DSHW-2024-007275

Utan Department of Environmental Quality
)ivision of Solid and Hazard{Waste
SQG Program
Dennis.S:
Blxffiffi'ctor
Salt Lake City, Utah 841f4-4880
HAZARDOUS WASTE GENERATION EVALUATION FORM
,(
RESPONSE DUE BYRESPONSENECESSARY:YES NO 1l
td_IE T: rt- 21 .1 , .L tcoMMENr s: Lrt\rlr" ;rl Clo* Fh\o r c s c"'t Lo*( vto?t'.-,, bt*n- -
This compliance evaluation 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 DUE DATE is indicated, you must take actions summarized in this audit
in order to come into compliance and NOTIFY THIS OFFICE lN WRITING by the indicated date. Please be advised that if we do not receive
written documentation of these corrective actions by the response due date you may be subject to lurther regulatory action, including
administrative penalties. Please include your EPA ld number with your correspondence.
lf you have further questions or would like to discuss these issues with the inspectors or their supervisor, you may contact them during business
hours at [phone]. ltems that must be submitted may be mailed to the address at the top of this page.
Signature:
Title:
INSPEGTOR:
Name, printed:
Signalure: 4
Date:
h(.t
Page 2
I
Example of Employee Training Log (this is only an example and must be adapted specifically to your
facility)
XYZ Companv Emplovee Trainins Los
Date: April9,2002 l
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 Containers
a. Maintain a log weekly on the hazardous waste containers; are the containers closed, labeled,
dated and in good condition. If not, please contact the emergency coordinator in order to
rectify the problem
m. Other topics as discussed
a.
b.
Employee Name (Please Print)Employee Signature
1,.
2.
3.
4.
-5.
page 3
UTAH DEQ SMALL QUANTITY GENERATOR EVALUATION FORM
Items that are marked "NO" on the line in the left hand column are not in compliance with the Utah Solid and Hazardous
Waste Regulations and require your immediate attention. ltems marked "OK" meet the minimum requirements of the
regulations. ltems marked "NA" do not apply to your facility.
dF ,. Rsls-s-l.11 DETERMTNATT.N oF *HETHER A *ASTE rs HMARDous
ACTION NEEDED:
2. R315.5.1.12 NOTIFICATION AND EPA HAZARDOUS WASTE IDENTIFICATION NUMBERS
a. lf you generate between '100 and 1 000 Kgs (200-22001bs) of hazardous waste per month or up to 1 Kg of acutely hazardous
waste, you are classified as a Small Quantlty 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 is accomplished by notifying the Utah Division of Solid and
Hazardous Waste at (801) 538-61 70.
b. lf you are a small quantity generator, you musl obtain an EPA ld Number in order offer hazardous wasts for management to a
lransporter 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 manilest lorm 87OO-22 and 8700-22A when offering hazardous wastes lor transport to a TSDF or use the manifest of the
state that the TSDF is located in, if required by that state.
b. Designate another facility or instruct a transporter to return wastes if they are undeliverable.
c. Fill out all applicable sections ol 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 KEEPING
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:
R31 5-5.4.42 EXCEPTION REPORTING
lf TSDF does not return generatods copy of manifest within 60 days, a generator must submit a letler stating so and a copy of the
manifest to the Executive Secretary ol the Utah Solid and Hazardous Waste Control Board.
ACTION NEEDED:
_6.
-O.
_7.
_4.
_b._c.
_d._e._f.
R315.5.3 PACKAGING, LABELING MARKING AND PLACARDING
Package, label and mark waste in accordance with DOT 49 CFR prior to shipment.
ACTION NEEDED:
R31 5.5-3.34 ACCUMULATION TIME
Do not store hazardous wastes for longer than 180 days or 270 days, if applicable, without a permit.
Do not exceed 6000 Kg ol hazardous wastes stored at your facility at any time.
Mark the date the accumulation period began on each container of hazardous waste, Satellite accumulation containers are the
exception.
Label each tank and container with the words "HAZARDOUS WASTE" while it is being use to accumulate hazardous wastes.
Designate and authorize an emerg€ncy coordinator (s) who is (are) readily available by some means at all times.
Post the following information next to each telephone at the facility: name and lslephons number of the emergency coordinator(s)
location(s) or fire extinguishers, spill control equipment, fire alarms, telephone number of the local fire department (or equivalent
emergency response for lacility).
Ensurs ihat all employees are lamiliar with hazardous wasts handling and emergency procedures.
The emergency coordinator must respond appropriately to emergencies that have the potential ol involving hazardous waste (s).
ACTION NEEDED:
R315.9 SPILL RESPONSE
Take appropriate action to minimize threats to human health and the environment by notifying the Utah State Department of
Environmental Quality at [phone] or 1 (800) 572-6/,00 (24 hour number) iI more than 1 Kg of acutely hazardous waste,
100 Kg oI hazardous waste, 25 gallons of used oil or material which when spilled becomes hazardous waste, as specified in notify
the National Besponse Center when applicable and provide the appropriate information listed in R315-9, in the spill report.
ACTION NEEDED:
These are only examples that will help you
following information and it make specific
to comply with the regulati
to your facility.
t
ons.You must adapt the
Page 4
SEE #10c
Today's date:
Letters to: Your Hospital
Your local Police Department
Your local Fire Department
Dear Sir or Madame:
In 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. In the event of an unforeseen emergency, you may be required to respond.
Your name and title
Your company name
See lfTc and 7f
IN CASE OF AN EMERGENCY DIAL9LI
EMERGENCY COORDINATOR IS CARL CAREFUL - EXT 2536
FIRE, EXTINQUISHERS LOCATION MARKED ON THE WALL
SPILL CONTROL EQUIPMENT LOCATED AT TIME CLOCK
UNIVERSAL WASTE
MERCURY CONTAINING LAMPS
DATE:
Page 5
i
9.
a.
b.
c.
d.
e.
f.
g.
h.
UTAH DEQ SMALL QUANTITY GENERATOR EVALUATION FORM
Rgls-7-1G usE AND MANAGEMENT oF conrhruens
Hold hazardous wastes in containers that are in good condition.
Store hazardous wastes in containers that are compatible with the waste.
Keep hazardous waste containers in a completely closed condition except when adding or removing wastes.
Do not open, handle or store containers of hazardous waste in a manner which may cause a release.
lnspect containers of hazardous waste at lease weekly to look for signs of leakage or deterioration. A log should be kept.
Do not store incompatible hazardous wastes in the same coniainer.
Do not store wastes in containers that previously held an irrcornpatible material without cleaning it first.
Separate incompatible wastes by means of a dike, berm or other method.
ACTION NEEDED:
R315.15 STANDARDS FOR USED OIL GENERATORS
Use permitted used oil transporter, (name, address and telephone number of transporter).
Storage tanks and associated piping in good condition and labeled used Oil".
Bum only their own used oil in vented space heater with a max. cap. ol 0.5 million BTUs or in (>0.5 cap.heater).
Hot drain punctured oil filters. Method of lilter disposal. Discarded in trash or recycled. lf recycled, by rvhom?
Clean up any used oil spills and any contaminated soil.
ACTION NEEDED:
a.
b.
10, R315.7.10 PREPAREDNESS AND PREVENTION
You must operate your lacility in such manner that MINIMIZES the possibility of fire, explosion or any unplanned release.
You must have the following preparedness and prevention equipment unless the wastes you store do rpt pose the hazards that the
equipment b designed to respond to: lnternal communications or alarm capable ol instruction (srrch as an intercom), a device
capable of summoning outside emergency assistance (such as a direct alarm to the fire deparfnent or a telephone), portable fire
extinguishers, water a adequate pressure and volume to supply fire fighting needs, alarms and communication devices accessible to
to personnel where they are handling hazardous wastes.
You must maintain and test, wtlere necessary, all communication systems; fire, spill response, decontramination and protective
equipment.
Make maintain aisle space to allow unobstructed movement of personnel and emergency equipment.
Make anangements with local lire, police and hospitals to respond to emergency situations at your facility. Maintain documentation
notification letters, responses or lack of responses from these agencies.
Document refusals by authorities to emergency arrangements.
ACTION NEEDED:
11. R315-13 LAND DISPOSAL RESTRTCTIONS (LDR)
a. lf you treat your hazardous wast€s to render them non-Land Disposal Restricted, you must develop and lollow a written waste
analysis plan. This waste analysis plan must be based on a laboratory analysis ol the waste and must contain all necessary elements
including frequency. The waste analysis plan must be submitted to the Executive Secretary of the Utah Solid and Hazardous Waste
Control Boad at least 30 days prior to treafrnent.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 it it is restricted, that it is land disposable after treatment, must
acodnpany each manifested shipment ol hazardous waste.d. Maintain all LDR Documentation for five years after the waste is shipped ofl site.
ACTION NEEDED:
12. R315.1 6 UNIVERSAL WASTES, FLUORESCENT LIGHT TUBESa. 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 t NIVERSAL WASTE-MERCURY CONTAINING |-AMPS".
ACTION NEEDED:
13.
a.
b.
c.
d.
e.
14. OTHER ACTIONS NEEDED:
5/6/03
\.,rJIY I AllYEft IVIAIYA\rtr,lYttrl\ I LtJt,Page 6
If any columns Are marked
NO describe what was done to
bring the contaiqer into
compliance?
Inspector's
Name
ar.}tainers
labeled with the
words
H.AZARDOUS
WASTE?
Is accumulation
date marked on
all hazardous
waste containers
and is that date
less than 180
days old?
Are il.dous
waste
containers
closed and are
all bungs and
bung rings
secure?