Document xZBaYQ4nE1BokORQrXd2jRaQ

Inspection Date(s): Time: Program: Regulatory Program(s): If Access is Denied: REGION 10 Enforcement Division INSPECTION REPORT 07/27/2021 - 07/27/2021 Announced: No Entry: 08:22 AM (AKT) Exit: 10:16 AM (AKT) RCRA Title 40 - ENVIRONMENTAL PROTECTION AGENCY Company Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) Type of Operation: Size of Facility: Length of Facility at Location: Geographic Coordinates: Mailing address: (Secondary Address) US Ecology Alaska US Ecology Alaska, LLC 44066 KENAI SPUR HIGHWAY KENAI, AK 99611 Hazardous waste transporter and 10-day transfer facility 10 acres, 11,000 square ft. Building Since 2011 60.619034, -151.328205 Rick Reimer, Director of Operations - Alaska 425 Outer Springer Loop Road Palmer, AK 99645 Phone: 907-258-1558 rick.reimer@usecology.com CC: Lori Wagoner, Kenai Branch Manager lori.wagoner@usecology.com (City, state, zip code) County: Palmer, AK 99645 Facility/Site Identifier: Media Number: NAICS: AKR000203984 N/A 54162 ENVIRONMENTAL CONSULTING SERVICES 562219 OTHER NONHAZARDOUS WASTE TREATMENT AND DISPOSAL 562998 ALL OTHER MISCELLANEOUS WASTE MANAGEMENT SERVICES Lead Inspector: Jon Jones Jones, Jon REGION 10 Digitally signed by Jones, Jon Date: 2021.09.30 07:29:11 -08'00' Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Jen Sullivan Jennifer A Sullivan REGION 10 Digitally signed by Jennifer A Sullivan Date: 2021.09.30 09:13:45 -07'00' Sullivan.Jennifer.A@epa.gov (206) 553-6978 1 of 5 NRC ALASKA, LLC. Inspection Date(s): 07/27/2021 - 07/27/2021 SECTION I - INTRODUCTION Purpose of the Inspection/Objective Type of inspection: CEI - Compliance Evaluation Inspection This was a Resource Conservation and Recovery Act (RCRA) inspection. 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 2021. Attendees Title Name Lead Inspector Jon Jones Kenai Branch Lori Wagoner Manager Phone Email 9072716329 Jones.Jon@epa.gov Present in Present in Opening Conf. Closing Conf. Yes Yes (907) 395-4623 lori.wagoner@usecology.com Yes Yes Opening Conference EPA Lead Inspector Jon Jones arrived at the US Ecology Alaska, LLC. at 08:22 AM (AKT) on 07/27/2021 for an inspection. I presented my credentials to Ms. Lori Wagoner, Kenai Branch Manager, and informed her that this was an EPA RCRA inspection. The table above presents all the opening and closing conference participants. During the inspection I looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. I looked for wastes that facility representatives had not yet identified or designated as hazardous. I also observed the facility's universal waste. I was accompanied for the duration of the inspection by Ms. Wagoner and Mr. Nick Russell, Technical Specialist 2. Facility/Site Description US Ecology Alaska, LLC is a Waste Management and Environmental Consulting Service. The facility also treats and disposes of non-hazardous wastes and operates as a hazardous waste transporter with an onsite 10-day transfer area. The facility is in an industrial/business area north of Kenai, AK. Facility Info Number of employees 11 Weather Conditions Cool and sunny Operating Hours 8:00 a.m. to 5:00 p.m., Monday through Friday Safety Training No Provided to Inspector(s)? What type of generator facility notified? VSQG 2 of 5 NRC ALASKA, LLC. Inspection Date(s): 07/27/2021 - 07/27/2021 What type of generator facility verified as? verified by Lori to be VSQG Process Description On the day of the inspection, the facility was in the process of mobilizing personnel for a spill response. I was greeted by Ms. Lori Wagoner, Kenai Branch Manager, and asked if I could give her a little time to get personnel mobilized prior to beginning the inspection. Ms. Wagoner followed up in an email, dated 8/6/21, to inform me that there were no fatalities or substantial injuries in the accident and that cleanup and disposal were ongoing. The following information was obtained from Ms. Wagoner during the opening conference: NRC Alaska, LLC was purchased by US Ecology and as of July 16, 2021 operates as US Ecology No longer taking drilling muds, due to the industry downturn in oil production and drilling (Hilcorp is now taking their own drilling muds to their own grind and inject wells.) Facility conducts Vac truck tank cleaning operations and transfer facility activities Facility also cleans equipment shipped down to them from North Slope Alaska, such as heat exchanger bundles. Vac truck tank cleaning takes place in several wash bays in the facility. The tanks are power washed and the contents flow into one of two large 4,200-gallon floor pits. Analytical testing is performed prior to pit clean-out. The water/liquids are trucked to the US Ecology (Formerly NRC Alaska, LLC), Viking road site in Anchorage, AK for processing. The solids are usually non-hazardous. They are solidified, bagged, then shipped to the Columbia Ridge Landfill in Oregon. Wastes at the facility include the infrequent generation of the following: Spent aerosol cans are accumulated and punctured onsite. The waste aerosol residue/liquids are managed as hazardous waste. Spent lamps and batteries that are managed as universal waste and disposed of at the local household hazardous waste facility. Building(s) Building/Area/Sub-area 10-day Transfer area Wash Bay Process Description 10-day transfer area for the staging of hazardous waste. Cleaning of Heat exchanger bundles (E&P exempt), Portable holding tanks, and Vac trucks Area of Concern No No SECTION II - OBSERVATIONS AND RECORDS REVIEW Observations Building: Wash Bay Observation #: JJ1-OB-001 Contains CBI: No Date: 07/27/2021 While in the wash bay I observed a very large heat exchanger bundle waiting to be cleaned. US Ecology provides 3 of 5 NRC ALASKA, LLC. Inspection Date(s): a bundle cleaning service for entities up on Alaska's North Slope. Photo(s) 1. Observation_Image-202107270949014911697251.jpg 07/27/2021 - 07/27/2021 Records Review Record: Shipping Documents/Tolling agreements Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: No Reviewed Date: 09/29/2021 Following the inspection, I received an email from Ms. Wagoner, dated 8/6/21, that included an attached log of the facility's receiving and outbound shipments through the Kenai facility. It was filtered for hazardous waste shipments and included the number of days onsite. In the email, Ms. Wagoner stated that there were four shipments that have exceeded the RCRA 10-day transfer holding time and she also included the manifests for those shipments in a second attachment to the email. The shipments are TSCA regulated ballasts that are required to travel on uniform hazardous waste manifests. They are not RCRA regulated. Document(s) 1. 2019-July 2021 Shipment Summary.pdf 2. US Ecology - Kenai 10-day Transfer Trailer Log.pdf SECTION III - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. I observed no areas of concern at the time of the inspection. SECTION IV - FOLLOW UP I observed no follow up at the time of the inspection. Closing Conference I held a closing conference to discuss the findings of my inspection. I thanked Ms. Wagoner for her time and cooperation during the inspection and told her that I did not observe any potential compliance concerns during my walk-through inspection. I explained the follow-up process that would take place after the inspection and then departed from the facility. SECTION V - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS - No sampling was conducted. 4 of 5 NRC ALASKA, LLC. Inspection Date(s): SECTION VI - LIST OF APPENDICES Photo Log Observation_Image202107270949014911697251.jpg 07/27/2021 09:49 AM (AKT) Jon Jones Wash Bay No CBI No PII View of a large heat exchanger bundle in the wash bay. 07/27/2021 - 07/27/2021 Document Log Document Type Document Name Contains Contains Uploaded By CBI PII Manifests TSCA regulated ballast manifests No No Jon Jones 2019-2021.pdf Records Review 2019-July 2021 Shipment Summary.pdf No No Jon Jones Records Review US Ecology - Kenai 10-day Transfer No No Jon Jones Trailer Log.pdf Facility Map Facility drawing.JPG No No Jon Jones Other - Amended Certificate of Registration Amended Certificate of Registration.JPG No No Jon Jones Inspection Reports Field_Notes_AKR000203984v1.0.pdf No No Jon Jones Date Received 09/28/2021 09/29/2021 09/29/2021 09/29/2021 09/29/2021 09/29/2021 5 of 5