DSHW-2011-005138 - 0901a0688021e4b7

HAZARDOUS WASTE INSPECTION REPORT
Date of Inspection
Facility
EPA ID No
Facility Contact
Notification
Applicable Regulations
Type of Inspection
Participants
Time In
Time Out
Weather Conditions
Report Prepared by
Wednesday, March 16, 2011
Nucor - Vulcraft Group
1875 West Highway 13 South
P O Box 637
Brigham City, Utah 84302
UTD980959035
Aaron Bell, Environmental Coordinator
435 734-4443
Large Quantity Generator
R315,Part5UAC
Compliance Evaluation Inspection (CEI)
Jon Parry, DSHW
Sam Schroyer, DSHW
Aaron Bell, Vulcraft
0900 hrs
inOhrs
Rain, ~ 45° F
Jon Parry
Facility Description
Vulcraft, a subsidiary of Nucor Steel builds and paints metal trusses and cold rolls steel
into various forms and shapes The Company presently employs about 320 people at the
Bngham City plant
Credentials, Purpose, and Scope
The inspector met with and presented credentials to Aaron Bell The purpose of the
inspection was to assess the facility's hazardous waste management practices for
compliance with R315 of the Utah Administrative Code (the Rules) The scope of the
inspection included a review of required records and plans and a tour of the facility
Waste Streams, Management Practices
The facility has recently switched from a lacquer to a water based truss fimsh Vulcraft
shipped 2 5 5-gallon drums of waste paint related material in March 2011 and 42 drums in
February of 2011 This is reportedly the last of the lacquer based paint material All the
truss dip vats are now filled with water based pamt
Vulcraft still 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 at Nucor and any remaining contents are managed as hazardous waste
Vulcraft does have a few parts washers that are serviced under Safety Kleen's continued
use program
Universals wastes are collected and appropriately managed
The facility expects to drop to a small quantity hazardous waste generator However they
may wait until after the next bienmal reporting cycle to submit a revised notification
form
Facility Inspection
R315-5 Hazardous Generator Requirements
5-1 10 Applicability No problems noted
5-111 Hazardous Waste Determination No problems noted
5-112 Identification Numbers No problems noted
5-2 Manifest No problems noted See checklist
5-3 Packaging. Labeling. Marking, and Placarding No problems noted
5-3 34 Accumulation Time No problems noted See checklist
5-4 Recordkeeping No problems noted
5-441 Biennial Reporting No problems noted
5-4 42 Exception Reporting No problems noted
5-4 43 Additional Reporting No problems noted
5-4 44 Requirements for Generators of between 100 and 1000 kg/month NA
5-5 Exports of Hazardous Waste NA
5-6
5-7
Imports of Hazardous Waste NA
Farmers NA
7-9 7 Personnel Training No problems noted See checklist
7-10 Preparedness/Prevention Plan No problems noted See checklist
7-11 Contingency/Emergencv Plan No problems noted See checklist
R315-13-1 Land Disposal^e^trictions No problems noted
Sign^^^ Date
777-1 XLS
Site (lolr^vcA-ft^ ID# Date 3llU("Z<=>ti
La
INSPECTION ITEM
Hazardous Was
irge Quantity Gen
Page 1
CITATION
te Inspection
erator Checklist
of 2
COMMENTS
Waste Determination
Has the generator determined whether his/her
solid waste is a hazardous waste
Has a waste determination been done for each
waste stream''
R315-5
R315-5-1 11
262 11
R315-2-3
261 3
Has the generator notified of regulated activity
and obtained an EPA ID# in accordance with
the requirements of Section 3010 of RCRA''
R315 5-1 12
262 12
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 the generator use the correct manifesf
R315-5-2 20(a)
262 20(a)
R315-5-2 20(b)
262 20(b)
R315-5-2 20(c)
262 20(c)
R315-5 2 20(a)
262 20(a)
Manifest requirements for the Generator
1 Did the generator sign the manifest
certification by hand''
2 Did the generator obtain a handwritten
signature from the initial transporter and the
date of acceptance''
3 Did the generator retain a copy of the
manifest in accordance with R315 5-4 40(a)''
R315-5-2 23(a)(1)
262 23(a)(1)
R315-5-2 23(a)(2)
262 23(a)(2)
R315-5-2 23(a)(3)
262 23(a)(3)
Recordkeeping
Is the generator maintaining signed copies of
the hazardous waste manifest for three years''
R315-5 4 40(a)
262 40(a)
Is the generator maintaining copies of each
Biennial Report and all Exception Reports for a
period of at least three years'?
R315 5-4 40(b)
262 40(b)
Inspector's Initials Page. of
777-1 XLS
Site
La
INSPECTION ITEM
ID#
Hazardous Wast
rge Quantity Gen
Paae 2
CITATION
Date
e Inspection
erator Checklist
of 2
COMMENTS
Is the facility maintaining records sufficient to
determine quantities and disposition of
hazardous waste or other determinations test
results or waste analyses made in accordance
with R315-5 1 11 for a period of at least three
years from the date of last shipmenf
R315 5-4 40(C)
262 40(c) LjO >
Biennial Reporting
Has the generator submitted complete
Biennial Report(s)''
R315-5-4 41
262 41
<^ e.{
Exception Reporting
Has the generator been required to prepare an
Exception Report if yes descnbe the
circumstances
R315-5-4 42
262 42
Packaging, Labeling, Marking, and
Placarding
1 Is the generator packaging his/her
hazardous waste is the appropriate DOT
shipping containers'?
2 Are containers labeled and marked in
accordance with DOT shipping requirement
prior to shipping'?
3 Is the generator providing the appropriate
placarding to the initial transporter when
initiating his/her shipmenf
R315-5-3 30
262 30
R315-5-3 31 &
R315-5-3 32
262 31 & 262 32
R315-5-3 33
262 33
f
Accumulation Times
(See Satellite 90 Day and Tank
Checklists as applicable)
R315-5-3 34
Also see checklist for
Personnel Training
Prepardness & Prevention
Contingency Plan & Emergency Procedures
and Manifest
Comments
Inspector's Initials. Page. of
777-1 XLS
Site 1 ID# Date -iU£>/vciti
Hazardous Waste Inspection
Satellite Accumulation Checklist Site Manaaer
< 55 gallons
INSPECTION ITEM CITATION COMMENTS
Is the satellite accumulation area at or near the
point of generation''
R315-5-3 34
262 34(c)(1)
Is the satellite area under the control of the
operator of the process generating the waste''
262 34(c)(1)
^«
Does the generator have the accumulation
container labeled with the words hazardous
waste or with other words that identify the
contents of the container'?
262 34(c)(1)(il)
The generator can not store more than 55
gallons of hazardous waste or 1 quart of acutely
hazardous waste at the satellite accumulation
area
262 34(c)(1)
Are the containers in good conditions'' 262 34(c)(1)(i)
Is the hazardous waste stored in containers that
are compatable with the waste'?
262 34(c)(1)(l)
is the accumulation container being maintained
in a closed condition except when waste is
being added or removed'?
262 34(0(1)0)
Is the generator managing the accumulation
container in a manner that will not cause it to
leak or spilP
262 34(0(1 )(i)
Is the generator correctly labeling and moving
hazardous waste in excess of the 55 gallon or 1
quart limits to a 90-day storage area within 72
hours of exceeding the limif?
262 34(c)(2)
inspector's Initials. Page. of
777-1 XLS
Site Ju \r(t.A.^ -V^ ID#
Hazardous Waste Inspection
90 Day Storage Site
> 55 gallons
Site Manager.
Date 3 Izt^ l\
INSPECTION ITEM CITATION COMMENTS
Is the container labeled with the words
Hazardous Waste"'?
Is the date upon which accumulation began
clearly marked and visibly for inspection'?
Is that date <= 90 days old''
R315-5-3 34
262 34(a)(3)
262 34(a)(2)
262 34(a) Is there a Preparedness and Prevention Plan
for this site or the facility as a whole including
this site •? (see separate Check List)
Operated to minimize chance of Spill or Fire '?
Spill and Fire control equipment'?
Emergency communication device Internal''
Emergency communication device External''
Sufficient Aisle and Access space''
262 34(a)(4)
265 Subpart C
R315-7-10 2
R315 7-10 3(c)
R315-7 10 3(a)
R315-7-10 3(b)
R315-7-10 6
Is there a Contingency Plan for this site or the
facility as a whole including this site ''
(see separate Check List)
Descnption of actions that should be taken '?
Name & Phone # for Emergency Coordinator'?
Primary and alternate evacuation routes '?
List of emergency equipment & location ''
262 34(a)(4)
265 Subpart D
R315-7 11 3(a)
R315-7-11 3(d)
R315-7 11 3(f)
R315 7-11 3(e)
Have personnel at this site Successfully
completed up to date Personnel Training on
HzW Handling & Fire & Spill Response''
Is the training documented''
(see separate Check List)
262 34(a)(4)
R315-7-9 7(a)
265 16(a)
R315-7-9 7(e)
262 16(e)
J
1
Are the containers accumulating and holding
hazardous waste in good condition''
Are they compatible with the HzW in them'?
262 34(a)(1)(i)
265 Subpart I AA
BB and CC
R315 7-16 2
R315 7-16 3
Is the generator maintaining his/her containers
in a closed condition except when adding or
removing waste from the container*?
R315 7-16 4(a)
262 173(a)
Containers holding hazardous waste must not
be opened handled and/or stored in a manner
which could cause it to leak
R315-7-16 4(b)
262 173(b)
Is the generator inspecting his/her containers at
least weekly and do the inspections look for
leaks deterioration and any factor that may
cause a release of hazardous waste*?
R315-7-16 5
262 174
No ignitable or reactive HzW within 50 feet of
the facility s property line
R315-7-16 6
265 176
Inspector's Initials Page. of
Site OwVt/iA-P'V- ID# Date
Hazardous Waste Inspection
Manifest Checklist (Rev 3-05)
Requirements Manifests Reviewed
Manifest Number (box 4) # #
Generator EPA ID#
R315-5 2 (box1)
Generator information
Mailing Address (box 5)
Phone Number o<—
Transporter #1 information
Company Name (box 6)
EPA ID# (box 6) i
Transporter #2 information
Company Name (box 7)
EPA ID# (box 7) e><~-
OL-
i
Q.
_r
Desianated Facilifv information
Name and Address (box 8)
EPA ID# (box 8) OL-J
Waste ShiDDina requirements
DOT Descnption (Including proper
name Hazard class and ID #) (box
9b)
(box 9a X If hazardous matenals)
Containers No & Type (box 10)
Total Quantity (box 11)
Unit - WtA/ol (box 12)
Waste Codes (box 13)
0^
i
0
0
Special Handling Instructions
(h"^ 14)
0 1
Manifest Certifications
Generators Signature (box15)
International Shipments (box 16)
Transporters Signature (box 17)
Discrepancy Indication (box 18)
Hazardous Waste Report
Management Method Codes
(box 19)
0
hi
0
{
Final Observations and / p " ' C^-
Comments LTM^ -
-1- Or-—
Common container codes DM - metal drum\barrel DF - fiberbarrel TT carao tank TC - tank car DT - dump truck CM metal box\carton (includes
roll-offs) Common Units of Measure G - aallons P - oounds T - tons Y - cubic yards)
Inspector's Initials Page. of
777-1 XLS
Site do\cL<^i^\— ID# Date 3ll^|-2.T>n
INSPECTION ITEM
Hazardous Waste Inspection
Personnel Training Checklist
Page 1 of 2
CITATION COMMENTS
Facility personnel must successfully
complete classroom instruction or on-the-job
training which teaches them to perform their jobs
such that the facility is operated in compliance
with the applicable hazardous waste
management requirements
R315-5-3 34
262 34(a)(4)
R315-7 9 7(a)(1)
265 16(a)(1)
Is the program directed by a person trained in
hazardous waste management procedures'?
R315-7 9 7(a)(2)
265 16(a)(2) 1
Does the training teach facility personnel
hazardous waste management and contingency
plan implementation procedures'?
R315-7 9 7(a)(2)
265 16(a)(2)
Does the training program include at a minimum
the following where applicable
1 Procedures for using inspecting repainng
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
6 Shutdown of operations and
7 Evacuation of personnel procedures
R315 7-9 7(a)(3)
265 16(a)(3)
R315-7 9 7(a)(3)(i)
265 16(a)(3)(i)
R315 7-9 7(a)(3)(ii)
265 16(a)(3)(ii)
R315 7-9 7(a)(3)(iii)
265 16(a)(3)(iii)
R315 7-9 7(a)(3)(iv)
265 16(a)(3)(iv)
R315-7-9 7(a)(3)(v)
265 16(a)(3)(v)
R315 7-9 7(a)(3)(vi)
265 16(a)(3)(vi)
Site
Inspector'
ID#
•'s Initials
4-J
^5
Date
Page. of
777-1 XLS
INSPECTION ITEM
Hazardous Waste Inspection
Personnel Training Checklist
Paae 2 of 2
CITATION COMMENTS
Have facility personnel successfully
completed the personnel training program
within SIX months of the their date of
employment or assignment to the facility''
R315-7-9 7(b)
265 16(b)
Do the facility personnel recieve an annual
review of their initial training'? R315 7-9 7(c)
265 16(0
The owner/operator of the facility must maintain
the following documents at the facility
1 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 writtem job descnption for each position
listed under #1
3 A written descnption 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 or job expenence required
by paragraphs 265 16 (a) (b) and (c)
R315-7-9 7(d)
265 16(d)
R315-7 9 7(d)(1)
265 16(d)(1)
R315-7-9 7(d)(2)
265 16(d)(2)
R315-7 9 7(d)(3)
265 16 (d)(3)
R315-7-9 7(d)(4)
265 16 (d)(4)
Are training records maintained at the facility for
current employees and for at least three years
for employees that have left the company''
R315 7-9 7(e)
265 16(e) 1
Inspector's Initials. Page. of
777-1 XLS
Site "^x^XcytJ^ ID# Date -SMC/Zot/
Hazardous Waste Inspection
Preparedness and Prevention Measures Checklist
Page 1 of 2
INSPECTION ITEM CITATION COMMENTS
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''
R315-7 10 2
265 31
R315-5-3 34
262 34(a)(4)
The facility must be equipped with items (1)-(4)
identified below unless it can be shown that
hazardous waste managed at the site would not
require the particular kind of equipment
specified
R315-7-10 3
265 32
1 Does the facility have an internal
communications or alarm system capable of
providing immediate emergency instruction to
Its personnel
R315 7-10 3(a)
265 32(a)
2 Does the facility have a device capable of
summoning external emergency assistance to
the facility (phone or two-way radio)'?
R315 7-10 3(b)
265 32(b)
3 Does the facility have portable extinguishers
fire control equipment (including special
extinguishing equipment necessary for their
facility) spill control equipment and
decontamination equipment"?
R315-7-10 3(0
265 32(0
^ t(
4 Does the facility have water at adequate
volume and pressure to supply water hoses or
foam producing equipment or automatic
spnnklers or water spray systems
R315-7-10 3(d)
265 32(d)
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"?
R315-7-10 4
265 33
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"?
R315-7-10 5(a)
265 34(a)
Is there ever just 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''
R315 7 10 5(b)
265 34(b)
Site ID# Date
Inspector's initials. Page of.
777-1 XLS
Hazardous Waste Inspection
Preparedness and Prevention Measures Checklist
Page 2 of 2
INSPECTION ITEM CITATION COMMENTS
Is aisle space maintained to allow the
unobstructed movement of emergency
personnel or equipment (un/essaisle space is
not needed for any of these purposes)*?
R315-7-10 6
265 35
The facility must arrange the following types
agreements or arrangements with local
organizations (as appropnate)
R315-7 10 7(a)
265 37(a)
1 Has the facility made or attempted to make
arrangements to familarize local police fire
departments and emergency response teams
with the layout of the facility character of the
hazardous waste(s) managed locations where
facility personnel normally work location of
facility entrances and possible evacuation
routes*?
R315-7-10 7(a)(1)
265 37(a)(1)
2 Has the facility designated pnmary
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*?
R315 7-10 7(a)(2)
265 37(a)(2) Y'
3 Have agreements with State emergency
response teams emergency responses
contractors and equipment suppliers been
made*?
R315-7-10 7(a)(3)
265 37(a)(3)
4 Have arrangements been made to familiarize
local hospitals with the properties of hazardous
waste handled at the facility and the types of
injuries or illnesses which could result from
fires explosions or releases at the facility*?
R315 7 10 7(a)(4)
265 37(a)(4)
If any State or local authorities have declined to
enter into such arrangements has the facility
documented the refusal in the operating record"?
R315-7-10 7(b)
265 37(b)
Inspector's Initials. Page. of
777-1 XLS
Site ID# Date 2(/u/zot(
Hazardous Waste Inspection
Contingency Plan and Emergency Procedures Checklist
Page 1 of 3
INSPECTION ITEM CITATION COMMENTS
General Requirements
Is a copy maintained at the facility"?
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*?
R315 5-3 34
262 34(a)(4)
R315-7-11 4(a)
265 53(a)
R315-7 11 4(0
265 53(b)
Content of the Continqencv Plan
1 Does the contingency plan descnbe 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 nonsudden release of
hazardous waste"?
2 Does the contingency plan descnbe
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) of pnmary 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 to date and include the
location and a physical descnption of each
Item on the list and a bnef outline of the
equipment s capability
5 Does the contingency plan include an
evacuation plan for the facility*? This plan must
include a descnption of signal(s) to be used to
begin an evacuation evacuation routes and
alternate evacuation routes
R315-7 11 3(a)
265 52(a)
R315-7-11 3(c)
265 52(0
R315-7-11 3(d)
265 52(d)
R315 7-11 3(e)
265 52(e)
R315 7-11 3(f)
265 52(f)
Y>
1
Y'>
-e:
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*?
Site
R315-7-11 6
265 55 ,^5
ID# Date
Inspector's Initials ^ Page. of
777-1 XLS
Hazardous Waste Inspection
Contingency Plan and Emergency Procedures Checklist
Page 2 of 3
INSPECTION ITEM CITATION COMMENTS
Does the contingency plan include procedures
for activation of the internal alarm by the
emergency coordinator*?
R315 7-11 7(a)(1)
265 56(a)(1)
Does the contingency plan include provision for
notifying the appropnate State and\or local
response agencies*?
R315-7-11 7(a)(2)
265 56(a)(2)
Does the contingency plan outline the
procedure(s) that the emergency coordinator
will follow to immediately identify the character
source amount and extent of released
matenal*?
R315-7 11 7(b)
265 56(b)
Does the contingency plan include procedures
for the emergency coordinator to follow in order
to assess possible hazards to human health or
the environment*?
R315-7 11 7(0
265 56(0 v«
If It IS determined that the incident could
threaten human health or the environment
outside the facility the emergency coordinator
must notify the appropnate local State and
Federal agencies Does the contingency plan
include provision for notifying the appropnate
agencies'? Do the notification measures
include information to be reported (name and
telephone # of reporter name and address of
facility name and quantity of matenal(s)
involved extent of injuries and possibility of
exposure outside the facility) and identify the
National Response Center and the State as
parties to be notified'?
R315 7-11 7(d)(1)
and (d)(2)
265 56(d)(1) and
(d)(2)
Does the plan include procedure to prevent the
spread of the incident to other hazardous waste
at the facility'?
R315-7-11 7(e)
265 56(e)
Are measure 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*?
R315-7 11 7(f)
265 56(f) CC
Site ID# Date
Hazardous Waste Inspection
Contingency Plan and Emergency Procedures Checklist
Page 3 of 3
Inspector's initials Page. of
777-1 XLS
oiiu
Hazardous Waste inspection
Contingency Plan and Emergency Procedures Checklist
Page 3 of 3
INSPECTION ITEM CITATION COMMENTS
Does the contingency plan provide procedures
to follow to manage the hazardous waste
generated as a result of an incidenf?
R315-7-11 7(g)
265 56(g)
Following implementation of the contingency
plan are provisions included to ensure that in
the affected area(s)
1 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 pnor to resuming
activities at the facility
R315 7-11 7(h)
265 56(h)
R315-7-11 7(h)(1)
265 56(h)(1)
R315-7-11 7(h)(2)
265 56(h)(2)
Does the contingency plan include provisions for
notifying the appropriate federal State and local
authorities that the facility is in compliance with
40 CFR 265 56(h) prior to resuming operations
in the affected area'?
R315-7-11 7(1)
265 56(0
The contingency plan must include provision for
recording the incident requinng implementation
of the contingency plan and specifying
information that will be recorded and reported
The requirements are as follows
1 Will a written report on the incident be
provided to the Utah State Department of
Environmental Quality within 15 days'?
2 The following information needs to be
recorded and reported
a) The name address and telephone # of the
owner/operator
b) The name address and telephone # of the
facility
c) Date time and type of incident
d) Name and quantity of matenal(s) involved
e) Extent of injury if any
f) An assessment of the actual or potential
hazard to human health or the environment
and
g) An estimate of the quantity and disposition
of recovered material(s) that resulted from the
incident
R315 7-11 70)
265 56(j)
R315-7-11 70)
265 560)
R315-7-11 70)(1)
thru 0)(7)
265 560)(1)thru
0)(7)
Inspector's Initials Page. of