint on the shelf. No PII IMG_2197.jpg Photographer: Jon Jones 61.21959722, -149.85885555 12 of 12