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DEPARTMENT OF ENIVIRONMENTAL QUALITY
DIVISION OF SOLID AND HAZARDOUS WASTE
288 Norttr 1460 West
P.O. Box 144880
Salt Lake city, Urah 841144880
(80 1) 53 8-6 1 70
(80 1) 53 8-67 1 5 Fax
(801) 536-4414 T.D.D.
Michael O. lravitt
Ooveruor
Dianne R. Nielson, Ph.D.
Exocrrtivc Director
Dennis R. Downs
Dircctor
May 9, 1994
Brent Hobson
Parker Hannifin Corporation
1425 West 2675 North
Ogden, Utah 8M04
RE: Hazardous Waste Inspection Number 9404020
Dear Mr. Hobson:
This letter is to follow-up the Parker-Hannifin hazardous waste inspection of
March 19, 1994. As you are aware, the purpose of the inspection was to evaluate
Parker-Hannifin's adherence to all applicable hazardous waste regulations. We
appreciate the cooperation your facility offered our representatives during their
visit.
Currently Parker-Hannifin is a conditionally exempt small quantity generator
(CESQG) and as such is in compliance with the regulations applicable to
CESQG's. The following comments are offered with the possibility that Parker
may change regulatory classes by either generating more that one hundred
kilograms of waste per month or storing more than one thousand kilograms of
waste on-site. They are mentioned not only as good business practices, but would
be requirements if Parker's regulatory class increases.
1. During the inspection in the Test and Assembly Area, there were three,
five, 5-gallon containers of waste Heptane and four, five-gallon containers
of waste alcohol which were labeled with their contents, but did not include
the word "waste" in the contents description, nor the date the waste
accumulation began. Wastes in containers should be identified as "waste. "
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A label of "waste heptane" or "waste alcohol" would avoid any inadvertent
product mixing with waste or using waste as product. The date the waste
accumulation began should be included on the container label.
2. All of the containers mentioned in Comment #1 were in an open
condition (bungs open, funnel in bung-hole). It is also a good practice to
keep containers of volatile liquids, like the Heptane and alcohol used at
Parker in a closed condition. This lessens the risk of fire, spillage and does
not expose employees to breathing the fumes.
3. Near the Laboratory Area there was a cabinet that contained a container
of MEK that was labeled "Do Not IJse. " The MEK in the storage cabinet
that was labeled "Do Not IJse" should be investigated. If it is waste, it
should be managed as such. If it is usable product the label should be
changed.
4. On several manifests the hazardous waste number was filled out
incorrectly and/or incompletely. It is imperative that all applicable sections
of the hazardous waste manifest are filled in completely and accurately.
If you have any questions regarding the correspondence please contact Scott M.
Hopkins of my staff at 538-6788
Sincerely,
?ry
Dennis R. DowoS, Executive Secretary
Utah Solid and Hazardous Waste Control Board
Craig Heninger, M.S., Acting Health Officer/Director of Administrative
Services, Weber/Morgan District Health Department
Larry Wapensky, EPA Region VIII