DSHW-2018-003357 - 0901a068807f00ec

{ro:COMPLIANCE EVALUATION INSPECTION
wASTE MANAGET'IENT
& RADIA'ION CONTROL
Date of Inspection:
Facility:
Facility Address:
County:
EPAID#
Latitude / Longitude:
Generator Status:
Arrival / Departure Time:
Weather Conditions:
Report Prepared By:
Names of Inspectors:
LHD Notifications / Date:
Facility Notification / Date:
Applicable Rules:
March 28,2018
Weber State College (Now University)
3750 Hanison Blvd
Ogden, Utah 84408
Weber/IVIorgan
urD073000895
4r.195025-111.948533
SQG
1:00 pm to 4:00pm
Sunny, about 50"F
Alex Pashley
Alex Pashley
Weber/Jvlorgan b y e-mail
on March 27,tlfr\ZetQ
March 27,ff43
R315: R315-262,R3 15-268, R3 15-273 and
R315-263 of the Utah Administrative Code
CREDENTIALS
TcxA
On March 28,'*68 the inspector met with and presented credentials to Patomchai Patitas
and Rick Wade.
PURPOSE AND SCOPE
The purpose of this Compliance Evaluation Inspection (CEI) was to evaluate the Facility's
waste management practices for compliance with applicable rules under R315 of the Utah
Administrative Code (the Rules) and the Utah Solid andHazardous Waste Act 19-6-101.
Page 1 of 9
FACILITY DESCRIPTION AND WASTE MANAGEMENT OPERATIONS
The Weber State University (WSU) waste management program is run by patomchai
Patitas. Hejs'works out of the building,affd gtoundr and^facilities maintenance office.
Hazardous wastes generated at WSU include universal wastes- rechargeable batteries,fluorescent and HID lamps, science department laboratory wastes, arf department- wasterags with paint and thinners and the photo laboratory film developing solutions (silver)
and small amounts of silver from the dentistry department, used oil from the building andgrounds maintenance and landscaping equipment and vehicles.
Over the last couple of years, WSU has been upgrading their lighting systems to thenewer LED lamp systems. The old HID lamps from the parking lot have already beenupgraded, so no more waste HID lamps are generated. The fluorescent lamps whenupgraded are managed as universal wastes (even though they are the low -"r"ury type).Rechargeable batteries are either traded in when n"ru on.rure purchased, or are managed
as universal wastes. All universal waste containers *ere properly labeled and dated.
Laboratory wastes generated in the science departments are accumulated in satelliteaccumulation containers (mostly behind fire proof and ventilated hoods). The containerswere properly labeled' Once full (or at the end of each semester) all wastes accumulatedin satellite containers are collected and taken to the WSU central accumulation buildingwhere they are relabeled, dated and over-packed for disposal by Clean Harbors.
Waste rags used to clean up after art classes are accumulated in flammable accumulationcontainers/cans and managed as satellite accumulation containers. Once full the rags arecollected and placed into large plastic bags and taken to the central accumulation
building. At the end of each semester they are over packed and picked up by Clean
Harbors for disposal.
The photo lab located in the art department, generates waste photo film finisher which iscollected in 5-gallon containers. These wastes are taken to the WSU central accumulation
building and picked up for disposal by clean harbors once each semester. It was
explained to Mr. Patitas that they could instead, send this silver containing waste off for
recycle and that they could probably receive money back for the recovered silver. He
indicated that he may look into it. The silver containing wastes from the dental lab are
managed with the silver film finishing wastes.
The hazardous waste central accumulation building is located on the East side of the
campus in an area by its self, behind a locked barbed wire fence. The building is airconditioned, vented, and contains an alarm and sprinkler system. It is also.ontuin,
hazard waste signage.
WSU manages their laboratory wastes according to the Subpart K waste management
rules for laboratories. However, they have not notified the Division that they aie
managing the laboratory wastes under subpart K as is required. They have not re-notified
since 1989, which was before the notification became required.
Page2 of9
Hazardous waste manifest *"r"'lrood order. Even though WSU is a SQG and it not
required, they have in place a written Emergency, Preparedness and Prevention plan.
Emergency phone numbers were posted near waste storage and accumulation areas'
Emergency responders have been notified as to the waste generated at WSU.
No problems with the required records or waste management practices were noted.
COMPLIANCE STATUS:
R3j15-5 Hazardous Waste Generator Requirements
5-3.30-3.33 Packaging. Labeling. Marking. and Placarding OK
5- 1.1 1
5-r.r2
5-2.20
5.3.34
5-4.40
5-4.41
5-4.42
5-4.43.r
R315-13-1.
13-1
R315-16
R315-9
Determination of Whether a Waste is a Hazardous Waste OK
EPA Identification Numbers UTD073000895
Manifest OK
Accumulation Time OK
Container Management OK
Tank Management N/A
Preoaredness and Prevention OK
Recordkeeping OK
Biennial Reporting N/A
ExceptionReporting N/A
Additional Reporting N/A
Land Disposal Restrictions
Land Disposal Restrictions N/A
Standards for Universal Waste
Spill Response
Page 3 of 9
FOLLOW.UP ACTIONS:
lnspector Signature:April2.2018
Date
CHMENTS:
Photos
SQG Checklist
valuation Form
1i,,, I
used oil tank located at the building and grounds maintenance shop
Page 4 of 9
Analytical equipment hazardous wastes. Labeled with its contents and the words
unwanted wastes.
Waste film developer solutions containing silver. Goes off for disposal, not for recycle.
Page 5 of 9
WSU waste central accumulation buildins
WSU waste central accumulation building
Page 6 of 9
Waste materials from the building grounds department waiting to be characterized, over
packed, and disposed of by Clean Harbors, located in flammable cabinet.
Various hazardous wastes located in central accumulation building
PageT of9
as such.Ii::"*',fromtheu'td"pu.tmeyaredried,butmanaged
various waste chemicals from science class laboratod
Page 8 of 9
Hazardous waste storage cabinets located in central accumulation building
Page 9 of 9
Utah Department of Environmental Quality
Division of Waste Management and Radiation Gontrol
P.O. Box 144880
Salt Lake Gity, Utah 84114-4880
Phone [phone]
Fax [phone]
SMALL BUSINESS ASSISTANCE PROGRAM FACILITY INFORMATION FORM
Facility Name:
Weber State University
EPA lD Number:
uTD073000895
Street Address:
3750 Harrison Blvd
City:
Ooden
Zip=
844048%
County:
Weber
Gontact Percon:
Rick Wade Patomchai Patitas
Telephone #:
Generator Status:
SOG
Number of Employees:Date of Visit:
March 28.2018
Evaluators:
Alex Pashlev
Other Perconnel:
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Gode
Fluorescent lamps
Recharable batteries
HID LAMPS
Used oil
Laboratory wastes
Photo labs silver
Art department paint relegated materials
Facilities management paint wastes thinnest
Dentistry lab silver photo
Estimated Quantity of Hazardous
Waste Generated Per Month
Date: March 28,2018
REGEIVED BY:
Name: (Printed)
Signature:
Title:
Patomchal Patitias
DWMRC REPRESENTATIVE:
i'ni Site Weber State University
aIl!.
-4.1I r'NLI,
"*"1'"','^i3lt".'':1?t'. HazardousWastelnspection
EPAID: UTD073O00B95 Datez312812018
- Small Quantity Generator Checklist
Waste Determination:
Has the generator determined whether his solid waste is a
hazardous waste?
Has a waste determination been made for each waste stream
Does the generator have documentation that supports the
determinations?
Notification & EPA Hazardous Waste Identification
Numbers
Has the generator notified of regulated activity and obtained
an EPA ID#?
Has the generator offered his hazardous waste to a transporter
or a treatment, storage, or disposal facility (TSDF) that does
not have an EPA ID#?
Does the generator know he must renotifr every 4 years?
Manifest
Has the generator used the approved manifest form 8700-22
and8700-224 for off-site transportation to a TSDF?
Have all applicable sections of each manifest been filled out
completely and legibly? (See attached manifest checklist)
Does the facility generate less than 1000 kg/month and use a
contractual agreement to reclaim his waste?
Have copies of the reclamation agreements been kept on file
for at least three years after termination of the agreement?
Record Keeping
Is the generator maintaining signed copies of the manifests
for three years?
Is the generator maintaining records of test results or waste
analyses for hazardous waste determinations for at least
three years?
Was the SQG a LQG for any month of the year?
Excention Reoorting
Has the generator been required to prepare an Exception
Report (if the TSDF does not return the generator's original
copy of the manifest within 60 days)? If yes, the generator
must submit a legible copy of the manifest to the Director,
with some indication that the confirmation of deliverv to
the TSDF has not been received.
Has the generator kept a copy of each Exception Report for
at least threes years?
Inspector's Initials:
F.31s-262.40(b)Yes
R3l5-262-rr
R3l5-261-3
R3l5-262-l l(f)
R3 l5-262-18(a)
R3l5-262-18(c)
R3ts-262-r8(dxl)
Ft3l5-262-20(a)
P.3rs-262-20(e)(1)
R3rs-262-20(e)(2)
R3r5-262-40(a)
F.3l5-262-40(c)
R3l5-262-l l(D
P.3r5-262-4r(a)
R3t5-262-42(b',)
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Page 1 of8
January 2018
Site Weber State Univers EPA rD: urDo73ooo895 Date: g/2gl211g
Hazardous waste rnspection - small euantity Generator checklist
Are hazardous waste containers packaged, labeled, marked,
and placarded in accordance with DOT 49 CFR prior to
shipment?
Accumulation Time
1. Has the generator stored hazardous wastes on-site for
longer than 180 days or 270 days (if the wastes are
transported over 200 miles to a TSDF) without a permit?
2. Has the generator ever accumulated more than 6000 kg
of hazardous waste on-site?
3. The date upon which each period of accumulation
begins must be clearly marked and visible for inspection
on each container ofhazardous waste.
4. While being accumulated on-site each container and
tank is labeled or marked clearly with the words,
"Hazardous Waste" & an indication ofthe hazards ofthe
contents.
5. Does the facility have at least one person on the premises
or on call (available to reach the facility in a short period of
time) with the responsibility for coordinating all emergency
response measures. This employee is the emergency
coordinator.
6. Has the generator posted the following information next
to the telephone: Name and phone number of emergency
coordinator; Location of fire extinguishers, spill control
material, and if present, fire alarm; and Telephone number
of the fire department, unless the facility has a direct alarm.
Does the generator ensure that all employees are thoroughly
familiar with the hazardous waste handling and "."rg"n.y-procedures relevant to their positions?
Will the Emergency Coordinator or his designee be
available to respond to any emergencies that arise.
Use and Management of Containers
Are hazardous waste containers in good condition?
R3rs-262-30,
F.3l5-262-31,
R3t5-262-32, &
F.3t5-262-33
R.3rs-262-r6(b),
R.3r5-262-16(c),
&R3rs-262-16(d)
R3ls-262- l6(bxl)
R3l5-262-16(bX6XiXC)
R3 l 5-262- l6(bX6)(D(A) & (B)
R3 r5-262-16(b)(exi)
R3 l 5-262-16(bxexiiXA-c)
R.3rs-262-r6(bx9xiii)
R3 I 5-262- I 6(b)(e)(ivXA
R3 ls-262-16(bx2xi)
R3 I 5-265-1,
40cFR26s.17l
Inspector's Initials:
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Page 2 of8
January 2018
sitt W"b"r State University EPA ID: UTD073000895
llazardous Waste Inspection - Small Quantity Generator Checklist
Date:312812018
Are the containers compatible with the hazardous waste?
Are hazardous waste containers kept closed except when
adding or removing waste.
Containers must not be opened, stored or handled in a
way that may cause them to rupture or leak hazardous waste.
Hazardous waste containers must be inspected weekly
looking for unlabeled, leaking and deteriorated containers.
Are incompatible wastes stored in the same containers?
Are hazardous wastes placed in containers that previously
held an incompatible waste?
Are hazardous wastes separated from incompatible wastes
by means of a dike, berm, wall, or other device?
Preparedness and Prevention
Is the facility maintained and operated in a way to minimize
the possibility of fire, explosion, or any unplanned release of
hazardous waste.
Does the facility have the following equipment unless the
wastes stored do not pose the hazards that the equipment is
designed to respond to: internal communications or alarm
capable of providing immediate emergency instructions
(voice or signal) to facility personnel, a device capable of
summoning outside emergency assistance (such as a
telephone or a direct line to the fire department), portable
fire extinguishers, fire control equipment, spill control
equipment, decontamination equipment, water at adequate
pressure and volume to supply fire fighting needs.
Does the facility maintain and test, where necessary, all
communications or alarm systems; fire protection
equipment, spill control equipment, and decontamination
equipment to assure proper operation when needed.
Inspector's Initials:
R3l5-262-16(bx2xii)
15-265-t,40CFR265.1
R3 1s-262-l 6(b)(2XiiD(A)
R3r5-265-1,
40CFR26s.173(a)
R3 l s-262-16(b)(2xiiD(B)
R3l5-265-1,
40cFR265.173(b)
R3 l5-262-16(bX2)(iv)
R3l5-265-1,
40cFR265.174
R3 I 5-262-16(b)(v)(A)
R3l5-265-1,
40CFR265.177(a)
R3 I s-262-l 6(b)(2XvXB)
R315-265-1,
40cFR265.177(b)
R3 l5-262-16(bX2Xv)
(c) R3l5-26s-1,
40CFR265.177(c)
R3 ls-262-16(bX8Xi)
R3 t5-265-1,
40cFR265.31
R3l s-262-16(bX8)(iD
R3l 5-265-1,
40cFR265.32
R3 l s-262-16(b)(8)(iiD
R3l5-265-1,
40cFR265.33
V
V
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Page 3 of8
January 2018
Site YY"5er State University
Do facility personnel have immediate access to an alarm or
emergency communication device whenever hazardous
waste is handled and if there is ever just one employee on
the premises during facility operation, does he hive
immediate access to a device (telephone or two_way radio)
capable of summoning external emergency assistance?
Does the facility maintain aisle space to alrow unobstructed
movement of personnel, fire protection equipment, spillcontrol equipment, and decontamination equipment?
Has the facility attempted to make arrangements with localfire, police, emergency response teams, and hospitals to
respond to emergency situations? The facility must
document any refusal to enter into such arrangements.
Snill Resnonse
Does the facility take appropriate action to minimize threats
to human health and the environment by notifing the Utah
Department of Environmental euality at (g0l) SiA_qtZZ if
more than I kg of acutely hazardous waste, 100 kg of
hazardous waste or material which when spilled becomes a
hazardous waste? Are spills cleaned up as required?
Notifi and report to the National Response Center, at g00_
424-8802, if required.
Has the facility provided written reports including all
information required by the rules to the Director within l5
days after any spill of hazardous waste or material which
becomes a hazardous waste when spilled?
Land Disnosal Restrictions (LDR)
Is the facility managing and treating hazardous waste to
Land Disposal Restriction standards found at26g.40?
If the generator is heating waste to meet LDR has he
developed and followed a written waste analysis plan which
describes the procedures they will carry out to comply with
the treatment standards? The waste analysis plan must be
based on a chemical and physical analysis of a representati
sample of the waste being treated.
ls the plan available on-site in the facilitv files?
lnspector's miriut'-&7
R3 1 s-268-7(a)(s)(ii)
EPA ID: UTD973OOO89S
Hazardous waste Inspection - small euantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
R3 I 5-262-l 6(b)(8)(iv)
R3 I 5-265-1.
40cFR26s.34
R3 I s-262-l 6(b)(8)(v)
R3 l5-265-1.
40cFR26s.35
R3 I s-262-l 6(b)(8)(vi)
R3 I 5-265- l.
40cFpz6s.37
R3 I s-262-16(b)(9)(iv)
R3l5-263-30
R3 I 5-262-l 6(b)(gXivXC)
R3 l 5-263-30
R3 l5-263-33
R3l5-265-1,
40cFR265.56(D
R3rs-262-r6(b)(7)
R3l5-268
Rit5-262-r6(b)(7)
R3 I 5-268-7(a)(s)
Date: gl2gl2}1g
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Does Not Treat Waste
N/A
Page 4 of 8
January 2018
Site YY"b"r State University EPA ID: UTD073000895
Hazardous Waste Inspection - Small Quantity Generator Checklist
Date: 312812018
Has the facility sent a one-time notice and certification that
eachhazardous waste is either not land disposal restricted,
or if it is restricted, that it is land disposable after treatment
with each initial manifested shipment of hazardous waste
or when the waste stream changes?
Does the facility maintain an assessment of LDR status on
file for eachhazardous waste generated at the facility?
Does the facility maintain all LDR documentation for at
least three years from the date the hazardous waste was
shipped off-site?
Standards for Universal Waste Management
Are fluorescent, high intensity discharge, neon, mercury
vapor, high pressure sodium or metal halide lamps being
managed as Universal Waste lamPs?
Are containers of universal waste lamps kept closed and
labeled "Universal Waste Lamps", "Waste Lamps", or
"Used Lamps"?
Are lamps being crushed? Has the generator obtained
from the Director an approved registration? Use Universal
Waste Checklist if needed.
Are rechargeable batteries being managed as a Universal
Waste, kept in a closed container labeled "Universal Waste
Batteries", "Waste Batteries" or "lJsed Batteries"?
Are aerosol cans being managed as a universal waste? Use
Universal Waste Checklist if needed.
Is antifreeze being managed as an universal waste?
Use Universal Waste Checklist if needed.
Is any Universal Waste being accumulated for longer
than one year?
Inspector's Initials:
R3 l5-273-15(a)No
R3l5-268-l
R3 I s-268-7(a)(2)
R3 I 5-268-7(a)(3)
R3l5-268-l
R3l5-268-7(aXl)
R3l5-268-l
R3 ls-268-7(a)(8)
R3l5-273-9(D
R3 I 5-273-5(a)
R3l5-273-13(dXl) &
R3 I 5-273-14(e)
R315-273-13(dX3)
R3l5-273-13(a)(l) &
R3 I 5-273-14(a)
Rsrs-273-r3(f)
R3l5-273-13(e)
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Page 5 of8
Januarv 20 I 8
Site VYs[sr State University EPA ID: UTD0730O0B95
Hazardous waste rnspection - smail euantify Generator checklist
Date: g/2g/211g
Manifest Ngmber (box )
Generator EPA ID #
R315-5-2 (box I
G"n.t
Mailing Address (box 5)
Phone number
Transporter #l information:
Company Name (box 6)
EPA ID# (box 6)
t."n
Company Name (box 7)
EPA ID # (box 7)
PesuName and Address (box S)
EPA ID # (box 8)
Phone Number (box g)
wllt"
DOT Description (including proper
name, Hazard class and ID#)
(box 9b)
(box 9a ,,X'if hazardous materials)
Containers: No & Type (box l0)Total Quantity (box 11)
Unit - Wt/Vot (box t2)
Waste Codes (bor 13)
Special Handling fnstructions
(box 14)
munit
Generator's Signature (box 15)
International Shipments (box l6)
Transporter's Signature (box 17)
Discrepancy Indication (box 1g)
Hazardous Waste Report
Management Method Codes
(box 19)
Facility Signature (box 20)
Final Observations and Comments:
Inspector's rnrr,*K
#01 1 1 73909 # 011173012 # ooooo84
33
# oozt385z4
Page 6 of8
January 2018
Sitt w"b"r state University EPA ID: urDoTgoooggs Date:312812018
Ilazardous Waste Inspection - Small Quantity Generator Checklist
Requirements for SQGs that Accumulate Hazardous
Waste in Tanks
1. A generator may accumulate hazardous waste in tanks
for less that 180 days (or 270 days if the generator must
ship the waste greater than 200 miles), and may not
accumulate over 6,000 kg on-site at any time.
2. Treatment or storage of hazardous waste in tanks must
not generate extreme heat or pressure, fire or explosion,
or violent reaction; produce toxic mists, fumes, dusts, or
gases; produce uncontrolled flammable fumes or gases;
damage the device or facility containing the waste; or
threaten human health or the environment.
3. Hazardous waste or treatment reagents must not be
placed in a tank if it could cause it to fail.
4. Uncovered tanks must have 2 feet of freeboard, unless
the tank has a containment structure that equals or exceeds
the volume of the top 2 feet of the tank.
5. If hazardous waste is continuously fed into a tank, the
tank must be equipped to the inflow (waste feed cutoff or
by-pass system to stand-by tank).
Small Quantity Generators that store hazardous
waste in tanks must inspect, where present:
l. Discharge control equipment at least once each operating
day to ensure good working order.
2.Datafrom monitoring equipment at least once each
operating day to ensure that the tank is operated to its
designs.
3. The level of the waste in the tank at least once each
operating day to ensure compliance with freeboard, if
required.
4. The tank construction materials, at least weekly, to
detect corrosion or leaking seams or fixtures.
5. The construction and surrounding area of discharge
confinement structures at least weekly to detect erosion or
signs of leakage.
R3 l 5-262-1 6(b)(l) & (bx3)
R3 1s-262-16(b)(3XiD(A)
R3 I 5-265-1,
40CFR265.199(a)
R3 I s-262- l 6(b)(3XiD(B)
R3 l5-265-1,
40CFR265.194(a)
R3 l 5-262-l 6(b)(3Xii)(C)
R3 l 5-265- l,
40cFR26s.194(bX3)
R3 l 5-262- l 6(b)(3)(iiXD)
R3 I 5-265-1,
40cFR26s.194(bX2)
R3 l5-262-16(bX3XiiD
R3 l 5-265- 1,
40CFR265.195(a)
R3 l s-262-16(b)(3)(iiD(A)
R3 l5-265-1,
40cFR26s. l9s(b)(l)
R3 l 5-262-l 6(b)(3)(iiD(B)
R3l5-265-1,
40CFM65.195(a)
R3 l 5-262-16(b)(3Xiiixc)
R3l5-265-1,
40cFR26s.195(bX2)
R3 l s-262-16(b)(3XiiD(D)
R3t5-265-1,
40cFR265. l9s(bX3)
R3 I 5-262-16(b)(3XiiD(E)
R3t5-265-1,
4ocFR265.195(bX3)
lnspector's Initials:
N/A
N/A
Page 7 of 8
January 2018
Site Weber State Unive EpA ID: UTDOT3OOOS9S Date: gl5gl21lg
Hazardous waste rnspection - small euantity Generator checklist
NOTES:
Page 8 of8
January 2018
Inspector's I^1rt^1", -{