Oklahoma Department of Environmental Quality

Transcription

1 Oklahoma Department of Environmental Quality EPA ID# Hazardous Waste LARGE QUANTITY GENERATOR INSPECTION REPORT Name of Facility Owner/Operator Phone Facility Mailing Address City Zip Code County Oklahoma Administrative Code (OAC) 252: adopts by reference certain federal regulations found in Title 40 of the Code of Federal Regulations (40 CFR). This document does not include all state and federal regulations that may be applicable. Certain non-hazardous industrial waste regulations are included on this form as referenced by OAC 252:520. Item No. OAC 252:205 A. EPA ID Number, Use of Only Permitted TSDs, and Disposal Plan A1. Generator has failed to obtain an EPA ID#: 40 CFR (a) A2. Generator has failed to notify as a LQG of hazardous waste: 40 CFR 270.1(b) A3. Generator has failed to use only transporters and TSDs which have EPA ID#s: 40 CFR (c) A4. Generator has failed to have an approved disposal plan: OAC 252: A5. Generator has failed to update disposal plan: OAC 252: (1) A6. Generator has failed to use disposal plan number on all manifests: OAC 252: B. Waste Determinations B1. Generator has failed to make necessary waste determination: 40 CFR B2. Generator has failed to make a waste determination on non-hazardous industrial waste: OAC 252: B3. Generator has failed to use approved method in making HW determination: 40 CFR (c) B4. Generator failed to keep records of waste analysis, test results, etc. for 3 years: 40 CFR (c) C. Manifest C1. Generator has failed to use manifest: 40 CFR (a) C2. Generator has failed to use manifest to ensure delivery of hazardous waste to a permitted facility: 40 CFR (b) C3. Generator has failed to sign manifest: 40 CFR (a)(1) C4. Generator has failed to obtain signature and date of acceptance from initial transporter: 40 CFR (a)(2) C5. Generator has failed to retain one copy of the manifest for three years, or until designated facility returns a signed copy: 40 CFR (a)(3) incorporating (a) C6. Generator has failed to file report for manifests not returned within 45 days: 40 CFR (a)(2) D. Land Disposal Restrictions, Hazardous Waste Disposal, and Endangerment D1. Generator has failed to determine that his hazardous waste is restricted from land disposal: 40 CFR 268.7(a)(1) D2. Generator has failed to send a treatment standard notice with the initial shipment to the treatment, storage, or disposal facility which includes information about the waste: 40 CFR 268.7(a)(2) or (3) and/or 268.7(a)(10). D3. Generator has failed to retain copies of LDR Notification/Certification on site for 3 years: 40 CFR 268.7(a)(8) D4. Generator has failed to develop and follow a written waste analysis plan for prohibited waste it has treated: 40 CFR 268.7(a)(5) D5. Generator has disposed of HW where no permit was obtained to do so: 40 CFR 270.1(c) D6. Generator has failed to properly dispose waste materials. If waste materials are determined to be hazardous waste, this is a violation of 40 CFR (a)-(c). If determined to be nonhazardous waste: OAC 252: (a). D7. Generator has failed to operate in a manner to prevent degradation of the environment and endangerment of public health: OAC 252: and 9-1 Area of Violation REMARKS DEQ Form # Page 1 of 5 March 2002

2 E. Satellite Accumulation E1. Generator has failed to mark containers as HW or with other words that identify the contents: 40 CFR (c)(1)(ii) E2. Generator has accumulated waste exceeding the limit (55 gal non-acute or 2.2 lbs acute) without excess being dated: 40 CFR (c)(2) E3. Generator has accumulated waste exceeding the limit (55 gal non-acute or 2.2 lbs acute) for more than 3 days in satellite accumulation area: 40 CFR (c)(2) E4. Generator has failed to ensure containers are in good condition: 40 CFR (c)(1)(i) incorporating 40 CFR E5. Generator has stored waste in incompatible containers: 40 CFR (c)(1)(i) incorporating 40 CFR E6. Generator has failed to keep waste containers closed: 40 CFR (c)(1)(i) incorporating 40 CFR (a) F. Storage Limits F1. Generator has accumulated HW on-site for longer than 90 days subjecting the generator to be regulated as a TSD: 40 CFR (a)&(b) G. Container Storage Area G1. Generator has stored waste in containers that are in poor condition or leaking: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I, specifically 40 CFR G2. Generator has failed to keep containers closed: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I, specifically 40 CFR (a) G3. Generator has failed to handle containers in a manner to prevent rupture or leakage: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I, specifically 40 CFR (b) G4. Generator has failed to inspect containers weekly: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I specifically 40 CFR G5. Generator has stored waste in containers that are incompatible with waste: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I, specifically 40 CFR G6. Generator has stored incompatible wastes in the same container: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I, specifically 40 CFR (a) G7. Generator has failed to keep incompatible wastes separated by physical barrier or distance: 40 CFR (a)(1)(i), incorporating 40 CFR 265 Subpart I, specifically 40 CFR (c) G8. Generator has failed to label or mark containers as "hazardous waste": 40 CFR (a)(3) G9. Generator has failed to mark containers with the accumulation start date: 40 CFR (a)(2) G10. Generator has stored ignitable or reactive wastes within 15 meters (50 feet) of property line: 40 CFR (a)(1)(i), incorporating Subpart I, specifically 40 CFR G11. Generator has failed to manage all hazardous waste placed in a container in accordance with the applicable requirements of 40 CFR 265 Subparts AA, BB and CC: 40 CFR (a)(1)(i), incorporating Subpart I, specifically 40 CFR H. Tank Storage Area H1. Generator has failed to label or mark hazardous waste tanks with the words hazardous waste : 40 CFR (a)(3) H2. Generator has failed to ensure that HW or treatment reagents don't cause the tanks or inner liner to rupture, leak or corrode: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (a) H3. Generator has failed to use appropriate controls and practices to prevent spills and overflows from tank or containment systems: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (b) H4. Generator has failed to remove immediately from service a tank system or secondary containment system from which there has been a leak or spill, or which is unfit for use: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR H5. Generator has failed to conduct daily inspection of tank systems and ancillary equipment: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (a) H6. Generator has failed to take precautions to prevent accidental ignition or reaction of ignitable or reactive wastes: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (a)(2) H7. For existing tanks (before July 14, 1986) without secondary containment, the generator has failed to keep on file a written assessment reviewed and certified by an independent, qualified registered professional engineer indicating that the tank system is not leaking and is fit for use: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (a) DEQ Form # Page 2 of 5 March 2002

3 H8. For existing tanks (before July 14, 1986), the generator has failed to provide secondary containment by the time the tank systems have reached 15 years of age: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (a)(4) H9. For new tanks (after July 14, 1986), the generator has failed to keep on file a written assessment reviewed and certified by an independent, qualified registered professional engineer indicating that the tank system has sufficient structural integrity and is acceptable for use: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (a) H10. For new tanks (after July 14, 1986), the generator has failed to provide secondary containment: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR (1) H11. Generator has failed to manage hazardous waste placed in a tank in accordance with the applicable requirements of 40 CFR 265 Subparts AA, BB, and CC: 40 CFR (a)(1)(ii) incorporating Subpart J, specifically 40 CFR I. Personnel Training I1. Generator has failed to develop and implement a training program for those employees who manage HW: 40 CFR (a)(4) incorporating 40 CFR (a) I2. Generator has failed to provide a training directed by a qualified person: 40 CFR (a)(4) incorporating 40 CFR (a)(2) I3. Generator has failed to provide training that includes procedures for using communications or alarms: 40 CFR (a)(4) incorporating 40 CFR (a)(3)(iii) I4. Generator has failed to provide training that includes responses to fires and explosions: 40 CFR (a)(4) incorporating 40 CFR (a)(3)(iv) I5. Generator has failed to provide training that includes shutdown of operations: 40 CFR (a)(4) incorporating 40 CFR (a)(3)(vi) I6. Generator has failed to provide annual review of training: 40 CFR (a)(4) incorporating 40 CFR (c) I7. Generator has failed to maintain training records at the facility: 40 CFR (a)(4) incorporating 40 CFR (d) I8. Generator has failed to include job title & name of each employee for positions related to hazardous waste in training record: 40 CFR (a)(4) incorporating 40 CFR (d)(1) I9. Generator has failed to include written job description for each job title in training record: 40 CFR (a)(4) incorporating 40 CFR (d)(2) I10. Generator has failed to include description of training of each position in training record: 40 CFR (d)(3) I11. Generator has failed to include documentation of training in training record: 40 CFR (a)(4) incorporating 40 CFR (d)(4) J. Preparedness & Prevention J1. Generator has failed to maintain and operate to minimize releases of hazardous waste or constituents to air, soil or surface water: 40 CFR (a)(4) incorporating 40 CFR 265 Subpart C, specifically J2. Generator has failed to provide internal communication equipment or an alarm system in the facility: 40 CFR (a)(4) incorporating 40 CFR 265 Subpart C, specifically 40 CFR (a) J3. Generator has failed to equip facility with telephone or radio to call emergency personnel: 40 CFR (a)(4) incorporating Subpart C, specifically 40 CFR (b) J4. Generator has failed to equip facility with fire extinguishers, spill control equipment, decontamination equipment, and water at adequate volume and pressure: 40 CFR (a)(4) incorporating Subpart C, specifically 40 CFR (c) and (d) [water volume and pressure] J5. Generator has failed to provide sufficient aisle space to allow unobstructed movement of personnel and equipment in storage areas: 40 CFR (a)(4) incorporating Subpart C, specifically 40 CFR J6. Generator has failed to provide local authorities with facility layout, properties of hazardous waste, locations of work areas, road entrances and evacuation routes: 40 CFR (a)(4) incorporating Subpart C, specifically 40 CFR (a)(1) J7. Generator has failed to make agreements with State emergency response teams, emergency response contractors, and equipment suppliers: 40 CFR (a)(4) incorporating Subpart C, specifically 40 CFR (a)(2) J8. Generator has failed to provide local hospitals with properties of HW handles and types of injuries possible: 40 CFR (a)(4) incorporating Subpart C, specifically 40 CFR (a)(4) J9. Generator has failed to test and maintain its emergency equipment to ensure its proper operation in time of emergency: 40 CFR (a)(4) incorporating 40 CFR 265 Subpart C, specifically 40 CFR K. Contingency Plan and Emergency Procedures K1. Generator has failed to develop a contingency plan: 40 CFR (a)(4) incorporating Subpart D of 40 CFR 265, specifically 40 CFR (a) DEQ Form # Page 3 of 5 March 2002

4 K2. Generator has failed to maintain a copy of contingency plan at facility: 40 CFR (a) K3. Generator has failed to include description of acts to be taken in event of fire, explosion, or release of HW in contingency plan: 40 CFR (a)(4) incorporating Subpart D of 40 CFR 265, specifically 40 CFR (a) K4. Generator has failed to include a description of the arrangements with local authorities in contingency plan: 40 CFR (a)(4) incorporating Subpart D, specifically 40 CFR (c) K5. Generator has failed to include list, kept up to date, of persons qualified to act as emergency coordinator in contingency plan: 40 CFR (a)(4) incorporating Subpart D of 40 CFR 265, specifically 40 CFR (d) K6. Generator has failed to list, describe location of, and outline capabilities of all emergency equipment in contingency plan: 40 CFR (a)(4) incorporating Subpart D of 40 CFR 265, specifically 40 CFR (e) K7. Generator has failed to include evacuation plan in contingency plan: 40 CFR (f) K8. Generator has failed to have emergency coordinator on-site or on-call: 40 CFR K9. Generator has failed to supply contingency plan to local authorities: 40 CFR (b) K10. Generator has failed to amend contingency plan as necessary: 40 CFR (a)(4) incorporating 40 CFR Part 265 Subpart D, specifically 40 CFR K11. Generator has failed to submit report to the DEQ within 15 days after an incident requiring implementation of the contingency plan: 40 CFR (a)(4) incorporating Subpart D of 40 CFR 265, specifically 40 CFR (j) K12. Generator failed to immediately notify the DEQ upon release of HW: OAC 252: L. Used Oil Requirements (Applicability: Used oil burned for energy recovery unless not exceeding levels of 40 CFR ) L1. Generator has failed to store used oil in proper containers: 40 CFR (a) L2. Generator has failed to ensure that used oil storage units are in good condition: 40 CFR (b)(1) L3. Generator has failed to ensure that used oil storage units are not leaking: 40 CFR (b)(2) L4. Generator has failed to label or mark used oil containers with the words "Used Oil": 40 CFR (c)(1) L5. Generator has failed to label or mark fill pipes used to transfer used oil into underground storage tanks with the words Used Oil : 40 CFR (c)(2) L6. Generator has failed to properly respond to a release of used oil: 40 CFR (d) L7. Generator has failed, if burned on-site, to burn used oil in a proper space heater: 40 CFR L8. Generator has failed to use a transporter who has an EPA ID number, unless generator self transports <55 gal to collection center/aggregation point, or a tolling arrangement exists: 40 CFR L9. Generator has failed to ensure off-site transportation of its used oil to a location where it is not used in a manner which constitutes disposal: 40 CFR M. Universal Waste Requirements (batteries, pesticides, thermostats, fluorescent bulbs) M1. Generator has failed to label or mark universal wastes with the words "Universal Waste " or "Waste " or "Used ": 40 CFR (small quantity handler); 40 CFR (large quantity handler) M2. Generator has improperly disposed/diluted/treated universal waste: 40 CFR (small quantity handler); 40 CFR (large quantity handler) M3. Generator has failed to adequately demonstrate the length of time universal waste has been stored: 40 CFR (c) (small quantity handler) and 40 CFR (c) (large quantity handler) M4. Generator has failed to provide employee training on managing universal waste: 40 CFR (small quantity handler); 40 CFR (large quantity handler) M5. Generator (large quantity handler only {>5,000kg}) has failed to keep record of each shipment of universal waste received at the facility and sent from the handler to other facilities: 40 CFR M6. Generator has failed to send universal waste to another universal waste handler or proper destination facility: 40 CFR (small); 40 CFR (large) N. Non-Hazardous Industrial Waste (NHIW) [OAC 252:520] N1. Generator has failed to obtain individual approval letter from the Solid Waste Compliance Section for disposal of NHIW: OAC 252: (a) N2. Generator has failed to submit notification to the DEQ on DEQ-supplied forms concerning its generation of NHIW: OAC 252: N3. Generator disposed of solid waste at a site for which a permit for solid waste disposal had not been issued: OSWMA, 27A, O.S (A)(1) and OAC 252: (a) DEQ Form # Page 4 of 5 March 2002

5 N4. Generator has disposed of solid waste at a facility which is not permitted to accept such waste: OAC 252: O. Recordkeeping O1. Generator has failed to file the Biennial Report during even-numbered years for off-site shipments that occurred during odd-numbered years: 40 CFR (a) O2. Generator has failed to submit quarterly reports to the DEQ: OAC 252: (a) O3. Generator has failed to appropriately complete quarterly reports: OAC 252: (b)&(c) O4. Generator has failed to keep Exception and/or Biennial Reports on file for 3 years: 40 CFR (b) INSPECTION TYPE ACTION [ ] Routine RCRA Compliance Evaluation Inspection [ ] No violations; no action required [ ] Routine Limited (Circle items inspected) [ ] Notice to Comply (NTO) [ ] NTO Follow-up (NTO Date ) (Circle Item # s inspected) [ ] Refer to Enforcement/Legal Staff [ ] Order Follow-up (Order Date ) (Circle Item # s inspected) [ ] Complaint Investigation (Complaint # ) Comments: Inspector Facility Representative Date Date DEQ Form # Page 5 of 5 March 2002