DSHW-2017-001844 - 0901a068806c7236

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WASTE MANAGEMENT
& RADIATION CONTROL
SQG/CESQG
COMPLIANCE EVALUATION INSPECTION
Date of Inspection:
Facility:
Facility Address:
County:
EPA ID #
Latitude / Longitude:
Generator Status:
Number of Employees:
Arrival / Departure Time:
Weather Conditions:
Report Prepared By:
Names of Inspectors:
LHD Notifications I Date:
Facility Notification / Date:
Applicable Rules:
February 16,2017
Nucor Vulcraft, Cold Finish
and Wire Product
1875 West Highway 13,
Brigham City, Utah 84302
Box Elder
urD980959035 /
4r.534709-112.06t943
SQG
360
11:00 a.m. to 1:30 p.m.
Partly Cloudy about 45'F
Alex Pashley
Alex Pashley
February 15,2017 by phone
Unannounced
R315: R3 15-262, R3 1 5-268,
R3I5-273 and R315-263 of
the Utah Administrative
Code
CREDENTIALS
On February 16,2017 the inspection team (team) met with and presented credentials to
Aaron Bell.
PURPOSE AND SCOPE
Page L of 10
DSHW - 2017 - 001844
The purpose of this Compliance Evaluation Inspection (CEI) was to evaluate the Facility's
waste management practices for compliance with applicable rules under R315 of the Utah
Administrative Code (the Rules) and the Utah Solid and Hazardous Waste Act 19-6-101.
FACILITY DESCRIPTION
Vulcraft, a subsidiary of Nucor Steel builds and paints metal trusses and cold rolls steel
into various forms and shapes, manly different sized rods and bars. The Company
presently employs about 360 people at the Bingham City plant.
WASTE MANAGEMENT OPERATIONS
About four years ago Nucor switched from lacquer based to a water based paint for their
trusses.
Vulcraft has a number of satellite areas that are used for the disposal of paint spray cans.
These are primarily empty cans which are punctured and drained. The cans are sent for
recycle, and any remaining contents are managed as hazardous waste.
Vulcraft has a couple parts washers that are serviced under Safety Kleen's continued use
program. The solvent has a flash point of I47'F.
Universals waste batteries and fluorescent lamps are collected and appropriately
managed. Vulcraft is testing some new LED lights at various areas of the plant and hopes
to eventually convert the entire plant over to them.
Used oil (hydraulic and other) is generated from various machines and vehicles. It is
picked up by Emerald Oil.
COMPLIANCE STATUS:
R315-5
5-1.11
5-r.t2
5-2.20
5-3.30-3.33 Packaging. Labeling. Marking. and Placarding No problems were noted.
Hazardous Waste Generator Requirements
Determination of Whether a Waste is a Hazardous Waste No problems
were noted.
EPA Identification Numbers No problems were noted.
Manifest No problems were noted.
Accumulation Time No problems were noted.
Container Management No problems were noted.
Tank Management N/A
5.3.34
Page 2 of 10
5-4.40
5-4.4r
5-4.42
5-4.43.1
R315-13-1
13-1
R3ls-16
R315-9
FOLLOW.UP ACTIONS:
lnspector Signature:
ATTACHMENTS:
1. Photos
2. SQG Checklist
SQG Evaluation Form
Preparedness and Prevention No problems were noted.
Recordkeeping No problems were noted.
Biennial Reporting No problems were noted.
Exception Reporting No problems were noted.
Additional Reporting No problems were noted.
Land Disposal Restrictions
Land Disposal Restrictions
Standards for Universal Waste No problems were noted.
Spill Response
February 27.2017
Date
Page 3 of 10
Truss paint dip tank with water based paints.
Satellite accumulation aerosol can puncture container.
Page 4 of 10
Safety Kleen solvent 147 parts washer.
Satellite accumulation aerosol can puncture container.
Page 5 of 10
Used oil containers.
Used oil vacuum and accumulation container.
Page 6 of 10
Steel rods manufactured at Vulcraft.
Satellite accumulation aerosol can puncture container.
Page 7 of 10
Steel rods manufactured at Vulcraft.
Steel rods manufactured at Vulcraft.
Page 8 of 10
Steel wire manufactured at Vulcraft.
Used oil containers.
Page 9 of 10
Empty containers used for fluorescent lamps.
Page 10 of 10
Utah Department of Environmental euatity
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah A4114-4880
Phone [phone]
Fax [phone]
Compliance Assistance Tracking Form
Facility Name:Date: L_ /a* t.-)
rime: /O"' V f
--.ry$.*r - tk L -{,L ud-lContact Person:
ciitl-lzio. ,u6-',rcf..= Lrft
EPA !D Numb#: I
On-Site Visit - lnformational Phone Cail Meeting - Training Presentation
Tr-;nr'j t-4/a4 "/ /, *a,.
k-2"r",/s f /a*t + {*-r7a^l /h*&z b&r-o nf A .2,g,
Waste Stream/Generation Process Est. Generation Rate/ Month
4 - H't-Lar dJt
d.fu Do
Estimated Quantity of Hazardous
Waste Generated Per Month
12120t20r6
o
a.
b.
c.
d.
e.
ry'
g.
h.
UTAH DEQ SMALL BUSINESS ASSITANCE FORM CONtiNUEd
40 CFR 265.170 through 178 USE AND MANAGEMENT OF GONTAINERS
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 container.
Do not store wastes in containers that previously held an incompatible material without cleaning it first.
Separate incompatible wastes by means of a dike, berm or other method.
ACTION NEEDED:
10.40 CFR 265.31 through 37 PREPAREDNESS AND PREVENTION
You must operate your facility 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 not pose the hazards that the
equipment is designed to respond to: lnternal communications 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.
Make maintain aisle space to allow unobstructed movement of personnel and emergency equipment.
Make arrangements 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.
Document refusals by authorities to emergency arrangements.
a.
b.
ACTION NEEDED:
R315-268 LAND DTSPOSAL RESTRTCTIONS (LDR)
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 submitted to the Executive Secretary of the Utah Solid and Hazardous Waste
Control Board at least 30 days prior to treatment.
Maintain an assessment of LDR status on file for each hazardous waste generated at the facility.
Prepare 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.
Maintain all LDR Documentation for three years after the waste is shipped off site.
ACTION NEEDED:
R315.273 UNIVERSAL WASTES, FLUORESCENT LIGHT TUBES
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.
Label either the waste tubes or container holding the tubes as 'UNIVERSAL WASTE-MERCURY CONTAINING LAMPS'.
lf you would like to crush the lamps, an application must be submitted and approved to the Direclor of Waste Management and Radiation Control.
ACTION NEEDED:
13. R315.15 STANDARDS FOR USED OIL GENERATORS
Use permifted used oil transporter, (name, address and telephone number of transporter).
Storage tanks and associated piping in good condition and labeled "Used Oil".
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)
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
L _t. For Spills greater than 25 gallons ,or smaller releases that pose a potential threat to human health or the environment, must be reported to DEQ at
'01-536-4123.
ACTION NEEDED:
a.
b.
c.
_14.COMMENTS -lf you have any questions, please call the Division at [phone].
/
lfr \i{\1 rt( .- {-^r,r[ 6il. - ?^U \--" ^ 6it'<- 2^\'I:
\
Example of Emplo,vee Traininq Loq (this is onlv an example and must be adaptedspecifically to your facility)
XYZ Companv Emplovee Traininq Loq
Date:April 9, 2015
Time: 10:00 am to 11:00 am
Discussion lead by: John Doe, Health and Safety Coordinator
Topics Discussed
l. Hazardous Waste Accumulation Timea. Do not store hazardous wastes for longer than 190 days on site.b. Label each container or tank with the words "Hazardous waste."
ll. Use and Management of Gontainersa' Maintain a log weekly on the hazardous waste containers; containers closed, labeled, dated and ingood 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)Employee Signature
1.
2.
3.
4.
5.
4
\
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Phone [phone]
Fax [phone]
WA$TE MANAGEMENT
& RADIATION CONTROL
SMALL BUSINESS ASSISTANGE
PROGRAM
sF E N Yreo
.*"tf
DWMRC REPRESENTATIVE:
Name: (Printed)
3,."' e *fiel*,
Signature:
Title: Environmental ScientisUEnqineer
Date:
\,T0ltvqiqo i r
UTAH DEQ SMALL BUSINESS ASSISTANCE FORM
Facility:,'r),.1 ,ro(&Date:7-- l@* t1
R315-262-11 DETERMINATTON OF WHETHER A WASTE IS HAZARDOUS
ACTTON NEEDED: a,ftz-"'r C-a. p^..,,1t v-.r.-[-r.,t 1I\,neL ,-a. ( 1 .
R315.262.12 NOTIFICATION AND EPA'HAZARDOUS WASTE IDENTIFICATION NUMBERS
lf you generate between 1 00 and 'l 000 Kgs (220-22oolbs) of hazardous waste per month or up to 1 Kg of acutely hazardous waste
you are classified as a Small Quantity Generator (SQG) and yoy must notify the Director of the the Division of Waste Management andRadiation control and obtain an EPA lD Number. This is accomplished uy noiitylng the Utah oivision or waste Managem;fil Radiation controlat (801) s36-0200.b lf you are a small quantity generator, you must obtain an EPA lD Number (Form 8700-12) in order to offer hazardous waste for managementto a transporter or to a treatment, storage and disposal facility (TSDF) that has an EpA lD Number.
ACTION NEEDED:_
2.
a.
3.
a.
b.
c.
d.
e.
T;,
Appendix to R315-262 MANTFESTS
only use approved manifest form 87oO-22 and 87oO-22Awhen offering hazardous wastes for transport to a TSDF.Designate another facility or instruct a transporter to return wastes if th-ey are undeliverable.Fill out all applicable sections of the manifest.
Use a contractual disposal agreement only if a generation rate is less than 1000 Kg/month (SeG or less).Keep copies of contractual agreements for three years after service ends.
ACTION NEEDED:
_8. B315-262-200.34(dXSXivXB) and (C) SptLL RESPONSE
-
a. Take appropriate action to niinirfii2e thieals to hunian'healttr inolne environmenfin the event of a spill by notifying the Utah StateDepartment of Environmental Quality at (8ol) 5364123 if the following quantities are exceeded more than 1 Kg of acutely hazardouswaste, 100 Kg of hazardous waste, or material which when spilled becomes hazardous waste, as specified in -notify the NationalResponse Center when applicable and provide the appropriaie information listed in nsr s-i03, in the spill report.
R3{5-262.40 RECORDKEEPING
Keep copies of manifests for three years.
Keep all records, including determination of generation rates, waste characterization documentation, disposition, etc., forthree years
ACTION NEEDED:
V s. R315-262.42 EXCEPTTON REPORT|NGI 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 thet.t / manifest to the Director of the Utah Division of Waste Managment and Radiation Control.V
ACTION NEEDED:
{, R315-262.30 PACKAGING, LABELTNG MARKTNG AND pLAcARDtNG
Y
Package, label and mark waste in accordance with DOT 49 CFR prior to shipment.
ACTION NEEDED:
ACTION NEEDED:{H Y TLvtr \J
I ttR315-262-34 ACCUMULATTON_TIME
-(_-1 P: g :!"r: h,"^r:llo.!. w-astes for tonger than 6]j)ays or 270 days, if appticabte, without a permit.
- -+k- b. Llo not exceed 6000 Kg of hazardous wastes stored at your facility at anytime.
Nr-P "' I*Jl;d," the accumulation period began on each container of hazaidous waste. satelite accumulation containers are the
1$L-A/y,o9! ea.cn tank and container with the words "HAzARDous WASTE' while it is being use to accumulate hazardous wastes."--rr9 Peslgftg and.authorize an emergency coordinator(s) who is (are) readily available b! some means at all times.i.\r' f^i:|tl:.j?l9Ying information next to each lelep.hone at-the facility: name and tetephone number of the emergency coordinator(s)' tocation(s) of fire extinguishers, spill control equipment, fire alarms, telephone number of the local flre departrientioiequivatent.Al emergency response for facility).(C S. Ensure that all,employees are familiar with hazardous waste handling and emergency procedures.The emergency coordinator must respond appropriately to emergencles that have the potential of involving hazardous waste (s).
ACTION NEEDED