Document rpoJ6N51jgNynyK3r7KLJVkKJ

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 07/11/2024 09:27 AM (AKT) Announced: No 07/11/2024 11:16 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 Staples Staples AKD983073792 4831 Old Seward Hwy Anchorage, AK 99503 Anchorage Municipality Small Quantity Generator (SQG) 493110 - GENERAL WAREHOUSING AND STORAGE Office supply warehouse/distributor 61.17644, -149.86816 Richard Benedetto, Fulfillment Center Manager 4831 Old Seward Hwy Richard.Benedetto@staples.com Anchorage, AK 99503 Anchorage, AK 99503 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA REGION 10 Jones.Jon@epa.gov (907) 227-4316 Supervisor Review: 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 Staples Facility (the "Site" or "Facility"), located at 4831 Old Seward Hwy, Anchorage, AK 99503, at 09:27 AM (AKT) on 07/11/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Kevin Knight that this was an EPA REGION 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). 1 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2024. This report is based on information supplied by Staples Facility representatives, observations made by the EPA Region 10 inspector, 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 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 Jon Jones RCRA Xiangyu Chu Inspector/Enforcement Officer/EPA ADEC/Inspector in Training Grace Tapulgo Fulfillment Center Manager /Staples Richard Benedetto Operations Supervisor Kevin Knight /Staples (907) 271-6329 (907) 269-7578 (907) 982-8708 (907) 306-6299 Email Jones.Jon@epa.gov Chu.Xiangyu@epa.gov Opening Closing Conf. Conf. Yes Yes Yes Yes Grace.Tapulgo@alaska.gov Yes Yes Richard.Benedetto@staples.com No Yes Kevin.Knight@staples.com Yes Yes Opening Conference Jon Jones, along with EPA Region 10 Inspector Xiangyu Chu, and Alaska Department of Environmental Conservation (ADEC) Inspector Grace Tapulgo, arrived at the facility at 9:27 am and met with Operations Supervisor, Kevin Knight, for the opening conference. We presented our inspector credentials, provided business cards, and informed Knight that this was a routine hazardous waste compliance inspection in accordance with RCRA. We explained that the ADEC inspector was accompanying the inspection for training purposes. During the opening conference, we explained that the focus of the RCRA inspection was to identify and observe types of waste generated, points of waste generation, methods of waste management, and review related documents. These documents included manifests, hazardous waste training, and weekly inspections from the last three years. Only areas of potential compliance concerns or other issues are recorded in this inspection report. Facility/Site Information Number of employees 15 Length of Facility at Location 24+ years Operating Hours Monday through Friday from 6:30 a.m. to 8:30 p.m. 2 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Safety Training Provided to Inspector(s)? Size of Facility What type of generator facility notified? What type of generator facility verified as? No Approximately 20K square feet Small Quantity Generator (SQG) SQG Process Description During the opening conference Mr. Knight explained that there is no storefront, and the facility is not open to the public. All goods are shipped directly to the customers. Additionally, Mr. Knight informed us that they recycle batteries and that the hazardous waste generated by Staples is either due to receiving damaged products from their supplier, or materials that have expired. The hazardous waste produced typically includes aerosols, paint, flammables in the form of ethyl alcohol and petroleum distillates, and corrosive wastes. They store hazardous waste in three locations: "Across from Roll-Up Door 8", the central accumulation area (CAA), and the "Northeast Corner". Mr. Knight accompanied us through the inspection, gave us permission to take photographs, and did not deny us access to any part of the facility. 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. We inspected the areas of the facility listed in the building(s) table below. Building(s) Building/Area/Sub-area Staples Across from roll-up door 8 CAA Northeast corner Process Description Pallet with cans of paint - awaiting waste determination. Universal Waste is stored here, also a box of waste paint. Damaged and expired items are stored on pallets until they are picked up quarterly by Clean Earth. Area of Concern Yes Yes Yes Yes SECTION II - OBSERVATIONS Building: Staples/CAA Observation #: JJ1-OB-001 Date: 07/11/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Kevin Knight Title: Operations Supervisor Mr. Knight led us over to where universal waste and hazardous waste is stored. We observed a carboard box on the ground that contained waste paint cans. Two of the cans of waste paint were determined to be hazardous waste due to their ignitability, but were not labeled with a hazard indicator, an accumulation start date (ASD), or the words "Hazardous Waste." 3 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Building: Staples/Northeast corner Observation #: JJ1-OB-002 Date: 07/11/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Kevin Knight Title: Operations Supervisor Mr. Knight led us over to the Northeast Corner where there were multiple pallets of waste items. We observed two pallets of hand soap that we were informed were non-hazardous. We also saw one pallet of hand sanitizer, a D001 hazardous waste with a flash point between 60-70 degrees Fahrenheit, that was missing a hazard indicator and a hazardous waste label. Mr. Knight informed us that it had been generated about 2 months prior. Additionally, we observed a pallet that contained hand sanitizing alcohol wipes. This pallet had a hazard indicator but was missing a proper label with the words "hazardous waste". This pallet also had a label indicating that it weighed 1,386 pounds and that it had been on site since 10/01/23, greater than 270 days. Building: Staples/Across from roll-up door 8 Observation #: JJ1-OB-003 Date: 07/11/2024 Contains AOC: No Contains CBI: No Person Interviewed: Kevin Knight Title: Operations Supervisor We observed a pallet with paint cans on it, all of which appear to be latex. Mr. Knight could not identify if the paints were waste. In an email received from Mr. Knight on 07/16/2024, he informed us that the paints we observed were not waste as they were still being used to paint the facility. SECTION III - RECORDS REVIEW Record: Manifests AOC: Yes Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 07/11/2024 When looking through manifests, we observed manifest 200798337CLE from May 10,2024, that was missing a signature from the destination facility and was past 60 days without an exception report. Additionally, we found manifest 200229445CLE from 08/18/22, that was missing a signature from the destination facility and was past 60 days without an exception report. Richard Benedetto, Fulfillment Center Manager, later sent us copies of the signed manifests on 07/16/24, and they were not over 60 days. Record: Inspections AOC: Yes Ref #: JJ1-RR-002 Reviewed By: Jon Jones Reviewed Date: 07/16/2024 At the time of the inspection, we requested that Richard Benedetto send us the last three years of weekly inspection logs. Benedetto sent over the documents on 07/16/24. 17 weeks from 2021 were not provided. Upon review, we observed a total of 18 weeks of inspections missing from 2021, 2 weeks missing from 2022, 10 weeks missing from 2023, and 8 weeks missing from 2024. Additionally, one inspection date 10/22/22 was on a Saturday, outside of the operating hours provided by Knight. SECTION IV - AREA OF CONCERN 4 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Staples JJ1-OB-001 Area: CAA Sub-area: Two, 1-gallon cans of waste paint were not labeled with a hazard indicator, an ASD, or the words "Hazardous Waste." Regulation: Sections: Building: Staples JJ1-OB-002 Area: Northeast corner Sub-area: One pallet of waste hand sanitizer was not labeled with the words "Hazardous Waste" or marked with a hazard indicator. Regulation: Sections: Building: Staples JJ1-OB-002 Area: Northeast corner One pallet containing waste hand sanitizing alcohol wipes was not labeled with the words "Hazardous Waste." Regulation: The pallet of waste hand sanitizing alcohol wipes had an ASD of 10/01/23 and had been accumulated onsite for greater than 270 days. Building: Staples Area: Across from roll-up door 8 JJ1-OB-003 A pallet with paint cans on it, unknown to employees if they were waste. Failure to make a hazardous waste determination. Regulation: In an email received from Mr. Knight on 07/16/2024, he informed us that the paints we observed were not waste as they were still being used to paint the facility. Sub-area: Sections: Sub-area: Sections: Record: Manifests JJ1-RR-001 5 of 20 Staples Inspection Date(s): Manifest 200798337CLE from Regulation: 5/10/24, missing a signature from the destination facility, past the 60 days permitted. Signed manifest was sent to us 07/16/24. Manifest 200229445CLE from 08/18/24, missing a signature from the destination facility and was past the 60 days permitted. Signed manifest was sent to us 07/16/24. Record: Inspections JJ1-RR-002 18 weeks of missing inspections from 2021, 2 weeks missing from 2022, 10 weeks missing from 23, and 8 weeks missing from 2024. Regulation: 07/11/2024 - 07/11/2024 Sections: 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 Staples Staff 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 we observed during my inspection of the facility. We requested the past three years of weekly inspections, a copy of the inspection checklist, the signed copies of the two manifests that were missing signatures, and the training certificates of the employees who handle the hazardous waste on site. Additionally, Mr. Knight stated that he would fix the labeling issues of the pallets and paint boxes and send us pictures of the corrections. Mr. Knight also stated that he would make a waste determination on the paints located "Across from Door 8". 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 documented violations. Follow Up On 7/17/2024, Mr. Benedetto sent me an email containing the past three years of weekly inspections, a copy of the inspection checklist, the signed copies of the two manifests that were missing signatures, and the training certificates of the employees who handle the hazardous waste on site. Additionally, photos of the corrected labeling of the pallets and box of paint cans were sent to us in a separate email, and they informed us that the paint cans located "Across from Door 8" were not waste. 6 of 20 Staples Inspection Date(s): SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 07/11/2024 - 07/11/2024 7 of 20 Staples Inspection Date(s): APPENDIX 1: PHOTO LOG 07/11/2024 - 07/11/2024 Two cans of hazardous waste paint at CAA 07/11/2024 09:51 AM No CBI No PII CAA Two cans of hazardous waste paint located at the CAA. 07-11-2024 Staples 003.jpg Photographer: Grace Tapulgo [Geographic Coordinates] Two cans of hazardous waste paint at CAA 07-11-2024 Staples 004.jpg 07/11/2024 09:51 AM No CBI No PII Photographer: Grace Tapulgo CAA [Geographic Coordinates] The back of the two cans of hazardous waste paint located at the CAA. 8 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Box of paints unlabeled 07-11-2024 Staples 005.jpg 07/11/2024 09:51 AM No CBI No PII Photographer: Grace Tapulgo CAA [Geographic Coordinates] Box of waste paint containing two hazardous waste paint cans located at the CAA. CAA 07/11/2024 09:52 AM No CBI CAA Establishing shot of the CAA. No PII 07-11-2024 Staples 006.jpg Photographer: Grace Tapulgo [Geographic Coordinates] 9 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Pallet of Hazardous Waste 07/11/2024 09:56 AM No CBI Northeast Corner Pallet of hazardous waste unlabeled. No PII 07-11-2024 Staples 007.jpg Photographer: Grace Tapulgo [Geographic Coordinates] Close up of Waste Product 07-11-2024 Staples 008.jpg 07/11/2024 09:57 AM No CBI No PII Photographer: Grace Tapulgo Northeast Corner [Geographic Coordinates] Close up of waste product on unlabeled pallet of hazardous waste. 10 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Close up of Waste Hand Sanitizer 07-11-2024 Staples 009.jpg 07/11/2024 09:57 AM No CBI No PII Photographer: Grace Tapulgo Northeast Corner [Geographic Coordinates] Close up of waste hand sanitizer on hazardous waste pallet. Close Up of Waste Floor Finish 07/11/2024 09:57 AM No CBI No PII Northeast Corner Waste floor finish on hazardous waste pallet. 07-11-2024 Staples 010.jpg Photographer: Grace Tapulgo [Geographic Coordinates] 11 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Hazardous Waste Pallet 07-11-2024 Staples 011.jpg 07/11/2024 09:59 AM No CBI No PII Photographer: Grace Tapulgo Northeast Corner [Geographic Coordinates] Hazardous Waste Pallet of hand sanitizing wipes marked flammable, missing Hazardous Waste label, and dated from October of 2023. Accumulation Date Label 07-11-2024 Staples 012.jpg 07/11/2024 09:59 AM No CBI No PII Photographer: Grace Tapulgo Northeast Corner [Geographic Coordinates] Label with date of accumulation on hazardous waste pallet. Dated from 10/01/2023, over the 270 days. 12 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Pallet of corrosive wastes 07-11-2024 Staples 016.jpg 07/11/2024 10:02 AM No CBI No PII Photographer: Grace Tapulgo Northeast Corner [Geographic Coordinates] Pallet of hazardous waste corrosives on a pallet. Damaged box of corrosives only partially contained in plastic wrap. Floor Stripper 07/11/2024 10:03 AM No CBI No PII Northeast Corner Bucket of floor stripper from corrosives pallet. 07-11-2024 Staples 017.jpg Photographer: Grace Tapulgo [Geographic Coordinates] 13 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Corrosive markers on boxes 07/11/2024 10:03 AM No CBI No PII Northeast Corner Close up of boxes marked corrosives on pallet. 07-11-2024 Staples 018.jpg Photographer: Grace Tapulgo [Geographic Coordinates] Pallet Across from Door 8 07-11-2024 Staples 022.jpg 07/11/2024 10:31 AM No CBI No PII Photographer: Grace Tapulgo Across from Door 8 [Geographic Coordinates] Pallet where paint cans were found that Knight could not identify as in-use or waste. 14 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Paint cans from "Across from Door 8" 07-11-2024 Staples 023.jpg 07/11/2024 10:31 AM No CBI No PII Photographer: Grace Tapulgo Across from Door 8 [Geographic Coordinates] Cans of paint from the pallet that was "Across from Door 8". Unidentified as either waste or in-use. [Title] 07-11-2024 Staples 025.jpg 07/11/2024 10:31 AM No CBI No PII Photographer: Grace Tapulgo Across from Door 8 [Geographic Coordinates] Close-up view of one of the paint cans from the pallet that was "Across from Door 8". Unidentified as either waste or in-use. 15 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 Manifest 200798337CLE 07-11-2024 Staples 001.jpg 07/11/2024 10:51 AM No CBI No PII Photographer: Grace Tapulgo [Building/Area] [Geographic Coordinates] Manifest 200798337CLE from 05/10/2024 missing signature from destination facility. Manifest 200229445CLE 07-11-2024 Staples 002.jpg 07/11/2024 10:52 AM No CBI No PII Photographer: Grace Tapulgo [Building/Area] [Geographic Coordinates] Manifest 200229445CLE from 08/18/2022 missing signature from destination facility. 16 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 [Title] IMG_0311.jpg [Image Capture Date] No CBI No PII Photographer: Facility photo CAA [Geographic Coordinates] Photo from facility documenting corrective action taken following the inspection. [Title] IMG_0312.jpg [Image Capture Date] No CBI No PII Photographer: Facility photo Northeast Corner [Geographic Coordinates] Photo from facility documenting corrective action taken following the inspection. 17 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 [Title] IMG_0313.jpg [Image Capture Date] No CBI No PII Photographer: Facility photo Northeast Corner [Geographic Coordinates] Photo from facility documenting corrective action taken following the inspection. [Title] IMG_0314.jpg [Image Capture Date] No CBI No PII Photographer: Facility photo Northeast Corner [Geographic Coordinates] Photo from facility documenting corrective action taken following the inspection. 18 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 [Title] IMG_0315.jpg [Image Capture Date] No CBI No PII Photographer: Facility photo Northeast Corner [Geographic Coordinates] Photo from facility documenting corrective action taken following the inspection. [Title] IMG_0316.jpg [Image Capture Date] No CBI No PII Photographer: Facility photo Northeast Corner [Geographic Coordinates] Photo from facility documenting corrective action taken following the inspection. 19 of 20 Staples Inspection Date(s): 07/11/2024 - 07/11/2024 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded By CBI PII Date Received Personnel Training Personnel Training Communications Manifests Manifests Weekly Inspections Weekly Inspections Communications Kevin Training.pdf No No Jon Jones Rich Training.pdf No No Jon Jones Staples Visit Items.msg No No Jon Jones M#200229445CLE.pdf No No Jon Jones M#200798337CLE.pdf No No Jon Jones Weekly Inspection No No Jon Jones Completed by Date.xlsx Weekly Inspection No No Jon Jones Report.pdf Staples Placard Pictures.msg No No Jon Jones 07/16/2024 07/16/2024 07/16/2024 07/16/2024 07/16/2024 07/16/2024 07/16/2024 07/16/2024 20 of 20