DSHW-2024-005339

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HAZARDOUS WASTE INSPECTION REPORT
Parker Hannifin Corporation
August 4, 2010
1425 West 2675 North
Ogden Utah 84403-2698
uTD98063 s577
Stephen Kittleson
Environment, Health and Safety Manager
801-786-3038
Small Quantity Generator (SQG)
Generator
Eric Baiden (Team Leader), DSHW
Ed Deputy, DSHW
Stephen Kittleson (Parker Hannifin Corp.)
9:30 a.m.
1 1:00 a.m.
Fair, 80oF
Facility:
Date:
Facility Address:
EPA ID Number:
Facility Contact:
Phone:
Facility Status:
Notification:
Time In:
Time Out:
Weather Conditions:
Applicable Regulations: R3l5 of the Utah Administrative Code
Type of Inspection: SQG Compliance Evaluation Inspection (CED
Participants:
Report Prepared by: Eric Baiden
2
Facility Description
Parker Aerospace is a private company categorized under Aircraft Control Systems, Electronic
and located in Ogden, UT. The company engages in the design, manufacture, and service of
hydraulic, fuel, and pneumatic components, systems, and related electronic controls for
aerospace and other high-technology markets.
Parker Aerospace builds and supports systems and components for virtually every aircraft flying
today. The company also provides extensive engineering expertise in motion and control system
with significant global distribution. Parker provides innovative components and complete
systems to customers worldwide and partners with customers to improve their productivity and
profitability.
Its products include flight control actuation systems and components, thrust-reverser actuation
systems, electro hydraulic servo valves, utility hydraulic systems and components, DC motor
pumps, fuel pumps, lubrication and scavenge pumps, fuel measurement and management
systems, cockpit instrumentation, flight inspection systems, pneumatic subsystems and
components, fluid metering delivery and atomization devices, and wheels and brakes.
The Ogden facility employs about 500 workers comprising administrative and manufacturing
staff.
Credentials, Purpose, and Scope:
The CEI Inspectors met with Stephen Kittleson at facility lobby and presented credentials. We
were escorted to a conference room to begin the inspection process
Inspectors explained to the group that the purpose of the inspection was to evaluate the facility's
hazardous waste management practices for compliance with Utah administrative code R315
hazardous waste rules.
Facility Inspection, Waste Streams and Waste Management:
Mr. Kittleson of Parker Aerospace Corporation presented an overview of the processes and
activities that generate hazardous waste at the facility. After the overview the inspection
proceeded by first taking a walk through the facility to examine waste generation areas, *aste
storage areas, and safety equipment requirements for the facility. After the facility walk through
the group retuned to the conference room and begun a review ofrecords required to be
maintained at the facility by regulation.
All hazardous wastes generated at the facility were solvent and solvent related wastes. Specific
wastes generated include seals putties, epoxies (D001), solvents and solvent wastes (stodder
solvent, hexanes and MEK) dip tanks for parts washing. The company contracts with Veolia
Industries to dispose of all wastes generated on site. Wastes are generated and disposed of at a
rate of 30 gallons a quarter.
Universal wastes in the form of fluorescent light bulbs are also generated at the facility and sent
off site to be recycled by Veolia Industries as well.
Record Review:
Record review followed the facility walk through. This included hazardous waste management
plans and manifests. The inspectors randomly selected four manifests for review dating back
from one to three years. All manifests examined were fully and properly completed.
In addition, the inspectors reviewed the facility's personnel training records with special focus on
new employees, the preparedness and prevention plan, and the contingency and emergency
procedure plan. All fire extinguishers at the facility are inspected annually to ensure reliability.
All plans and records were found to be in order, complete and consistent with state rules.
Compliance Status
R315-5 Hazardous Waste Generator Requirements
Determination of Whether a Waste is aHazardous Waste. OK5-l.1I
5-1 .12
5-2.20 Manifest. OK
5-3.30 Packaging. Labeling. Marking. and Placarding. NA
5-3 .34.1 Accumulation Time. OK
Identification Numbers. OK
ContainerManagement. OK
Tank Management. NA
Preparedness and Prevention. OK
Recordkeeping. OK
Biennial Reporting. NA
5-4.40
5-4.41
5-4.42 Exception Reporting. OK
5-4.43.1 Additional Reporting. NA
R315-13-1 Land Disposal Restrictions
13-1 Land Disposal Restrictions. OK
4
R315-16 Standards for Universal Waste. OK
R315-9 Spill Resnonse. NA
Eric Baiden, Team Leader
F:\WP\Parker Hannifin Aerospace 2010 Insp.doc
Date
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Signature
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Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
Waste Determination:
Has the generator determined whether his solid waste is a
hazardous waste?
Has a waste determination been made for each waste stream!
Notification and EPA Hazardous Waste Identification
Numbers
Has the generator notified of regulated activity and obtained
an EPA ID#?
Has the generator offered his hazardous waste to a
transporter or a treatment, storage, or disposal facility
(TSDF) that does not have an EPA ID#?
Manifest
Has the generator used the approved manifest form 8700-22
and 8700-22A for off-site transportation to a TSDF?
Have all applicable sections of each manifest been filled out
completely and legibly? (See attached manifest checklist)
Does the facility generate less than 1000 kg/month and use a
contractual agreement to reclaim his waste?
Have copies of the reclamation agreements been kept on file
for at least three years after termination of the agreement?
Record Keeping
Is the generator maintaining signed copies of the manifests
for three years?
Is the generator maintaining records of test results or waste
analyses for hazardous waste determinations for at least
three years?
Excention Reportine
Has the generator been required to prepare an Exception
Report (if the TSDF does not return the generator's original
copy of the manifest within 60 days)? If yes, the generator
must submit a legible copy of the manifest to the Executive
Secretary, with some indication that the confirmation of
delivery to the TSDF haS not been received.
Has the generator kept a copy of each Exception Report for
at least threes years?
Inspector's Initia ,r, #Page I of 7
R3 15-5- l .l I
262.r1
R3 t5-2-3
262.3
R3 l5-5- t.r2
262.12
R3 l5-5- I .12
262.12
R3 I s-s-2.20 (a)
262.20(a)
R3 1 5-5-2
R-3 ts-s-2.20(eX I )
262.20(e)
R-3 ts-s-z.20(e)(2)
262.20(e)
R-3 15-5 -4.40(a)
262.a0(a)
R-3 l5-5-4.40(c)
262.40(c)
R3 I 5-5-4.42(b)
262.42(b)
R3 l s-s-4.40(b)
262.40(b)
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INSPECTION ITEM
Hazardous Waste Inspection - Small Quantity Generator Checklist
CITATION COMMENTS
Packaging. Labeling. Marking. and Placarding
Are hazardous waste containers packaged, labeled, marked,
and placarded in accordance with DOT 49 CFR prior to
shipment?
Accumulation Time
Has the generator stored hazardous wastes on-site for longer
than 180 days or 270 days (if the wastes are transported over
200 miles to a TSDF) without a permit?
Has the generator ever accumulated more than 6000 kg of
hazardous waste on-site?
The date upon which each period of accumulation begins
must be clearly marked and visible for inspection on each
container of hazardous waste.
While being accumulated on-site each container and tank is
labeled or marked clearly with the words, "Hazardous
'Waste".
Does the facility have at least on person on the premises or
on call (available to reach the facility in a short period of
time) with the responsibility for coordinating all emergency
response measures. This employee is the emergency
coordinator.
Has the generator posted the following information next to
the telephone: Name and phone number of emergency
coordinator; Location of fire extinguishers, spill control
material, and if present, fire alarm; and Telephone number
of the fire department, unless the facility has a direct alarm.
Does the generator ensure that all employees are thoroughly
familiar with the hazardous waste handling and emergency
procedures relevant to their positions?
Will the Emergency Coordinator or his designee be available
to respond to any emergencies that arise: Applicable
responses are specified in 262.34(dx5)(iv)
Use and Manaqement of Containers
Are hazardous waste containers in good condition?
R3 15-5-3
262.30,262.31,
262.32, &.262.33
R3 I 5-5-3.34
262.34(d) &
262.34(e)
R3 1 5-5-3.34
262.34(dX l )
R3 1 5-s-3.34
262.34(dX4)
262sa@)Q)
R3 I 5-5-3.34
262.34(dX4)
262.34(a)(3)
R3 l 5-s-3.34
262.34(dXs)
262.34(dxsXi)
R3 l 5-5-3.34
262.34(dXs)
262.34(dXsXii)
R3 I 5-5-3.34
262.34(dxs)
262.34(dXsXiii)
R3 l 5-5-3.34
262.34(dXs)
262.34(dXs)(iv)
R3 l 5-s-3.34
262.34(d)(2)
265.171
Inspector's Initia ,r, *Page 2 of 7
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Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
Are the containers compatible with the hazardous waste?
Are hazardous waste containers must be kept closed except
when adding or removing waste.
Are containers must not be opened, stored or handled in a
way that may cause them to rupture or leak hazardous waste.
Hazardous waste containers must be inspected weekly
looking for unlabeled, leaking and deteriorated containers.
Are incompatible wastes must not be stored in the same
containers.
Are hazardous wastes placed in containers that previously
held an incompatible waste?
Are incompatible hazardous wastes containers separated
from incompatible wastes by means of a dike, berm, wall, or
other device?
Preparedness and Prevention
Is the facility maintained and operated in a way to minimize
the possibility of fire, explosion, or any unplanned release of
hazardous waste.
Does the facility have the following equipment unless the
wastes stored do not pose the hazards that the equipment is
designed to respond to: internal communications or alarm
capable of providing immediate emergency instructions
(voice or signal) to facility personnel, a devic e capable of
summoning outside emergency equipment (such as a
telephone or a direct line to the fire department), portable
fire extinguishers, fire control equipment, spill control
equipment, decontamination equipment, water at adequate
pressure and volume to supply fire fighting needs.
Does the facility must maintain and test, where necess ary, all
communications or alarm systems; fire protection
equipment, spill control equipment, and decontamination
equipment to assure proper operation when needed.
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Inspector's Initials: ( l*rF Page 3 of 7
262.34(d)(2)
265.172
262.34(d)(2)
265.173(a)
262.34(dX2)
265.173(b)
262.34(d)(2)
26s.17 4
262.34(d)(2)
26s.177(a)
262.34(d)(2)
265 .177 (b)
262.34(dX2)
26s .177 (c)
R3 1 5-5-3.34
262.34(dX4)
265.3r
262.34(dX4)
26s.32
262.34(dX4)
26s.33
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Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
Do facility personnel have immediate access to an alarm or
emergency communication device whenever hazardous
waste is handled and if there is ever just one employee on
the premises during facility operation, does he have
immediate access to a device (telephone or two-way radio)
capable of summoning external emergency assistance?
Does the facility maintain aisle space to allow unobstructed
movement of personnel, fire protection equipment, spill
sontrol equipment, and decontamination equipment?
Has the facility attempted to make arrangements with local
fire, police, emergency response teams, and hospitals to
respond to emergency situations? The facility must
document any refusal to enter into such arrangements.
Spill Response
Take appropriate action to minimize threats to human health
and the environment by notifying the Utah Department of
Environmental Quality at (801) 5 36-4123 if more than 1 kg
of acutely hazardous waste, 100 kg of hazardous waste or
material which when spilled becomes a hazardous waste, or
25 gallons of used oil. Provide information as required.
Notifo and report to the National Response Center, at 800-
424-8802, if required.
Provide a written report including all information required in
R3 I 5-9-4 to the Executive Secretary within 15 days after an
spill of hazardous waste or material which becomes a
hazardous waste when spilled and is reported under R3 I 5-9-
l.
Land Disposal Restrictions (LDR)
Is the facility managing and treatinghazardous waste to mee
Land Disposal Restriction standards found'at 268.40. The
generator must also develop and follow a written waste
analysis plan which describes the procedures they will carry
out to comply with the treatment standards. The waste
analysis plan must be based on a chemical and physical
analysis of a representative sample of the waste being
treated. Such plans must be kept in the facility's on-site files
and available to inspectors. Wastes shipped off-site pursuan
to this paragraph must comply with the notification
requirements of 268.7(aX3).
Inspector's Initia ,r, €3T Page 4 of 7
262.34(dX4)
265.34
262.34(dX4)
265.35
262.34(dX4)
265.37
R3 1 5-9
R3 l5-9- 1
R3 I5-9-l.1
R3 1 s-9-4
R3 l5-13-l
262.34(dX4)
268.7(aXs)
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Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMENTS
If the hazardous waste meets the treatment standard at the
original point of generation, with each initial shipment of
waste or if the waste changes, the generator must send a one-
time written notice to each treatment, storage, or disposal
facility receiving the waste, and keep a copy in the file. The
notice must include the information included in column
"268.7(a)(3)" in the Table in 268.7(a)(4).
Does the facility maintain an assessment of LDR stafus on
file for eachhazardous waste generated at the facility
A notice and certification that each hazardous waste is either
not 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 at least three years
from the date the hazardous waste was shipped off-site.
Standards for Universal Waste Management
High mercury containing lamps must be recycled or
disposed of as hazardous waste. Any broken lamps must be
disposed of as a huzardous waste. Do not dispose of high
mercury containing lamps in the regular trash or dumpster.
Container of mercury containing lamps must be closed and
labeled "Universal Waste Lamps", "Waste Lamps", or
"Used Lamps".
Universal waste lamps should not be accumulated for longer
than one year.
Are rechargeable batteries recycled or managed as a
hazardous waste, kept in a closed container labeled
"Universal Waste Batteries", and not accumulated for longer
than one year.
Inspector's Initials:Page 5 of 7
262.34(dX4)
268.7(a)(5)
268.7(a)(3)
R3 15-13-1
268.7(a)
R3 l5-13-r
268.7(a)
R3 l5-13-1
268.7(a)(8)
R3 1 5-16
R3 r 5-16-2
R3 1 s-16-2
R3 1 5-16-2
R3 1 s-16-2
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Hazardous Waste Inspection - Small Quantity Generator Checklist
INSPECTION ITEM CITATION COMMBNTS
Manifest Number ftox )
Generator EPA ID #
R315-5-Z (box I
Generator inform ation :
Mailing Address (box 5)
Phone number
Transporter #1 informqtion:
Company Name (box 6)
EPA ID# (box 6)
Transporter #2 information:
Company Name (box 7)
EPA ID # (box 7)
Desisnated Facilitv information :
Name and Address (box 8)
EPA ID # (box 8)
Phone Number (box 8)
Waste shipping requirements:
DOT Description (including proper
name, Hazard class and ID#)
(box 9b)
(box 9a 56X" if hazardous materials)
Containers: No & Type (box 10)
Total Quantity (box 11)
Unit - Wt/Vol (box 12)
Waste Codes (box 13)
Special Handling Instructions
(box 14)
Manifest Certifications :
Generator's Signature (box 15)
International Shipments (box 16)
Transporter's Signature (box 17)
Discrepancy Indication (box 18)
Hazardous Waste Report
Management Method Codes
(box 19)
Facility Signature (box 20)
Final Observations and Comments:
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Hazardous Waste Inspection - Small Quantity Generator Checklist
CITATION COMMENTSINSPECTION ITEM
Requirements for SOGs that Accumulate Hazardous
Waste in Tanks
A generator may accumulate hazardous waste in tanks for
less that 180 days (or 270 days if the generator must ship
the waste greater than 200 miles), and may not accumulate
over 6,000 kg on-site at any time.
Treatment or storage of hazardous waste in tanks must not
generate extreme heat or pressure, fire or explosion, or
violent reaction; produce toxic mists, fumes, dusts, or
gases; produce uncontrolled flammable fumes or gapCs;
damage the device or facility containing the was!;or
threaten human health or the environment.
Hazardous waste or treatment reagents t not be placed
in a tank if it could cause it to fail.
262.34(dX3)
265.201
R3 l 5-5-3.34
262.34(d)(3)
265 I (a)
R3 l 5-5-3.34
262.34(dX3)
26s .201(bx l )
R3 1 5-5-3.34
262.34(dX3)
26s.201(bx2)
5-5-3.34
262.34(dX3)
26s.201(c)
262.34(dX3)
26s.201(cX I )
262.34(dX3)
26s.201(cX2)
262.34(dX3)
26s.201(cX3)
1262.34(dX3)
265.201(cX4)
262.34(dX3)
26s.2at (cXs)
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Uncovered tanks must have 2 feer{of freeboard, unless the R3 I 5-5-3.34
tank has a containment stru that equals or exceeds the 262.34(d)
volume of the top 2 feet of b tank.26s.20rybx3)
lf hazardous waste
must be equipped t
is gdntinuously fed into a tank, the tank
feed cutoff or by-e inflow (waste
pass system to s d-by tank).
Small Quantity Generators that store hazardous waste
tanks must inspect, where present:
Discharge control equipment at least once each ,,'
operating day to ensure good working order. ,,,''
Datafrom monitoring equipment at least onc/each
operating day to ensure that the tank is operaled to its
designs. , '
The level of the waste in the tank at leAst once each
operating day to ensure compliance witfi freeboard, if
required.
The tank construction materials at least weekly to detect
corrosion or leaking seams or fixtures.
The construction and surrounding area of discharge
confinement structures at'least weekly to detect erosion or
signs of leakage.
,,262.34(dX3)
,.,,, 265.201 (bX4)
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Inspector's Initials:Page 7 of 7