Alaska’s Transportation Department Used a Table Edge to “Recycle” Toxic Waste
Investigation Published: December 2025 • Source: EPA Expedited Settlement Agreement, Docket No. RCRA-10-2025-0164, Filed December 15, 2025
The Alaska Department of Transportation and Public Facilities punctured aerosol cans of toxic chemicals on the sharp edge of a worktable and threw them in the trash alongside regular garbage, while a broken mercury lamp sat open in an uncovered bucket in the same facility.
The State Agency That Turned a Worktable Into a Hazmat Station
On April 27, 2021, EPA inspectors walked into the Alaska Department of Transportation and Public Facilities’ Soldotna Maintenance Station on Sterling Highway and found a facility operating as if federal hazardous waste law did not exist. The violations were not minor paperwork errors. Inspectors found evidence of multiple active, ongoing failures to identify, contain, and manage materials that federal regulations classify as hazardous waste.
The facility is designated a Small Quantity Generator of Hazardous Waste and a Small Quantity Handler of Universal Waste. Those designations come with legally binding obligations about how to store, label, track, and dispose of dangerous materials. The EPA’s inspection found ADOT&PF violated virtually every category of those obligations at once.
The settlement was not finalized until December 2025, more than four years after inspectors first walked through the door. The final order was signed by Sean Holland, Central Region Director of ADOT&PF, and filed with the EPA Regional Hearing Clerk on December 15, 2025.
Toxic Paint Stored for Years With No Hazard Label
Inside the facility’s sand shed, inspectors found a 250-gallon tote collecting waste traffic paint generated between 2016 and 2018. The safety data sheets for both the Alaska Low VOC White Solvent Paint and the Alaska Low VOC Yellow Solvent Paint both clearly state the paint is a hazardous waste under federal regulations. Both paints had flash points of -4°F in liquid form, classifying them as ignitable hazardous waste at the time they were collected. ADOT&PF never labeled the tote as hazardous waste and never took steps to drain it before letting the paint harden.
A separate 5-gallon container of Corothane Paint was found open, inside an open plastic bag, in the Cold Storage Connex. The container was labeled with a flammable hazard classification right on the side. Its safety data sheet confirmed a flash point of 93.2°F, meeting the federal definition of ignitable hazardous waste. The EPA inspector confirmed the container still had material in it. ADOT&PF had not flagged it as hazardous waste.
“The Facility did not identify the waste paints as hazardous waste, nor did the Facility remove as much of the waste paint as possible from the tote using common practices before allowing it to dry.”
The Table-Edge “Recycling” Program
In the State Equipment Fleet section of the Soldotna shop, EPA inspectors found punctured aerosol cans of CRC Brakleen and Aerokroil sitting in regular trash cans mixed with ordinary solid waste. When inspectors asked how the cans were punctured, a facility representative confirmed the cans were punctured on the sharp edge of a worktable or with a punch tool. Federal law requires that aerosol can puncturing be done with a device specifically engineered to safely puncture the can and fully contain whatever comes out. A table corner is not that device.
After puncturing, the cans were supposed to be recycled in a designated recycling container separated from regular garbage. Instead, they went straight into the trash. The safety data sheets for both CRC Brakleen and Aerokroil confirm flash points below 140°F, meaning their contents qualify as ignitable characteristic hazardous waste. The CRC Brakleen safety data sheet goes further, explicitly stating that if discarded, the product is a RCRA ignitable waste and that warning labels must be followed when handling emptied containers because they retain product residue.
A facility representative confirmed to the inspector that ADOT&PF does not collect or manage the released contents of the aerosol cans in any way. The hazardous chemical that came out of those cans when they were punctured went wherever it went, with no tracking, no containment, and no disposal protocol.
Mercury in a Bucket. Open.
Federal law requires that any broken lamp containing hazardous constituents must be immediately cleaned up and placed in a closed container. Fluorescent and high-pressure sodium lamps contain mercury. That is not a technicality; mercury exposure causes neurological damage, kidney failure, and developmental harm in children. Inside the Cold Storage Connex, inspectors found a broken high-pressure sodium lamp sitting in an open bucket. No cover. No containment. No cleanup.
Across three separate locations inside the facility, lamps were stored in open containers with no labels identifying them as universal waste and no dates showing how long they had been accumulating. When inspectors asked how long the lamps had been there, the facility representative said he was not sure, guessed August 2020, and wrote that date on the container while the inspector stood and watched. Another facility representative said he simply did not know how long the lamps had been sitting there.
The Non-Financial Ledger: What the Fine Doesn’t Count
There are workers inside the Soldotna Maintenance Station who showed up to their jobs every day not knowing they were sharing a building with a broken mercury lamp sitting in an open bucket. That is not a hypothetical risk. That is a confirmed fact documented in a federal inspection report. High-pressure sodium lamps contain mercury vapor. When they break, that vapor can be released into the air. The people breathing that air did not get a memo about it. They got nothing.
ADOT&PF is a state government agency. The workers at that facility are public employees. They maintain Alaska’s roads, bridges, and transportation infrastructure. The Soldotna station exists to serve the public good. But behind that civic identity, the agency stored years-old liquid hazardous paint in a 250-gallon tote without ever telling regulators or workers what was actually in it. The paint was generated between 2016 and 2018. The inspection happened in 2021. That tote sat unidentified as hazardous waste for years.
The aerosol situation carries its own particular indignity. Workers were puncturing cans of CRC Brakleen, a product whose own safety data sheet explicitly states it is a RCRA ignitable waste if discarded, by pressing the cans against a table edge. That is the kind of improvised, corners-cut practice that gets workers hurt. The toxic contents that sprayed or dripped out went uncontained, untracked, and undisposed. No one at the agency had a protocol for it. A facility representative told the EPA inspector that managing the released contents simply was not done.
The settlement gives ADOT&PF a clean legal exit for $13,750 (roughly what a typical Alaskan maintenance worker earns in three months of labor). In signing it, the agency explicitly neither admits nor denies the factual allegations. The workers who breathed that air, who punctured those cans on a table edge, who worked alongside that open mercury lamp bucket, get no acknowledgment that anything was wrong. They get no remediation. They get nothing. The state government wrote a check, and the record was closed.
Legal Receipts: Straight From the Document
These are direct quotations from the EPA’s settlement agreement. No paraphrasing. No interpretation. Just what the document says.
The Facility representative told the EPA inspector that the waste aerosol cans were punctured on the sharp edge of a worktable or with a punch tool.
EPA Expedited Settlement Agreement, Paragraph 4(b)(v) • Docket No. RCRA-10-2025-0164
A Facility representative told the Inspector that the Facility does not collect the released contents of the cans or manage them in any way.
EPA Expedited Settlement Agreement, Paragraph 4(b)(vi) • Docket No. RCRA-10-2025-0164
A broken high-pressure sodium lamp was accumulated in the open container. The Respondent’s failure to place the broken high-pressure sodium lamp in a closed container constitutes a violation of 40 C.F.R. § 273.13(d)(2) since the placement of the lamp in an open container could cause the release of hazardous constituents into the environment.
EPA Expedited Settlement Agreement, Paragraph 4(b)(iv) • Docket No. RCRA-10-2025-0164
The Facility representative was unsure how long the lamps had been accumulated but thought they had been in the Connex since August of 2020. He marked the container in the presence of the EPA inspector with the date 8/2020. The Facility was unable to demonstrate the actual date upon which it started accumulating the universal waste lamps and was only able to estimate the month and year in which the facility representative thought they might have begun accumulating the lamps.
EPA Expedited Settlement Agreement, Paragraph 4(b)(iii) • Docket No. RCRA-10-2025-0164
The CRC Brakleen SDS confirms this information and specifically states that if discarded, the product is a RCRA ignitable waste and warning labels should be followed when handling emptied containers since they may retain product residue.
EPA Expedited Settlement Agreement, Paragraph 4(b)(v) • Docket No. RCRA-10-2025-0164
Societal Impact Mapping
Environmental Degradation
The aerosol cans of CRC Brakleen and Aerokroil were punctured using a worktable edge and the released contents were discarded into regular trash with no containment. Both products have flash points below 140°F, meeting the federal threshold for ignitable hazardous waste. When ignitable hazardous waste enters a regular municipal waste stream, it poses a contamination and fire risk at every point it travels: the trash can, the dumpster, the truck, and the landfill.
The 250-gallon tote of waste solvent paint, generated between 2016 and 2018 and never identified as hazardous, represented years of improper on-site storage. RCRA regulations require hazardous waste determination at the point of generation, precisely because improper storage creates the conditions for ground and surface water contamination. The Soldotna facility sits along the Sterling Highway corridor in the Kenai Peninsula, a region known for its rivers and salmon habitat. No environmental testing results appear in the source document.
The broken high-pressure sodium lamp in an open bucket represents a direct pathway for mercury-containing materials to enter the facility’s environment. Federal regulations require immediate cleanup and closed containment of broken lamps for this exact reason. An open bucket in a storage connex is not containment. Whatever particulate or vapor escaped before and during the inspection is unquantified and unacknowledged in the settlement.
Public Health
Mercury exposure from broken fluorescent and high-pressure sodium lamps is a documented public health concern. The EPA’s own regulations around universal waste lamp handling exist because mercury vapor released from a broken lamp in an enclosed space can cause acute respiratory harm and long-term neurological damage with repeated exposure. Workers in the Cold Storage Connex and Electrician’s Connex had no way to know a broken lamp was sitting open in an unsecured bucket unless they were told. The settlement does not address worker notification, medical monitoring, or any post-incident health assessment.
CRC Brakleen, one of the aerosol products punctured on a worktable, contains chemical solvents with known health hazards including respiratory irritation and central nervous system effects upon inhalation. The product’s own safety data sheet issues explicit warnings. Workers puncturing these cans on a table edge, with no engineered containment device, were exposed to whatever released during that process. The released contents went unmanaged. The settlement does not address occupational exposure records or any worker safety review by OSHA.
Three separate locations inside the facility had open containers of lamps with no labels and no tracking of accumulation dates. In a workplace where hazardous materials are not labeled, workers cannot exercise basic informed precaution. The right to know what you are working around is fundamental to workplace safety. ADOT&PF denied its own employees that right through years of non-compliance.
Economic Inequality
The $13,750 penalty (roughly the amount an average American family spends on groceries in one year) resolves six categories of federal violations spanning multiple materials, multiple locations, and multiple years of non-compliance. That sum represents no meaningful deterrent for a state government agency with a capital budget in the billions. It is functionally a parking ticket.
The workers at the Soldotna Maintenance Station are public employees, overwhelmingly working-class people maintaining Alaska’s roads in one of the most physically demanding environments in North America. They are the ones who faced the actual risk: the open mercury lamp, the improperly punctured aerosol cans, the unlabeled hazardous containers. The state agency that employs them failed to protect them. The settlement requires the agency to pay a fine and does not require the agency to compensate workers, fund medical screenings, or make any public disclosure about the violations to the people who worked inside that building.
This is the economic logic of regulatory settlements as currently structured: the institution pays a predetermined sum calibrated to close the case, not to repair the harm. Workers absorb the risk. The agency absorbs the fine. Nobody absorbs accountability.
Four Years to a $13,750 Check: The Timeline
The Cost of a Life: By the Numbers
The settlement explicitly states that ADOT&PF “neither admits nor denies the factual allegations.” The agency paid the fine. The violations are sealed. The workers who breathed that air are not mentioned again.
What Now: Who’s Watching and What You Can Do
The People Who Signed This
- Sean Holland, Central Region Director, Alaska Department of Transportation and Public Facilities, signed the settlement agreement on behalf of the agency.
- Ryan Anderson, Commissioner, Alaska Department of Transportation and Public Facilities, received the final filed order via mail to ADOT&PF headquarters in Juneau.
- Edward J. Kowalski, Director, Enforcement and Compliance Assurance Division, EPA Region 10, signed the agreement on behalf of the EPA.
Regulatory Bodies With Jurisdiction
- EPA Region 10: Primary enforcement authority on this settlement. Headquartered in Seattle, WA. Contact them if you have information about additional RCRA violations at ADOT&PF facilities across Alaska.
- EPA National Enforcement and Compliance Assurance: Tracks repeat violators and systemic non-compliance across state agency facilities.
- OSHA Alaska: Occupational safety authority with jurisdiction over worker exposure to hazardous chemicals. This case documents conditions that raise direct workplace safety concerns. OSHA was not mentioned in the settlement; that gap is worth noting.
- Alaska Legislature: ADOT&PF operates on state appropriations. Legislators on the transportation and budget committees have oversight authority over agency operations and compliance culture.
What You Can Do Right Now
If you work at an ADOT&PF facility or any government maintenance station and you have seen aerosol cans punctured without proper equipment, unlabeled containers, or unsecured broken lamps, you can file a complaint directly with EPA Region 10 and with OSHA. You do not need a lawyer to do this, and retaliation against whistleblowers is illegal. Connect with Alaska’s labor unions and worker safety organizations who can support you through that process. Share this article with ADOT&PF employees you know. The people most harmed by regulatory violations are always the people closest to the work, and they deserve to know what was found inside their own building.
The source document for this investigation is attached below.
The file in this provided link is what was referenced to write this article: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/781A1ACE6374CA9A85258D61006DE439/$File/ESA%20ADOTnPF%20RCRA%2010%202025%200164.pdf
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