DSHW-2024-006632

Inspections
Judy Moran, Environmental Scientist
[e-mail]
[phone]
Our Mission.
Safeguarding and improving Utah’s air, land and water
through balanced regulation.
Hazardous Waste
Generators
Inspections & Ensuring Compliance
Inspection
process
Permied
Facilities
Achieving
Compliance
LQG/SQG
Inspection Process
●Compliance &
inspection history
●Notifications
●Electronic sources of
data
Site Selection &
Preparation
●Records request
●Corrections
●Closeout or
enforcement
Follow-up
●Access
●Opening meeting
●Site walk
●Records review
●Closing meeting
Site Visit
DEQSubmit
DEQSubmit is the oicial means to submit documents and
records requested in association with inspections and
enforcement actions.
[e-mail]
Business
Confidentiality
●Photographs
●Records
●Submit a wrien claim along with
the record.
●Submit a version with confidential
information redacted.
During the inspection After the inspection
Common Issues For Small Quantity Generators
1.Waste Determination & Waste
Counting
2.Container Management
3.Training
4.Accumulation Area Inspections
5.Contingency Planning
6.Manifests/shipping
Common Issues For Large Quantity Generators
1.Waste Determination
2.Container Management
3.Training
4.Contingency Plan
5.Emergency Response/Spill Cleanup
6.Accumulation Area Inspections
7.Manifests/shipping
Frequent Training Violations
1.Manifest signers not trained (SQGs and LQGs)
2.Training not documented (SQGs)
3.No job descriptions or descriptions don’t
include hazardous waste duties (LQGs)
4.Emergency coordinators and/or responders
not included in training plan (LQGs)
5.Contractors not included in training plan
(LQGs)
6.Type & amount of initial and continuing
training not specified (LQGs)
7.Annual refresher training not completed or
not completed in a timely manner (LQGs)
Discussion
Job Title and
Name
LQG Training Plan R315-262 -17(a)(7)
Type and Amount
of Introductory
and Continuing
Training
Job Description
Record of
Training for Each
Employee
Training for Manifest Signers
○Hazardous Waste Shipping is Jointly Regulated.
○If you are signing a hazardous waste manifest you are
oering hazardous materials for transportation.
○When you sign you are CERTIFYING (49 CFR §172.204)
○See RCRA Online#14687 for reference
Reference
DOT HazMat Shipping
Training
49 CFR 172.704
General Awareness
Function-Specific
Safety
Documentation
1.Employee’s name
2.Date of the training
3.A description,copy,or the location of the training materials
4.The name and address of the person providing the training
5.Certification that the hazmat employee has been trained and
tested
Reference
49 CFR 172.704
The plan fails in an emergency
The generator facility changes--in its design, construction, operation,
maintenance, or other circumstances--in a way that materially increases the
potential for fires, explosions, or releases of hazardous waste or hazardous
waste constituents, or changes the response necessary in an emergency
Amendment of Contingency Plan
R315-262 -263
a
b
c
The list of emergency coordinators changes d
Applicable regulations are revised
The list of emergency equipment changes03e
CAA Inspection Records
○Include date and time of inspection
○Include who performed inspection
○Note observations made
○Note any corrective actions taken
○Noting these shows that you are actually
inspecting and not just checking boxes
○Keep these records –we typically ask for
three years’ worth of container inspections
when doing compliance evaluation
inspections
○Be consistent –ideally no more than 6 days
pass between inspections
Analysis
01
Date and Time:
5/16/23 at 10:00 am
Inspector:
Jonathan Brown
Hazardous Waste Container (Y/N)Corrective action
Are there signs of leaking or deteriorating
containers?
Y Waste in rusting container transferred to new drum
Are the containers properly and visibly labeled?N Labels including “Hazardous Waste”, an indication of the hazard,
and accumulation start date added to all containers
Are containers closed?Y
Is waste stored in compatible containers?Y
Is aisle space between containers suicient to
inspect containers?
N Drums spaced out
Is spill cleanup and fire suppression equipment
present in the area?
Y
Any waste over accumulation time limit??Find out and ship o any waste over limit o
AISLE SPACE
Inadequate Adequate
Enforcement Voluntary compliance is always our goal.
Formal
Notice of Violation
Informal
Compliance Advisory
Your facility
just got an
NOV/CO in the
mail.
What’s next??
Correct identified violations and
provide evidence of corrections to
the Division.
Request For Agency Action
Stipulation and Consent Order
Come into Compliance!Sele or Contest
Selement
Conference
Seling a Notice of Violation
Public
Participation
Stipulation & Consent
Order (SCO)
Comply with the
SCO
Questions?
Thank you
hps://deq.utah.gov/division-waste-management-radiation -control
Judy Moran
Environmental Scientist
PHONE
[phone]
EMAIL
[e-mail]