DSHW-2024-005748

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urnn(tpARTMENT oF ENVrnCnrENTAL euAury
DIVISION OF SOLID AND HAZARDOUS WAST
Dennis R. Downs. Directgr
SQG Program
P. O Box 144880
Salt Lake City, UT 84114-4880
z'oar/2 (801)'538'6170
HAZARDOUS WASTE GENERATOR EVALUATION FORM
Facility Name:EPATD Numoer lCZ aO oo?,f8,/
Street Address: ZZ Z O //-r,Gity: JZ C. zipGode= ?a/Z(
County= 5Z Contact Person Phone Number: 7Z Z - -766O
Generator Status = . <frG Number of Employees Date of Visit:?-/- q9
tnspectors:t'.2o:rf
other Personnet: 5.t/)rl '
WASTE STREAM / GENERATION PROCESS GENERATION RATE
PER MONTH
HAZARDOUS
WASTE CODE
PROPERLY
MANAGED ?
r*s{- 5o,4zz.zt-s 3oo Ztb .2a/Yz€
%;t^c- Z//?/a /
El g g , /rryry$[u.,,'f ,d"{,72
Total Quantity of Hazardous
Waste Generated per Month:,7oo//s/a
REsPoNSE NEcESSARY' @ No RESPONSE DUE BY: ./O - /- oB
COMMENTS:Z.4 'iz€12
z,b<- 4
This compliance 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 the actions, summarized in this audit, in order to come into compliance and NOTIFY THIS
IEFICE lN WRITINQ[y the indicated date. Please be advised, that if we do not receive written docffiEfrIdti6frtl-ffiuvtn",".ponseouedate,youmaybesubjecttofurtherregulatoryaction,including
administrative penalties. Please include your EPA 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:
Name, Printed:
Signatufe:
Title:
INSPECTOR:
Name, Printed
Signature:
Title:
Date:Date:
Page 2 of 6
(Example) XYZ Company Employee Training Log
Date: April9, 1997
Time: 10:00 am to 11:00 am
Discussion lead by: John Doe, Health and Safety Coordinator
Topics discussed
I. 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."
II. Use and Management of Containers
a. Maintain a 1og weekly on the hazardous waste containers, are the containers closed,
labeled, dated and in good condition. If not, please contact the emergency coordinator in order to
rectiff the problern
Itr. Other topics as discussed.
a.
b.
Employee Name (Please Print)
1.
2.
3.
Employee Signature
6THIS IS ONLY AN EXAMPLE AND MUST BE ADAPTED SPECIFICALLY TO
YOUR FACILITY AND TRAINING FOil,MAT.
OurAH DrvrsroN oF soLrD O Page 3 of 6
AND HAZARDOUS WASTE
SMALL QUANTITY GENERATOR
COMPLIANCE EVALUATION FORM
hems that are marked "NO" on the Iine in the left-hand column are not in compliance with the Utah Solid and
Regulations and require your immediate attention. ltems marked "OK" meet the minimum requirements of the
regulations. hems marked "NA" do not apply to your facility.
r'a bR31s-5-2 DETERMINAT.N oF wHETHER A wASTE rs HAzARDous
ACTION NEEDED:
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R315.3 NOTIFICATION AND EPA HAZARDOUS WASTE IDENTIFICATION NUMBERS:
Hazardous Waste
a.
b
c.
d
e.
€.2.
ll you generate between 100 and 1000 Kgs (220-22OO pounds) of hazardous waste per month or up to 1 Kg of acutely
hazardous waste, you are classilied as a Small Quantity Generator (SaG), 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.
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:
R315.5.4 MANIFESTS
Only use approved manifest lorm 8700-22 and 8700-22A when otfering 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:
R315.5.5 RECORD KEEPING
Keep copies of manifests for three years.
Keep all records, including determination of generation rates, waste characterization documentation, disposition, etc., lor three
years.
ACTION NEEDED:
R315.5.7 EXCEPTION REPORTING
lf TSDF does not return generators'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.
R315.5.9 PACKAGING, LABELING, MARKING AND PLACARDING
Package, Label and mark waste in accordance with DOT 49 CFR prior to shipment.
ACTION NEEDED:
4.
ct.
b.
oK 5.
{a
lK 6.\Ya
OKT
t
b
#
7. R315.5.10 ACCUMULATION TIME
a. Do not store hazardous wastes for longer than 180 days, or 270 days if applicable, without a permit.b. Do not exceed 6000 Kg of hazardous wastes stored at your facility at any time.c. Mark the date the accumulation period began on each container of hazardous wastes. Satellite accumulation containers are
the exception.
d. Label each tank and container with the words "HAZARDOUS WASTE" while it is being used to accumulate hazardous wastes.
A -. Designate and authorize an emergency coordinator(s) who is(are) readily available by some means at all times.(\)Q Post the following information next to each telephone at the racility: Name and telephone number of the emergency- coordinato(s) location(s) of fire extinguishers, spill control equipment and fire alarms, telephone number of the local fire
department (or equivalent emergency response for lacility).
S. Ensure that all employees are familiar with hazardous waste handling and emergency procedures.h. The emergency coordinator must respond appropriately to emergencies that have the potential of invofuing hazardous waste(s).
ACTION NEEDED:
Page 4 of 6
These are only examples that will help you comply with the regulations, you must ADAPT the following information
for and make it specific to YOUR facility.
SEE #10e
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, we are required to notify you that we generate hazardous waste(s). The
waste(s) that we generate is (are)...examp1es might be; paint wastes, paint sludges, Methyl Ethyl Ketone, Acetone,
other solvents, acids, bases, listed wastes, etc.
We make every effort to properly manage our waste, but in the event of an emergency we may require your assistance.
In the event of an unforseen emergency, you may be required to respond.
Your Name and Title
ABC Company
#7 e and 7f
[s IN CASE OF EMERGENCY DIAL 91 1!a EMERGENCY COORDINATOR IS CARL CAREFUL-
EXT. 2536[g FIRE EXTINGUISHERS, LOCATION MARKED ON
WALLrs SPILL CONTROL EQUIPMENT LOCATED AT TIME
CLOCK
UI{IYERSAL WASTE,
MERCURY.CONTAINING
LAMPS
date
tr 8.
Q'AH DrvrsroN oF soLrD
AND HAZARDOUS WASTE
Page 5 of 6
SMALL QUANTITY G ENERATOR
COMPLIANCE EVALUATION FORM
SPILL RESPONSE (THESE RULES ARE FOUND IN R31s-9)
Take appropriate action to minimize threats to human health and the environment by nofifying the Utah State Department of
Environmental Quality at [phone] or 1-800-572-6400 ( 24 hour number) if more than 1 Kg ol acutely hazardous waste
or 100 Kg of hazardous waste or material which when spilled becomes hazardous waste, is spilled as specified in 40 CFR
261 .33(e). Notlfy the National Response Center when applicable and provide the appropriate information, listed in R315-9(c), in
the spill report.
ACTION NEEDED:
usE AND MANAGEMENT OF CONTATNEHS (THESE RULES ARE FOUND lN 40 CFR 26s SUBPART D
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 conlainers of hazardous waste in a manner which may cause a release.
lnspect containers of hazardous waste at least 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 hazardous wastes in containers that previously held an incompatible material without cleaning it first.
Separate incompatible hazardous wastes by means of a dike, berm or other method.
ACTION NEEDED:
10. PREPAREDNESS AND PREVENTION (THESE RULES ARE FOUND lN 40 CFR265 SUBPARTC)
a. You must operate your facility in such a manner that MINIMIZES the possibility of fire, explosion or any unplanned release.b. You must have the following preparedness and prevention equipment unless the wastes' you stores 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 assislance (such as a direct alarm to the fire department or a telephone);
portable fire extinguishers; water at adequate pressure and volume to supply fke fighting needs; Alarms and communication
devices accessible 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.
d. You must maintain aisle space to allow unobstructed movement of personnel and emergency equipment
G)#Make arrangements with iocal fire, police and hospitals to respond io emerg"n"y situatidns at yourfacility. Maintain
documentation of notification letters, responses or lack of responses from these agencies.
f. Document refusals by authorities to emergency arrangements.
AcroN Neeoeo: &.2y' Zfz.zS /o *z a#Z€Q c
11. LAND DISPOSAL RESTRICTIONS (LDR) (THESE RULES AHE FOUND lN 40 cFR 268.7(a)(4))
a. lf you treat your hazardous wastes to render them non-Land Disposal Restricted, you must develop and lollow 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 ol 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 not 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:
a.
9.
%
1A
#
4
J_
R315.16 UNIVERSAL WASTES, FLUORESCENT LIGHT TUBES
Fluorescent light tubes must be recycled or disposed of 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 CONTAININGLAMPS".
12.
a.
b.
13.
cl.
14.
a.
15.
16.
ACTION NEEDED:ru vo ,rz o,?/4k.2? *al#
H315.5.13 EXPORTS OF HAZARDOUS WASTE
R315.5.14 IMPORTS OF HAZARDOUS WASTE
usE AND MANAGEMENT OF TANK SYSTEMS (THESE RULES ARE FOUND lN 40 CFR 265.201SUBPART J)
OTHER ACTIONS NEEDED:
'ab
a,
Page 6 of6 '
CONTAINER MANAGEMENT LOG
Date lnspectors
Name
Are containers
labeled with the
words
*}IAZARDOUS
WASTE"?
Is accumulation
date marked on all
hazwdous waste
containers and is
that date less than
180 old ?
Are hazwdous
waste containers
closed and are all
bungs and bung
rings secure?
Are all
Hazardous
waste
containers in
good
condition?
If any columns are marked
N0,what was done to bring the
container into compliance?
.:.:.:.:.:.iiiiiil Yes No Yes No Yes No Yes No
?j
Page 6 of 6
CONTAINER MANAGEMENT LOG
t
Date lnspectors
Name
Are containers
labeled with the
words
,,HAZARDOUS
WASTE"?
Is accunrulation
date marked on all
hazardous waste
containers urd is
that date less than
180 old ?
Are hazudous
waste containers
closed urd are all
burgs urd bturg
rings sectre?
Are all
Hazardous
waste
containers in
good
condition?
If ury columns are mnrked
NO,what was done to bring the
container into compliance?
Yes No Yes No Yes No Yes No