DSHW-2024-005822

UTAH UPARTMENT OF ENVIRUT,IENTAL QUALITY
DNISION OF SOuD AND HAZtrRDOUS WASTE /
Dennis R. Downs. Director ^ ,/
SQG Program VP.OBox144880 | A
Salt Lake City, UT 84114-4880 l-/ \(801)-538-6170 \
HMARDOUS WASTE GENERATOR EVALUATION FORM
Facility Name:R.E O HAdG€A \,Q,4 EPA tD Number u(r0 9g l5 q j I53
Other Personnel:
It
street rooress: 2 6 5 So^t h L{oo Eqst city: 6t l- 3q(r- C{y zip code: gt{ I t I
County: S^t 0"
Generatorstatus: 59G
= Numberof Emptoye"", -5* Dateof visit:.lulJ Z, tlXatrr/l3 joO
tnspectors: Ar-I"nt, t S."tt t'ltpf;"s
WASTE STREAM / GENERATION PROCESS GENERATION RATE
PER MONTH
HAZARDOUS
WASTE CODE
PROPERLY
MANAGED ?
tJas{.- Tt{r rl^lor o*fl"yfr.-q sqa th/.Jh FooT Yes
Total Quantity of Hazardous
Waste Generated per Month:3 yD \b/-^1 l^
RESPONSE NECESSARY:@
.Jo.p
NO RESPONSE DUE BY:A,A 1, Ln17
MMENTS: f'l,Gf^"fio\AlP. 0o rjor{r., CQzr ?
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
OFFICE IN WRITING by the indicated date. Please be advised, that if we do not receive written documentation of
these corrective actions by the response due date, you may be subject to further regulatory action, 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 superuisor, 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, Printgd:
Signature:
Title:
INSPECTOR:
Name, Printed
Signature:
Title:
Date:Date:
p-0
Page 2 of 6
(Example)
Date: April 9, 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 log 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
rectify the problem.
III. Other topics as discussed.
a.
b.
Employee Name (Please Print)
1.
2.
3.
Employee Signature
ETHIS IS ONLY AN EXAMPLE AND MUST BE ADAPTED SPECIFICALLY TO
YOUR FACILITY AND TRAINING FORMAT.
Hazardous Waste
aUTAH DTVTSTON OF SOLrD
-AND HAZARDOUS WASTE
Page 3 of 6
SMALL QUANTITY GENERATOR
COMPLIANCE EVALUATION FORM
Items that are marked "NO" on the llne ln the left-hand column are not In compllance with the Utah Solld and
Regulatlons and requlre your lmmedlate attentlon. ltems marked "OK" meet the mlnlmum requlrements of the
rcgulatlons. ltems marked 'NA" do not apply to your faclllty.
R315-5.2 DETERMINATION OF WHETHER A WASTE IS HAZARDOUS
ACTION NEEDED:
Dr( 1.
0t(-pK 2.R315€ NOTIFICATION AND EPA HAZARDOUS WASTE IDENTIFICATION NUMBERS:
lf you generate between 100 and 1000 Kgs (220-2200 pounds) of hazardous waste per month or up to 1 Kg of acutely
hazardous waste, you are classified as a Small Ouantlty Generator (SOG), and you must notily the Executive Secretary ol
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 otfer 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 87O0-22 and 8700-22A when otfering hazardous wastes for transport to a TSDF or use
the manilest ol the state that the TSDF is located in, il 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 contractua! agreements for three years after service ends.
-.--> ACTION NEEDED:Ar-L 0a 31 t- dark <o0p;
a.
oKb
a(ffi
OK
ffi
3.
a.
b.
c.
d.
e.
a.
b.
R315.5.5 RECORD KEEPING
Keep copies of manifests lor three years.
Keep all records, including determination of generation rates, waste characterization documentation, disposition, etc., for
three years.
ACTION NEEDED:
R315.5.7 EXCEPTION REPORTING
ll 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:
nlA s.ro[a
0K e. R315-5-9 pAcKAGTNG, LABELTNG, MARKTNG AND pLAcARDTNG
O r( a. Package, Label and mark waste in accordance with DOT 49 CFR prior to shipment.
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a.
b.
c.
d.
ACTION NEEDED:
R315.5.10 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 ol hazardous wastes. Satellite accumulation containers
are the exception.
Label each tank and container with the words "HAZARDOUS WASTE'while it is being used 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) of lire extinguishers, spill control equipment and 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:
-CIKo|1 e.
f.
g.
h.
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Page4of 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
lrtters 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)...examples 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
#7e andTf
!s IN CASE OF EMERGENCY DIAL 91 1rs EMERGENCY COORDINATOR IS CARL CAREFUL-
EXT. 2536rs FIRE EXTINGUISHERS' LOCATION MARKED ON
WALLra SPILL CONTROL EQUIPMENT LOCATED AT TIME
CLOCK
UNIVERSAL WASTE
MERCURY.CONTAINING
LAMPS
date
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9.
a.
b.
c.
d.
e.
f.
g.
h.
10.
a.
b.
OIAH DrvrsroN oF soLID Page 5 of 6
AND HMARDOUS WASTE
SMALL QUANTITY GENERATOR
COMPLIANCE EVALUATION FORM
sPrLL BESPONSE CTHESE RULES ARE FOUND rN R315-9)
Take appropriate action to minimize threats to human health and the environment by notifying the Utah State Department of
Environmental Quality at [phone] or 1-800-572-6400 (24 hour number) if more than 1 Kg of 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). Notify 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 CONTATNERS (THESE RULES ARE FOUND !N 40 CFR 265 SUBPART r)
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 containers 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:
OKTKolL
OK#
OK
c.
d.
e.
f.
11.
a.
PREPAREDNESS AND PREVENTTON OHESE RULES ARE FOUND lN 40 CFR 265 SUBPART C)
You must operate your facility in such a manner that MINIMIZES the possibility of fire, explosion or any unplanned release.
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 assistance (such as a direct alarm to the fire department or a
telephone); portable fire extinguishers; water at adequate pressure and volume to supply fire fighting needs; Alarms and
communication devices accessible to personnel where they are handling hazardous wastes.
You must maintain and test where necessary all communication systems; fire, spill response, decontamination and
protective equipment.
You must maintain aisle space to allow unobstructed movement of personnel and emergency equipment
Make arrangements with local fire, police and hospitals to respond to emergency situations at your facility. Maintain
documentation of notification letters, responses or lack of responses from these agencies.
Document refusals by authorities to emergency arrangements.
ACTION NEEDED:
LAND DISPOSAL RESTRICTIONS (LDR) (THESE RULES ARE FOUND lN 40 CFR 268.7(aX4))
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 bqsed 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.
Maintain an assessment of LDR status on file for each hazardous waste generated at the facility.
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.
Maintain all LDR Documentation for five years alter the waste is shipped otf site.
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12.
a.
b.
--+
13.
a.
14.
a.
15.
16.
ACTION NEEDED:p a,.l(-L0( AJsta.J<[Js h"(F o6
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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".
, )tnoi i.r y"\ri;a{o^r,,.^g< 4o i,^" ., ; f L , t{ t; g L{r ?
R315.5.13 EXPORTS OF HAZARDQUS WASTE
R315.5.14 IMPORTS OF HAZARDOUS WASTE
usE AND MANAGEMENT OF TANK SYSTEMS (THESE RULES ARE FOUND tN 40 CFR 265.201 SUBPART J)
OTHER ACTIONS NEEDED:
oo
CONTAINER MANAGEMENT LOG
Date Inspectors
Name
Are containers
labeled with the
words
,,HAZARDOUS
WASTE"?
Is accumulation
date marked on
all hazardous
waste containers
and is that date
less than 180 old
?
Are hazardous
waste containers
closed and are
all bungs and
bung rings
secure?
Are all
Hazardous
waste
containers in
good
condition?
If any columns are marked
NO,what was done to bring the
container into compliance?
Yes No Yes No Yes No Yes No