DSHW-2018-005913 - 0901a0688085c8d2

.1 "i:*o'-ffl"i COMPLIANCE EVALUATION INSPECTIONiI l -.o L.L.- a
', tt>,.st
WASTE MANAGEMENT
& RAOIATION CONTROL
Date of Inspection:
Facility:
June 14,2018
Bio Fire Diagnostics
Facility Address: 515 Colorow Drive
Salt Lake City, Utah 84108
County: Salt Lake
EPA ID # UTROOOO14OO1
Latitude / Longitude: 43.435906-111.935716
Generator Status: LQG
Number of Employees: 1500.
Arrival / Departure Time: 1:30 pm to 4:00pm
Weather Conditions:
Report Prepared By: Alex Pashley
Names of Inspectors: Alex Pashley, Rebecca Troutman
LHD Notifications lDate: Salt Lake County by e-mail on June
13,2018
Facility Notification / Date: June 7, 2108
Applicable Rules: R315: R3l5-262, R315-268, R3l5-
273 and R315-263 of the Utah
Administrative Code
CREDENTIALS
On June 14,2IO8 the inspection team (team) met with and presented credentials to Todd
Robinson and Taylor Perkins.
PURPOSE AND SCOPE
Page 1 of 10
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.
FACILITY DESCRIPTION AND WASTE MANAGEMENT OPERATIONS
Bio-Fire Diagnostics (Bio Fire) manufactures rapid respiratory panel diagnostics test kits
(kits) and diagnostic machines (Film- Array instruments) for the medical industry. Their
kits are designed to detect germs, diseases, and illnesses, such as respiratory (flu), GI
tract infections, blood borne diseases, meningitis, etc.
Bio Fire is located in four different buildings and locations in Salt Lake City. Three of
them are located in the University of Utah research park; one is office space and the other
is for the maintenance of the film anay instruments that have been returned for repair and
calibration. The third building is about a year old and is the headquarters for the entire
operation. It consists of research and development, sales, marketing manufacturing, etc.
A fourth building is located in West Valley which is used primarily for shipping and
receiving of raw materials for manufacturing and for products going out. Also, it has two
large temperature controlled rooms for storage of the kits.
Bio Fire has purchased property located in west side of Salt Lake City, where they are
ready to build another very large manufacturing facility, which is suppose to increase
their manufacturing capability by as much as four times. This inspection was performed
at the new building located at 515 Colorow Drive, Salt Lake City,
Bio Fire recently re-notified from a SQG to a LQG. The main waste stream generated at
Bio Fire is a spent solvent consisting of various concentrations of dicholoroacetic acid(DCA), toluene and water. The waste description for this waste is: ignitable spent non-
halogenated solvent D00l and F005. DCA is corrosive at full concentration. but once
mixed with the toluene and water it loses its corrosivity (has been pH tested), but
becomes ignitable because of the toluene.
Waste solvent from a DNA Synthesizer machine (located in clean room) is pumped via
pipe a few feet, into a small stainless steel container on a daily basis. It is then pumped
via pipe through the wall into a 55-gallon drum, located in a waste accumulation room.
This drum is managed as a 90 day accumulation container. This drum is kept open and
vented to prevent over pressurization due to the pumping of the waste into it. Ii is vented
directly outside. Located in the same clean room is a DNA Synthesizer machine with the
identical waste containers and pipe/pumping configuration. However, the second 55-
gallon accumulation container is located in a different waste storage room. It takes about
a week to fill each 55-gallon container.
It was explained to Mr. Robinson that 90 day accumulation container must be kept
closed at all times, however if the 55-gallon container was managed as a satellite
accumulation container instead, that there is an exclusion that allows it to be left open to
prevent over pressurization. Jeff (last name ?) the supervisor for this area, help design
Page 2 of 10
this system. He indicated that its best if they don't have to open and closed the bung lid
every time they pump it, because it would most likely lead to human error where
someone would forget, which would then create the danger of the container bursting open
and spilling and creating larger problems. It was also explained to Mr. Robinson that the
stainless steel container needed to be labeled with the words hazardous waste and a label
indicating the hazard of the container. He indicated that he would label it immediately
after the inspection. Once the containers are filled, they are moved to another storage
room. AET Environmental picks up two, sometimes three 55-gallons of this waste
weekly.
Mr. Robinson phoned a couple days after the inspection and indicated that they plan on
managing these containers as satellite accumulation containers, where they are allowed to
leave the container open to prevent over pressurization.
Hazardous waste manifests, Contingency Emergency and Preparedness plans (CEPP),
and personal training records were reviewed. And all were in good order. However, the
CEPP had recently been updated and did not include a Quick Reference Guide (QRG).
The requirements of the QRG were explained to Mr. Robinson. Because the QRG is a
new requirement, he was unaware of it. On June 15, 2018 before this report was
prepared, a QRG was developed by Bio Fire and was e-mail to the Division. It was
reviewed and includes everything that is required. Revised copies of the CEPP and QRG
were also sent to the Fire and police departments and Hospital. Emergency phone
numbers were posted throughout the facility.
This Bio Fire location is new and is equipped with LED lights. No waste fluorescent
lamps are generated. Very few if any batteries are used. No used oil is generated.
The only issue discovered during the inspection is the open 90 day accumulation
containers. Discussions with Mr. Robinson and Perkins indicate that they will probably
start managing the 90 day containers as satellite accumulations containers. Because this is
a change in the operations of the manufacturing process, it was to be discussed and
approved by the engineering and operations personal before the change can be made.
However that is the plan.
COMPLIANCE STATUS:
R315-5
5- 1.1 I
5-r.r2
5-2.20
Hazardous Waste Generator Requirements
Determination of Whether a Waste is a Hazardous Waste OK
EPA Identification Numbers UTR000014001
Manifest OK
5-3.30-3.33 Packaging. Labeling. Marking. and Placarding OK
Page 3 of 10
5.3.34
5-4.40
5-4.4r
5-4.42
5-4.43.r
R315-13-1
13-1
R315-16
R315-9
FOLLOW-UP ACTIONS:
Inspector Signature:
ATTACHMENTS:
l. Photos
2. SQG Checklist
SQG Evaluation Form
Accumulation Time OK
container Manasement Bio Fire is going to change their 90 day containers
to satellite accumulation containers.
Tank Management N/A
Preparedness and Prevention OK
Recordkeeping OK
Biennial Reporting Not Reviewed
Exception Reportine N/A
Additional Reporting N/A
Land Disposal Restrictions
Land Disposal Restrictions OK
Standards for Universal Waste
Spill Response
June 2l 2018
Date
Page 4 of 10
Emergency phone numbers are posted at various locations
Waste sharps container
Page 5 of 1,0
Alcohol used to clean workins surfaces
Emergency phone numbers
Page 6 of 10
90 day waste container of DCA/toluene and water from the DNA Synthesizer machine.
Note: open container being vented.
Hazardous waste and accumulation date label for container shown in picture above. Label
was located on back of drum.
Page 7 of L0
Hazatd label for container shown in picture above. Label was located on back of drum.
]"ff[fiifriieus
Second container and labels for spent solvent from DNA Synthesizer machine. Located
in different accumulation room that he first container.
Page 8 of L0
Venting system for the DNA Synthesizer machine wastes
Venting system for the DNA Synthesizer machine wastes
Page 9 of L0
KFull container of DNA Synthesizer machine wastes, waiting to be picked up for disposal
Weekly inspection checklists.
Page 10 of 10
6t21t2018 State of Utah Mail - Quick Reference Guide for BioFire
Alex Pashley <[e-mail]>
Quick Reference Guide for BioFire
1 message
Taylor Perkins <Taylor. [e-mail]>
To: "[e-mail]" <[e-mail]>
Alex.
Fri, Jun 15, 2018 at 10:26 AM
It was nice to meet you yesterday and thank you for helping us tighten up our hazardous waste program in a few areas.
just wanted to inform you that I am working on the Quick Reference Guide now, and it should be reviewed and ready to
send out by Monday. We have already drafted letters to local police, fire, and hospitals, and we will send them out with
the guide attached once | finish. We will send a copy of the guide and letters over to you on Monday so you can view it
and have it for your records. Thank you for your help.
Regards,
Taylor
Toylor Perkins
Heolth, Sofefy, Environment Professionol
BioFire Diognostics, ILC
515 Colorow Drive lSalt Lake City, Utah 84108
Office: 801 -736-6354 x2055
Emoil : Taylor. [e-mail]
Bro*FrRE
www.biofiredx.com
TOFI'bRKntrE
CONFIDENTIALITY NOTICE: This email and any attachments are confidential information of the sender and are for the
exclusive use of the intended recipient. lf you are not the intended recipient, be aware that any disclosure, copying,
distribution, or use of this email or any attachment is prohibited. lf you have received this email in error, please notify us
immediately by returning it to the sender and delete this copy from your system. Thank you for your cooperation.
https://mail.google.com/mail/u l0l?ui=2&ik=4978962dc2&jsver=KY)(XBrjF19M.en.&cbl=gmail_fe_180617.14j4&view=pt&search=inbox&th=1640444e... 111
6t21t2018 State of Utah Mail - Deliverables per recent inspection
Alex Pashley <[e-mail]>
Deliverables per recent inspection
1 message
Todd Robinson <[e-mail]> Mon, Jun 18,2018 at2:44 PM
To: "[e-mail]" <[e-mail]
Cc: Bill Phifer <[e-mail]>, Taylor Perkins <[e-mail]>
Alex,
Per our recent Hazardous Waste inspection and your recommendation, please find attached the Quick Reference Guide
to our Emergency Action/Contingency Plan and the letters sent to the localfire, police, and hospital.
We look forward to receiving your site inspection report. Please don't hesitate to contact me with any follow on questions.
Best Regards,
TR
Todd Robinson
Heolth, Sof ety, Environment Monoger
BioFire Diognostics, ILC
515 Colorow Drive I Solt Loke City, Utoh 84108
Office: 801-736-6354 xl 102
Emoil: Todd. [e-mail]
Blo*FrRE ffi
www.biofiredx.com
CONFIDENTIALITY NOTICE: This email and any attachments are confidential information of the sender and are for the
exclusive use of the intended recipient. lf you are not the intended recipient, be aware that any disclosure, copying,
distribution, or use of this email or any attachment is prohibited. lf you have received this email in error, please notify us
immediately by returning it to the sender and delete this copy from your system. Thank you for your cooperation.
2 attachments
r-fl lrffi Reference Guide.docx
tr fjL,,|t""
letters fire-police-U of U.pdf
hftps://mail.google.com/mail/u l0l?ui=2&ik=4978962dc2&jsver=KY)fiBrjF19M.en.&cbl=gmail_fe_180617.14_p4&view=pt&search=inbox&th=16414a4b..
6t21t2018 State of Utah Mail - BioFire Follow Uo
Alex Pashley <[e-mail]>
BioFire Follow Up
1 message
Taylor Perkins <Taylor. Perki [e-mail]>
To: "[e-mail]" <[e-mail]>
Cc: Todd Robinson <[e-mail]>
Alex,
Wed, Jun 20,2018 at 10:34 AM
ljust wanted to give you a quick update. I spoke with Jeff and the instruments that generate the waste are called DNA
Synthesizers. ln the next day or two l'll get the labels created for SAAs and put the hazardous waste labels on the silver
containers. Once I do that, l'll take pictures of them and send them over to you.
Thanks,
Taylor
Toylor Perkins
Heolfh, Sofety, Environment Professiono/
BioFire Diognostics, [[C
515 Colorow Drive lSalt Lake City, Utah 84108
Office: 801 -/36-6354 x2055
Emoil: Taylor.Perkins@biofi redx.com
BrofrFrRE ffi
www.biofiredx.com
CONFIDENTIALITY NOTICE: This email and any attachments are confidential information of the sender and are for the
exclusive use of the intended recipient. lf you are not the intended recipient, be aware that any disclosure, copying,
distribution, or use of this email or any attachment is prohibited. lf you have received this email in error, please notify us
immediately by returning it to the sender and delete this copy from your system. Thank you for your cooperation.
https://mail.google.com/mail/ulol?ui=2&ik=4978962dc2&jsver=KYXXBrjF19M.en.&cbl=gmail_fe_180617.14j4&view=pt&search=inbox&th=1641e0bd.
BioFire Diagnostics
Quick Reference Guide
To Emergency Action Plan/
Contingency Plan
0611512018
This Quick Reference Guide to BioFire Diagonstics' (BFDX) Emergency Action
Plan/Contingency Plan has been created to comply with Utah Administrative Code (UAC) R3l5-
262-262. As a Large Quantity Generator (LQG) of hazardous waste, BFDX has oeated this
guide to assist local emergency responders (i.e., police departments, fire departments, hospitals,
and State and local emergency response teams) in the event of a hazardous waste chemical spill
at the BFDX facility located at 515 Colorow Drive in Salt Lake City, Utah. Facility details and
emergency contacts are listed below:
Facility Name: BioFire Diagnostics,LLCAddress: 515 Colorow Drive
Salt Lake City, UT. 84108
Emergency Coordinator: Todd Robinson, HSE Manager
Office Phone: [phone] ext.ll02
Mobile Phone: [phone]
Email:Todd. Robinson@biofredx. com
lst Backup EC: Taylor Perkins, HSE Professional
Office Phone:
Mobile Phone:
Email:
Office Phone:
Mobile Phone:
Email:
3'd Backup EC:
Office Phone:
Mobile Phone:
Email:
801-736-6354 ext.2055
435-88 1-75 16
Taylor. Perkins@biofiredx. com
2nd Backup EC: Bill Phifer, VP of Facilities
801-736-6354 ext. 1698
80r-230-2026
Bi ll.Phifer@biofi redx. com
801-736-6354 ext. l2IL
801-556-0346
Brendon Norris, Facilities Manager
Brendon.Norris@biofi redx. com
Emerqencv Response Contractor for Environmental Incidents
Contact Name: Enviro Care
24-hr. Phone: [phone]
BFDX generates the followinghazardous waste listed below:
BFDX has four fire hydrants at its 515 Colorow Drive, with a flow rate of 1418 gallons per
minute (GPM). A map of the locations of fire hydrants as well as the control panel for the fire
alarm system is located at the end of this document.
The following pages contain maps showing the location of hazardous waste generation and
storage, access routes to generation and storage areas, the locations ofnearby businesses and
attractions that may be impacted by an emergency, the location of fire hydrants, and the location
of the main control panel for the firelemergency alarm system.
TypeA.Iame of Hazardous Waste Maximtrm Quantity
Present (eallons)
Unique or Special Medical
Treatment Required?
Ignitable spent nonhalogenated
solvent (EPA waste codes D001 &
F005)
330 No
Hazardous Waste Locations
L't Floor 515 Colorow Drive LEGEND*+.
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BioFire Diagnostics Site Map i.l " .,
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Pharmaceuticals
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Fire Hydrant
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LEG END
' -iff r Fire Hvdrant
I \, water rtow = 1418 GPMl:
Fire Hydrant
|une 15, 2018
SLC Fire Dept.
Attn. Fire Prevention
475 5o.300 E.
SLC, UT. 84TL4
To whom it may concern,
ln accordance with UAC R315 262-262, it is required that we notiff you that we are a Large
Quantity Generator (LQG) of hazardous waste. The waste thatwe generate is classified under EPA
Hazardous Waste Codes D001and F003 - Ignitable Hazardous Waste as derived from spent non-
halogenated solvents and/or spent solvent mixtures/blends.
We make every effort to properly manage our waste, but in the event of an unforeseen emergency
we may require your assistance and response. Attached with this letter is a quick reference guide of our
Hazardous Waste Contingency Plan including a map indicating tlte location of hazardous waste storage at
our site.
Should you have any questions regarding this correspondence please do nothesitate to contact
me.
Health, Safety and Environmental (HSEI Manager
BioFire Diagnostics, LLC
515 Colorow Dr.
salt Lake ciry, uT. 84108
Office Phone: 80I-736-6354 ext, 1102
Email : Todd.Robinson@biofi redx.com
Bro *t RE'390 !\lokoro Woy . Solt Loke Cify. Uloh 8,ll08. USA . 801 736 6354 bcol . I 8m 735 6544 tol-fe . 801 588 0507 for
EirtieDX.com
A BtorrtRtEUx coMPANY
fune 15,2018
SLC Police Dept.
AttN. HDU
P.0 Box L45497
SLC, UT. 84LI4
To whom itmay concern,
In accordance with UAC R315 262-262, it is required that we notiff you that we are a Large
Quantity Generator [LQG) of hazardous waste. The waste that we generate is classified under EPA
Hazardous Waste Codes D001 and F003 - Ignitable Hazardous Waste as derived from spent non-
halogenated solvents and/or spent solvent mixtures/blends.
We make every effort to properly manage our waste, but in the event of an unforeseen emergency
we may require your assistance and response. Attached with this letter is a quick reference guide of our
Hazardous Waste Contingency Plan including a map indicating the location of hazardous waste storage at
our site.
Should you have any questions regarding this correspondence please do not hesitate to contact
me.
Health, Safety and Environmental (HSE) Manager
BioFire Diagnostics, LLC
515 Colorow Dr.
salt Lake city, uT. 84108
0ffice Phone: 80L-736-6354 ext. 1102
Email : [e-mail]
Blo *t RE'390 Wokoro Woy . Soll toke Cih. Uloh 8.1106, USA . 8Ol 736 635,1 bcor . I 800 735 6544 lor-lrac . 8Ol 588 O507 lox
lIoFireDX,com
A BIOMf NITUX COMPANY
Utah Department of Environmental Quality
Division of Waste Management and Radiation Gontrol
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Phone [phone]
Fax [phone]
INSPECTION WORKSHEET
Facility Name:
BioFire Diognostics
EPA lD Number:
uTR00001 4001
Street Address:
515 Colorow Drive
Gity:
Salt Lake Citv
Zip=
84108
Gounty:
Salt Lake Citv
Contact Person:
Todd Robinson. Taylor Perkins
Telephone #:
13857702055
Generator Status:
LQG
Number of Employees:
1500
Date of Visit:
June 14,2018
Evaluators:
Alex Pashley, Rebecca Troutman
Other Perconnel:
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Code
Toluene
Dicholoro acetic acid (DCA)2 to 3 drums each week
LED IGHTS NON HAZARDOUS
NO BATTERIES
a
Estimated Quantity of Hazardous
Waste Generated Per Month
Date: June 1412018
REGEIVED BY:DWTUIRC REPRESENTATIVE:
Name: (Printed)
Signature:
Title:
Name: (Printed)
Signature:
Title:
Waste Stream/Generation Process Estimated Generation Rate Per
Month
Hazardous Waste Code
Estimated Quantity of Hazardous
Waste Generated Per Month
NOTES:
6lt9/20t7
sit., BioFire Diognostics EpA#: urR000014001
Hazardous Waste Inspection
Manifest Checklist
0611412018
Date:
WASTE MANAGEMENT
& RADIATION CONTROL
Manifest Number (box 4)" 01 16649384 q I o71oo'72a(
Generator EPA ID#
Appendix to R3l5-262 (box 1)
Generator information :
Mailing Address (box 5)
Phone Number
I
/
I
I
Transporter # I information:
Company Name (box 6)
EPA ID# (box 6)
Transporter #2 information:
Company Name (box 7)
EPA ID# (box 7)
I I'I
I
I
I
It]
II
r
i
I
Desisnated Facility information:
Name and Address (box 8)
EPA ID# (box 8)
Phone Number (box 8)
I
I
Waste Shipoing reouirements:
DOT Description (lncluding proper
name, Hazard class, and ID #) (box 9b)
(box 9a "X" if hazardous materials)
Containers: No & Type (box l0)
Total Quantity (box I l)
Unit - Wt/Vol (box 12)
Waste Codes (box l3)
Special Handlins Instructions
(box l4)
I
I
Man ifest Certifi cations :
Generator's Signature (box15)
Intemational Shipments (box l6)
Transporter's Signature (box 17 )
Discrepancy Indication (box l8)
Hazardous Waste Report Management
Method Codes (box l9):b t -l I t
:lTI
Facility Signature (box 20)rn I I '*
.A
*7t
Final Observations and Comments:*o-!
Common container codes: DM - metal drum\barrel; DF - fiberbarrel; TT - cargo tank; TC - tank car; DT - dump truck; CM - metal
box\carton (includes roll-offs) Common Units of Measure: G - gallonsl P - pounds: T - tons: Y - cubic vards)
6/19/2017 Page I of I Inspectors Initials
. ar €r!'4o.} --.*,^-.-,,
',x,Nj
WASTE MANA6EMENT
&RADIATION CONTROL
site. BioFire Diognostics EPA#: uTR000014001 Date:June 14,2018
Hazardous Waste Inspection
Personnel Training Checklist
CIA
Facility personnel must successfully complete
classroom instruction, online training or on-
the-job training which teaches them to
perform theirjobs, such that the facility is
operated in compliance with the applicable
hazardous waste management requirements.
R3 1 5 -262- | 7 (a)(7XiXA)
40CFR262. I 7(a)(7)(D(A)
Is the program directed by a person trained in
hazardous waste management procedures?
R3 | 5 -262 - | 7 (a)( 7)( iXB)
40CFR262. I 7(a)(7XiXB)
b\,1-
Does the training teach facility personnel
hazardous waste management and contingency
plan implementation procedures?
R3 | 5 -262 - | 7 (a\(7)( i ) (B)
40CFR262.l 7(a)(iXiXB)
Does the training program include, at a
minimum, the following, where applicable:
l. Procedures for using, inspecting, repairing,
and replacing facility emergency equipment;
2. Key parameters for automatic waste cut-off
systems;
3. Communications or alarm svstems:
4. Response to fires or explosions;
5. Response to groundwater
contamination incidents;
6. Shutdown ofoperations; and
R3 | 5 -262 - t7 (a)(7X iXC)
40CF M62. t7 (a)(7)(iXC)
P3 | s -262- r7 (a)(7 XD(CX I )
40CF R262.r 7 (a)(7XD(CX I )
R3 | s -262- L't (a)(7 XD(CX2)
40CFR262. I 7(a)(7XD(CX2)
R3rs-262-17(a)(7xi)(CX3)
40CFR262, t 7(a)(7XD(CX3)
R3ts-262-17(a)(7XD(CX4)
a0CFR262.r7(a)(7XD(CX4)
R3ts-262-t7(a)(7XD(CX5)
40CFR262. I 7(a)(7XD(CXs)
R3t5-262-t7(a)(7XiXCX6)
40CFR262.17(a)(7XD(CX6)
Have facility personnel successfully completed
the personnel training program within six
months of the date of their employment or
assignment to the facility?
R3r5-262-t7(aX7)(ii)
40CFR262. I 7(a)(7)(ii)
Do the facility personnel receive an annual
review oftheir initial trainine?
R3 | 5 -262- t7 (a)(7)( i i i)
40CFR262.r7(aXTXiii)\l2
December 2017 Page I of2 Inspectors Initials f
sit., BioFire Diognostics EPA#: uTR000014001 June 14,2019Date:
Hazardous Waste Inspection
Personnel Training Checklist
The owner/operator of the facility must
maintain the following documents at the
facility:
I . The job title for each position at the facility
related to hazardous waste management, and
the name of the employee filling each job;
2. A writtenjob description for each position
listedunder#l;
3. A written description of the type and
amount of both introductory and continuing
training that will be given to the employees
listed in #1. and:
4. Records that document that employees have
the training orjob experience required by
paragraphs 265.16 (a), (b), and (c).
R3 | 5 -262- r7 (a)(7)( iv)
R262.t7(a)(7)(iv)
I s-262- I 7(a)(7)(iv)(A)
40CFR262.17(a)(TXivXA)
R3 I 5-262- I 7(a(7)(iv)(B)
40CFM62.17(a)(TXivXB)
R3ts-262-t7(a)(7)(iv)(C)
40CFR262.t7(a)(TXivXC)
l s-262-17(aX7)(ivXD)
l7(a)(7)(iv)(D)
Are training records maintained at the facility
for current employees and for at least three
years for employees that have left the
company?
R.3r5-262-r7(a)(7)(v)
40CFR262.t7(a)(7)(v)
December 2017 Page 2 of2 Inspectors Initials
.io,.*',"o,- Site:g1Oplta
9--'-"
".tN.'
ln/ASTE MANAGEMENT
II RADIATION CONTROL
Diognostics EPAID: UTR000014001
Preparedness and Prevention Checklist
f)Afg June 14,2018
R3ts-262-2st (LQG)
R3 l s-262- l 6(b)(8)(i) (SoG)
R3 I 5-26 l -a I 0(a) (HS,tf)
Is the facility maintained and operated to
minimize the possibility of a fire, explosion, or
any unplanned sudden or non-sudden release
of hazardous waste or hazardous waste
constituents?
R3rs-262-2s2 (LQG)
R3 l 5-262- l 6(b)(8Xii) (SoG)
R3 l5-261-4lo(b) (HSM
R3ts-262-252(a) (LQc)
R3 l s-262- l 6(b)(8)(iD(A) (.sQG)
R3 l s-26 l -4 l 0(b)( l) (HsM)
R3rs-262-252(b) (LQG)
R3 I 5-262- l 6(b)(8XiD(B) (SoG)
R3 l s-26l-410(b)(2) (HSL4)
R3t5-262-252(c) (LQG)
R3 l 5-262- r 6(b)(sXiiXC) (SoC)
R3 I 5-26 l -4 I 0(bX3) (HS,t/)
R3ts-262-2s2(d) (LQC)
R3 l 5-262- l 6(b)(8XiiXD) (SOG)
R3 l s-26 r -4 l 0(b)(4\ (Hstil)
The facility must be equipped with items ( I )'
(4), identified below, unless it can be shown
that hazardous waste managed at the site
would not require the particular kind of
equipment specified.
l. Does the facility have an intemal
communications or alarm system capable of
providing immediate emergency instruction to
its personnel?
2. Does the facility have a device capable of
summoning external emergency assistance to
the facility (phone or two-way radio)?
3. Does the facility have portablelfi ::ill?l;flH'#ill0'".",
necessary for their facfifiyTSpllErfrol
equipment, and decontamination equipment?
4. Does the facility have water at adequate
volume and pressure to supply water hoses, or
foam producing equipment, or automatic
sprinklers, or water spray systems?
R3ts-262-2s3 (LQG)
R3 l 5-262-16(b)(8XiiD (SOG)
R3 l5-261-410(c) (HSM)
Are facility communications or alarm systems,
fire protection equipment, spill control
equipment, and decontamination equipment
tested and maintained to assure its proper
operation in time of an emergency?
Do facility personnel have immediate access to
an internal alarm or emergency
communication device, either directly through
visual or voice contact, while managing
hazardous waste?
R3ts-262-2sa@) (LQG)
R3 I s-262- I 6(b)(8XivXA) (sOc)
R3 I 5-26 l 4 l 0(d)( l) (HS,1.1)
Is there everjust one employee on the
premises while the facility is operating? If
yes, does that person have immediate access to
device capable of summoning external
emergency assistance?
R3ts-262-2s4(b) (LQG)
R3 I s-262- I 6(b)(8Xiv)(B) (sOG)
R3 l s-26 l -4 l 0(d)(2) (HSM)
fan 2018 Page I of2 Inspector's Initials f,[') .
s;,". BioFire Diognostics EPA rD: uTR00001 4001
Preparedness and Prevention Checklist
Date June 14,
2018
Is aisle space maintained to allow the
unobstructed movement of emergency
personnel or equipment (unless aisle space is
not needed for any of these purposes)?
R3ts-262-2ss (LQG)
R3 I 5-262- I 6(b)(8Xv) (.tpc)
rs-261-atfi@) (HStrt)
The facility must arrange the following types
of agreements or arrangements with local
organizations (as appropriate):
l. Has the facility made or attempted to make
arrangements to familiarize local police, fire
departments, and emergency response teams
with the layout ofthe facility, character ofthe
hazardous waste(s) managed, locations where
facility personnel normally work, location offacility entrances and possible evacuation
routes?
2. Has the faiility designated primary
emergency authority to a specific police or fire
department, when more than one police or fire
department might respond in the event of an
emergency?
3. Have agreements with State emergency
response teams, emergency responses
contractors, and equipment suppliers been
made?
4. Have arrangements been made to
familiarize local hospitals with the properties
ofhazardous waste handled at the facility and
the types of injuries or illnesses which could
result from fires, explosions, or releases at the
facility?
R3ts-262-2s6(a) (LQG)
R3 I s-262- l 6(b)(8)(vi)(A) (.tec)
R3 r5-261-410(0(D (HSM
R3 | s -262 -2 5 6 (a)(2) (L Q G)
R3 I 5-262- l6(b)(8)(vi)(A)(If (sec)
R3 I 5-26 I -4 I 0(D( I XD (tls,]r.1)
R3 | 5 -262 -2 s 6 (a) (3 ) (L e G)
R3 I 5-262- I 6(b)(8)(vi)(A)(tII) (,sec)
R3 l s-26 l -4 I 0(0( I Xii) (11S,t/)
R3 I 5-262-2s6(a) (t) (LQG)
R3 I 5-262- I 6(b)(8)(viXAXI) (sQG)
R3 l 5-26 l -4 I 0(0( I )(iii) (HS,r,1)
R3 | s -262-25 6(a) (2) (L Q c)
I s-262-l 6(bX8Xvi XAXil ) (SOc)
R3 I 5-26 l -4 I 0(0( I Xiv) (fl.tM)
Ifany State or local authorities have declined
to enter into such arrangements, has the
facility documented the refusal in the
operating record?
R3ts-262-2s6(b) (LQG)
I 5-262- I 6(bX8XviXB) (.sQc)
3 | s-26 l-4t0(0(2) (HStv\
fan 2018 Page 2 of 2 Inspectorstnitials (
*.x"""--.-
"niNf,"'
WASTE HANAGEHENT8 RADIATION CONTROL
s16. BioFire Diognostics EpA #: UTR000014001 pu1.. June 14
Contingency Plan and Emergency Procedures Checklist
,Vote.' this checklist is applicable fo LQG3 and to HSM handlers (except where indicated) who accumulate >6,000 kg (-13,228 lbs.)
Have copies been distributed to all local police and
fire departments, hospitals, and State and local
emergency response teams that may be called upon
for assistance?
Ls-262-t7(a)(6) (LQG)
Rjts-262-262(a) (LQG)
R3 I s-26 I 420(c)(2) (H S tt4)
Content ofthe Contingencv Plan:
L Does the contingency plan describe the
actions facility personnel will take to minimize the
hazard to human health or the environment when
responding to fires, explosions, or any unplanned
sudden or non-sudden release ofhazardous waste?
2. Does the contingency plan describe
arrangements agreed to by local police and fire
departments, hospitals, contractors, and State and
local emergency response teams?
3. Does the contingency plan list the names,
addresses, and phone numbers (office and
home) ofprimary and all other persons
qualified to act as emergency coordinator?
4. Does the contingency plan include a list of
all emergency equipment at the facility? The list
must be kept up{o-date, and include the location
and a physical description ofeach item on the list,
and a briefoutline ofthe equipment's capability.
5. Does the contingency plan include an
evacuation plan for the facility? This plan must
include a description ofsignal(s) to be used to
begin an evacuation, evacuation routes, and
alternate evacuation routes.
R3ts-262-261(a) (LQG)
R3 r 5-261-420(bXl) (HSn4
R3rs-262-261(c) (LQG)
R3 l s-26 l-420(bX3) (HSn4
ts-262-26t(d) (LQG)
1 s -2 6 | - 420 (b) (4) (H S M)
ts-262-261(e) (LQG)
R3 I 5-26 l -420(bX5) (HS,r.1)
3ls-262-261(f) (LQG)
I s -26 | - 420 (b) (6) (HSM)
Ifthe facility first became subject to these
provisions after May 30,2017, or has otherwise
amended its contingency plan, has it developed and
submitted a quick reference guide ofthe
contingency plan to local emergency responders in
R315-262-262(a), and state and local emergency
response teams that could be called for assistance?
R3ts-262-262(b) (LQG)
Not required - HSM
Ifthe facility has a quick reference guide for its
contingency plan, does it have the following
required elements?:
I . Types/names of haz wastes and the associated
hazard for each haz waste present at any one time
(e.g., toxic paint wastes, spent ignitable solvent,
etc.)
2. Estimated maximum amount of each haz waste
that may be present at any one time
3. Identification of any haz wastes for which
exposure would require unique/special treatment by
medical or hospital staff
4. Map of the facility showing where haz wastes are
generated, accumulated and treated, and routes for
accessing these wastes
5. Street map ofthe facility in relation to
surrounding businesses, schools and residential areas
for the purpose ofgetting to it and/or cvacuating
citizens and workers.
6. Locations ofwater supply (fire hydrant, flow rate)
7. Identified on-site notification systems (alarms)
8. Name of emergency coordinator and7/24-hour
This section not
applicoblefor HSM
handling
R3 1 s -2 62 -2 62 (b) (r) (L Q G)
R3 | s -2 62 -2 62(b) (2\ ( L Q G )
R3 | s -262-262(bX3) (r.QC)
R3 | s -2 62 -2 62 (b) (4) (L Q C )
R3 | s -262-262(bX5) (rOC)
R3 | s -262 -2 62(b) (6) (L Q C )
R3 | s -262-262(b)(7 ) (LQG)
R3 | s -262 -262(bX 8 ) (r, 0C)
January 2018 Page I of3 Inspectors Initials
,,,". BioFire EPA#: uTR000014001 June 14.2018Date:
Contingency Plan and Emergency Procedures Checklist
Note: this checklist is applicable fo LQG's and to HSM handlers (except where indicated) who accumulate >6,000 kg (-13,228 lbs.)
Does the facility have a least one employee
on-site or on-call at all time who is qualified to
act as the emergency coordinator?
Does the contingency plan include procedures
for activation of the internal alarm by the
emergency coordinator?
Does the contingency plan include provisions
for notifing the appropriate State and\or local
response agencies?
R3r5-262-264 (LQG)
R3 | s -26 r - 420 (e) (H S Ia)
R3 | 5 -262 -26 s (a)(t) (L Q G)
R3 | s -26 r - 420(fX I Xi ) (ss,t[)
R3 | 5 -2 62 - 26 s (a) (2) (L Q c)
R3 l 5-26 l -420(0( I )(ii) (11s,tf)
Does the contingency plan outline the
procedure(s) that the emergency coordinator
will follow to immediatelv identifv the
character, source, amount, and extent of
released material?
3rs-262-26s(b) (LQG)
3 | s -26 r - 420 (f)(2) (H S i4)
Does the contingency plan include procedures
for the emergency coordinator to follow in
order to assess possible hazards to human
health or the environment?
R3rs-262-26s(c) (LQG)
R3 l 5-26 l -420(0(3 ) (/1,5,11)
If it is determined that the incident could
threaten human health or the environment,
outside the facility, the emergency coordinator
must notify the appropriate local, State and
Federal agencies. Does the contingency plan
include provisions for notifying the
appropriate agencies? Do the notification
measures include information to be reported
(name and telephone # of reporter, name and
address of facility, name and quantity of
material(s) involved, extent ofinjuries, and
possibility of exposure outside the facility),
and identify the National Response Center
and the State as parties to be notified?
R3rs-262-265(d) (LQG)
R3 I 5-26 I -420(D(4) (HS/t/)
Does the plan include procedures to prevent
the spread of the incident to other hazardous
waste/material at the facility?
R3rs-262-26s(e) (LQG)
R3r5-261-420(D6) @SA oU-
Are measures included to monitor for leaks,
pressure buildup, gas generation, or ruptures in
valves, pipes, or other equipment, when it is
necessary to shut-down operations as a
response to an incident?
R3ts-262-26s(f) (LQC)
R3 | s -26r -420(f)(6) (H S IO
R3rs-262-26s(g (rQG)
R3 l 5-26 1 -420 (f)(7) (H S M)
Does the contingency plan provide procedures to
follow to manage the hazardous waste/material
generated as a result ofan incident?0 ltt
Following implementation of the contingency
plan, are provisions included to ensure that in
the affected area(s):
l. No waste that may be incompatible with the
released material is treated, stored, or disposed
of until the cleanup is complete.
2.That all equipment listed in the contingency
plan is cleaned and fit for use prior to
resuming activities at the facility.
R3 | s -262-265(hX I ) (rqc)
R3 l 5-26 I -420(fX8Xi) (HS,l.1)
R3 | s -262 -26 5 (h)(2) (L g G)
R3 | s -26 | -420(f)(8)(i i) (Hs,t[)
January 2018 Page 2 of 3 Inspectors Initials
Site:EPA #:
Contingency Plan and Emergency Procedures Checklist
Date:
Note: this checklist is applicable to LQG's and to HSM handlers (except where indicated) who accumulate >6,000 kg (-13,228 tbs.)
The contingency plan must include
provisions for recording the incident
requiring implementation of the
contingency plan and specifying
information that will be recorded and
reported. The requirements are as follows:
L Will a written report on the incident be
provided to the Utah State Department of
Environmental Quality within l5 days?
2. The following information needs to be
recorded and reported:
a) The name, address, and telephone # ofthe
owner/operator;
b) The name address, and telephone # ofthe
facility;
c) Date, time, and type of incident;
d) Name and quantity of material(s) involved;
e) Extent of injury, if any;
f) An assessment ofthe actual or potential
hazard to human health or the environment;
and
g) An estimate of the quantity and disposition
ofrecovered material(s) that resulted from the
incident.
R3rs-262-26s(i) (LQG)
R3 | s -26| -420(0(9) (t1st4)
3r5-262-26s(i) (LQC)
3 | 5 -26 | - 420 (f) (e) (H S M)
R3 l5-262-265(D(r)thlu (D(7) (zqo
R3 l 5-26 l-420(0(exi) thlu (o(gxviD
HSM Only: Are all employees thoroughly
familiar with proper waste handling and
emergency procedures relevant to their
responsibilities during normal facility
operations and emergencies?
R3t5-26r-420(d @SM)
January 20 I 8 Page 3 of3 Inspectors Initials
]une 15, 2018
U of U Public Safety
t735F,. South Campus Drive
SLC, UT. 84LL2
To whom it may concern,
In accordance with UAC R315 262-262, it is required that we notiff you that we are a Large
Quantity Generator (LQG) of hazardous waste. The waste that we generate is classified under EPA
Hazardous Waste Codes D001and F003 - Ignitable Hazardous Waste as derived from spent non-
halogenated solvents and/or spent solvent mixtures/blends.
We make every effort to properly manage our waste, but in the gvent of an unforeseen emergency
we may require your assistance and response. Attached with this letter is a quick reference guide of our
Hazardous Waste Contingency Plan including a map indicating the location of hazardous waste storage at
our site.
Should you have any questions regarding this correspondence please do not hesitate to contact
me.
Health, Safety and Environmental (HSE) Manager
BioFire Diagnostics, LLC
515 Colorow Dr.
Salt Lake City, UT.84108
Office Phone: 80L-736-6354 ext. 1102
Email : [e-mail]
Blo *l RE'390 Wokoro Woy . Solt loke Cily. Utoh 8a108, USA . 801 736 635.1 locol . | 80o 735 6544 lol-lrca r 8Ol 588 05O7 tox
BioF?eDX.com
A EIOMERITUX COMPANY
6r21t2018 State of Utah Mail - BioFire SAA Update
Alex Pashley <[e-mail]>
BioFire SAA Update
2 messages
Taylor Perkins <Taylor. Perki [e-mail]>
To: "[e-mail]" <[e-mail]>
Cc: Todd Robi nson <Todd. Robinson@biofi redx.com>
Alex,
Thu, Jun 21,2018 at2:42PM
' : v r',','::- ..'i...,t :-."'ct-:
,r J tr., : ;lr:n I.q1"' :
JUli 2 I 2018
ljust wanted to give you a quick update to our changes here. We have updated the rooms where the waste is generated
to satellite accumulation areas, as seen in the pictures attached. Once full, drums will be closed and moved to the central
accumulation area. We have also labeled the intermediate containers with hazardous waste labeling, also shown in the
attached pictures. We have also updated our quick reference guide to specifically name the chemical constituents of our
waste stream. lf you have any other comments/questions, please don't hesitate to ask.
Thanks,
Taylor
Toylor Perkins
Heolth, Sofety, Environment Professiono/
BioFire Diognostics, LLC
515 Colorow Drive lSalt Lake City, Utah 84108
Office: 801-236-6354 x2055
Emoil : Taylor. Perkins@biofi redx.com
Blo*FrRF &
www.biofiredx.com
CONFIDENTIALITY NOTICE: This email and any attachments are confidential information of the sender and are for the
exclusive use of the intended recipient. lf you are not the intended recipient, be aware that any disclosure, copying,
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4 aftachments
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6t21t2018 State of Utah Mail - BioFire SAA Uodate
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Alex Pashley <[e-mail]>
To : Taylor Perki ns <Taylor. Perkins@biofi redx.com>
thnaks, Looks good
lQuoted text hiddenl
Alex Pashley lEnvironmentalScientist I Hazardous Waste Section
Phone:[phone]
7l i",':,.,..::.,:.tl^I' WASTE MANAGEMENT
"lL & RADrArloN coNrRoL
195 North 1950 West Salt Lake City, Utah 841144880
Email: [e-mail]
Thu, Jun 21,2018 at 3:03 PM
https://mail.google.com/mail/u l0t?ui=2&ik=4978962dc2&jsver=KYXXBrjF19M.en.&cbl=gmail_fe-180617.14j4&view=pt&search=inbox&th=16424290... 212
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