DSHW-2018-004585 - 0901a06880825f34

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WASTE MANAGEMENT
&RADIATION CONTROL
COMPLIANCE EVALUATION INSPECTION
Date of Inspection:
Facility:
Facility Address:
County:
EPA ID #
Latitude / Longitude:
Generator Status:
Number of Employees:
Arrival / Departure Time:
Weather Conditions:
Report Prepared By:
Names of Inspectors:
LHD Notifications I Date:
Facility Notification / Date:
Applicable Rules:
May 5,
Macy's South Town
10600 South 110 West
Sandy Utah, 84110
Salt Lake County
uTR000014084
40.562901-11t.894914
SQG
unknown
12:20 pm to 1:45pm
Sunny, about 50"F
Alex Pashley
Alex Pashley
May 2,2018
Unannounced
R315: R3I5-262, R3l5-268, R315-273 and
R315-263 of the Utah Administrative Code
CREDENTIALS
retg
On May 3,?fA9 the inspector met with and presented credentials Ed Gulbransen.
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 of 10
FACILITY DESCRIPTION AND WASTE MANAGEMENT OPERATIONS
Macys is a chain of large department stores that carries a large verity of products such as:
clothing, house wares, cosmetics, basic tools, spray paints, and various other items that
may be a hazardous waste when disposed of.
Hazardous wastes are generated when items from the store become damaged, off spec, or
are returned and need to be disposed of, and are determined to be hazardous. The
majority of the wastes are cosmetics, i.e., aerosols, hair spray, nail polish and perfume.
Macy's corporate has set up a new hazardous waste management program that will be
used at all Macy stores. All items sold at Macys have had a hazardous waste pre-
characterization, in the event they become a waste. When the item is scanned, the
computer system has instructions how the waste is to be managed, i.e., labeled, dated, and
the container that the waste is be place in. Wastes are placed in to separate totes based on
waste compatibility. All containers were properly labeled, including the new hazard label,
dated, and were closed.
Macy's manages their waste under the SQG rules, although, only VSQG amounts of
wastes are being generated. Previous to the new management system, all cosmetics were
being accumulated in a 55-gallon drum and shipped off every 180 days. Every time the
drum was shipped off for disposal, they were paying for a full drum when it was less and
% full. Wastes will now go to 6lean Harbors for disposal.
Macy's had several years of hazardous waste manifests on file. All manifests were in
good order. Emergency phone numbers were posted.
No problems were noted.
COMPLIANCE STATUS:
R315-5 Hazardous Waste Generator Requirements
5-1.11 Determination of Whether a Waste is a Hazardous Waste OK
5-1.12 EPAIdentificationNumbersUTR0000140S4
5-2.20 Manifest OK
5-3,30-3.33 Packaging. Labeling. Marking. and Placarding OK
5.3.34 Accumulation Time OK
Container Management OK
Tank Management N/A
Preparedness and Prevention OK
Page 2 of 10
5-4.40 Recordkeeping OK
5-4.41 Biennial Reporting OK
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
May 8.2018
Page 3 of 10
New waste management containers
Page 4 of 10
Hazardous waste labels include the hazard of the waste, and type of wastes for each
particular container. Accumulation dates have not yet been marked, because they haven't
had any wastes place into them yet.
Hazardous waste labels include the hazard of the waste, and type of wastes for each
particular container. Accumulation dates have not yet been marked, because they haven't
had any wastes place into them yet.
Page 5 of 10
Hazardous waste labels include the hazard of the waste, and type of wastes for each
particular container. Accumulation dates have not yet been marked, because they haven't
had any wastes place into them yet.
Page 6 of 10
Hazardous waste labels include the hazard of the waste, and type of wastes for each
particular container. Accumulation dates have not yet been marked, because they haven't
had any wastes place into them yet.
Universal waste lamps
Page 7 of 10
Universal batteries
Spill Kit.
Page 8 of 10
55-gallon of waste cosmetics and perfumes.
Label for the 55-gallon of waste cosmetics and perfumes.
Page 9 of L0
Emergency phone numbers are posted in the waste management area.
Page 10 of 10
ttffi: site Macv's south rown EPA ID: UTR000O1 4OB4 Datez5l3l2018
-*-1'"1:,i3il1'iJ1it'. Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
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?
Excepfion Renorting
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 vears?
F.3l5-262-ll
R3l5-261-3
R3l5-262-r l(f)
R3l5-262-18(a)
R315-262- I 8(c)
P.3ts-262-r8(dxl)
R-3r5-262-20(a)
F.3rs-262-20(e)(l)
F-3rs-262-20(eX2)
F-3r5-262-40(a)
R3r5-262-40(c)
R3l5-262-l l(0
R3r5-262-41(a)
R3rs-262-42(b\
Inspector's Initials:
F.3r5-262.40(b)N/A
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Page 1 of8
January 2018
sitt M"cy's South Town EPA ID: urRooool 4oB4
Hazardous waste Inspection - Small Quantity Generator checklist
Date: SBl2Olg
Packagins. Labelins. Marking. and Placarding
Are hazardous waste containers packaged, labeled, marked,
and placarded in accordance with DOT 49 CFR prior to
shipment?
Accumulation Time
l. 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 eood condition?
R.3r5-262-30,
R.3t5-262-31,
R3t5-262-32, &
R3l5-262-33
R.3rs-262-16(b),
R3l5-262-16(c),
& R3l s-262-r6(d)
R3l5-262-16(bXl)
R3l5-262-16(bX6XiXC)
R3l 5-262-16(bX6XiXA) & (B)
R3 l5-262- I 6(bX9Xi)
R3 l 5-262-16(bX9XiiXA-C)
R3rs-262-r6(bXeXiii)
R3 I 5-262-16(b)(e)(iv)(A
R3 l5-262-16(bX2Xi)
R3 l5-265-1,
40cFR265. l7l
lnspector'sfnitials: /&P
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Page 2 of 8
January 2018
sit" M"ay's South rown EPA ID: UTR00001 4084
Hazardous Waste Inspection - Small Quantity Generator Checklist
Date: 51312018
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?
PreDaredness 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 I"iti"f* AQ
R3 l 5-262- l6(bX2XiD
R3 I 5-265-1. 40CFR265. I 72
R3 l 5-262- l 6(b)(2XiiixA)
R3l5-265-1,
40CFR265.173(a)
R3 r s-262-16(b)(2xiiiXB)
R3l5-265-1,
40cFR265.173(b)
R3 I s-262-16(b)(2)(iv)
R3 l5-265-1,
40cFR265.t74
R3 I s-262- I 6(b)(v)(A)
R3l5-265-1,
40CFR265.177(a)
R3 I 5-262-16(b)(2XvXB)
R3l5-265-1,
40cFR265.177(b)
R3 l5-262-16(bX2Xv)
(c) R3l5-265-1,
40CFR265.177(c)
R3ls-262-r 6(bX8Xi)
R3 I 5-265-1.
40cFR265.31
R3 r 5-262- l 6(bxsxiD
R3l5-265-1,
40cFR265.32
R3 l s-262- l 6(bXSXiii)
R3l5-265-1,
40cFR265.33
n
V
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Page 3 of8
January 2018
Site Macy,s South Town EPA ID: UTR00OO1 4OB4
Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
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] 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?
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 meet
Land Disposal Restriction standards found at 268.40?
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 representative
sample of the waste being treated.
Is the plan available on-site in the facility files?
R3 I s-262-16(b)(8)(iv)'R3ls-265-1,
40cFR265.34
R3 ls-262-16(b)(8)(v)
R3 l5-265-1,
40cFR265.35
R3 I s-262-16(b)(8)(vi)
R3 I 5-265-1.
40cFR265.37
R3 1s-262-16(b)(9)(iv)
R3 I 5-263-30
R3 I 5-262-16(b)(gXivXC)
R3 I 5-263-30
R3 I 5-263-33
R3l5-265-1,
40cFR26s.s6(D
R3 l s-262- l 6(bX7)
R3l5-268
R3 l 5-262-16(bX7)
R3 ls-268-7(a)(s)
Inspector's Initiak: A{2
R3 l s-268-7(aX5Xii)N/A
Date: Slgl2019
Yes
Yes
Yes
Yes
N/A
N/A
Does Not Treat Waste
N/A
Page 4 of 8
January 2018
site Y".t's South Town
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 chanses?
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 year?
Inspector's rrrnrurrr K
R3l5-273-15(a)N/A
EPA ID: UTR00001 4084
Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
R3l5-268-l
R3 I s-268-7(a)(2)
R3 I s-268-7(a)(3)
R3l5-268-l
R3 ls-268-7(aXl )
R3l5-268-l
R3 l5-268-7(a)(8)
R3l5-273-9(i)
R3 I 5-273-5(a)
R3l5-273-13(dXl) &
R3 I 5-273-14(e)
R3 l 5-273-r 3(dX3)
R3l5-273-13(a)(l) &
R3 l5-273-14(a)
R3ls-273-13(0
R3ls-273-13(e)
Date: 51312018
Yes
Yes
Yes
Yes
Yes
No
Yes
N/A
N/A
Page 5 of8
January 2018
Site N/ssy's South Town EPA ID: UTR00O01 4OB4
Hazardous waste Inspection - small Quantity Generator checklist
Date: SBl2O1'g
Manifes! Number (box )
Generator EPA ID #
R315-5-2 (box I
Generator information :
Mailing Address (box 5)
Phone number
Transporter #1 information:
Company Name (box 6)
EPA ID# (box 6)
Transporter #2 information:
Company Name (box 7)
EPA ID # (box 7)
Desisnated Facilitv information :
Name and Address (box 8)
EPA ID # (box 8)
Phone Number (box 8)
Waste shippinq 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 l6)
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:
Inspector's
+ 1o3o7oo3 # orr287g7Loa
Page 6 of 8
January 2018
si" M"ry's south rown EPA ID: urRooool 4oB4
Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
Requirements for SOGs that Accumulate Hazardous
Waste in Tanks
l. 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 ofthe 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. Data from 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 weeklv to detect erosion or
signs of leakage.
R3 l5-262-16(b)(l) & (bX3)
R3 l s-262-16(b)(3XiD(A)
R3ls-265-1.
40CFR265.199(a)
R3 l 5-262-16(b)(3XiD(B)
R3l5-265-1,
40CFR265.194(a)
R3 l 5-262-l 6(b)(3)(ii)(C)
R3 l 5-265-1,
40cFR265.194(bX3)
R3 l s-262-l6(b)(3xiD(D)
R3l5-26s-1,
40cFR265.194(bX2)
R3 ls-262-16(bX3)(iiD
R3 l 5-265-1,
40CFR265.19s(a)
R3 ls-262-16(b)(3XiiiXA)
R315-265-1,
40cFR265.195(bX l)
R3 ls-262-16(b)(3XiiiXB)
R3l5-265-1,
40CFM65.l9s(a)
R3 l 5-262- l6(b)(3XiiD(C)
R3 l5-265-1,
40cFR265.195(b)(2)
R3 l s-262- l 6(b)(3XiiD(D)
R3 l5-265-1,
40cFR265. l9s(bX3)
R3 r 5-262-l 6(b)(3XiiD(E)
R3l5-265-1,
40cFR26s.195(bX3)
Inspector's Initiufrr -K
Date: Slgt211g
Page 7 of8
January 2018
Macy's South TowrE EPA ID: UTR00001 4084 Date: Slgl201g
NOTES:
Hazardous Waste Inspection - Small Quantity Generator Checklist
Page 8 of 8
January 2018
Inspector's rnnrut' Sf
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 FACILIry INFORMATION FORM
Date: 5t3t2018
RECEIVED BY:DWMRC REPRESENTATIVE:
Name: (Printed);$
Signature:
Title:
Name: (Printed)
Signature:
Title: