Document v1kKwNM7Y4ryZ2JMZDv7DaD1Y

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 09/11/2024 08:26 AM (AKT) Announced: No 09/11/2024 10:30 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 Seekins Ford-Lincoln, Inc. Seekins Ford-Lincoln, Inc. AKD035416007 1625 Old Steese Hwy Fairbanks, AK 99701 Fairbanks North Star Borough Very Small Quantity Generator (VSQG) 811114 - Specialized Automotive Repair 811121 - Automotive Body, Paint, and Interior Repair and Maintenance 81119 - Other Automotive Repair and Maintenance Automotive Dealership 64.857998, -147.686347 Aaron Seekins, Customer/Employee Relations Manager Aarons@seekins.com Seekins Ford-Lincoln, Inc. 1625 Seekins Ford Drive Fairbanks, AK 99701 CC: Marty Snyder, Environmental Coordinator martys@seekins.com Margaret Russell, General Manager margaret@seekins.com Fairbanks, AK 99701 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) 1 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 EPA Region 10 Lead Inspector, Jon Jones, arrived at the Seekins Ford Lincoln Mercury Facility (the "Site" or "Facility"), located at 1625 Old Steese Hwy, Fairbanks, AK 99701, at 08:26 AM (AKT) on 09/11/2024 for an unannounced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Marty Snyder that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Parts 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 Seekins Ford Lincoln Mercury 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 after the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Lead Inspector/EPA Jon Jones REGION 10 Environmental Coordinator /Seekins Marty Snyder RCRA Inspector-in- Emily training/ADEC Vannortwick Opening Conference Phone (907) 2716329 (907) 3226594 (907)-2694580 Email jones.jon@epa.gov martys@seekins.com Opening Conf. Yes Closing Conf. Yes Yes Yes emily.vannortwick@alask Yes Yes a.gov EPA Region 10 inspector Jon Jones and ADEC inspector in training. Emily VanNortwick arrived at Seekins Ford Lincoln at 8:26AM. We met with employees at the front desk and informed them that this was an unannounced RCRA inspection and asked for the manager. After about ten minutes, Marty Synder arrived and introduced himself as the environmental manager for this facility. We then presented our credentials to Mr. Snyder and explained that this was a routine RCRA hazardous waste inspection that would be focusing on identifying types of waste, points of 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 Seekins Ford. Mr. Snyder took us to a conference room where we began the opening conference. When asked about their hazardous waste generation and management, Mr. Snyder explained that they generate fluorescent bulbs, paint related waste, fuel waste, and used oil. Mr. Snyder informed the inspectors that they used to burn their own used oil years ago, but do not anymore. Now their oil is stored on site and routinely shipped out for recycling using Republic Services. With this summary of their hazardous waste management, Mr. Snyder and the inspectors opted to begin the walk-through portion of the inspection. 2 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Facility/Site Information What type of generator facility verified as? Mr. Snyder verified his facility's generator status was Very Small Quantity Generator (VSQG) What type of generator facility notified? Small Quantity Generator (SQG) Size of Facility 71,765 square feet Safety Training No Provided to Inspector(s)? Operating Hours 7:00AM to 7:00PM Monday through Friday, 7:00AM to 6:00PM Saturday, and closed on Sunday Length of Facility at Location 43 Years Number of employees 90 - 100 Process Description Seekins Ford Lincoln is a car dealership and service shop located in Fairbanks, AK. The location that was inspected performs all types of automotive related work to include repairs, body work, transmission work, paint jobs, etc. At the time of the inspection, Marty Snyder informed inspectors that they produce several types of hazardous and universal waste, including fluorescent bulbs, used oil, acetone paint waste, contaminated waste fuel, used batteries, and aerosol cans. The facility used to burn used oil years ago, but use gas heaters now and no longer do this, sending their used oil off to be recycled after being stored on site for a time. The company that picks up their used oil is Republic Services. Used batteries are also stored onsite and regularly sent out for recycling. Hazardous and universal wastes are sent out on an as-needed basis with no set schedule. During the inspection, inspectors examined the facility's processes, hazardous waste management practices, points of generation, and accumulation areas. Also observed was the facility's universal waste management practices. Specific areas that were inspected are listed below. Building(s) Building/Area/Sub-area Body Shop Paint mix room Service Shop Detail shop Electrical room Parts area Quick Lane Service Bays Used Oil Storage Process Description Used oil, aerosol cans and fluorescent bulbs Satellite Accumulation Area (SAA) Used oil storage Waste aerosol can puncture Universal waste lamp storage Recycled automotive batteries Used oil collection and storage Used oil collection and storage Main storage for used oil 3 of 14 Area of Concern No No Yes No Yes Yes No Yes Yes Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 SECTION II - OBSERVATIONS Building: Service Shop/Used Oil Storage Observation #: JJ1-OB-001 Date: 09/11/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Marty Snyder Title: Environmental Coordinator When we asked about where used oil is stored, we were directed to the back of the building where I observed two above ground storage tanks totaling 20,000 gallons in capacity. The amount of oil in the tanks at the time of the inspection was unknown. Mr. Snyder said Republic (formerly US Ecology) pumped out the tanks two months ago. At the time of the inspection, the facility had not labeled the tanks with the words "Used Oil." There was a concrete wall concealing the tanks that the facility had also not labeled. On 10/02/2024, Marty Snyder sent a photo showing facility personnel had labeled the tanks with the words "Used Oil." Photo(s) 1. IMG-20240911085844584489387.jpg Building: Service Shop/Service Bays Observation #: JJ1-OB-002 Date: 09/11/2024 Contains AOC: No Contains CBI: No Person Interviewed: Marty Snyder Title: Environmental Coordinator At the south end of a service bay within the service shop, I observed a universal waste aerosol container that facility personnel labeled with the words "Used Aerosols." At the time of the inspection, the container was not closed and there were two aerosol cans inside the container. Photo(s) 1. IMG-2024091109091691686111.jpg 2. IMG-2024091109092392355451.jpg Building: Service Shop/Paint Mix Room Observation #: JJ1-OB-003 Date: 09/11/2024 Contains AOC: No Contains CBI: No Person Interviewed: Marty Snyder Title: Environmental Coordinator Within the service shop, we visited the paint mixing room. I observed a 55-gallon SAA drum that the facility was using to accumulate solvent waste. Facility personnel labeled the container with the words "Hazardous Waste," but did not mark it with a hazardous waste indicator. The lid to the funnel mechanism at the top was ajar. The lid was closed during the inspection. At the time of the inspection, the facility was operating as a VSQG and although the labeling and marking containers is a good practice, it's not required for a VSQG. 4 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): Photo(s) 1. IMG-202409110915431543103815.jpg 2. IMG-202409110916011612118514.jpg 3. IMG-202409110916091692029574.jpg 4. IMG-2024091109164516451886465.jpg 6. IMG-202409110920062062020777.jpg 09/11/2024 - 09/11/2024 Building: Service Shop/Electrical room Observation #: JJ1-OB-004 Date: 09/11/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Marty Snyder Title: Environmental Coordinator In the electrical room, I observed five boxes containing used fluorescent lamps that the facility labeled "Used Fluorescent Lamps." The facility labeled four of the five boxes with the date 8-22-2024. According to Mr. Snyder the facility replaces all of their lamps at one time. During the inspection, we saw one box the facility had not closed or marked with the date the lamps first became a waste. On 10/02/2024, Marty Snyder sent a photo showing that the facility closed and dated that box of used lamps. Photo(s) 1. IMG-2024091109274327431670088.jpg Building: Service Shop/Service Bays Observation #: JJ1-OB-005 Date: 09/11/2024 Contains AOC: Yes Contains CBI: No Person Interviewed: Marty Snyder Title: Environmental Coordinator In the service bays, I observed a rolling used oil collection container with faded and illegible labeling. I explained that containers storing used oil were required to be clearly marked with the words "Used Oil." Photo(s) 1. IMG-2024091109332933291992439.jpg 2. IMG-2024091109031631682225.jpg 3. IMG-2024091109033833879665.jpg Building: Service Shop/Parts area Observation #: JJ1-OB-006 Date: 09/11/2024 Person Interviewed: Marty Snyder Contains AOC: Yes Contains CBI: No Title: Environmental Coordinator 5 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 In the parts area, I observed a large container of used automotive batteries. According to onsite personnel, the facility recycles their used batteries through Airland Factory Motor Parts, and they ultimately end up at a lead smelter. At the time of the inspection, the facility did not have a Land Disposal Restriction Notice (LDR) on file for the batteries. Photo(s) 1. IMG-2024091109434243421804025.jpg SECTION III - RECORDS REVIEW Record: Shipping Documents/Tolling agreements AOC: No Ref #: JJ1-RR-001 Reviewed By: Jon Jones Reviewed Date: 09/11/2024 We inspected relevant paperwork and manifests while at the facility and identified no areas of concern. SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Service Shop JJ1-OB-001 Used oil storage tanks not labeled with the words "Used Oil." Area: Used Oil Storage Regulation: Sub-area: Sections: On 10/02/2024, Marty Snyder sent a photo showing the facility labeled the tanks with the words "Used Oil." Building: Service Shop Area: Electrical room JJ1-OB-004 A container of universal waste lamps was not closed or marked with the Regulation: date the lamps first became a waste. On 10/02/2024, Marty Snyder sent a photo showing the facility had closed and dated that container. Sub-area: Sections: Building: Service Shop JJ1-OB-005 Area: Service Bays Sub-area: Facility personnel had not legibly labeled a used oil receiver with the words "Used Oil." Regulation: Sections: Building: Service Shop Area: Parts area Sub-area: 6 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): JJ1-OB-006 There was no LDR on file at the facility for the waste automotive batteries the facility was recycling, and their recycler sends the batteries to a lead smelter. Regulation: 09/11/2024 - 09/11/2024 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 Mr. Snyder for his 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. 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. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 7 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): APPENDIX 1: PHOTO LOG 09/11/2024 - 09/11/2024 20,000 Gallon Used Oil Tanks IMG-20240911085844584489387.jpg 09/11/2024 08:58 AM No CBI No PII Photographer: Emily Vannortwick Service Shop/Used Oil Storage [Geographic Coordinates] The two above ground tanks serving as used oil storage, each tank totals 10,000 gallons in capacity. The tanks are missing a "Used Oil" label. Used Oil Pump IMG-2024091109031631682225.jpg 09/11/2024 09:03 AM No CBI No PII Photographer: Emily Vannortwick Service Shop/Service Bays [Geographic Coordinates] This is where used oil is accumulated and pumped into the 10,000-gallon tanks for storage and pickup. 8 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Rolling Used Oil Container IMG-2024091109033833879665.jpg 09/11/2024 09:03 AM No CBI No PII Photographer: Emily Vannortwick Service Shop/Service Bays [Geographic Coordinates] This is a rolling used oil container, of which there are 25-30 in the entire facility. Open Aerosol Can Container IMG-2024091109091691686111.jpg 09/11/2024 09:09 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Service Bays 64.85663314, -147.67855281 Universal waste aerosol container at south end of service shop. The container is not marked with the date that waste aerosol cans first became a waste. 9 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Open Aerosol Can Container IMG-2024091109092392355451.jpg 09/11/2024 09:09 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Service Bays 64.85663122, -147.67882807 Second photo showing the inside of the universal waste aerosol container at south end of service shop. Waste paint SAA IMG-202409110915431543103815.jpg 09/11/2024 09:15 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Paint Mix Room 64.85656971, -147.67935409 Waste paint SAA, the lid on the funnel mechanism is ajar and the drum does not have a hazard indicator. 10 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Waste paint SAA IMG-202409110916011612118514.jpg 09/11/2024 09:16 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Paint Mix Room 64.8565631, -147.67931904 Second photo of waste paint SAA, the lid on the funnel mechanism is ajar and the drum does not have a hazard indicator. Paint Waste SAA IMG-202409110916091692029574.jpg 09/11/2024 09:16 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Paint Mix Room 64.85656613, -147.6793246 Third photo of waste paint SAA, the lid on the funnel was closed per us informing Mr. Snyder, but it still lacks a hazard indicator. 11 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Acetone Waste Container 09/11/2024 09:16 AM (AKT) No CBI Service Shop/Paint Mix Room Photo of acetone container. No PII IMG-2024091109164516451886465.jpg Photographer: Jon Jones 64.85653923, -147.67926294 Paint Waste SAA IMG-202409110920062062020777.jpg 09/11/2024 09:20 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Paint Mix Room 64.85659903, -147.67921588 Fourth photo of the waste paint SAA funnel mechanism that was closed at the time of the inspection 12 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Used Fluorescent Bulbs IMG-2024091109274327431670088.jpg 09/11/2024 09:27 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Electrical room 64.85670254, -147.67929876 View of box of used fluorescent lamps that is not closed or dated. Faded Used Oil Label IMG-2024091109332933291992439.jpg 09/11/2024 09:33 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Service Bays 64.85687461, -147.67939955 A rolling used oil collection container with the "Used Oil" label worn off. 13 of 14 Seekins Ford Lincoln Mercury Inspection Date(s): 09/11/2024 - 09/11/2024 Used Batteries IMG-2024091109434243421804025.jpg 09/11/2024 09:43 AM (AKT) No CBI No PII Photographer: Jon Jones Service Shop/Parts area 64.85684108, -147.67909679 A box of used batteries that is awaiting shipment to a recycling facility. APPENDIX 2: DOCUMENT LOG Document Type Document Name Communications FW_ corrections.pdf Contains Contains Uploaded By CBI PII No No Jon Jones Date Received 10/07/2024 14 of 14