DSHW-2018-003826 - 0901a0688080786e

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COMPLIANCE EVALUATION INSPECTIONnI l 16ol A
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WASTE MANAGEMENT
& RADIATION CONTROL
Date of Inspection: April23,20l8
Facility: Hallmark Cabinets
Facility Address: 4851 Warehouse Road
Salt Lake City, Utah 84118
County: Salt Lake
EPA ID # UTD063319958
Latitude / Longitude: 40.663524-ll2.Ott932
Generator Status: SQG
Number of Employees: 33
Arrival / Departure Time: Z:I0amto about 3:30pm
Weather Conditions: Sunny, 65"F
Report Prepared By: Alex Pashley
Names of Inspectors: Alex Pashley
LHD Notifications /Date: Salt Lake Countv e-mail on4lI9l20l8
Facility Notification / Date: Unannounced
Applicable Rules: R315: R3I5-262, R315-268, R3L5-273 and
R315-263 of the Utah Administrative Code
CREDENTIALS
On April 23, 2OL8 the inspector met with and presented credentials to John Field.
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 and Hazardous Waste Act 19-6-101.
Page I of5
FACILITY DESCRIPTION AND WASTE MANAGEMENT OPERATIONS
Hallmark Cabinet (Hallmark) has been building custom kitchen and bathroom cabinet
since 1986. The company manufactures high quality custom cabinetry for the home and
business. The cabinets are built with the finest domestic and exotic hardwoods with a
wide range of exclusive custom finishes, topped by a tough, high solids conversion
varnish. The company has dealers distributed throughout the western half of the US.
Hazardous wastes generated are mainly a result of varnishing operations in the
manufacturing shop. Rags are used to apply varnish to surfaces of wood materials and
products. Rags soaked with varnish are managed as hazardous waste. The varnish spray
gun is cleaned out about once a week. The waste varnish and gun cleaning solvent is also
managed as hazardous waste. The paint shop/booth area uses a 5-gallon bucket of solvent
to soak and clean various painting equipment. When spent, this waste solvent is managed
as hazardous waste. It is considered product up to the point where it is spent. The
following waste codes are listed on the manifest; D001, D035, F003 and F005.
Hallmark uses Clean Harbors for waste transport and disposal. Hazardous wastes are
accumulated in a central accumulation area located in a closed room, near the painting
booths and manufacturing area. At the time of the inspection, no satellite accumulation
areas were observed. Wastes are taken directly to the 180 day accumulation containers.
There were four 55-gallon drums in storage. They were properly labeled and dated.
Manifests and other records were reviewed. There were three shipments over about the
last year. They were in good order; however, Mr. Field had to call Clean Harbors to
obtain copies. Hallmark was not maintaining them on site. The emergency coordinator
and responders phone numbers, located near the phone had disappeared or fallen of the
wall. They were re-printed and posted immediately after the inspection, and photos
documenting them were sent to the division (see attached). Letters to emergency
responders have been sent out previous years, but copies of them could not be located, so
Mr. Field agreed to re-send out updated ones as a reminder.
No problems were noted.
COMPLIANCE STATUS:
R315-5
5-1.1 1
5-r.r2
5-2.20
Hazardous Waste Generator Requirements
Determination of Whether a Waste is a Hazardous Waste Yes
EPA Identification Numbers UTD0633 19958
Manifest OK
5-3.30-3.33 Packaging. Labeling. Marking. and Placarding OK
5.3.34 Accumulation Time OK
Page 2 of 5
Container Management OK
Tank Management OK
Preparedness and Prevention OK
5-4.40 Recordkeeping OK
5-4.41 Biennial Reporting N/A
5-4.42 Exception Reporting OK
5-4.43.1 Additional Reporting OK
R315-13-1 LandDisposalRestrictions
13-1 Land Disposal Restrictions OK
R315-16 Standards for Universal Waste
R315-9 Spill Response
FOLLOW.UP ACTIONS:
lnspector Signature:
ATTACHMENTS:
1. Photos
2. SQG Checklist
SQG Evaluation Form
April25.2018
Page 3 of5
Hallmark Cabinets
180 dav accumulation container label
Page 4 of 5
Characteristic label
Four 55-gallon drum of hazardous waste in the 180 central accumulation area.
Page 5 of 5
4t24t2018 State of Utah Mail - Thanks
Alex Pashley <[e-mail]>
Thanks
1 message
John Field <[e-mail]>
To: [e-mail]
Alex.
Mon, Apr 23,2018 at 4:40 PM
Thanks for sharing all the info with me today and helping make sure that we are doing things properly. Sometimes whenpeople come and go information is not passed along and things are forgotten. Hopefully now I can put the processes inplace to make sure that doesn't happen again.
Herg are the pictures of the info by the phones and the letter that I am sending out to the police and First Med which isthe local clinic we use.
We have a meeting scheduled tomorrow morning as a refresher for everyone on what and where everything is just as yousuggested. I also talked with Clean Harbor and they are bringing us new labels that reflect our current waste weproduce. T
Please let me know if I can do anything else.
Thanks for your time today.
John Field
Hallmark Cabinet
Phone: [phone]
Cell: [phone]
Fax: [phone]
Email: [e-mail]
Website: www. hallmarkcabinet.com
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Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 841144880
Phone [phone]
Fax [phone]
SMALL BUSINESS ASSISTANCE PROGRAM FACILITY INFORMATION FORM
Facility Name:
Hallmark Cabinets
EPA lD Number:
uTD06331 9958
Street Address:
4851 Warehouse Road
Gity:
Salt Lake City
zip:
84118
Gounty:
Salt Lake
Contact Percon:
John Field
Telephone #:
801-966-0562
Generator Status:
SQG
Number of Employees:
33
Date of Visit:
4t23t2018
Evaluators:
Alex Pashley
Other Perconnel:
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Code
Waste Pant related wastes-generated
during the manufacture of cabinets
Door,Do35
Foo3
Etnnr
q LD.,
Estimated Quantity of Hazardous
Waste Generated Per Month
\
\w
Date: 412312018
RECEIVED BY:DWMRC REPRESENTATIVE:
Name: (Printed
Signature:
Name: (Printed)
Signature:
Title:
John Feild
Title:
Site Hallmark Cabinets EPA ID: UTDO63319958 Date:412312018
Hazardous waste Inspection - small euantity 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 renoti4r every 4years?
Manifest
Has the generator used the approved manifest form 8700-22
and 8700-224 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?
Exception Reportine
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 ofeach Exception Report for
at least threes vears?
R3t5-262-11
R3 t5-261-3
R3l5-262-11(f)
R3 15-262- l8(a)
R3 l5-262- I 8(c)
R3ts-262-18(dxl)
R3r5-262-20(a)
R3rs-262-20(e)(l)
R.3rs-262-20(e)(2)
R3r5-262-40(a)
R3r5-262-40(c)
R3l5-262-ll(0
R3rs-262-4r(a)
R3ts-262-42(b)
Inspector's rni,iufr' @tf
R.3rs-262.40(b)N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
N/A
N/A
Page 1 of8
January 20 I 8
sitt H"lhark cabinets EPA ID: UTDO633199SB
flazardous Waste Inspection - Small Quantity Generator Checklist
Date: 4t2gl2o19
Packagins. Labeling. Markins. and Placarding
Ar e hazar dous waste containers packaged, labe led, 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 of the hazards of the
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 emergency
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?
R3l5-262-30,
R3l5-262-3r,
R3t5-262-32, &
P.3rs-262-33
P'3ts-262-16(b),
R3l5-262-16(c),
&R3rs-262-16(d)
R3 rs-262-16(bXl )
R3 r5-262-16(bX6XiXC)
R3 l5-262-16(bx6)(iXA) & (B)
F.3rs-262-r6(bx9xi)
R3 r s-262-l 6(bX9XiiXA-C)
R3l5-262- l6(bXeXiiD
R3 I s-262- l6(b)(9XivXA-C
R3 l5-262-16(bX2XD
R3 l5-265- I,
40cFR265.171
Inspector's Initials: AP
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Page 2 of 8
January 2018
sitt H"lhark Cabinets EPA ID: UTDO63319958
Hazardous waste Inspection - small euantity Generator checklist
Date: 412312018
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 o
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.
R3 l 5-262- l 6(bX2XiD
15-26s-r.40cFR265. I
R3 l 5-262-l 6(b)(2xiiiXA)
R3l5-265-1,
40CFR265.173(a)
R3 r 5-262-16(b)(2xiiD(B)
R315-265-1,
40cFR26s. I 73(b)
R3 I s-262-16(b)(2)(iv)
R3 l5-26s-1,
40cFR265. I 74
R3 I s-262-l 6(b)(v)(A)
R3l5-265-1,
40CFR265. I 77(a)
R3 I s-262-l 6(b)(2Xv)(B)
R3l5-265-1,
40cFR26s. I 77(b)
R3 l s-262-16(b)(2)(v)(c) R3l5-26s-1,
40CFR265.177(c)
R3 l 5-262-r 6(bX8Xi)
R3 I 5-265- I,
40cFR265.31
R3 ls-262-16(bXsXiD
R3 I 5-26s-1,
40cFR265.32
R3l s-262-I6(bX8XiiD
R3 I 5-265-1.
40cFR265.33
Yes
Yes
Yes
Yes
Yes
Yes
Yes I lil^rro{^
0lt-
Page 3 of8
January 2018
Site Hallmark Cabinets EPA ID: UTD063319958
Hazardous Waste Inspection - Small Quantity Generator Checklist
Date: 412312018
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 have
immediate access to a device (telephone or two-way radio)
capable of summoning external emergency assistance?
Does the facility maintain aisle space to allow unobstructed
movement of personnel, fire protection equipment, spill
control equipment, and decontamination equipment?
Has the facility attempted to make arrangements with local
fire, 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 notiffing the Utah
Department of Environmental Quality at [phone] it
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?
Notiff and report to the National Response Center, at 800-
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 at268.40?
If the generator is treating 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
sample of the waste being treated.
Is the plan available on-site in the facility files?
R3 I s-262-16(b)(8)(iv)
R3r5-265-1.
40cFR265.34
R3 ls-262-16(b)(8)(v)
R3l5-265-1.
40cFR265.35
R3 I 5-262- l6(b)(8)(vi)
R3l5-265-1,
40cFR265.37
R3 I 5-262-16(bX9Xiv)
R3 I 5-263-30
R3 I 5-262- I 6(b)(9XivXC)
R3 l 5-263-30
R3l5-263-33
R3l5-265-1,
40cFR265.s6(D
R3l s-262- l6(b)(7)
R3l5-268
R3 l 5-262-16(bX7)
R3 I s-268-7(aX5)
Inspector's Initials: AP
R31s-268-7(aXs) (ii)No
Yes
Yes
No
Yes
Yes
Yes
N/A
Does Not Treat Waste
N/A
Page 4 of 8
January 2018
site 5"11rark Cabinets
Has the facility sent a one-time notice and certification that
each hazardous 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 "Used 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 vear?
lnspector's Initials: AP
R3 I 5-273-15(a)No
EPA ID: UTD063319958
Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
R3 l 5-268-l
R3l5-268-7(a\2)
R3 I s-268-7(a)(3)
R3l5-268-l
R3 ls-268-7(a)(l)
R3l5-268-l
R3 15-268-7(a)(8)
R3r5-273-9(D
R3 l5-273-5(a)
R3l5-273-13(dXl) &
R3 I 5-273-14(e)
R3 l 5-273- 13(dX3)
R3l5-273-13(a)(l) &
R3 I 5-273-14(a)
R3r5-273-r3(f)
R3l5-273-13(e)
Date: 4l2gl20'lg
Yes
Yes
Yes
N/A
N/A
No
N/A
N/A
N/A
Page 5 of 8
January 2018
Site 6s1lpark Cabinets
Manifest Number (box )
Generator EPA ID #
R315-5-2 (box I
Generator information:
Mailing Address (box 5)
Phone number
Transnorter #1 information:
Company Name (box 6)
EPA ID# (box 6)
Transporter #2 information :
Company Name (box 7)
EPA ID # (box 7)
Desienated Facilitv information :
Name and Address (box 8)
EPA ID # (box 8)
Phone Number (box 8)
Waste shinnins requirements:
DOT Description (including proper
name, Hazard class and ID#)
(box 9b)
(box 9a "X'if hazardous materials)
Containers: No & Type (box 10)
Total Quantity (box 11)
Unit - Wt/Vol (box 12)
Waste Codes (box 13)
Special Handling Instructions
(box 14)
Manifest Certifications :
Generator's Signature (box 15)
International Shipments (box 16)
Transporter's Signature (box 17)
Discrepancy Indication (box 18)
Hazardous Waste Report
Management Method Codes
(box 19)
Facility Signature (box 20)
Final Observations and Comments:
lnspector's Initials: AP
EPA ID: UTD063319958
Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS@t
Date: U2gt2O1A
W
Page 6 of 8
January 2018