DSHW-1992-002222 - 0901a0688013ff62

HAZARDOUS WASTE INSPECTION REPORT
DSHW TN
1992.20400
Date of Inspection:
Facility:
Facility Contact:
Notification:
Applicable Regulations:
Type of Inspection:
Participants:
Weather Conditions:
Time In:
Time out:
Report Prepared by:
September 8 and 9, 1992
Hercules Aerospace Company
Bacchus Works
Magna, Utah 84044-0098
Richard Anderson,
Manager Environmental Engineering
Generator and
Treatment, Storage and Disposal
R315-2, R315-4, R315-5, and R315-7
CEI
BIN Wallner (TU, DSHW
Jon Parry, DSHW
Rolf Johnson, DSHW
Janice Pearson, EPA Region Vlll
John Waugaman, Hercules
George Gooch, Hercules
Richard Anderson, Hercules
Clear, warm 75°
0855 0850 0923
1630 1630 1300
Bill Wallner
Facilitv Descriotion
Hercules Is a Delaware Corporation doing business in Utah. Hercules began operating
the Bacchus Works as a producer of commercial blasting powder In 1915. The plant
was renovated, beginning In 1958, Into a modern self-sufficient solid rocket propulsion
facility with research, development, and production capability. In 1971 Hercules
began manufacturing carbon fiber, at Plant 3.
Credentials. Puroose and Scooe
The Inspection team met with Hercules personnel and presented credentials. It was
explained that the purpose of the Inspection was to review facility records, and
conduct an inspection of hazardous waste management areas. The inspection was
pre-arranged with Hercules' environmental personnel. In addition to representatives
from Hercules and the State Division of Solid and Hazardous Waste, a representative
1
from EPA Region Vlll came along on the Inspection. The Salt Lake City/County Health
Department was invited to participant in the Inspection but choose not to attend.
Waste Streams. Manaoement Activities
Hercules has Interim status for the storage and treatment of hazardous waste.
Hercules acquired Interim status, to allow themselves the ability to store hazardous
waste generated on-site and accept hazardous waste, for storage, from other Hercules
owned manufacturing operations In the State and to operate the 'Burn Grounds.' The
Bacchus Works operates, the 'Burn Grounds,' a hazardous waste treatment area used
for the open burning/open detonation (OB/OD) of waste explosives and explosive
contaminated materials. Hercules also has five Interim status storage areas, these
sites are designated as HS-1, HS-3, ES-1. Resthouse 1 and Building 4643. HS-1 and
HS-3 generally store non-explosive hazardous waste. ES-1 Is the facility's designated
storage site for explosive waste. Resthouse 1 Is used for storing rocket casing that
have gone bad or have been filled with waste propellent. Building 4643 Is intended as
a staging or storage area for Burn Ground designated waste. In addition to the storage
and treatment units. Pit 38 was also Inspected.
Hazardous Waste Storage Area: HS-1
HS-1 Is Plant l's hazardous waste container storage area, which consist of two
separate storage and handling operations. HS-1 Is designed for the storage of
primarily solid and seml-solld hazardous and nonhazardous wastes, but also receives
laboratory waste from the Bacchus Facility. During this inspection Hercules was
accumulating solvent contaminated wastewater In a tanker at HS-1. The tanker was
being managed as a container. Hercules has maintained that Interim status container
storage areas did not require secondary containment. The solvent contaminated
wastewater is being shipped off-site to a facility if Texas for deep well injection.
Hercules had the tanker properly labeled with the words "Hazardous Waste" and a
date of accumulation.
Hazardous Waste Storaae Area: HS-3
HS-3 is primarily for the storage of liquid hazardous waste, but provisions have been
made to also allow the storage of solids. HS-3 Is located at Plant 3. Liquid
hazardous waste containers are stored on a 2-Inch thick steel grating, secondary
containment basins are beneath each basin. The basins are separated to avoid
accidental mixing of Incompatible materials. Solids are stored on a concrete pad
along the south side of the facility. Drums of compatible materials are grouped
together. Incompatible are separated by partitions.
Hazardous Waste Storaae Area: ES-1
ES-1 is located on Plant 1 In Building 2105, and is designated for the storage of
explosive hazardous waste (primarily HMX and ammonium perclorate).
Hazardous Waste Storaae Area: Resthouse #1 and Building 4643
Resthouse #1 and Building 4643 received interim status when Hercules received
approval from the Executive Secretary, amending its Part A of April 15, 1991. The
amended Part A allows Hercules to store hazardous waste explosives (i.e., waste
propellant) at two additional locations, Resthouse #1 and Building 4643. This
amendment increases the storage capacity by 37,492 pounds.
Resthouse #1
Resthouse #1 Is designed for the storage of vvaste propellant. Hercules uses this
storage unit to house large quantities of waste propellant. This waste stream is
generated either during propellant mixing or casting activities, when something goes
wrong and it is determined that the mix or casting can not be used. The waste
being stored in this unit is In quantities greater than Hercules Is allowed to OB\OD
on-site. Waste will be stored in this unit until Hercules is able to obtain a disposal
date from UTTR.
Buildina 4643
Building 4643 Is used as a staging area for the Burn Grounds. Hercules will collect
its waste propellant and propellant contaminated materials from the satellite
accumulation areas at the facility and transport It here for safekeeping until It can
be segregated and organized for OB/OD. This storage area was not Inspected
during this Inspection.
Satellite Accumulations Areas:
Hercules has chosen to maintain a satellite accumulation area at each generation site
at the Bacchus Works. The satellite accumulation areas are inspected daily and
waste is segregated and removed as necessary.
Wastewater Treatment Plant:
Wastewaters generated at the Bacchus Work are treated on-site at the wastewater
pretreatment plant which treats explosive contaminated and other wastewaters. The
effluent Is discharged to the Magna wastewater treatment system under a
pretreatment permit.
Hercules is not permitted to discharge wastewater generated outside of the Main
Bacchus facility, this Includes purge water generated from off-site groundwater
monitoring wells and wastewater generated at Bacchus West. Consequently,
Hercules has chosen to collect these wastewaters and shipped them off-site for deep
wellinjection.
The Wastewater Treatment Plant was not visited during this Inspection.
Deep Well injection Waste:
Solvent contaminated wastewater is generated at a rate of approximately 10,000
gallons per month, it Is also shipped off-site for deep well Injection. Hercules Is
collecting the solvent contaminated wastewater with Its pumper trucks and storing
for 90 days in a tanker. Hercules considers the tanker to be a container, and
therefore not subject to the secondary containment standards for hazardous waste
tanks. Hercules maintains that the "container" of wastewater is subject to the
Interim status container management standards which do not require secondary
containment.
Pit 38:
Hercules operates Pit 38 as an explosives and propellant testing area. The purpose
for the testing is to establish DOT shipping classifications and determine the stability
of different explosives and propellants when subjected to varying stimuli. Hercules
does not treat hazardous waste at this site but does generate explosive and
propellant residues.
Complaint Follow-up
The Inspection looked Into a complaint about Plant 3 wastewater being discharged to
Bacchus Lake. It was determined that this practice Is routine and that the
wastewater Is non-contact condensate water from one of the carbon fiber line.
Hercules Indicated that this wastewater is not hazardous and that discharging It to
Bacchus Lake is standard method of operations.
Compliance Status
R450-2 Hazardous Waste Characterization:
R450-2-1 Hazardous Waste - Definition. Identification, and Characterization:
Hercules has characterized Its waste streams in accordance with the
State rules.
R450-4 Hazardous Waste Manifest:
R450-4-2 Manifest Procedures: Hercules is using an Uniform Hazardous Waste
Manifest when shipping hazardous waste off-site.
R450-4-3 Transporter Manifest Procedures: Hercules Is occasionally acting as Its
own transporter. Uniform Hazardous Waste Manifests are used whenever
this occurs.
R450-4-4 Off-Site Hazardous Waste Storaae. Treatment or Disposal Facilities
Manifest Procedures: Hercules does accept hazardous waste for storage
and disposal from other Hercules owned and operated manufacturing
facilities in the State, manifest are used for the shipments and Hercules
is signing as the designated facility.
R315-5 Hazardous Waste Generator Requirements:
R315-5-1 Purpose. Scope and Applicability: In addition to having interim status for
storage and treatment of hazardous waste, Hercules Aerospace Company
Is also a large generator and subject to the applicable requirements of the
Utah Solid and Hazardous Waste Act and Utah Administrative Code.
R315-5-2 Determination of whether a waste is a hazardous waste: Okay this
inspection, (see R315-2 Compliance Status)
R315-5-3 Identification Number: Okay this inspection.
R315-5-4 Manifest: Okay this Inspection, (see Attachment A)
R315-5-5 Recordkeeping: Okay this inspection.
R315-5-6 Biennial Reporting: Okay this Inspection.
R315-5-7 Exception Reporting: N/A
R315-5-8 Additional Reporting: N/A
R315-5-9 Packaging. Labeling. Marking, and Placarding: Not reviewed during this
inspection.
R315-5-10 Accumulation Time: See R315-7 compliance status.
R315-5-11 Farmers: N/A
R315-5-12 Special Reouirements for Generators of Between 100 and 1000
kg/month: N/A
R315-5-13 Export of Hazardous Waste: Not reviewed During this Inspection.
R315-5-14 Import of Hazardous Waste: N/A
R315-7 Subpart B: Interim Status Reguirements for Hazardous Waste Treatment.
Storage, and Disposal Facilities
R315-7-8 General Interim Status Requirements: Hercules has Interim status for the
storage of hazardous waste and for Its open burning and open detonation
activities (OB/OD).
R315-7-9 General Facilitv Standards:
7-9.2 Identification Number: In accordance with Section 3010 of RCRA
Hercules has applied for and received an EPA Identification
Number.
7-9.3 Reguired Notices: N/A
7-9.4 General Waste Analvsis: Not evaluated during this inspection.
7-9.5 Security:
7-9.5(a) Hercules Is operating its facility In a manner that prevents the
unknowing and minimizes the possibility of unauthorized entry of
persons or livestock onto the active portion of the facility.
7-9.5(b) Hercules only allows access to the facility through gates that are
manned by guards, which are on duty 24-hours a day. The entire
facility Is surrounded by a fence, and Hercules maintains additional
controls on the hazardous waste management units.
7-9.5(c) Hercules has the proper signs around Its hazardous waste
management units. Also, signs are on the perimeter fences which
warn people of the dangers of the on-site activities.
General Inspection Reouirements:
Hercules is conducting routine inspections at Its facility.
Hercules is complying with this provision of the Rules, (see
Attachments B, C, D, E, F and G).
Hercules Is complying with this provision of the Rules, (see
Attachments B, C, D, E, F and G).
Hercules Is maintaining records of the Inspections in the form of
an inspection log. (see Attachments B, C, D, E, F and G).
Personnel Training:
Hercules employees are provided with classroom Instruction which
teaches them to perform their jobs In a way that ensures the
facility's compliance with the Rules.' Instruction is being provided
by a person trained in hazardous waste management procedures.
For additional details see Attachment H.
7-9.7(b) Facility personnel are successfully completing the training program
within six months of being hired, assigned to a position at the
facility, or transferred to a new position at the facility, (see
Attachment H)
7-9.7(c) Facility personnel are being provided with an annual review of their
Initial training.
7-9.7(d) Hercules Is maintaining the required documents and records, (see
Attachment H)
7-9.6
7-9.6(a)
7-9.6(b)
7-9.6(c)
7-9.6(d)
7-9.7
7-9.7(a)
7-9.7(e) Hercules is maintaining personnel training records of past and
current employees for the required time frames, (see Attachment
H)
7-9.8 General Reouirements for Ignitable. Reactive, or Incompatible
Waste:
7-9.8(a) Hercules is taking precautions to prevent the accidental ignition or
reaction of Ignitable or reactive waste, (see Attachments B, C, D,
E, F and G)
7-9.8(b) Hercules treats its ignitable and reactive in a manner consistent
with this section of the Rules.
7-9.9 Location Standards: N/A
R315-7-10 Preparedness and Prevention: Hercules operates the Bacchus facility In
accordance with the guidelines of this Rule, for details of the compliance
status see Attachment I.
R315-7-11 Contingency Plan and Emeroency Procedures: Hercules was In
compliance with the requirements of this section of the Rules at the time
of the inspection, see Attachment J for details.
R315-7-12 Manifest System. Recordkeeping, and Reporting: Manifest reviewed
during the Inspection were In order, see Attachment A for details.
R315-7-13 Groundwater Monitoring: Not reviewed during this Inspection.
R315-7-14 Closure and Post-Closure: Reviewed along with the Financial Assurance
requirements of section R315-7-15, no violations found.
R315-7-15 Financial Requirements: Reviewed during an independent evaluation, no
violations found.
R315-7-16 Use and Management of Containers: Hercules manages hazardous waste
in containers. The Inspection documented that Hercules was using and
managing hazardous waste In containers In accordance with the
requirements of this section of the Rules. See Attachment B, C, D and F
for details.
R315-7-17 Tanks: Hercules Is accumulating hazardous waste In tanks. The tanks
replaced open sumps that were present at each mixing and casting
house. Hercules operates these tanks as satellite accumulation areas and
vyill pump the tank on a dally basis when the facilities are In operation.
Wastewater is managed in tanks at the wastewater treatment unit.
wastewater Is treated and discharged to the Magna POTW. Wastewater
generated at the Bacchus West facility Is transported by a pumper truck
to a tanker located at HS-1. See attachment G for details.
R315-7-18 Surface Impoundments: N/A
R315-7-19 Waste Piles: N/A
R315-7-20 Land Treatment: N/A
R315-7-21 Landfills: N/A
R315-7-22 Incinerators: N/A
R315-7-23.6 Open Burning; Waste Explosives: The Burn Grounds were
upgraded prior to the hazardous waste inspection conducted In
September 1991. The new burning grounds have 14 burn pans
and one cage. Each pan Is filled with pea gravel and equipped
with a leachate collection system. The pans sit on asphalt pads
with earthen berms between them. Hercules did this upgrade as a
precursor to obtaining a Part B Permit for this unit.
R315-7-24 Chemical. Physical, and Biological Treatment: N/A
R315-7-25 Underground Injection: N/A
R315-7-26 Air Emission Standards for Process Vents: N/A
R31 5-7-27 Air Emission Standards for Equipment Leaks: N/A
R315-13-1 Land Disposal Restrictions: See Attachment K
Physical Description
The main Bacchus Works Is owned/leased (with the exception of NIROP) and operated
by Hercules Incorporation. The Bacchus Works are located near Magna, Utah and
consists of active and Inactive operations. The facility occupies approximately six
square miles.
Signature Date
8
PRE-INSPECTION CHECKLIST
1. General Information:
Facili ty ^pxtx\.&b Agvo.6fta£^ ^a::^. Date of Inspection :_%pr__S^^
Address: P?A<^KO^ (AJ<pg.t^^ Time:
/VIAAIOA ^ OrArt <6t|oi4H-ooqfl Type of Inspection; (iSi
2. Team Leader: "g?n^ L»4alU^v
Team members: >ioM '9arr^
^^cAk ODUias»o A.
3. Pre-inspection conference: Date: Time:
4. Scope of inspection: ^gtfieuJ record<, ^^^^ €£/&^cf hazarJaus.
LKia<.-fe t^O'n^a/'MeyiJ- /Ar.eas
5. Equipment taken: P^&
6. Inspection notification (Person contacted, time, date)
a) Facility to be inspected: ^o^^ lA^AJ^An^A^ //2^, ^/>'//^i^
b) Local Health Department:
Signature (Team Leader) Signature (Supervisor)
3179
Site: //Q2^oue'& ID#: OTI>i»l-io^ oz.^
Hazardous Waste Inspection
Manifest Checklist
Date: ^/BM:
hTACHtAejJT A
Requirements: #0ooz^ \#/fi^^^ |#//gj^
Manifests Reviewed:
#//gZ5|# tP2.t3|#O<0<^W|# >oaW
Generator EPA ID# O/c Otc oK oi^ _skL. OMC. ou.
Manifest Document #
Number of Pages ^k. oOc _£^ tf>t< oK fiXC (3*^
Mailing Address (box 3)
Phone Number (box 4) O/t <D/C c?K <?K OK e?K~ OK:
Transporter #1 information:
Company Name (box 5)
EPA ID# (box 6)
Phone Number (box D) OK. z>K aVc OK dJK <<M-oK
Transporter #2 information:
Company Name (box 7)
EPA ID# (box 8)
Phone Number (box F) A/A A//1 Ml /^/4 k>A ^J^ NA
Designated Facilitv information:
Name and Address (twx 9)
EPAID# (box 10)
Phone Number (box H) 6lc
Tooo.le_
€>K OK ©K e?\d-aK,
Waste ShiDDlna requirements:
US DOT Description (Including proper
shipping, Hazard class, and ID #)
(box 11)
Containers: No. & Type (box 12)
Total Quantity (box 13)
Unit- Wt/Vol (box 14)
Waste Codes (box I)
Ok. e>K oK o«< <9KL o<<
Additional Desaiptions (box J) Ofe. <s>l<i cPt^ <DK ky OK
Special Handling Instructions (box 15)
OK. d?*< NJ. M.
Ot< «£>V*. OU. Ol<
Generator's Signature (box16)
Transporter's Signature (box 17 & 18)
Facility owner/operator Signature
(box 20)
Discrepancy Indication (box 19)
€>k
<OK. OUC OU^
Final Obsen/ations and Comments: UpoC« "TA^
wJ/v o"i-v^
Ok - compliance. No - noncompliance, NA - not applicable (Common container codes: DM - metal drum\barrel; DF - fiberbarrel; TT - cargo
tank; TC - tank car; DT - dump truck; CM - metal boxNcarton (includes gondolas) (Common Units of Measure: G - gallons; P - pounds; T - tons
Y - cubic yards) (Box K codes: STR - storage; TRT - treatment; DSP - disposal; RCY - recycling)
Inspector's Initials: P/T Page ._L_ of '^^
Site: A ^ r «^wLe-,g ID#: iSroot>r*t)^o2.*i
Hazardous Waste Inspection
Manifest Checklist
#
Date: S/g/'^Z,
Requirements:
Manifests Reviewed:
#io2oi |# i^^ca|# ^At^ |# to;2oy|#/;tf^/ |# (3go^3|# 1VD67-
Generator EPA ID# -w^ <£>»<. *«• gK _^^ OK
Manifest Document #
Number of I OK s'K O^ QK> Oto
Generator information:
Mailing Address (box 3)
Phone Number (box 4) <5>K. CJvl «yK
<5K «£>< oi<
Transporter #1 information:
Company Name (box 5)
EPA ID# (box 6)
Phone Number (box D)
e?t< OK <DK e>\< (SK. au,.
Transporter #2 information:
Compeiny Name (box 7)
EPA ID# (box 8)
Phone Number (box F)
^k VJA-W4 UA OA y]k
Designated Facility information:
Name and Address (box 9)
EPAID# (box 10)
Phone Number (box H) OU. CVd. OU OK OK. GSA
Waste ShiPDing requirements:
US DOT Description (Including proper
shipping. Hazard class, and ID #)
(box 11)
Containers: No. & Type (box 12)
Total Quantity (box 13)
Unit- Wt/Vol (box 14)
Waste Codes (t)ox I)
<Ei,K. o>-^ OIA OK «L<. ^«,
Additional Desaiptions (box J) «K a-«-OK 6^ CD i.^ oK
Special Handling Instructions (box 15) ©Wl o\<. OK cK (Dc^ e>A^
Manifest Ce
Generator's Signature (box16)
Transporter's Signature (box 17 & 18)
Facility owner/operator Signature
(box 20)
Discrepancy Indication (box 19)
OUC OVL o(^ OK. <£iK. o^^
Final Observations and Comments: HM)< iWoCrt-r »e.L iU'KpO-»HB/ \tt Gw.w
O-^ J. llZfi_«Uj^«_| y
Ok - compliance. No - noncompliance, NA - not applicable ^Common container codes: DM - metal drum\barrel; DF - filjerbarrel; TT - cargo
tank; TC - tank car; DT - dump truck; CM - metal boxNcarton (includes gondolas) (Common Units of Measure: G - gallons; P - pounds; T - tons;
Y - cubic yards) (Box K codes: STR - storage; TRT - treatment; DSP - disposal; RCY - recycling)
Inspector's Initials:. Ru Page. of X.
DRUMCLST.XLS
Site: Ue*^ul*«
Gc
INSPECTION ITEM
Container Storaae and Manaoement:
Is the date upon which each accumulation period
began clearly marked and visibly for inspection?
Is the container labeled with the words
"Hazardous Waste' while its being accumulated
on-site?
Are the containers accumulating and holding
hazardous waste in good condition?
Are the containers compatible with the
hazardous waste being stored In them?
Is the generator maintaining his/her containers in
a closed condition except when adding or
removing waste from the container?
Containers holding hazardous waste must not be
opened, handled andtor stored in a manner
which may rupture the container or cause it to
leak.
Is the generator inspecting his/her containers at
least weekly, and do the inspections look for
leaks, deterioration, and other factors that may
cause a release of hazardous waste or
constituents to the environment?
The generator must store ignitable or reactive
hazardous waste at least 15 meters (15 feet)
from the facility's property line, (not applicable to
SQG)
Special Reouirements for Incomoatible Waste:
1) Hazardous waste must not be placed In a
container that previously held hazardous waste.
2) Incompatible waste must not be stored
together.
lD#:OTbOO
Hazardous Waste 1
)ntainer Manageme
CITATION
R315-5-10
262.34(a)(1)-(3)
262.34(a)(2)
262.34(a)(3)
265.171
265.172
265.173(a)
265.173(b)
265.174
265.176
265.177(a), (b)&(c)
nspec
ntCh
C
y
y
/
y
y
/
y
y
\
Jtion
ecklis
NC
!t
NA
Date: 5 SfffT^i
AirA^M*v\6Mr •&
Nl COMMENTS
Inspector's lnitials:yJ«'^lM Page > of _L
DRUMCLST.XLS
Site: h.Pjr(.C^\e,<.
C<
INSPECTION ITEM
Container Storaae and Manaoement:
Is the date upon which each accumulation period
began clearly marked and visibly for inspectton?
Is the container labeled with the words
"Hazardous Waste" while Its being accumulated
on-site?
Are the containers accumulating and holding
hazardous waste in good condition?
Are the containers compatible with the
hazardous waste being stored in them?
Is the generator maintaining his/her containers In
a closed condition except when adding or
removing waste from the container?
Containers holding hazardous waste must not be
opened, handled and\or stored in a manner
which may rupture the container or cause it to
leak.
Is the generator inspecting his/her containers at
least weekly, and do the inspections look for
leaks, deterioration, and other factors that may
cause a release of hazardous waste or
constituents to the environment?
The generator must store Ignitable or reactive
hazardous waste at least 15 meters (15 feet)
from the facility's property line, (not applicable to
SQG)
Soecial Reouirements for Incompatible Waste:
1) Hazardous waste must not be placed in a
container that previously held hazardous waste.
2) Incompatible waste must not be stored
together.
ID#: OTOfi^
Hazardous Waste 1
antainer Manageme
CITATION
R315-5-10
262.34(a)(1)-(3)
262.34(a)(2)
262.34(a)(3)
265.171
265.172
265.173(a)
265.173(b)
265.174
265.176
265.177(a), (b)&(c)
nspei
ntCf
C
y
>/
y
J
J
•J
J
y
y
:::tion
lecklij
NC
5t
NA Nl
Date: 6 Sao\- ^1.
hru-HPA&yr C
COMMENTS
Inspector's Initials: (M'*lt^ Page. of
DRUMCLST.XLS
Site: ]^tfe.0Ui'
o
INSPECTION rrEM
Container Storaae and Manaoement:
Is the date upon which each accumulation period
began clearly marked and visibly for inspection?
Is the container labeled with the words
"Hazardous Waste" while its being accumulated
on-site?
Are the containers accumulating and holding
hazardous waste in good condition?
Are the containers compatible with the
hazardous waste being stored in them?
Is the generator maintaining his/her containers in
a closed condition except when adding or
removing waste from the container?
Containers holding hazardous waste must not h&
opened, handled and\or stored in a manner
which may rupture the container or cause it to
leak.
Is the generator inspecting his/her containers at
least weekly, and do the inspections look for
leaks, deterioration, and other factors that may
cause a release of hazardous waste or
constituents to the environment?
The generator must store Ignitable or reactive
hazardous waste at least 15 meters (15 feet)
from the facility's property line, (not applicable to
SQG)
$pecial pequirgments for lncomp^ti|?|g Waste:
1) Hazardous waste must not be placed in a
container that previously held hazardous waste.
2) Incompatible waste must not t)e stored
together.
iD#:.i3rrrpfic
Hazardous Waste 1
Dntainer Manageme
CITATION
R315-5-10
262.34(a)(1)-(3)
262.34(a)(2)
262.34(a)(3)
265.171
265.172
265.173(a)
265.173(b)
265.174
265.176
265.177(a), (b)&(c)
nspei
ntCf
C
7
;
J
J
J
J
J
/
/
561/
:tion
ecklii
NC
5t
NA
At
Nl
y
Date: B Se^r '\'L.
COMMENTS
Inspector's Initials:, Page. of
GEN.XLS
Site: UrSfi-oOf^s.
INSPECTION ITEM
Hazardous Waste Generator Requirements:
Waste Determination: Has the qenerator
determined whether his/her solid waste is a
hazardous waste? Has a waste determination
been done for each waste stream?
Has the generator notified of regulated activity
and obtained an EPA 1D# In accordance with the
requirements of Section 3010 of RCRA?
Manifest:
1. Is the generator using a Uniform Hazardous
Waste Manifest for its shipments of hazardous
waste?
2. Did the generator designate a facility permitted
to handle its waste?
3. Was an alternate facility designated?
4. Did ttie generator use the correct manifest?
M£Miif?5t requirements fpr the generator:
1. Did the generator sign the manifest
certification by hand?
2. Did ttie generator obtain a handwritten
signature from ttie initial ta-ansporter and ttie date
of acceptance?
3. Did ttie generator retain a copy of ttie manifest
in accordance wltti R315-5-4(a)?
Manifest reouirements for SQG's:
1. Does ttie generator have a contractural
agreement for his/her waste?
2. Does the agreement specify ttie type of waste
and frequency of shipments?
3. Does the recycling facility own ttie
transportation vehicle? (ttiey must)
4. Is a copy of Uie contt-actural agreement
mainlained at ttie facility?
ID#: OTD OO \'^o€>Ot^ Date: S ^SPr f 2-
Hazardous Waste Inspection ,
Generator Checklist , A^fiCViiAe^ & ;
CITATION
R315-5
R315-5-2
40 CFR 262.11
R315-5-3
R315-5-4
(R315-4-2(a)-(h))
R315-5-4
(R315-4-2(1))
R315-5-4
{R315-4-2(1)}
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Nl COMMENTS
Inspector's Initials: lA^W^l^ Page. of
GEN.XLS
Site: HiircuJeA
INSPECTION ITEM
Recordlteeping
Is ttie generator maintaining signed copies of ttie
hazardous waste manifest for three years?
Is ttie generator maintaining copies of each
Biennial Report and all Exception Reports for a
period of at least ttiree years?
Is ttie facility maintaining records sufficient to
determine quantities and disposition of hazeirdous
waste or ottier determinations, test results, or
waste analyses made in accordance witti R4315-
5-1 for a pertod of at least ttiree years from ttie
date of last shipment?
Biennial Reporting
Has ttie generator submitted complete Biennial
Report(s)?
Exception Reporting
Has ttie generator t)een required to prepare an
Exception Report, If yes describe ttie
circumstances.
Packaging, Lal>eiing, Marking, and Placarding
1. Is tiie generator packaging his/her hazardous
waste is ttie appropriate DOT shipping
containers?
2. Are containers labeled in accordance witti
DOT shipping requirement prior to shipping?
3. Is ttie generator providing ttie appropriate
placarding to tfie Initial t-ansporter when initiating
his/her shipment?
AccuipMlanvn Tlm«
(See Container and Tank Checklist
as applicable)
Also see checklist for: Personnel Training.
Prepardness & Prevention Measures,
Contingency Plan & Emergency Procedures,
Satellite Accumulations, and Manifest. (Large
quantity generator requirements)
ID#:
Hazardous Waste
Generator Ch<
CITATION
R315-5-5(a)
R315-5-5(b)
R315-5-5(0)
R315-5-6
R315-5-7
R315-5-9(a)
R315-5-9(b), (c)&(d)
R315-5-9(e)
R315-5-10
Inspe
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COMMENTS
Inspector's Initials:. Page. of
SATCLIST.XLS
Site: VxefCOU^
S
INSPECTION ITEM
Sateiiita Accumulation Araas
Is ttie satellite accumulation area at or near the
point of generation?
Is ttie satellite area under ttie conb'ol of ttie
operator of ttie process generating the waste?
The generator can not store more ttian 55 gallons
of hazardous waste or 1 quart of acutely
hazardous wasto at ttie satellite accumulation
area.
Are ttie containers in good conditions?
Is ttie hazardous waste stored In containers that
are compatable witti ttie waste?
Is ttie accumulatton container t)eing maintained in
a closed condition except when waste Is being
added or removed?
Is ttie generator managing ttie accumulation
container in a manner ttiat will not cause It to
rupture or leak?
Does ttie generator have ttie accumulation
container labeled witti ttie words 'hazardous
waste" or wiUi ottier words ttiat identify ttie
contents of the container?
Is the generator correctiy labeling and moving
hazardous waste, In excess of ttie 55 gallon or 1
quart limits, to a 90-day storaga area wittiin 72
hours of exceeding ttie limit?
ID#:L>rD OC
Hazardous Waste 1
atellite Accumulatic
CITATION
R315-5-10. 262.34(c)
262.34(c)(1
262.34(c)(1)
262.34(c)(1)
262.34(c)(1)(i)
262.34(c)(1)(i)
262.34(c)(1)(i)
262.34(c)(1)(i)
262.34(c)(1)(il)
262.34(c)(2)
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Date: & ^€^f ^2.
rrAoiM^Njr f
COMMENTS
Inspector's Initials:. Page. of
TANKCUST.XLS
Site: [^erco\e<i. 1D#: Date: 6 Scpr *?7^
Hazardous Waste Inspection
Tank Storage Checklist AllA^U^^g^f ^
INSPECTION ITEM
Tank Storage:
Is the tank clearly labeled witti ttie words
"Hazardous Waste' and does it have a
accumulation start date?
Tank System Integrity:
1) Does ttie tank have secondary containment?
If no, does ttie facility have a written assessment
certifying tiiat attest to ttie integrity of ttie tank?
2) Was the integrity of the tank system tested
prior ttie January 12, 1988?
The assessment of the integrity must consider, at
a minimum, ttie following:
1) Design standard(s) if available;
2) Hazardous characteristics of the waste(s) ttiat
have been or may be stored;
3) Existing corrosion protection measures;
4) A documented age or an estimated age; and
5) Results of leak test(s), internal inspection, or
otiier tank integrity examinations.
General operating Reqgirement?:
1) Hazardous waste or treatinent reagents
placed in ttie tank must be compatible witti ttie
construction materials of ttie tank system.
2) The owner/operator must use appropriate
controls to minimize spills and overfills from Uie
tank. Prevention measures must include: spill
prevention conti-ols, overfill prevention conti-ols,
and adequate freeboard to prevent overtopping
by wave or wind action.
3) The owner/operator must comply with ttie leak
or spill requirements (265.196).
CITATION
R315-5-10
262.34(a)(1)
Subpart J, 265
262.34(a)(2) & (3)
265.191(a)
265.192(b)(1)-(5)
265.194(a)
265.194(b)(1)-(3)
265.194(c)
C NC NA
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Nl COMMENTS
\a^M>
Inspector's Initials:, Page. of
TANKCLST.XLS
Site: U/?rt:ol£«. ID#: Date: 6 f«Fr 92-
Hazardous Waste Inspection
Tank Storage Checklist
INSPECTION ITEM
TanK storage RMUIrwnfnt?: (cont.)
iri?pection Requirerrents:
1) The ownerVoperator must conduct daily
inspections of the ovetfill\spJll conttol equipment,
al)oveground portion to determine whettier a leak
has or is occurring, data gattiered from leak
detection equipment, and secondary containment
devices.
2) If ttie owner/operator has a cattiodic protection
system it must be inspected 6 monttis after
installation and annually ttiereafter.
3) All sources of impressed current must be
inspected and/or tested at least bimonttily.
4) The ovmer/operator must maintain
documentation that records ttie atx3ve
inspections.
Special Requirement for Ignitable or Reactive
Wastes:
1) If ttie owner/operator places ignitable or
reactive wastes in a tank, have ttie following
measures been taken:
a) The waste was treated, rendered, or mixed
before or immediately after placement in ttie tank
and Uie resultant waste, mixture, or dissolved
material Is no longer hazardous.
b) The owner/operator has taken precautions to
prevent accidental ignition or reaction of ignitable
or reactive waste.
c) If ttie ownerVoperator is tteating or
commingling incompatible waste, or incompatible
waste and materials, ttie process must not
generate exti-eme heat or pressure, fire or
explosions, or violent reaction; produce
unconttolled toxto mists, fumes, dusts, or gases
ttiat would ttireaten human heaitti; produce an
unconttolled fumes or gases ttiat would pose a
risk of fire or explosion; damage ttie sttuctural
integrity of ttie device or facility containing tiie
waste; or ttireaten human heaitti or ttie
environment by ottier means.
CITATION
265.195(a)(1)-(4)
265.195(b)(1)
265.195(b)(2)
265.195(c)
265.198(a)
265.198(a)(1)
265.198(a)(2)
265.17(b)
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Inspector's Initials:. Page. of
PT-CLIST.XLS
Site: HefjcUL^i,
INSPECTION ITEM
Personnel Training Program
Facility personnel receive classroom
instmction or on-the-job training which
teaches them to perform their jobs,
such that the facility operated in
compliance with the applicable
hazardous waste management
requirements.
Is the program directed by a person
trained in hazardous waste
management procedures?
Does the training teach facility
personnel the procedures necessary to
implement the Contingency Plan and
Emergency Procedures?
Does the training program include, at a
minimum, following:
1. Procedures for using, inspecting,
repairing, and replacing facility
emergency equipment;
2. Key parameters for automatic
waste cut-off systems;
3. Communications or alarm
systems;
4. Response to fires or explosions;
5. Response to groundwater
contamination incidents; and
6. Shutdown of operations.
ID#: Date: 8Sef>f. 9z
Hazardous Waste Inspection
Personnel Training Checklist ] AirA^Hi»tBS>r ^
CITATION
R315-5-10
262.34(a)(4)
256.16(a)(1)
265.16(a)(2)
265.16(a)(2)
265.16(a)(3)(i)
ttirough (vi)
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•lmfc»vin<\ r-eiwki-fc •%*«««*••• 1
•H^'rtvtfaU. -V»rv>«.«vV
Jtr^\,^\^\c.^
Inspector's lnitials:^iS^ Page. of
PT-CLIST.XLS
Site: ^^(^coi.e's.
INSPECTION ITEM
Personnel Training (cont.)
Have facility personnel sucessfully completed
ttie personnel ttaining program within six monttis
of ttie ttieir date of employment or assignment to
Uie facility?
Do Uie facility personnel recieve a annual review
of ttieir initial ttaining?
The owner/operator of ttie facility must maintain
ttie following documents at ttie facility:
1. The job titte for each position at ttie facility
related to hazardous waste management, and
ttie name of ttie employee filling each job;
2. A writtem job description for each position
listed under #1.;
3. A written description of ttie type and
amount of tx>tti infroductory and continuing
ttaining ttiat will be given to ttie employees
listed in #1, and;
4. Records ttiat document ttiat employees
have ttie ttaining or job experience required
by paragraphs (a), (b), and (c).
Are ttaining records maintained at Uie facility for
current employees and at least ttiree years for
employees ttiat have left ttie company?
ID#:
Hazardous Waste
Personnel Training
CITATION
40 CFR 265.16(b)
40 CFR 265.16(c)
40 CFR 265.16(d)(1),
(2), (3), and (4)
40 CFR 265.16(e)
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Date: B ^ePT 9^
COMMENTS
tkecK a I- o^<^<
rc««>r«is.
Inspector's Initials:. Page. of
DATE: 92/09/08
TIME: 12:25:31
TRAINING BY PROCED'TRE
WITH HISTORY
DEPARTMENT: F410 CP FIBER BUILDINGS 1,2,3
PROCEDURE: 025000AZTO026 RV: 01 RP: 1
HAZARDOUS WASTE DISPOSAL REFRESHER TRAINING
NAME
BANKHEAD, NANCY R
BUNKER, ALICE J
BUNKER, ALICE J
CARLYLE, CHRISTOPHER S
CASSITY, JOHN E
DURFEY, VERLYN M
EWELL, S CLIFFORD
GREER, CINDY A
HAUN, KIM A
HENLINE, DENNIS R
JACKMAN, HOWARD W
JOHANSEN, DANIEL R
JOHNSON, JOYCE A
LANNING, RICHARD F
MARTINEZ, SARAH R
MORTENSEN, B WAYNE
PETERSON, LEONA K
PETERSON, LEONA K
SUNDQUIST, MARK F
TRUJILLO, RUTH A
TURPIN, JEFFREY B
VARLEY, PHILLIP D
SSN RV RP TRAINED DATE
555356876
527562557
527562557
529980468
528040690
528788228
528842571
528942710
529901325
528944964
529648599
528767566
549645539
233360812
528785868
528542754
528709511
528709511
525061035
528740226
528903689
529687547
00
00
01
01
01
01
01
01
01
01
01
00
01
00
00
00
00
01
01
00
00
00
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
X
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
91/09/11
91/09/11
92/08/30
92/08/30
92/08/25
92/08/25
92/08/30
92/08/30
92/08/30
92/08/25
92/08/25
91/08/27
92/08/30
91/08/30
91/08/30
91/10/02
91/08/26
92/08/25
92/08/30
91/08/28
91/08/27
91/08/21
* RV - RI
* P = PI
* RP - RI
RETRAIN DATE
92/09/11
92/09/11
93/08/30
93/08/30
93/08/25
93/08/25
93/08/30
93/08/30
93/06/30
93/08/25
93/08/25
92/08/27
93/08/30
92/08/30
92/08/30
92/10/02
92/08/26
93/08/25
93/08/30
92/08/28
92/08/27
92/08/21
TOTAL FOR THIS PROCEDURE: 00020
PP-CLIST.XLS
Site: l^e^coue'i. ID#:On)0Or?C>60V^ Date: ^ ^-^ ^2
Hazardous Waste Inspection ^
Preparedness and Preventran Measures Checklist i AtfA^Hi^^^T •*-
• •
INSPECTION ITEM
Preparedness and Prevention Measures
Is ttie facility maintained and operated to
minimize ttie possibility of a fire, explosion, or any
unplanned sudden or non-sudden release ot
hazeirdous waste or hazardous waste
consfituents?
The facility must be equipped witti ttie items (1)-
(4), identified betow, unlsss it can be shown ttiat
hazardous waste managed at ttie site woukl not
require a particular kind of equipment.
1. Does ttie facility have an internal
communications or alarm system capable of
providing immediate emergency insfruction to its
personnel?
2. Does tiie facility have a device capable of
summoning emergency assistance to ttie
facility?
3. Does the facility have portable extinguishers,
fire conttol equipment (including special
extinguishing equipment necessary for their
facility), spill conttol equipment, and
decontamination equipment?
4. Does tiie facility have water at adequate
volume and pressure to supply water hoses,
foam producing equipment, automatic sprinklers,
or water spray systems.
Facility communications or alarm systems, fire
protectionequipment, spill conttol equipment, and
decontamination equipment tested and
maintained fo assure its proper operation In time
of an emergency?
Do facility personnel have immediate access to
an internal alarm or emergency communication
device, elttier directiy ttirough visual or voice
contact, while managing hazardous waste?
Is tiiere ever just one employee on ttie premises
while the facility is operating? If yes, does ttiat
person have immediate access to device capable
of summoning external emergency assistance?
CITATION
R315-5-10
40 CFR 262.34(a)(4)
40 CFR 265.32
40 CFR 265.32(a)
40 CFR 265.32(b)
40 CFR 265.32(c)
40 CFR 265.32(d)
40 CFR 265.33
40 CFR 265.34(a)
40 CFR 265.34(b)
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I i.**.ll;»A M^rt^ WV-
Inspector's lnitials:\t^l^jJ-Page. of.
PP-CLIST.XLS
Site: UcrcoU^ ID#: Date: 5 ^^Fr ^^'
Hazardous Waste Inspection
Preparedness and Prevention Measures Checklist
INSPECTION ITEM
Preparedness and Prevention Measures
(conL)
Is aisle space maintained to allow ttie
unobsbucted movement of emergency personnel
or equipment (un/es:saisle space is not needed
for any of ttiese purposes)?
The facility must arrange ttie following types
agreements or arrangements witti local
organizations (as appropriate);
1. Has the facility made or attempted to make
arrangements to familarize local police, fire
departtnents, and emergency response teams
witti ttie layout of ttie facility, character of ttie
hazardous waste(s) managed, locations where
facility personnel normally work, location of
facility enttances and possible evacuation
routes?
2. Has the facility designated primary emergency
authority to a specific police or fire departtnent,
when more ttian one police or fire departtnent
might respond in ttie event of an emergency?
3. Have agreements witti State emergency
response teams, emergency responses
conttactors, and equipment suppliers been
made?
4. Have arrangements been made to familiarize
local hospitals witti ttie properties of hazardous
waste handled at ttie facility and ttie types of
injuries or illnesses which could result from fires.
explosions, or releases at the facility?
If any State or local auttiorities have declined to
enter into such arrangements, has the facility
documented ttie refusal in the operating record?
CITATION
40 CFR 265.35
40 CFR 265.37(a)
40 CFR 265.37(a)(1)
40 CFR 265.37(a)(2)
40 CFR 265.37(a)(3)
40 CFR 265.37(a)(4)
40 CFR 265.37(b)
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AO OA« WA^* ^IcX^M^'
Inspector's Initials:. Page. of
CP-CLIST.XLS
Site: Ue/UOL-e^
Contingency
INSPECTION ITEM
Contingency Pian and Emergency Procedures
General Requirements:
Is a copy maintained at ttie facility?
Have copies been disfributed to all local police
and fire departtnents, hospitals, and State and
local emergency response teams ttiat may be
called upon for assistance?
Content of ttie Contingency Plan:
1. Does ttie contingency plan describe ttie
actions facility personnel will take to minimize
ttie hazard to human health and ttie
environment, when responding to fires,
explosions, or any unplanned sudden or
nonsudden release of hazardous waste?
2. Does ttie contingency plan describe
arrangements agreed to by local police and fire
departtnents, hospitals, confractors, and State
and local emergency response teams?
3. Does ttie contingency plan list ttie names,
addresses, office and home phone numbers of
all persons qualified to act as emergency
coordinator?
4. Does ttie contingency plan include a list of all
emergency equipment at the facility? The list
must be kept up-to-date, and include ttie
location and a physical description of each item
on ttie list, and a brief ouUine of ttie equipment's
capability.
5. Does ttie contingency plan include an
evacuation plan for ttie facility? The evacuation
plan must include a description of signal(s) to
be used to initiate an evacuation, evacuation
routes, and alternate evacuation routes.
Does the facility have a least one employee on-
site or on-call at all ttme who is qualified to act as
tiie emergency coordinator?
ID#: LfTt> 00f90S0z.f Date: ^ SePT ^2.
Hazardous Waste Inspection
Plan and Emergency Procedures Checklist /S[^•rl'^y,^rtVe^Jx' ^
•
CITATION
R315-5-10and
40 CFR 262.34(a)(4)
40 CFR 265.53(a)
40 CFR 265.53(b)
40 CFR 265.52(a)
40 CFR 265.52(c)
40 CFR 265.52(d)
40 CFR 265.52(e)
40 CFR 265.52(0
40 CFR 265.55
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Inspector's Initials: IfiUfti^ Page. of
CP-CLIST.XLS
Site: W^rwUi
Contingency
INSPECTION ITEM
Contingency Ptan and Emergency Procedures
(cont)
Does ttie contingency plan Include procedures for
activation of ttie Internal alarm by ttie emergency
coordinator?
Does ttie contingency plan include provision for
notifying the appropriate State andVor local
response agencies?
Does ttie contingency plan outiine ttie
procedure(s) ttiat ttie emergency coordinator will
follow to immediately identify ttie character,
source, amount, and extent of released material?
Does ttie contingency plan Include procedures
for the emergency coordinator to follow In order
to assess possible hazards to human heaitti or
ttie environment?
If it is determined ttiat ttie incident could ttireaten
human heaitti or ttie environment, outside ttie
facilify, ttie emergency coordinator must notify
ttie appropriate local, State and Federal
agencies. Does ttie contingency plan include
provision for notifying ttie appropriate agencies?
Do ttie 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 of injuries, and
possibility of exposure outside ttie facility), and
identify ttie National Response Center and Uie
State as parties to be notified?
Does Uie plan include procedure to prevent ttie
spread of the incident to ottier hazardous waste
at ttie facility?
Are measure included to monitor for leaks,
pressure buildup, gas generation, or ruptures In
valves, pipes, or otiier equipment, when it is
necessary to shut-down operations as a
response to an Incident?
ID#:
Hazardous Waste 1
Plan and Emergenc
CITATION
40 CFR 265.56(a)(1)
40 CFR 265.56(a)(2)
40 CFR 265.56(b)
40 CFR 265.56(c)
40 CFR 265.56(d)(1)
and (2)
40 CFR 265.56(e)
40 CFR 265.56(0
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ate: fe 5epr ''"^
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COMMENTS
Inspector's Initials: Page. of
CP-CLIST.XLS
Srte: U^^^t^^ ID#: Date: 5 ^e?T ^1^
Hazardous Waste lnspectk>n
Contingency Plan and Emergency Procedures Checklist
INSPECTION ITEM
Contingency Plan and Emergency Procedures
(cont)
Does ttie contingency plan provide procedures to
follow to manage ttie hazardous waste generated
as a result of an Incident?
Following implementation of contingency plan are
provisions included ttiat allow assurances ttiat ttie
affected area(s) are:
1. No waste Uiat may be incompatible witti the
released material is tteated, stored, or disposed
of until the cleanup is complete.
2. That all equipment listed in ttie contingency
plan Is cleaned and fit for use prior to resuming
activities at ttie facility.
Does ttie contingency plan Include provisions for
notifying ttie appropriate federal. State and local
auttiorities ttiat ttie facility is in compliance witti 40
CFR 265.56(h) prior to resuming operations in ttie
affected area?
The contingency plan must include provision for
recording Uie Incident requiring imptomentation of
the contingency plan and specifying information
ttiat will be recorded and reported. The
requirements are as follows:
1. Will a written report on ttie incident be
provided to ttie Regional Adminisfrator within 15
days?
2. TTie followrtng information needs to be
recorded and reported:
a) TTie name, address, and telephone # of the
owner/operator;
b) The name address, and telephone # of ttie
facility;
c) Date, time, and type of incident;
d) Name and quantity of material(s) involved;
e) Extent of injury, if any;
0 An assessment of ttie actual or potential
hazard to human heaitti or ttie environment;
and
g) An estimate of the quantity and disposition of
recovered material(s) ttiat resulted ft^om ttie
incident.
CITATION
40 CFR 265.56(g)
40 CFR 265.56(h)
40 CFR 265.56(h)(1)
40 CFR 265.56(h)(2)
40 CFR 265.56(i)
40 CFR 265.S6(j)
40 CFR 265.56(i)
4OCFR265.560)(1)
ttiru (7)
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NC NA Nl COMMENTS
Inspector's Initials: Page. of
EXPLOSIVE A AND B. FOR EMERGENCY RESPONSE: Robert Quigley
[phone]
GUIDE 46
POTENTIAL HAZARDS
FIRE OR EXPLOSION:
May explode and throw fragments 1/3 mile or more if fire reacJies cargo area.
HEALTH HAZRDS:
Fire may produce irritating or poisonous gases.
EMERGENCY ACTION
In case of fire, stop all traffic and begin to clear the area for 2500 feet (1/2 mile)
in all directions.
Keep unnecessary people away.
Do not fight fire in cargo. Try to prevent a fire from reaching the explosive cargo
compartment.
Self-contained breathing apparatus (SCBA) and structural firefighter's protective
clothing will provide limited protection.
CALL CHEMTREC AT 1-800-424-9300 AS SOON AS POSSIBLE, especially if there is no local
hazardous materials team available.
FIRE:
Truck and Equipment Fires: Flood with water; if no water is available use Halon, dry
chemical or dirt. CAUTION: Tire fires may start again. Unhook and separate
tractor from trailer if possible.
Cargo Fires: Do not move cargo or vehicle if cargo has been exposed to heat. Do not
fight fire when it reaches cargo. Withdraw from area and let fire burn.
Promptly isolate the scene by removing all persons from the vicinity of the incident
if there is a fire. First, move people out of line-of-sight of the scene and away
from windows. Obtain more information and specific quidance from competent
authorities who may be listed on the shipping papers.
If you know of or suspect that heavily-encased class A explosives, such as bombs or
artillery projectiles, are being exposed to heat or flames, expand the isolation
area in all directions to: 4000 feet (3/4 mile) for a Tractor/Trailer load: 5000
feet (1 mile) for a Railcar load.
SPILL OR LEAK:
Shut off ignition sources; no flares, smoking or flames in hazard area.
Do not touch spilled material.
FIRST AID:
Call emergency medical care.
Use first aid treatment according to the nature of the injury.
LAND DISPOSAL RESTRICTIONS CHECKLIST
FACILITY fiej^c/\e-'> EPA ID #
R315-13-1 of Itll® Utah AdmonisltraltJv© C©d®, 40 CFR Part 268
LV-..C. 5.VtM. «<. J ^•**"'l*'^ '••»«0
Name and number of waste T^^^^.-C 6VUL.^V^UJ Dooz^Doc-=f-jl^ati^ »^.^~.-^-W i\Qbs'
1. Has the generator tested his waste or an extract of the waste or used knowledge
to determine If the waste is restricted from land disposal (268.7(a)|?_vg^
Has the generator notified the treatment or storage facility of appropriate treatment
standards and any applicable prohibition levels for each shipment of restricted
waste not meeting applicable treatment standards (268.7(a)(1))? yes
a. Does the notice include:
(i) the EPA hazardous waste number (268
(ii) the corresponding treatment standards
(iii) the manifest number
(26a.7la)(1)(nn)? vts
(iv) waste analysis data iZGB.
associated
7(a)(1)(iv))?.
;Jia)(n(i))
(268,
with
y^.^
7(a) 1
the
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:')(!«))? j^
shipment of waste
.mm. 3. Has the generator submitted to the treatment, storage, or land disposal facility for
each shipment of restricted waste determined to be able to be land disposed
A^ \^ without further treatment a notice and a certification stating the waste meets
applicable treatment standards (26B.7(a.)(2)>?
a. Does the notice include:
(i) the EPA hazardous waste number (26B.7(a)(.2)(i)(A))?_
(ii) the corresponding treatment standards (26BJ(«)(2)(i)(B))?
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(iii) the manifest number associated with the shipment of waste
(268,7(a)(2)(J)(C))?
(iv) waste analvsis data i26B.7(a)(2)(i)(C))?
b. Is the certification signed by an authorized representative and does it contain
the required statement (268.7(a)(2)(H))?
«» 4. Is the generator's waste subject to an exemption from a prohibition on the type of
land disposal method utilized for the waste?
If so, has the generator submitted a notice to the facility receiving the waste
with each shipment stating that the waste is not prohibited from land
disposal (268.7(a)(3))?
Does the notice include:
(i) the EPA hazardous waste number (268.7(,g)(3)(i))?
(ii) the corresponding treatment standards (2B8.7(a)(3)(n))?
(iii) the manifest number associated with the shipment of waste
(26B.7(a)(3)(Mi))?
(iv) wast© analysis data (268.7(a)(3)(lv|)?
(v) the date the waste is subject to the prohibitions (268J(a)(3)(iv))?
^"^ •—- 5. Is the generator managing a prohibited waste in tanks or containers and treating
the waste to meet applicable treatment standards (268.7(a)(4))?
If so, has the generator developed a written wast© analysis plan describing the
procedures the generator will carry out to comply with the treatment standards
(268.7(a)(4))?
Waste Analysis Plan;
(i) Is the plan based on a detailed chemical and physical analysis of a
representative sample of the prohibited waste being treated, and contain all
information necessary to treat the waste, including selected testing
frequency (26B.7(a)(4)(i))?
(ii) Was the plan filed with the Executive Secretary a minimum of 30 days
prior to treatment activity, with delivery verified (268/7(a)(4)<ii))?
(iii) For wastes shipped offsite, hav© notification requirements of 268.7(a)(2)
been met (26S.7(a)(4)(i!i))?
6. a. Did the generator determine whether the waste is restricted based solely on his
knowledge of the waste? ^xs .
If so, is all supporting data used to make this determination retained onsite in the
generator's files (268.7(a)(5))? y^^s.
b. Did the generator determine whether th© wast© is restricted based on testing
this waste or an extract? w;s
If so, is all waste analysis data retained onsite in the generator's files (268,7(a)(5;)
f' —
7. Has the generator retained onsite a copy of all notices, certifications,
demonstrations, waste analysis data and other documentation for at least five
years from the date that the waste was sent to onsite or offsite treatment, storage,
or disposal (268.7(a)(6))? w<.
8. Has the initial generator of the solid determined ©ach waste code applicable to the
waste, including r©l©vant charact©ristic wast© cod©s, in order to determine the
applicable treatment standards (268i)(a))?
9. Has the generator stored restricted waste onsite for reasons other than to
accumulate such quantities of hazardous waste as necessary to facilitate proper
recovery, treatment, or disposal (268 5(Ha}(1))? AO
Has the generator complied with requirements in 40 CFR 262.34 for containerizing
waste, dates of accumulation, and labeling with the words 'Hazardous Waste'
(268.50(a) (t))?
^^
COMMENTS
INSPECTOR \L^1l , DATE ^-6'^^
Revised 10/91