DSHW-2024-009394

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SQG Program
Dennis R. Downs, Director
P.O. Box 144880
Salt Lake City, Utah 8,1114-4880
HAZARDOUS WASTE SMALL QUANTITY GENERATOR EVALUATION FORM
Facility Name: fl.o fJ Eq*Ipt..dt (o f,"r,< . i EPA lD Number: lLT0700ollTbI
Street Address: 7?91 Sorftti -l o o ^ t J<.Sf i City: n:9,0aLe-, i2ip:g1o't7County:.failEK.|contaiiFirson:ga*A".tgc|tuiTeteprron;#:8@
Generator Status:Cgfq C, Numbe r gf Employees:7 I oate oiViiii: A/i,i:9;- Zoo a
lnspectors:ELDAut, ,/ f{o PoDWf
Other Personnel:I I f
Waste Stream/Generation
Process
Generation Rate Per
Month
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Hazardous Waste Code Properly
Managed?
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Estirnated Quantity of Hazardous
Waste Generated Per Month d - :;i .,;-, ). r:
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RESPONSE NECESSARY: YES NO VT_RESPONSE DUE BY
coMMENrs, Aabe-l *4J.,P, D: I { ,.€ \ .{s<. 4,^1; Ff qL?q ' <p/qfq:/rqf .r,
This 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 orderto
ensure and NOTIFY THIS OFFICE lN WRITING by the indicated date. Please be advised that if we do not receive written documentation of
these conective actions by the response due date you may be subject to further 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.
RECEIVED BY:INSPECTOR:
Name, printed:Name, Printed:
Signature:Signature:
Title:Title: Comp!iance Officel
Date:
wu*+L
Page 2
t
See #7g
Example of Employee Training Log (this is only an example and must be adapted specifically to your
facility)
Date: April 9, 2002
Time: 10:00 am to t 1:00 am
Discussion lead by: John Doe, Health and Safety Coordinator
Topics Discussed
,.
XYZ Companv Emplovee Training Log
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."
Use and Management of Containers
a. Maintain a log weekly on thehazardous 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.
Other topics as discussed
a.
b.
l.
ll.
ru.
Employee Name (Please Print)
1.
Employee Signature
)aa
3.
4.-J.
Page 3
rtems that are marked "*oY't#,P"=ff.:Tlh:[Yffi']:.ffffiH]"*IJ]h'*ll?l[l"3l#* the utah sorid 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.
1. R315.5-1.11 DETERMINATION OF WHETHER AWASTE IS HAZARDOUS
ACTION NEEDED:
2. R315.5.1.12 NOTTFICATION AND EPA HAZARDOUS WASTE IDENTIFICATION NUMBERS
a. lf you generate between '100 and 1000 kgs (200-22001bs) of hazardous waste per month or up to 1 kg of acutely hazardous
waste, you are classified as a Small Quantity Generator (SQG) and you must notify the Executive Secretary of the Utah Solid and
Hazardous Waste Control Board and obtain an EPA ld Number. This is accomplished by notifying the Utah Division of Solid and
Hazardous Waste at [phone].
b. lf you are a small quantity generator, you must obtain an EPA ld Number in order to offer hazardous waste for management to a
transporter or to a treatment, storage and disposal facility (TSDF) that has an EPA ld Number.
ACTION NEEDED:
3.
a.
R315.5.2 MANIFESTS
Only use approved manifest lorm 8700-22 and 87OO-22Awhen offering hazardous wastes for transport to a TSDF or use the manifest of the
state that the TSDF is located in, if required by that state.
Designate another facility or instruct a transporter to return wastes if they 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 (SQG or less).
Keep copies of contractual agreements for three years after service ends.
ACTION NEEDED:
R315-5.4 RECORD KEEPING
Keep copies of manifests for three years.
Keep all records, including determination of generation rates, waste characterization documentation, disposition, etc., for three years.
ACTION NEEDED:
5. R315.5.4.42 EXCEPTION REPORTINGa. lf TSDF does not return generator's copy of manifest within 60 days, a generator must submit a letter stating so and a copy of the
manifest to the Executive Secretary of the Utah Solid and Hazardous Waste Control Board.
ACTION NEEDED:
b.
c.
d.
g.
4.
a.
b.
Ao.
a.
R31 5-5.3 PACKAGING, LABELING MARKING AND PLAGARDING
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 of 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 emergency 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 telephone 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 facility).
Ensure that all employees are familiar with hazardous waste handling and emergency procedures.
The emergency coordinator must respond appropriately to emergencies that have the potential of 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 [phone] (24 hour number) if more than 1 Kg of acutely hazardous waste,
100 Kg of hazardous waste, 25 gallons of used oil or material which when spilled becomes hazardous waste, as specified in notify
the National Response Center when applicable and provide the appropriate information listed in R315-9, in the spill report.
ACTION NEEDED:
4.,
Page 4,
These are only examples that will help you to comply with the regulations. You must gg[gp! the following
information and it make specific to your facility.
SEE #l0c
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 #7 c and 7f
IN CASE OF AN EMERGENCY DIAL 911
EMERGENCY COORDINATOR IS CARL CAREFUL - EXT 2536
FIRE EXTINQUISHERS LOCATION MARKED ON THE WALL
SPILL COI\TROL EQUIPMENT LOCATED AT TIME CLOCK
UNIVERSAL WASTE
MERCURY CONTAINING LAMPS
DATE:
Page 5
UTAH DEQ SMALL QUANTITY GENERATOR EVALUATION FORM
R315.7.16 USE AND MANAGEMENT OF CONTAINERS
Hold hazardous wastes in containers that are in gcod condition.
Store hazardous wastes in containers that are ccfi:patible with ihe waste.
Keep hazardous waste containers in a completely :losed condiiion except when adding or removing wastes.
Do not open, handle or store containers of hazarcious 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 v\astes 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. R315.7.10 PREPAREDNESS AND PREVENTION
r. You must operate your facility in such manner that MINIMIZES the possibility of fire, explosion or any unplanned release.c. 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 ftre department 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.s. You must maintain and test, where necessary, all communication systems; fire, spill response, decontamination and protective
equipment.d. Make maintain aisle space to allow unobstructed movement of personnel and emergency equipment.a. Make arrangements with local fire, police and hospitals to respond to emergency situations at your facility. Maintain documentation
notification letters, responses or lack of responses from these agencies.l. Document refusals by authorities to emergency arrangements.
ACTION NEEDED:
11. R315-13 LAND DISPOSAL RESTRICTIONS (LDR)a. lf you treat your hazardous wastes to render them non-Land Disposal Restricted, you must develop and follow a written waste
analysis plan. This waste analysis plan must be based on a laboratory analysis of the waste and must contain all necessary elements
including frequency. The waste analysis plan must be submitted to the Executive Secretary of the Utah Solid and Hazardous Waste
Control Board at least 30 days prior to treatment.b. Maintain an assessment of LDR status on file for each hazardous waste generated at the facility.c. A notice and certification that each waste is either land disposal restricted, or if it is restricted, that it is land disposable after treatment, must
accompany each manifested shipment of hazardous waste.d. Maintain all LDR Documentation for five years after the waste is shipped off 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 'UNIVERSAL WASTE-MERCURY CONTAINING LAMPS'.
ACTION NEEDED:
13. R315-1 5 STANDARDS FOR USED OIL GENERATORS
a. Use permitted used oil transporter, (name, address and telephone number of transporter).b. Storage tanks and associated piping in good condition and labeled "Used Oil'.c. Burn only their own used oil in vented space heater with a max. cap. of 0.5 million BTUs or in (>0.5 cap.heater).d. Hot drain punctured oil filters. Method of filter disposal. Discarded in trash or recycled. lf recycled, by whom?e. Clean up any used oil spills and any contaminated soil.
ACTION NEEDED:
14. OTHER ACTIONS NEEDED:
5/6/03
NTAI NER MANAGEME .Page 6
If any columns are mar$ed
NO describe what was done to
bring the container into
compliance?
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Are containers
labeled with the
words
HAZARDOUS
WASTE?
fs accumulation
date marked on
all hazardous
waste containers
and is that date
less than 180
days old?
Are haztrdous
waste
containers
closed and are
all bungs and
bung rings
secure?
Inspector's
Itiame