Document oM9m9L1G7eL6X6Zgo4drJ5m7D

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA Region 10 Enforcement Division INSPECTION REPORT 01/05/2023 09:45 AM (AKT) Announced: No 01/05/2023 01:49 PM (AKT) 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 Type of Operation Geographic Coordinates Mailing Address/Secondary Address City, State, Zip Code The Alaska Native Tribal Health Consortium (ANTHC) Alaska Native Medical Center AKR000209999 4315 Diplomacy Dr. Anchorage, AK 99508 Anchorage Very Small Quantity Generator (VSQG) 62211 - General Medical and Surgical Hospitals Hospital 61.182875, -149.800531 Valerie Herrera, REHS, MPH vsherrera@anthc.org Alaska Native Tribal Health Consortium (ANTHC) Alaska Native Medical Center (ANMC) VP of Support Services 4315 Diplomacy Dr. Anchorage, AK 99508 (907) 729-7526 Anchorage, AK 99508 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones JONATHAN JONES EPA Region 10 Digitally signed by JONATHAN JONES Date: 2023.03.01 07:58:48 -09'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan EPA Region 10 Digitally signed by Jennifer A Sullivan Date: 2023.03.02 08:21:30 -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 The inspection at the Alaska Native Medical Center Facility was a multi-media inspection to determine compliance with Clean Air Act (CAA) and Resource Conservation and Recovery Act (RCRA). This report covers 1 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 the RCRA portion of the inspection. A separate report will document the CAA portion of the inspection. This report is based on information supplied by Alaska Native Medical Center Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility and its HQ including, 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 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 subsequent to 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 Jon Jones Region 10 (907) 2716329 CAA Inspector/EPA John Pavitt (907) 2713688 CAA Inspector/ADEC Rachel McKenna (907) 2697698 Vice President of Support Services/ANMC Valerie Herrera (907) 5194839 Senior Safety Technician/ANMC Javier Meraz Accredited Campus Erin Keith Safety Officer/ANMC Institutional Environmental Health Manager/ANMC Keith Cook Vice President of Professional Services/ANMC Vivian Echavarria Pharmacy Quality Improvement Manager/ANMC Sara DoranAtchison Interim Hospital Alan Vierling Administrator/ANMC Email Jones.Jon@epa.gov Opening Conf. Closing Conf. Yes Yes pavitt.john@epa.gov Yes No rachel.mckenna@alaska.gov Yes No vsherrera@anthc.org Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No Yes Opening Conference EPA Region 10 Lead Inspector, Jon Jones, arrived at the Alaska Native Medical Center Facility (the "Site" or "Facility"), located at 4315 Diplomacy Dr., Anchorage, AK 99508, at 09:45 AM (AKT) on 01/05/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Valerie Herrera that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 2 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 Facility/Site Information The Alaska Native Medical Center (ANMC) is a non-profit health center and Level II Trauma Center based in Anchorage, Alaska, United States, which provides medical services to 158,000 Alaska Natives and other Native Americans in Alaska. It acts as both the secondary and tertiary care referral hospital for the Alaska Region of the Indian Health Service (IHS). Established in 1997, ANMC is jointly owned and managed by the Alaska Native Tribal Health Consortium and Southcentral Foundation as well as tribal governments, and their regional health organizations. Number of employees ~1,200 Length of Facility at Location May 1997 Operating Hours 8:00 am to 5:00 pm Safety Training No Provided to Inspector(s)? Size of Facility The hospital is a 380,635 sq ft, 167-bed facility What type of generator facility notified? Non-Notifier What type of generator facility verified as? Verified Very Small Quantity Generator by facility personnel and supported by monthly waste generation records. Weather Conditions Cloudy and cold Process Description During the opening conference, facility representatives, present during the opening conference, provided the following information: ANMC is a VSQG of hazardous waste. ANMC manages their hazardous waste pharmaceuticals as RCRA hazardous waste as opposed to managing this waste stream under Subpart P as HWPharms. The facility's combined hazardous waste pharmaceuticals and RCRA hazardous waste generation rate is less than 220 pounds each month. Medical waste, trace chemo waste, and non-hazardous pharmaceuticals are managed through Safety Waste Incineration, Inc. where it is either incinerated or processed through an autoclave. Waste batteries and waste lamps (bulbs) are managed as universal waste through Total Reclaim. Waste lamps ( Four and eight-foot fluorescent light tubes) generated at the facility are low mercury lamps and are managed in an onsite "Bulb Eater" (Drum top lamp crusher). The crushed lamps are disposed of at the local landfill and the associated filter is managed as hazardous waste. Building(s) Building/Area/Sub-area ANMC Main Building Boom Room Process Description Hazardous waste and universal waste battery accumulation area. 3 of 12 Area of Concern Yes Yes Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 Inpatient Pharmacy Loading Dock Third floor mechanical -Hazardous waste accumulation area (waste No pharmaceuticals) -Potentially creditable pharmaceutical accumulation area (reverse distributor) Biological waste accumulation area and Autoclave. No The following waste streams are managed through Safety Waste Incineration, Inc. -Red bag/container (medical waste) -Yellow bag/container (trace chemo) -White bag/container (non-hazardous pharmaceuticals) -Accumulation area for universal waste lamps No -Lamp crusher/bulb eater for non-hazardous/low mercury fluorescent lamps/tubes SECTION II - OBSERVATIONS Building: ANMC Main Building/Boom Room Observation #: JJ1-OB-001 Date: 01/05/2023 Person Interviewed: Javier Meraz Contains AOC: Yes Contains CBI: No Title: Senior Safety Technician While inspecting the facility's waste inside the Boom Room, I saw an area where waste batteries were being accumulated. Upon closer inspection of these waste batteries, I saw that there were a total of nine waste batteries. There were four waste Lithium-ion, one waste Ni-MH, and 4 waste lead-acid batteries that were being accumulated on the top of a shelf, inside the Boom Room. I asked Mr. Meraz how his facility managed waste batteries and how long the waste batteries had been onsite, and he told me they were managed as universal waste batteries and that they had been on-site for about a week. At the time of the inspection, there were nine waste batteries in the Boom Room that were not labeled with the words "Universal Waste Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." Photo(s) 1. IMG_0414.jpg 2. IMG_0415.jpg 3. IMG_0416.jpg 4. IMG_0417.jpg 5. IMG_0418.jpg 6. IMG_0419.jpg 7. IMG_0420.jpg 8. IMG_0421.jpg 9. IMG_0422.jpg 4 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 SECTION III - RECORDS REVIEW Record: Others Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: No Reviewed Date: 01/05/2023 The records listed in the Appendix 2: Document Log were obtained and reviewed following the inspection. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: ANMC Main Building JJ1-OB-001 Area: Boom Room Sub-area: At the time of the inspection, there were nine waste batteries in the Boom Room that were not labeled with the words "Universal Waste Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." 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 5 of 12 Alaska Native Medical Center Inspection Date(s): APPENDIX 1: PHOTO LOG 01/05/2023 - 01/05/2023 [Title] IMG_0414.jpg 01/05/2023 11:52 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80056666 View of waste batteries that were not labeled with the words "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." [Title] IMG_0415.jpg 01/05/2023 11:52 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80058333 Close-up view of a waste battery that was not labeled with the words "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." 6 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 [Title] IMG_0416.jpg 01/05/2023 11:52 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80058333 Close-up view of a waste battery that is not labeled with the words "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." [Title] IMG_0417.jpg 01/05/2023 11:52 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80058333 Close-up view of a waste battery that is not labeled with the words "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." 7 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 [Title] IMG_0418.jpg 01/05/2023 11:53 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18336388, -149.80049166 Close-up view of a waste battery that is not labeled with the words "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." [Title] IMG_0419.jpg 01/05/2023 11:53 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80058333 Close-up view of a waste battery that is not labeled with the words "Universal Waste - Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)." 8 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 [Title] IMG_0420.jpg 01/05/2023 11:56 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18335833, -149.80053611 View of the facility signage posted on the wall above the waste batteries. [Title] IMG_0421.jpg 01/05/2023 11:56 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80056666 View of the facility signage posted on the wall above the waste batteries. 9 of 12 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 [Title] IMG_0422.jpg 01/05/2023 11:57 AM No CBI No PII Photographer: Jon Jones ANMC Main Building/Boom Room 61.18334444, -149.80056666 View of the facility signage posted on the wall above the waste batteries. 10 of 12 Alaska Native Medical Center Inspection Date(s): APPENDIX 2: DOCUMENT LOG 01/05/2023 - 01/05/2023 Document Type Document Name Contains Contains Uploaded By CBI PII Facility Map Alaska-Native-Health- No No Campus-map- 02.26.2020.pdf Other - Opening/closing Attendance List EPA No No conference attendees list Site Visit to ANMC Hospital on 05 January 2023.pdf Other - Boom Room Boom Room 2020 No No Inventory Inventory Logs combined.pdf Other - Boom Room Boom Room 2021 No No Inventory Inventory Logs combined.pdf Other - Boom Room Boom Room 2022 No No Inventory Inventory Logs combined.pdf Other - Chem HazMat Inventory CHEMIC~1.PDF No No Other - Chem HazMat Inventory CHEMIC~2.PDF No No Other - Chem HazMat Inventory CHEMIC~3.PDF No No Process Description/Flow Pharmacy ONLY Waste No No Diagram Stream Diagram 2022.pdf Communications Re_ ANMC EPA site visit No No 05 Jan 2023.pdf Other - Pharmacy Reverse Pharmacy 2023.01.05 No No Distributor Report 2022 YTD Inmar Report SD.xlsx Other - Pharmacy waste Pharmacy Expired Box No No inventory Inventory 1-5-23.pdf Other - RCRA RCRA20~1.PDF pharmaceutical inventory No No Other - RCRA RCRA20~2.PDF pharmaceutical inventory No No Other - RCRA RCRA20~3.PDF pharmaceutical inventory No No Universal Waste Disposal Universal Waste 12 No No Receipts December Pick-Up 11 of 12 Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Jon Jones Date Received 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 Alaska Native Medical Center Inspection Date(s): 01/05/2023 - 01/05/2023 Invoice _670.pdf Universal Waste Disposal Universal Waste No No Jon Jones Receipts 12.1.22 Total Reclaim. Bill of Lading pick up #39491.pdf Facility Map ANMC-Clinic-Map-Dec- No No Jon Jones 2017.pdf Other - Pharmaceutical RCRA Pharmaceutical No No Jon Jones contract with Stericycle CONTRACT Stericycle_RCRA Pharmaceuticals.pdf Other - Pharmaceutical contract modification RCRAPH~1.PDF No No Jon Jones Communications 1.6.23 email from No No Jon Jones ANMC.pdf Process Description/Flow Waste Stream Diagram No No Jon Jones Diagram 2019.pdf 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 02/28/2023 12 of 12