Document rn1LjyxjQdaeNoVrz0356vbr

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 08/08/2023 08:40 AM (AKT) Announced: No 08/08/2023 09:33 AM (AKT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Mailing Address/Secondary Address City, State, Zip Code Alpine Surgicenter, LLC Alpine Surgery Center AKR000209585 3801 Lake Otis Parkway Anchorage, AK 99508 Anchorage Borough Very Small Quantity Generator (VSQG) 621493 Freestanding Ambulatory Surgical and Emergency Centers 61.185814, -149.837201 Ms. Danna Grant, BSN, RN, CASC, CAIP Administrator 3801 Lake Otis Parkway Anchorage, AK 99508 danna.grant@hcahealthcare.com Anchorage, AK 99508 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones JONATHAN JONES EPA Region 10 Digitally signed by JONATHAN JONES Date: 2023.08.15 15:04:29 -08'00' Jones.Jon@epa.gov (907) 227-4316 Supervisor Review: Matt Quarterman MATTHEW QUARTERMAN Date: 2023.08.16 10:31:44 -07'00' Digitally signed by MATTHEW QUARTERMAN EPA Region 10 Quarterman.matthew@epa.gov (206) 553-2146 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) EPA Region 10 Lead Inspector, Jon Jones, arrived at the Alpine Surgery Center (ASC) Facility (the "Site" or "Facility"), located at 3801 Lake Otis Parkway, Anchorage, AK 99508, at 08:40 AM (AKT) on 08/08/2023 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Ms. Danna Grant, Administrator, that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 1 of 7 Alpine Surgicenter, LLC Dba Alpine Surgery Center Inspection Date(s): 08/08/2023 - 08/08/2023 The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273). The inspection was conducted as part of a Core Program requirement for FY 2023. This report is based on information supplied by ASC 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 REGION 10 ASC Administrator RCRA Inspector-intraining/ADEC RCRA Inspector-intraining/ADEC Jon Jones Danna Grant Grace Tapulgo Emily Vannortwick (907) 2274316 (907) 5631555 Email Jones.Jon@epa.gov Opening Conf. Yes danna.grant@hcahealthcare.com Yes Yes Yes Closing Conf. Yes Yes Yes Yes Opening Conference Shortly after arriving at ASC, we were met by Ms. Danna Grant, ASC Administrator and taken to a facility conference room where I held the opening conference. During the opening conference, I explained that the focus of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. Ms. Grant told us that in 2019 ASC was bought by HCA Health Care. I asked about the facility's notification as a LQG and Ms. Grant said that she initially counted the red bag medical waste as hazardous. Ms. Grant said that the amount of hazardous waste/HWPharms generated was well below 220 pounds in any calendar month. I inspected the hazardous waste/HWPharms that has been accumulated onsite since last fall and based on the quantity accumulated, the facility is a very small generator (VSQG) with greater than 220 pounds in accumulation. The facility notified under Subpart P however, at the time of the inspection the facility was not managing their waste as HWPharms. Based on the amount of HWPharms generated per month (VSQG) the facility is not required to manage their hazardous waste pharmaceuticals under Subpart P. Only those areas in which we observed potential compliance concerns or noted other pertinent issues are discussed in Section III of this inspection report. Facility/Site Information Operating Hours 5:00 a.m. to 5:00 p.m., Monday through Friday Length of Facility at Since March 2015 2 of 7 Alpine Surgicenter, LLC Dba Alpine Surgery Center Inspection Date(s): 08/08/2023 - 08/08/2023 Location Number of employees 80 Safety Training No Provided to Inspector(s)? Size of Facility ~18,779 Square feet What type of generator facility notified? Large Quantity Generator (LQG) What type of generator facility verified as? Verified as VSQG by Ms. Grant Weather Conditions Rainy Process Description According to Ms. Grant, a pharmacist comes once a quarter to manage the pharmaceutical inventory. Expired vials of crash cart medications and routine pharmaceutical waste is accumulated in a black, 18-gallon capacity hazardous waste container located in Pre/Post Op. Red bag medical waste is picked up every day and disposed of locally through Entech. The facility is in the process, which started last fall, of setting up service with Stericycle to manage the facility's hazardous waste/hazardous waste pharmaceuticals (HWPharms). I reviewed Stericycle's Master Service Agreement that HCA has for their surgery centers in Alaska and the "Services to be Provided" were marked as hazardous waste disposal and not pharmaceutical waste disposal. We were accompanied during the inspection by Ms. Grant. We looked at the facility's processes, hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. Building(s) Building/Area/Sub-area Main Bldg Biohazard room Pre/Post Op Process Description Accumulation of red bag medical waste and hazardous waste/HWPharms Generation of hazardous waste/HWPharms Area of Concern No No No SECTION II - OBSERVATIONS We inspected the areas listed above and everything observed was found to be consistent with that of a VSQG. SECTION III - RECORDS REVIEW The facility was determined to be a VSQG and there were no records to be reviewed. SECTION IV - AREA OF CONCERN No areas of concern were observed during the inspection of the facility. 3 of 7 Alpine Surgicenter, LLC Dba Alpine Surgery Center Inspection Date(s): 08/08/2023 - 08/08/2023 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 Ms. Grant for her time and cooperation during the inspection. I told Ms. Grant that I observed no areas of concern 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. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 4 of 7 Alpine Surgicenter, LLC Dba Alpine Surgery Center Inspection Date(s): APPENDIX 1: PHOTO LOG 08/08/2023 - 08/08/2023 [Title] IMG-2023080808572157212385378.jpg 08/08/2023 08:57 AM (AKT) No CBI No PII Photographer: Jon Jones Main Bldg/Pre/Post Op 61.18561367, -149.83772096 View of 18-gallon container of hazardous waste/HWPharms. [Title] IMG-202308080911081181639292.jpg 08/08/2023 09:11 AM (AKT) No CBI No PII Photographer: Jon Jones Main Bldg/Biohazard room 61.18589684, -149.83744557 View of black containers of hazardous waste/HWPharms. 5 of 7 Alpine Surgicenter, LLC Dba Alpine Surgery Center Inspection Date(s): 08/08/2023 - 08/08/2023 [Title] IMG-2023080809111811181603566.jpg 08/08/2023 09:11 AM (AKT) No CBI No PII Photographer: Jon Jones Main Bldg/Biohazard room 61.18595345, -149.83736643 Another view of black containers of hazardous waste/HWPharms. 6 of 7 Alpine Surgicenter, LLC Dba Alpine Surgery Center Inspection Date(s): 08/08/2023 - 08/08/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Service Agreement Flow Chart Stericycle Service No No Jon Jones Agreement Summary of No No Jon Jones Pharmaceutical Waste Streams 08/09/2023 08/09/2023 7 of 7