DSHW-2024-006901

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Small Business Assistance Program
P.O. Box 144880
Salt Lake City, Utah 84114-4880
SMALL BUSINESS ASSITANCE FORM
Facility Name:crui O;l fnc-EPA ID Number: trtAOOOl
SiieefAaoress: It6o -t l qtWS"WtA<CffzW l
Gounty:So laK,Contact Person Lgq_t_,tolr-x?e
, Date of Visit: illqo, 17. AOOi
Generator Status:wt9]'1"'Evaluators:
Other Personnel:C'
Waste Stream/Generati-;n Process Estimated Generation Rate Per
Month
Hazardous Waste Code
,.1 ov\q-
Estimated Quantity of Hazardous
Waste Generated Per Month
RESPONSE: YES- *rrX RESPONSE Requested BY
COMMENTS:s+L 1r4r
This SMALL BUSINESS ASSISTANCE FORM notes areas where your hazardous waste management practices may not meet the regulatory
requirements of the Utah Solid and Hazardous Waste Management Rules. lf a RESPONSE is requested, you are asked to address the areas
that you have corrected to the Division by the response date.
lf you have further questions or would like to discuss these issues with the evaluators or their supervisor, you may contact them during
business hours: at [phone]. ltems that are to be submitted may be mailed to the address at the top of this page.
RECEIVED IJ
Name: (Priri DnuE 'rtrY Evaluator:
Name: (Printed)
Title: Environmenta
,.{
Signature:Signature:
Title: _dFtiee
3lt3l07
Date:
Scientist
Page - 1 of 6
Example of Emplovee Traif Loq (this is onlv an example andfst be adapted specificplly to
your facility) '7
XYZ Companv Emplovee Traininq Loq
Date: April 9, 2A02
Time: 10:00 am to 11:00 am
Discussion lead by: John Doe, Health and Safety Coordinator
Topics Discussed
l. Hazardous Waste Accumulation Time
a. Do not store hazardous wastes for longer than 180 days on site.
b. Label each container or tank with the words "Hazardous Waste."
ll. Use and Management of Gontainers
a. Maintain a log weekly on the hazardous waste containers; are the containers
closed, labeled, dated and in good condition. lf not, please contact the
emergency coordinator in order to rectify the problem.
lll. Other topics as discussed
a.
b.
Employee Name (Please Print)
1.
Employee Signature
2.
3.
4.
5.
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Items that are checked on the ,,"" ,l#,3o=fl:ylttt-?Li:#::,=rli"Til,#"T,1l., the Utah sorid and Hazardous
_ Waste Regulations and require your attention.
1. R315.5.1.11 DETERMINATION OF WHETHER A WASTE IS HAZARDOUS
ACTION NEEDED:
_z R315-5-1.12 NOT|FICAT|ON AND EPA HAZARDOUS WASTE IDENT|FICATION NUMBERS
_ a. lf you generate between 1 00 and 1 000 Kgs (220-22001bs) of hazardous waste per month or up to 1 Kg of acutely hazardous
waste, you are classified as a Small Quantity Generator (SQG) and you must notify the Executive Secretary of the Utah Solid and
Hazardous Waste Control Board and obtain an EPA ld Number. This ls accornplished by notifying the Utah Division of Solid and
Hazardous Waste at [phone].
_ b. lf you are a small quantity generator, you must obtain an EPA ld Number in order to offer hazardous waste for management to a
transporter or to a treatment, storage and disposal facility (TSDF) that has an EPA ld Number.
ACTION NEEDED:
_3. R315-5-2 MANIFESTS
_ a. Only use approved manifest form 8700-22 and 8700-22A when offering hazardous wastes for transport to a TSDF.
_ b. Designate another facility or instruct a transporter to return wastes if they are undeliverable.
_ c. Fill out all applicable sections of the manifest.
_ d. Use a contractual disposal agreement only if a generation rate is less than 1000 Kg/month (SQG or less).
_ e. Keep copies of contractual agreements for three years after service ends.
ACTION NEEDED:
_4. R315-5-4 RECORD KEEPTNG
-
a. Keep copies of manifests for three years.
_ b. Keep all records, including determination of generation rates, waste characterization documentation, disposition, etc., for three years.
ACTION NEEDED:
_ 5. R315-s-4.42 EXCEPTTON REPORTING
_ a, lf TSDF does not return generator's original copy of manifest within 60 days, a generator must submit a letter stating so and a copy of the
manifest to the Executive Secretary of the Utah Solid and Hazardous Waste Control Board.
ACTION NEEDED:
_6. R315-5-3 PACKAGTNG, LABELTNG MARKTNG AND PLACARDTNG
_a. Package, label and mark waste in accordance with DOT 49 CFR prior to shipment.
ACTION NEEDED:
_7. R315-5-3.34 ACCUMULATTON TIME
_ a. Do not store hazardous wastes for longer than 180 days or 270 days, if applicable, without a permit.
_ b. Do not exceed 6000 Kg of hazardous wastes stored at your facility at any time.
_ c. Mark the date the accumulation period began on each container of hazardous waste. Satellite accumulation containers are the
exception.
_ d. Label each tank and containerwith the words "HAZARDOUS WASTE" while it is being use to accumulate hazardous wastes.
_ e. Designate and authorize an emergency coordinator(s) who is (are) readily available by some means at all times.
_ f. Post the following information next to each telephone at the facility: name and telephone number of the emergency coordinato(s)
location(s) of fire extinguishers, spill control equipment, fire alarms, telephone number of the local fire department (or equivalent
emergency response for facility).
_ g. Ensure that all employees are familiar with hazardous waste handling and emergency procedures.
_ h. The emergency coordinator must respond appropriately to emergencies that have the potential of involvlng hazardous waste (s).
ACTION NEEDED:
_ 8. R315-9 SPTLL RESPONSE
_ a. Take appropriate action to minimize threats to human health and the environment by notifying the Utah State Department of
Environmental Quality at (801 ) 536-4123 or I [phone] (24 hour number) if more than 1 Kg of acutely hazardous waste,
100 Kg of hazardous waste, 25 gallons of used oil or material which when spilled becomes hazardous waste, as specified in notify
the National Response Center when applicable and provide the appropriate information listed in R315-9, in the spill report.
ACTION NEEDED;
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These are onlv examples tl3[will help you to comply with the rgulations. You must
adapt the following informatf and it make specific to yggafacit r
SEE #10c
Today's date:
Letters to: Your Hospital
Your local Police Department
Your local Fire Department
Dear Sir or Madame:
ln accordance with 40 CFR 265 Subpart C, it is required that we notify you that we generate
hazardous waste(s). The waste(s) that we generate is (are) ...(examples might be: waste
paints, paint sludges, Methyl 'Ethyl Ketone, Acetone, other solvents, acids, bases, listed
wastes, etc).
We make every effort to properly manage our wastes, but in the event of an emergency we
may require your assistance. ln the event of an unforeseen emergency, you may be required
to respond.
Your name and title
Your company name
See #7c and 7t
IN CASE OF AN EMERGENCY DIAL 911
EMERGENGY COORDINATOR IS CARL GAREFUL -
EXT 2536
FIRE EXTINQUISHERS LOGATION MARKED ON THE WALL
SPILL CONTROL EQUIPMENT LOGATED AT TIME CLOCK
UNIVERSAL VI/ASTE
MERCURY CONTAI NING LAMPS
DATE:
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UTAH oeQrraLL BUSTNESS AssrrAr.rce rO$ontinued
_s. R31s-7-16 USE AND MANAGEMENT OF CONTATNERS
_ a. Hold hazardoLrs wastes in containers that are in good condition.
_ b, Siore hazardous ,vastes in containers that are compatible wilh the waste.
_ c. Keep hazardous waste containers in a comptetely closed condition excepr when adding or removing wastes.
_ d. Dc not open. handle or stcre containers of irazardous waste in a inanner which may cause a release.
_ e. lnspect containers of hazardous waste at iease weekiy to lock for signs of ieakage or deterioration. A log should be kept.
_ f. Dc not store incompatible hazardous wastes in ihe same container.
_ g. Do not store wastes in containers that previously held an incompatible material without cleaning it first.
_ h. Separate incompatible wasies by means of a dike, berm or other method.
ACTION NEEDED:
_10. Rs15-7-1 0 PREPAREDNESS AND PREVENTTON
_ a. You must operate your facility in such manner that MINIMIZES the possibiliiy of fire, explosion or any unplanned release.
_ b. You must have the following preparedness and prevention equipment unless the wastes you store do not pose the hazards that the
equipment is designed to respond to: lnternal communimtions or alarm capable of instruction (such as an intercom), a device
capable of summoning outside emergency assistance (such as a direct alarm to the fire department or a telephone), portable fire
extinguishers, water at adequate pressure and volume to supply fire fighting needs, alarms and communication devices accessible to
to personnel where they are handling hazardous wastes.
_ c. You must maintain and test, where necessary, all communication systems; fire, spill response, decontamination and protective
equipment.
_ d. Make maintain aisle space to allow unobstructed movement of personnel and emergency equipment.
_ e. Make anangements with local fire, police and hospitals to respond to emergency situations at your facility. Maintain documentation of
notification letters, responses or lack of responses from these agencies.
_ f. Document refusals by authorities to emergency arrangements.
ACTION NEEDED:
_11. R3{5.13 LAND DTSPOSAL RESTRTCTTONS (LDR)
_ a. lf you treat your hazardous wastes to render them non-Land Disposal Restricted, you must develop and follow a written waste
analysis plan. This waste analysis plan must be based on a laboratory analysis of the waste and must contain all necessary elements
including frequency. The waste analysis plan must be submifted to the Executive Secretary of the Utah Solid and Hazardous Waste
Control Board at least 30 days prior to treatment.
_ b. Maintain an assessment of LDR status on file for each hazardous waste generated at the facility.
_ c. A notice and certification that each waste is either land disposal restricted, or if it is restricted, that it is land disposable after treatment, must
accompany the original manifested shipment of hazardous waste or when the waste stream changes.
_ d. Maintain all LDR Documentation for three years after the waste is shipped off site.
ACTION NEEDED:
_12.R315-16 UNTVERSAL WASTES, FI_UORESCENT LTGHT TUBES
-
a. High mercury fluorescent light tubes must be recycled or disposed as hazardous waste. Any broken tubes must be managed as a hazardous
waste but can still be recycled. Do not dispose of tubes in the regular trash or in the dumpster._ b. Label either the waste tubes or container holding the tubes as 'UNIVERSAL WASTE-MERCURY CONTAINING LAMPS'.
ACTION NEEDED:
_13. R315-15 STANDARDS FOR USED OtL GENERATORS
_ a. Use permitted used oil transporter, (name, address and telephone number of transporter).
_ b. Storage tanks and associated piping in good condition and labeled "Used Oil".
__ c. Burn only their own used oil in vented space heater with a max. cap. of 0.5 million BTUs or in (>0.5 cap.heater).
-
d. Hot drain punctured oil filters. Method of filter disposal. Discarded in trash or recycled. lf recycled, by whom?
_ e. Clean up any used oil spills and any contaminated soil.
ACTION NEEDED:
14. OTHER ACTIONS NEEDED:
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n:#f3'#}:jf-ilply
with the rrylations. You must ad?pt the
CONTAI NHR MANAGEMENT LOG
lnspector's
Narne
Are containers
labeled with the
wor"ds
HAZARDOUS
WASTE?
ls accurnulation
date marked on
all hazardous
waste
containers and
is that date less
than 180 days
old?
Are hazardous
waste
containers
closed and are
all bungs and
bung rings
secu re?
lf any columns are mark:ld NO
describe what was dc':e to
bring the container into
compliance?
MANIFEST MANAGEMENT LOG
If any columns are marked
NO, what is being done to
bring manifest file into
compliance?
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