RE: SAFETY-KLEEN SYSTEMS, INC., OHD …chagrin.epa.ohio.gov/edoc/images/111700/1117000001.pdf ·...

ohomState of Ohio Environmental Protection Agency

Northeast District Office

2110 East Aurora Rd. TELE: (330) 963-1200 FAX: (330) 487-0769 Ted Strickland, Governor

Twinsburg, Ohio 44087

www.epa.stato.oh.us Lee Fisher, Lieutenant Governor

Chris Korleski, Director

June 10, 2009

Ms. Lynn VizdosBranch General ManagerSafety-Kleen Systems, Inc.1169 N Industrial ParkwayBrunswick, OH 44212

RE: SAFETY-KLEEN SYSTEMS, INC., OHD 000720987, MEDINA COUNTYLQGITRANSFER FACILITY/TRANSPORTER, USED OIL TRANSPORTERUSED OIL TRANSFER FACILITY, NOV/RTC

Dear Ms. Vizdos:

On May 21, 2009 and June 4, 2009 the Ohio Environmental Protection Agency (EPA),Division of Hazardous Waste Management (DHWM), conducted a complianceevaluation inspection at Safety-Kleen Systems, Inc. (Safety-Kleen) located at 1169 NIndustrial Parkway, Brunswick, Ohio. The purpose of the inspection was to determineSafety-Kleen's compliance with Ohio's hazardous waste laws as found in Chapter 3734.of the Ohio Revised Code (ORC) and Chapter 3745. of the Ohio Administrative Code(OAC). On May 21, 2009, Safety-Kleen was represented by Kathy Sustar and you.The Ohio EPA was represented by Nyall McKenna and me. On June 4, 2009, Safety-Kleen was represented by Greg Chiappini and the Ohio EPA was represented by me.

Safety-Kleen is a hazardous waste transporter and operates a transfer facility at theBrunswick location. Activities conducted at the transfer facility cause Safety-Kleen to bea large quantity generator of hazardous waste. Safety-Kleen is also a used oiltransporter, a used oil transfer facility, and is a small quantity handler of universalwaste. Please see the attached process flow sheet for a listing of the major wastestreams noted during this inspection.

The following violation was noted, and abated, during this inspection:

1. Ohio Administrative Code (OAC) Rule 3745-279-22-(C)(1); used oil storagerequirements for generators.

A fifty five gallon drum containing used oil sampling jars was not labeled as "usedoil". This violation was abated at the time of the inspection when the drum wasproperly labeled. No further information is requested.

0 Printed on recycled paper Ohio EPA is an Equal Opportunity Employer

SAFETY-KLEEN SYSTEMS, INC.JUNE 10, 2009PAGE —2—

Should you have any questions, please feel free to call me at (330) 963-1162. You canfind copies of the rules and other information on the division's web page athttp://www.epa.state.oh.us/dhwm . Ohio EPA also has helpful information aboutpollution prevention at the following web address: http://www.epa.state.oh.us/opp.

The Division of Hazardous Waste Management has created an electronic news serviceto provide the regulated community with news related to hazardous waste activities inOhio. If you haven't already, we encourage you to sign up for this free service by goingto http://www.eça.state.oh.us/dhwm/listserv.

Sincerely,

(" N, Uff,Marlene M. Kinney

Environmental SpecialistDivision of Hazardous Waste Management

MMK:ddwEnclosures

cc: Natalie Oryshkewych, DHWM, NEDOGreg Chiappirii, CHMM, EHS Manager, Safety-Kleen Systems, Inc.

ec: Nyall McKenna, DHWM, NEDOHarry Sarvis, DHWM, CO

NOTICE:Ohio EPA's failure to list specific deficiencies or violations in this letter doesnot relieve your company from having to comply with all applicable regulations.

Ohio Environmental Protection Agency For Ohio EPA use

RCRA SUBTITLE C SITEIDENTIFICATIONNERIFICATION FORM

E-mail this completed form to kristinadurnellepa. state. oh.usor mail it to Kristina Durnell, central Office

EPA ID Number: OHD 000 720 987• Name: Safety-Kleen Systems, Inc.

Website:(Optional)

Street Address: 1169 N Industrial ParkwayCity, Town, or Village: Brunswick, OH 44212 State: OHCounty Name: Medina Zip Code: OH

Private County District Federal Indian Municipal State OtherEl El El El El [1 El

562112

First Name: Lynn MI: Last Name: VizdosPhone Number 330-273-3111 Phone Number Extension:E-Mail Address: Iynn.vizdossafety-kIeen.comFax Number 330-225-4033 Fax Number Extension:Street or P.O. Box:City, Town or Village:State: Zip Code:

Name of Site's Legal Owner:Safety-Kleen Systems, Inc Date Became Owner (mm/dd/yyyy):Owner Private County District Federal Indian Municipal StateType: 0 El El El El El El

Street or P.O. Box: 5360 Legacy Dr, Bldg 2, Suite 100City, Town or Village: Piano TX 75024 Owner Phone #:State: Country: Zip Code:Name of Site's Operator: Date Became OperatorSafety-Kleen Systems, Inc (mm/dd/yyyy):Operator Private County District Federal Indian Municipal State

Type: 0 El El El El El ElStreet or P.O. Box: 1169 N Industrial ParkwayCity, Town or Village: Brunswick Operator Phone #: 330-273-3111State: OH United States Zip Code: 442

ItRES1E: Yes El No I

Not a HW Generator

(LOG)

Cited for violation of 3745-52-11

LJ Mixed Waste (Hazardous andj Generator

OtherEl

OtherEl

Recycler of Hazardous Waste

Exempt Boiler and/or Industrial FurnaceUnderground Injection Control Facility

El Small Quantity On-Site Burner ExemptionHazardous Waste Transporter

fl Smelting, Melting, Refining Furnace Exemption

Treater. Storer or Disooser of Hazardous Waste

Revised 11 .03.05SiteVerifyForni.doc

PROCESS, WASTE, P2 SUMMARY SHEET

Facility Name: Safety Kleen Brunswick Facility Type: ZLQG LII SQG EII CESQ G LIITSD Date of Inspection: 5/21 and 6/4 2009 EPA

Trtxrvc'tc- &i;47 tTrcnsor1cr Used I +vnrs.porie_r/trtlns'&r AcW4y_ID#: OHD 000 720 987

Waste Generated On- or Off-Site P2 ActivitiesManagement

Process/Activity Waste QTY Generated Type of On- Name, state, and current P2 P2 OpportunitiesGenerating Waste Description per Month, Type of Site type of activity Activities(e .g. plating bath machining (e .g. sludge Accumulation (container, Treatment occurring at thebaghouse painting general solvent ash used tank etc) and location of (recycle t .ff_cife facility.maintenance etc) oil spent lamps waste accumulation area etc)

etc.) and EPAWaste Code ifappiic

1 Branch Debri-solids: F002 F003 800 pounds per Accumulati Smithfield, KYDiscarded PPE from F005 0004 month onworkers, sampling DOGS 0006material, gloves,cohwasa,

2 Branch Debri- DOOl F002 320 pounds per Accumulati Smithfield, KYliquids: sampling F003 FOGS month onmaterial, waste 0004 DOGSgenerated on-site,etc.

3 Sludge generated DOOl 0039 280 pounds per Accumulati Smithfield, KYfrom drum washing month on

4 Drums are brought DOOl 0018 Less than 5000 Consolidati Dolton, Iiin by Safety Kleen 0039 0040 gallons per week ontransportation andare condolidatedinto 5000 gallontanker truck parkedon site.

5 Fluorescent bulbs, Universal Waste varies Accumulati Safety Kleen,generated on site onand from other

P38 Table Format Electronic UseJune 2007 Page 1 of 2

facilities.

Used oil

Used oil andabsorbant

Me ire 1 "TTAnn

Bulking of used variesoil as a used oiltransfer facility

clean up varies

varies

Safety Kleen,Buffalo, NY

United WasteWater, Inc CincinattiOhio

Allied Waste

REMARKSBGENERAL INFORMATION

General Process Information:Safety Kleen Brunswick is a transporter of hazardous waste, hazardous waste transfer facility, large quantity generator, used oil transporter/transferfacility and a small quantity handler of universal waste. Hazardous waste is brought into the facility in drums, totes, ect. Material destined forrecylce at the Dolton, Illinois Safety-Kleen is consolidated into a 5000 gallon tanker truck. The shipment to Dolton, Illinois is a weekly event. Otherdrums of hazardous waste are stored for 10 days or less in the transfer facility. Branch generated wastes include PPE, sampling materials, and asludge generarted from the drum washer. Used oil and used oil/water is brought in on vac trucks and is accumulated on-site in three tanks. Twotanks are dedicated for used oil and one is dedicated for used oil/water. Used oil is transported off-site within the 35 days allowed for a transferfacility. Safety-Kleen also collects UW. Only UW bulbs were noted during this inspection. All boxes containing UW lamps were closed, properlylabeled and had an accumulation start date on them to ensure they would not be stored for greater than 1 year.

Regulatory/Enforcement History (if applicable):

Additional P2 remarks and information:

Would this facility be interested in a P2 assessment? E Yes* U No *If yes, refer promptly to your district P2 coordinator.Office of Compliance Assistance and Pollution Prevention - 1-800-329-7518 [email protected]

Other:

PSS Table Format Electronic UseJune 2007 Page 2of2

LARGE QUANTITY GENERATOR REQUIREMENTSCOMPLETE AND ATTACH A PROCESS DESCRIPTION SUMMARY

CESQG: !^1 00Kg. (Approximately 25-30 gallons) of waste in a calendar month or < 1 Kg. of acutely hazardous waste.SQG: Between 100 and 1,000 Kg. (About 25 to under 300 gallons) of waste in a calendar month.LOG: ^! 1,000 Kg. (-300 gallons) of waste in a calendar month or ^t1 Kg. of acutely hazardous waste in a calendar month.NOTE: To convert from gallons to pounds: Amount in gallons x Specific Gravit y x 8.345 = Amounts in pounds.

SafetyEquipment Used: Mi1 to-t- krtt'ko J1L}Ic %&LoA&GENERAL REQUIREMENTS 1. Have all wastes generated at the facility been adequately evaluated? [3745- Yes W No LI N/A LI

52-1112. Are records of waste determination being kept for at least 3 years? [3745-52- Yes LI No LI N/A LI

40(0)]3. Has the generator obtained a U.S. EPA identification number? [3745-52-12] Yes ,JZ No D N/A LI

4. Were annual reports filed with Ohio EPA on or before March 1st? [3745-52- Yes No 0 N/A LI41(A)]

5. Are annual reports kept on file for at least 3 years? [3745-52-40(B)] Yes No LI N/A LI

6. Has the generator transported or caused to be transported hazardous waste Yes LI No N/A LIto other than a facility authorized to manage the hazardous waste? [ORO3734.02(F)]

7. Has the generator disposed of hazardous waste on-site without a permit or Yes LI No N/A LIat another facility other than a facility authorized to dispose of the hazardouswaste? [ORC 3734.02(E) & (F)]

8, Does the generator accumulate hazardous waste? Yes XNo LI N/A LI

NOTE: If the LQG does not accumulate or treat hazardous waste, it is not subject to 52-34 standards. All otherrequirements still apply, e.g., annual reports, manifest, marking, record keeping, LDR, etc.9 Has the generator accumulated hazardous waste on-site in excess of 90 days Yes D No X N/A LI

without a permit or an extension from the director ORC §3734.02 (E) & ( F)?

NOTE: If F006 waste is generated and accumulated for> 90 days and is recycled see 3745-52-34(G) & (H).10. Does the generator treat hazardous waste in a: [ORC 3734.02(E)&(F)]

a Container that meets 3745-66-70 to 3745-66-77' Yes LI No 0 N/A

b Tank that meets 3745-66-90 to 3745-66-101 except 3745-66-97(C)' Yes LI No 0 N/A

C. Drip pads that meet 3745-69-40 to 3745-69-45 7Yes LI No 9 N/A

d Containment building that meets 3745-256-100 to 3745-256-102 Yes LI No U N/A 7'NOTE: Complete appropriate checklist for each unit.NOTE: If waste is treated to meet LDRs, use LDR checklist.11. Does the generator export hazardous waste? If so: Yes LI No SON/A LI

a. Has the generator notified U.S. EPA of export activity? [3745-52- Yes LI No 0 N/A V53(A)]

b. Has the generator complied with special manifest requirements? Yes LI No 0 N/A[3745-52-54]

C. For manifests that have not been returned to the generator: has an Yes LI No U N/Aexception report been filed? [3745-52-55]

d. Has an annual report been submitted to U.S. EPA? [3745-52-56] Yes LI No 0 N/A JZi

[Facility Name/Inspection Date][ID number]

LOG/March 2009Page 1 of 6

e. Are export related documents being maintained on-site? [3745-52- Yes No 0 N/A57(A)]

MANIFEST REQUIREMENTS12. Have all hazardous wastes shipped off-site been accompanied by a Yes No N/A J

manifest? (U.S. EPA Form 8700-22)[3745-52-20(A)(1)]13. Have items (1) through (20) of each manifest been completed? Yes Vr No fl N/A J

[3745-52-20(A)(1)] & [3745-52-27(A)]

NOTE: U.S. EPA Form 6700-22(A) (the continuation form) may be needed in addition to Form 6700-22. In thesesituations items (21) through (35) must also be completed. [3745-52-20(A)(1)]14. Does each manifest designate at least one facility which is permitted to Yes No 0 N/A fl

handle the waste? [3745-52-20(B)]

NOTE: The generator may designate on the manifest one alternate facility to handle the waste in the eventof an emergency which prevents the delivery of waste to the primary designated facility. [3745-52-20(C)].15. If the transporter was unable to deliver a shipment of hazardous waste to the Yes fl No 0 N/A

designated facility did the generator designate an alternate TSD facility or_____ give the transporter instructions to return the waste? [3745-52-20(D)]16. Have the manifests been signed by the generator and initial transporter? YesNo D N/A U

[3745-52-23(A)(1) & (2)]

NOTE: Remind the generator that the certification statement they signed indicates: 1) they have property preparedthe shipment for transportation and 2) they have a program in place to reduce the volume and toxicity waste theygenerate.17. If the generator did not receive a return copy of each completed manifest Yes fl No U N/A

within 35 days of the waste being accepted by the transporter did thegenerator contact the transporter and/or TSD facility to check on the status ofthe waste? [3745-52-42(A)(1)]

18. If the generator has not received the manifest within 45 days, did the Yes U No I U N/A 4generator file an exception report with Ohio EPA' [3745-52-42(A)(2)]19 Are signed copies of all manifests and any exception reports being retained Yes No U N/A U

for at least three years? [3745-52-40]

NOTE: Waste generated atone location and transported along a publicly accessible road for temporary consolidatedstorage or treatment on a contiguous property also owned by the same person is not considered "on-site" and manifestingand transporter requirements must be met To transport "along" a public right-of-way the destination facility has to act asa transfer facility or have a permit because this is considered to be "off-site." For additional information see the definitionof "on-site" in OAC rule 3745-50-10.PERSONNEL TRAINING20. Does the generator have a training program which teaches facility personnel Yes No 0 N/A U

hazardous waste management procedures (including contingency plan_____ implementation) relevant to their positions? [3745-65-16(A)(2)]21. Does the personnel training program, at a minimum, include instructions to Yes Z No 0 N/A U

ensure that facility personnel are able to respond effectively to emergenciesinvolving hazardous waste by familiarizing them with emergency procedures,emergency equipment and emergency systems (where applicable)? [3745-65-1 6(A)(3)(a-f)]

22. Is the personnel training program directed by a person trained in hazardous Yes J( No fl N/A LIIwaste management procedures? [3745-65-16(A)(2)]

23. Do new employees receive training within six months after the date of hire (or Yes ,J2?f No fl N/A Uassignment to a new position)' (3745-65-16(B)]

24. Does the generator provide annual refresher training to employees? [3745- Yes No 0 N/A U65-16(C)]

25. Does the generator keep records and documentation of:a. Job titles? [3745-65-16D(1)] Yes ,Z1' No D N/A U



b. Job descriptions? [3745-65-16D(2)] Yes No El N/A Elc. Type and amount of training given to each person? [3745-65-16D(3)] Yes f7 No El N/A Eld. Completed training or job experience required? [3745-65-16D(4)] Yes No 0 N/A El

26. Are training records for current personnel kept until closure of the facility and Yes No El N/A Elare training records for former employees kept for at least three years fromthe date the employee last worked at the facility? [3745-65-16(E)]

NOTE: The following section can be used by the inspector to document that all personnel who are involved withhazardous waste management have been trained. The employees who need training (written and/or on-the-job) mayinclude the following: environmental coordinators, drum handlers, emergency coordinators, personnel who conducthazardous waste inspections, emergency response teams, personnel who prepare manifest, etc.

Job Performed Name of Emøloyee Date Trained

CONTINGENCY PLAN

27. Does the owner/operator have a contingency plan to minimize hazards to Yes ,?IJ No D N/A Elhuman health or the environment from fires, explosions or any unplannedrelease of hazardous waste? [3745-65-51 (A)]

28. Does the plan describe the following:a, Actions to be taken in response to tires, explosions or any unplanned Yes No El N/A LI

release of hazardous waste? [3745-65-52(A)]b. Arrangements with emergency authorities? [3745-65-52(C)] Yes No El N/A ElC. A current list of names, addresses and telephone numbers (office and Yes g No 0 N/A El

home) of all persons qualified to act as emergency coordinator?[3745-65-52(D)]

d. A list of all emergency equipment, including: location, a physical Yes JZ No El N/A Eldescription and brief outline of capabilities? [3745-65-52(E)]

e. An evacuation plan for facility personnel where there is possibility that Yes Ø No El N/A Elevacuation may be necessary? [3745-65-52(F)]

NOTE: If the facility already has a "Spill Prevention, Control and Countermeasures Plan" under CEP Part 112 or 40 CR?Part 1510, or some other emergency plan, the facility can amend that plan to incorporate hazardous waste managementprovisions that are sufficient to comply with OAC requirements. [3745-65-52(8)]29. Is a copy of the plan (plus revisions) kept on-site and been given to all Yes No El N/A El

emergency authorities that may be requested to provide emergency services?[3745-65-53 (A) & (B)]

30. Has the generator revised the plan in response to rule changes, facility, Yes No El N/A Elequipment and personnel changes, or failure of the plan? [3745-65-54]

31. Is an emergency coordinator available at all times (on-site or on-call)? 13745- Yes VS No El N/A El65-55]

NOTE: The emergency coordinator shall be thoroughly familiar with: (a) all aspects of the facility's contingency plan: (b)all operations and activities at the facility; (c) the location and characteristics of waste handled; (d) the location of allrecords within the facility; (e) facility layout; and (f) shall have the authority to commit the resources needed to implementprovisions of the contingency plan.EMERGENCYPROCEDLJRES -''-

L A1JMi-4 m&&j 1-f L4J32. Has there been a fire, explosion dr relea&of hazardous waste or hazardous Yes 'Q1 NoN/A El

waste constituents since the last inspection? If so: 1

a.iNas the contingency plan implemented? [3745-65-51 (B)] Yes El No El N/A El

A)O,[Facility Name/Inspection Date]

1... ^aj [ID number]

&TVA''" °--' o' LOG/March 2009T Page 3of6

b. I Did the facility follow the emergency procedures in 3745-65-56(A) Yes J No El N/Athrough (H)?

C. Did the facility submit a report to the Director within 15 days of the Yes LI No LI N/Aincident as_ required _by_3745-65-56(J)?

NOTE: OAC 3745-65-51(b) requires that the contingency plan be implemented immediately whenever there is afire,explosion, or release of hazardous waste or hazardous waste constituents, which could threaten human health and theenvironmentPREPAREDNESS AND PREVENTION33. Is the facility operated to minimize the possibility of fire, explosion, or any Yes No 0 N/A LI

unplanned release of hazardous waste? [3745-65-31]34. Does the generator have the following equipment at the facility, if it is required

due to actual hazards associated with the waste:a. Internal communications or alarm system? [3745-65-32(A)] Yes 2 No LI N/A LI

b. Emergency communication device? [3745-65-32(B)] Yes kET' No 0 N/A LI

C. Portable fire control, spill control and decon equipment? [3745-65- Yes No 0 N/A LI32(C)]

d. Water of adequate volume/pressure per documentation or facility rep? Yes No 0 N/A fl[3745-65-32(D)]

NOTE: Verify that the equipment is listed in the contingency plan.35. Is emergency equipment tested (inspected) as necessary to ensure its proper Yes No 0 N/A LI

operation in time of emergency? [3745-65-33]36. Are emergency equipment tests (inspections) recorded in a log or summary? Yes 1J24 Nm. 0 N/A El

[3745-65-33] 37. Do personnel have immediate access to an internal alarm or emergency Yes No 0 N/A LI

communication device when handling hazardous waste (unless the device isnot required under 3745-65-32)? [3745-65-34(A)]

38 If there is only one employee on the premises is there immediate access to a Yes J?T' No 0 N/A LIdevice (eg phone hand held two-way radio) capable of summoning externalemergency assistance (unless not required under 3745-65-32)? [3745-65-

_____ 34(8)]39. Is adequate aisle space provided for unobstructed movement of emergency Yes No 0 N/A LI

or spill control equipment? [3745-65-35]40 Has the generator attempted to familiarize emergency authorities with Yes No 0 N/A LI

possible hazards and facility layouts' [3745-65-37(A)]41 Where authorities have declined to enter into arrangements or agreements Yes 0 No 0 N/A

has the generator documented such a refusal? [3745-65-37(B)]

SATELLITE ACCUMULATION AREA REQUIREMENTS42. Does the generator ensure that satellite accumulation area(s):

a Are ator near a point of generation' [3745-52-34(C)(1)] Yes No 0 N/A LI

b. Are under the control of the operator of the process generating the YesNo 0 N/A 0waste? [3745-52-34(C)(1)]

C. Do not exceed a total of 55 gallons of hazardous waste per waste YesNo 0 N/A LIstream? [3745-52-34(0)(1)1

d Do not exceed one quart of acutely hazardous waste at any one time? Yes ,JZ' No 0 N/A El[3745-52-34(C)(1)]

e. Containers are closed, in good condition and compatible with wastes Yes 71 No U N/A LIstored in them? [3745-52-34(C)(1)(a)]

f. Containers are marked with words "Hazardous Waste" or other words Yes No 0 N/A LIidentifying the contents? [3745-52-34(C)(1)(b)]



43Is the generator accumulating hazardous waste(s) in excess of the amounts Yes fl No N/A Ellisted in the preceding question? If so:

a. Did the generator comply with 3745-52-34(A)(1) through (4) or other Yes Z' No El N/A LIapplicable generator requirements within three days? [3745-52-34(C)(2)]

b. Did the generator mark the container(s) holding excess with the Yes No El N/A Elaccumulation date when the 55 gallon (one quart) limit wasexceeded ?[3745-52-34(C)(2fl

NOTE: The satellite accumulation area is limited to 55 gallons of hazardous waste accumulated from a distinct point ofgeneration in the process under the control of the operator of the process generating the waste (less then 1 quart foracute hazardous waste). There could be individual waste streams accumulated in an area from different points ofgeneration.USE AND MANAGEMENT OF CONTAINERS IN <90 DAY ACCUMULATION AREAS44. Has the generator marked containers with the words "Hazardous Waste?" Yes 12" No 0 N/A El

[3745-52-34(A)(3)]45. Is the accumulation date on each container? [3745-52-34(A)(2)] Yes . 171 No El N/A ElFn 3 ,tn2n n&.cdy'- L,-6-4ta

V.-.

46. Are hazardous wastes stored in containers which are:a. Closed (except when adding/removing wastes)? [3745-66-73(A)] Yes 21 No El N/A LIb. In good condition? [374566711 Yes 2 No 0 N/A ElC. Compatible with wastes stored in them? [3745-66-72] Yes Pr No El N/A Eld. Handled in a manner which prevents rupture/leakage? [3745-66-73(B)] Yes No El N/A El

NOTE: Record location on process summary sheets, photograph the area, and record on facility map.47. Is the container accumulation areas(s) inspected weekly? [3745-66-74] Per Yes No El N/A El

ORC1.44(A) "Week" means 7 consecutive days.a Are inspections recorded in a log or summary? [3745-66-74] Yes jJ2' No El N/A El

46. Are containers of ignitable or reactive wastes located at least 50 feet (15 Yes 2( No El N/A Elmeters) from the facility's property line? [3745-66-76] __________________

49 Are containers of incompatible wastes stored separately from each other by Yes No El N/A Elmeans of a dike berm wall or other device'? [3745-66-77(C)] /

50 If the generator places incompatible wastes or incompatible wastes and Yes El No El N/A 7materials in the same container, is it done in accordance with-3745-65-17(B)?____ [3745 -66-77 (A) ] dtoU-4 jA) p I43ii.LZL5F-Q51. If the generator places hàardous waste in an ttWahèd container that Yes El No El N/A El

previously held an incompatible waste, is it done in accordance with 3745-65-17(B)? [3745-66-77(B)] I

NOTE: OAC 3745-65-17(B) requires that the generator treat, store, or dispose of ignitable or reactive waste, and themixture or commingling of incompatible wastes, or incompatible wastes and materials so that it does not createundesirable conditions or threaten human health or the environment52, If the generator has closed a <90 day accumulation area does the closure Yes El No 0 N/A

appear to have met the closure performance standard of 3745-66-11?[3745-52-34(A)(1)]

NOTE: Please provide a description of the unit and documentation provided by the generator for the file to demonstratethat closure was completed in accordance with the closure performance standards. If the generator has closed a <90 day

tank, closure must also be completed in accordance with OA C 3745-66-97 (except for paragraph C of this rule). [3745-52-34]


LQG/March 2009Page of 6

PRE-TRANSPORT REQUIREMENTS53. Does the generator package/label its hazardous waste in accordance with the YesNo Li N/A fl

applicable DOT regulations? [3745-52-30, 3745-52-31 and 3745-52-32(A)]

54. Does each container <119 gallons have a completed hazardous waste label? Yes V No Li N/A Li[3745-52-32(B)]

55. Before off-site transportation, does the generator placard or offer the Yes 2' No 0 N/A Liappropriate DOT placards to the initial transporter? [3745-52-33]

[Facility Name/Inspection Date]LID number]

LQG/March 2009Page 6 of 6

GENERATOR LDR CHECKLISTDOES NOT APPLY TO CESQGS

GENERAL REQUIREMENTS1. If LDRs do not apply, does the generator have a statement that Yes fi No LI NIA

lists how the HW was generated, why LDRs don=t apply andwhere the HW went? [3745-270-07 (A)(7)]

2. Did the generator determine if the HW/soil must be treated to Yes fi No fi N/A f-meet the LDR treatment standard prior to disposal? Generatorknowledge or testing may be used. [3745-270-07(A)(1)]

NOTE: This is done by determining if the HWIsoil contains levels of constituents greater than thelevels given in its LDR treatment standard in 3745-270-40. However, if a specific treatmentmethod is given in 3745-270-40 for the HW, no determination is required [3745-270-07 (A)(1)(b)].If soil, generator can choose to have soil treated to LDR levels given in 3745-270-49 (alternativetreatment levels for soils).3. Does the generator have documentation of how he determined Yes No fl N/A

whether the HW/soil meets or does not meet the LDRtreatment standard in 2, above? [3745-270-07(A)(6)(a) or3745-270-07(A)(6)(b)]

4. Does the generator keep the documentation required in #2, Yes fl No fi N/Acabove, on-site for at least three years from the last date theHW/soil was sent on-site/off-site for treatment/disposal? [3745-270-07(A)(8)]

5. Does the generator generate a listed HW that exhibits a Yes" No fl N/A E1characteristic? If yes,a Did the generator determine if the listed HW exhibits a Yes' No E] N/A LI

characteristic that is not treated under the LDR treatmentstandard for the listed HW? [3745-270-09(A)

FOR EXAMPLE: F006 that exhibits the characteristic for silver or K062 that is corrosive, D002.Review LDR treatment standard in 3745-270-40 to determine what constituents the listed HWistreated for.6 Did the generator determine if its characteristic HW contains Yes No f.J N/A E1

underlying hazardous constituents that need to be treated?[3745-270-09(A)]

NOTE: This is done by evaluating which underlying hazardous constituents (UHC) are in the HWat levels above the universal treatment standards given in 3745-270-48. This requirement doesnot apply to high total organic carbon (La, contains >10% TOG) D001 wastes or listed HWs.

NOTE: Written documentation of this determination is not required.

7. 1

Did the generator treat his HW /soil on-site to meet the LDR Yes fi No N/A fitreatment standard?

NOTE If A Yes (a see question #16.8 Did the generator send a one-time LDR notification form to the Yes No till N/A LI

TSD with the first shipment to that facility?[3745-270-07(A)(2)]9 Did the generator resubmit the LDR notification form to the Yes E] No LI N/A

TSD when the HW changed or the generator used a newTSD? [3745-270-07(A)(2)]

10. Does the generator have a copy of the LDR notification form Yes RJ No E] N/A E]on file?[3745-270-07(A)(2)]

Generator LDR Checklist{Facility Name/inspection Date}

(ID Number]May 2008

Page 1 of 3

a. Is the form kept on file for three years after last HW Yes E' No El N/A Elshipped? [3745-270-07(A)(8)]

NOTIFICATION FORM11. Does the LDR Notification form contain the following

information:a. Manifest number of the first waste shipment to the Yes No LI N/A El

TSD?[3745-270-07(A)(2)Jb. Applicable waste codes (includes characteristic codes for Yes No Li N/A El

a listed HW if applicable)? [3745-270-07(A)(2)]

C. A statement that conveys that the HW is subject to LDRs Yes No LI N/A Eland must be treated to meet LDR treatmentrequirements? [3745-270-07(A)(2)]

d. A designation whether the HW is a wastewater or non- Yes No El N/A Elwastewater? [3745-270-07(A)(2)]. I

NOTE A wastewater contains <1% by v.4. total suspended solids(TSS) and <1% by wt. TOG. Ifyou doubt the HW is a wastewater or non-wastewater, the HW can be tested using for example,StandardMethods (SM) 160.2 for TSS, SW-846 method 9060a for TOG.

e. Designation of the waste subcategory when applicable? Yes No fl N/A El[3745-270-07(A)(2)]

NOTE: Subcategories are found on the LDR treatment standards table under the applicablewastecode. Not all HWs have subcategories

f. A listing of the underlying hazardous constituents for Yes, No U N/A Elwhich a characteristic waste must be treated? [3745-270- 07(A)(2)]

NOTE: Not required if the waste is high TOG DOOl or the TSD tests its treatment residues for allunderlying hazardous constituents.

g If the HW is F001-F005 or F039, did the generator note Yeskl No El N/A Elon the LDR form what solvents or constituents,respectively, the waste contains and must be treatedfor?[3745-270-07(A)(2)1

NOTE: Not required if the TSD tests its treatment residues for all underlying hazardousconstituents.PROHIBITED DILUTION12. Is the HW treated by burning? Yes X No ELI N/A El

If AN0,@ go to #15.13. Is the HW a metal-bearing HW? Yes,J No El N/A El

NOTE: Generally, metal-bearing I-INs contain heavy metals above TGLP levels or were listeddue to the presence of metals. A list of the restricted metal-bearing HWs are given in theAppendixto 3745-270-03.

14. a. Metal-bearing HWs cannot be incinerated, combusted or,blended and burned for fuel unless one of the followingconditions apply. [3745-270-03(c)]i. Contains> 1%TOC? Yes No El N/A Elii. Contains organic constituents or cyanide at levels Yes El No El N/A El

Generator LDR Checklist{Facility Name/Inspection Date}

[ID Number]May 2008

Page 2 of 3

greater than the UST levels? -iii. Is made up of combustible material e.g., paper, Yes LI No fl N/A fl

wood, plastic?iv. Has a reasonable heating value (e.g., > 5000 Btu)? Yes fl No LIII N/A El

V. Co-generated with a HW that must be combusted? Yes fl No El N/A LII

b. If all responses to 14 a.i. through 14 a.v. are AN0@, HW Yes fl No N/A Elis being improperly treated by dilution, violation of 3745-

____ ____ 270-03(C). Is HW being treated by dilution?15. Was the HW treated by wastewater treatment? Yes El No N/A El

a. Is a LDR treatment method, other than DEACT or a Yes El No 29 N/A Elnumerical value, specified for the waste? [3745-270-03(B) and 3745-270-40(A)(3)]

NOTE: If Yes, HW is improperly being treated by dilution. ______________________b. Does the waste carry the D001 code and contain 10% Yes El No LI N/A

TOC?C. Does the wastewater treatment process include a Yes El No El N/A

process to separate/recover the organic phase of thewaste?

NOTE: If the answers to b & c are Ayes@ and Ano@, respectively, waste is improperly beingtreated by dilution and generator is in violation of [3745-270-03(B) and 3745-270-40(A)(3)].

NOTE: A list of separation/recovery processes are given in 3745-270-42 under RORG.

GENERATOR TREATMENT16. Does the generator treat to meet LDRs on-site [3745-270- Yes El No'ØN/A El

40(A)]?Did the generator treat his hazardous waste/soil on-site in a Yes El No El N/Atank, container, drip pad or containment building to meet theLDR treatment standard?If 1\Yes@ . . .complete the rest of the checklist. IfAN0@ ... stop ... you are done.a. Does the generator have a written waste analysis plan Yes J No El N/A 'j

(WAP) that describes the procedures he will follow totreat the I-lW/soil to the LDR treatment standard? [3745-

_____ 270-07(A)(5)]b. Did the generator use a detailed chemical and physical Yes El No El

analysis of the HW/soil in order to develop the WAP?[3745-270-07(A)(5)(a)]

NOTE: This is a laboratory analysis but it does not have to be kept by the generator.c. Does the WAP contain all information necessary to treat Yes El No El N/A

the HW/soil to the [DR treatment standard? [3745-270-07(A)(5)(a)]

d. Does the WAP include the testing frequency of the Yes fl No El N/Atreated HW/soil to demonstrate that the [DR treatment

Generator LL)K UflecKlist{Facility Name/Inspection Date}

[ID Number]May 2008

Page 3 of 3

standard is being met? [3745-270-07(A)(5)(a)]e. Does the generator keep the WAR on-site? [3745-270- Yes fl No fl N/A &EP

07(A)(5)(b)]f. Is the WAR available for the inspector=s review during Yes fl No Li N/A3Vj

the inspection? [3745-270-07(A)(5)(b)]NOTIFICATION FORM

17. a. Contains all information in #11 a-g above and Yes M No

b. If the treated HW/soil is listed .....notification contains the Yes fl No LI N/A flfollowing certification statement:

A I certify under penalty of law that I personally haveexamined and am familiar with the waste, throughanalysis and testing or trough knowledge of the waste, tosupport this certification that the waste complies with thetreatment stands specified in rule 3745-270-40 to 3745-270-49 of the Administrative Code. I am aware thatthere are significant penalties for submitting a falsecertification, including the possibility of fine andimprisonment. @

C. If the treated HW/soil no longer exhibits a characteristicand is no longer a HW, did the generator:i. Send a one-time notification to the director7[3745- Yes fl No L] N/A.

270- 09 (D)]Maintain a copy of the notice onsite 7 [3745-270- Yes fl No LI N/Ai\09(D)]

iii. Include in the notification: [3745-270-09(D)(1)(a)]1 Name & address of receiving landfill? Yes LI No LI N/AC1

2 Description of HW when generated? Yes LI No LI N/A-IR.,

3 HW code when generated? Yes J No fl N/A

47— Treatability group when generated? Yes Li No Li5. Underlying hazardous constituents present Yes Li No LI N/ic

when generated?iv. Contain the right certification statement as required Yes Li No fl

by3745-70-07(b)(4)?

Generator LDR Checklist{Facility Name/inspection Date}

[ID Number]May 2008

Page 4 of 3

HAZARDOUS WASTE TRANSPORTER REQUIREMENTSGENERAL INFORMATIONPlease provide a brief description of site activity/waste handling procedures:1. Has the transporter registered with and obtained a permit (i.e., a credential) Yes No 0 N/A LI

from the Public Utilities Commission of Ohio? [3745-53-11(A)]

Note: Credentials issued by PUCO are on its website at http://www.puco.ohio.gov/apps/l-lazmatsearch/ . PUCO'sTransportation Division at 614-466-3392 also provides information on issued credentials or credential applications.Example of a credential ID number UPW00286330H 2. Has the transporter received a U.S. EPA ID number? [3745-53-11(B)] Yes W No 0 N/A El

3. Have all hazardous wastes accepted been accompanied by a manifest? Yes )Rfr No fl N/A LI[3745-53-20(A)]a. If no, was the waste generated by a CESQG or by a SOG shipped Yes LI No 0 N/A ,kr

a reclamation agreement? [3745-53-20(H)(1)] _______________

4. Has the transporter signed and dated the manifest and left a copy with Yes. ,7J No 0 N/A LIgenerator or prior transporter and carried the manifest with the wasteshipment? [3745-53-20(B)&(C))

5. Are manifests with all required signatures retained for at least three years? Yes X1 No 0 N/A LI[3745-53-22(A)]

6. Has the transporter delivered the entire quantity of waste accepted from the Yes 'j71 No LI N/A LIgenerator/transporter in accordance with OAC 3745-53-21(A)?

a. If the hazardous waste cannot be delivered in accordance with OAC Yes LI No H N/A I?13745-53-21 (A) other than rejection of the waste by the designatedfacility, did the transporter contact the generator for furtherinstructions and revise the manifest accordingly? 13745-53-21 (13)(1)]

b. Was the transporter on the designated facility's premises when the Yes LI No LI N/A 0facility rejected a partial load of the shipment or regulated quantitiesof container residues? If so:1. Did the transporter obtain a copy of the original manifest Yes LI No 0 N/A

including the rejecting facility's date and signature, themanifest tracking number that will accompany the shipment,and a description of the partial rejection or container residuein the "Discrepancy" block? [3745-53-21 (13)(2)(a)]

U. Has the transporter retained the original manifest for at least Yes LI No 0 N/Athree years? [3745-53-21 (13)(2)(a)]

Hi. Did the transporter obtain a new manifest if the transporter Yes LI No 0 N/Awas forwarding the rejected part of the shipment or aregulated container residue toan alternate facility or returning

it to the generator? [3745-53-21 (B)(2)(a)]C. Was the transporter on the designated facility's premises when the Yes LI No LI N/A

facility rejected a full load of the shipment? If so:1. Did the transporter obtain the original manifest including the Yes LI No 0 N/A JJ7

rejecting facility's signature and date attesting to therejection, a description of the rejection in the "Discrepancy"block of the manifest, and the name, address, phone number,and U.S. EPA identification number for the alternate facility orthe generator? [3745-53-21 (13)(2)(b)]

H. Has the transporter retained the original manifest for at least Yes LI No. 0 N/Athree years? [3745-53-21(B)(2)(b)]

Hi. Did the transporter obtain a new manifest if the original Yes LI No - 0 N/Amanifest was not used? [3745-53-21 (13)(2)(b)]

7, For hazardous waste delivered by the original transporter to a rail or Yes LI No 0 N/A 71'water transporter: Did the original transporter comply with the manifesthandling requirements of 3745-53-20(E)&(F)?

Facility Name/Inspection Date][ID Number]

Hazardous Waste Transporter Requirements Checklist/April 2009Page 1 of 3

NOTE: OAC not apply to water (bulk shipment) transports or

8. For hazardous waste shipped out of the country: Has the transporterretained signed copies of the manifest for at least three years indicating thatthe waste left the U.S.A.? [3745-53-22(D)]

9. Has the transporter ever had a discharge of hazardous waste during thetime that the waste was under the transporters control? If so:a. I Was immediate action taken? [3745-53-30(A)]

b. Was Ohio EPA's Office of Emergency Response immediatelynotified? [3745-53-30(C)(1)]

C. Did the transporter report in writing to Ohio EPA's Office ofEmergency Response? [3745-53-30(C)(2)]

d. Was the discharge cleaned up as required by Ohio EPA or a federalagency to remove hazard to protect human health or theenvironment? [3745-53-31]

Does the transporter store manifested containerized hazardous wastes at aspecific location en route to the destination facility? If so:a. Are wastes stored for ten days or less at a transfer facility? [3745-

53-12]b. Do containers used for waste storage meet DOT requirements?

Yes LI No 0 N/A

Yes LI No SN/A LI

Yes LI No LI N/A

Yes LI No 0 N/A [

Yes LI No LI N/A

Yes LII No LI N/A

Yes NJ No LI N/A LI

Yes N No 0 N/A LI

Yes No LI N/A LINOTE: Temporary storage in tanks is not permitted under transfer facility rules and tank storage requires a RCRApermit Any storage by the transporter which is not authorized under OAC 3745-53-12 transfer facility requirementsis subject to full RCRA regulations.A "transfer facility" means any transportation-related facility, including loading docks, parking areas, storage areasand other similar areas where hazardous waste is held during the normal course of transportation. (This does notinclude storage at the designated facility.)DOT regulations on packaging are contained in 40 CFR 176, 178 and 179.11. Does the transporter import hazardous waste into the United States? If so: Yes LI No j N/A LI

a. Did the transporter comply with the generator standards of OACChapter 3745-52? [3745-53-10(C)(1)] (Complete generatorchecklist)

Yes LI No 0 N/A

uoes the transporter accept exports of hazardous waste NOT subject to 40 I Yes LI No LI N/A 91LfrK ZbZ.t$U to 262.89? It so:a. Did the transporter accept only hazardous waste that conforms to

the U.S. EPA "Acknowledgement of Consent"? [3745-53-20(A)(2)(a13. Does the transporter accept exports of hazardous waste subject to 40 CFF

262.80 to 262.89? If so:a. Was the transporter provided with a U.S. EPA "Acknowledgment of

Consent" which, except for shipments by rail, was attached to the

Yes LI No 0 N/A

Yes LI No LI N/A

Yes LI No LI N/A

b. Was the transporter provided with a tracking document including all Yes LI No 0 N/Ainformation required by 40 CER 262.84? [3745-53-20(A)(2)(b)]

NOTE: Hazardous wastes that are destined for recovery operations in the countries listed in 40 CFR 262.58(a)(1) aresubject to 40 CFR 262.80 to 262.89.14. Does the transporter mix hazardous wastes of different U.S. DOT Yes $ No 0 N/A LI

descriptions by placing them into a single container? If so:a. Did the transporter comply with the generator standards of OAC Yes No 0 N/A LI

Chapter 3745-52? [3745-53-1O(C)(2)} (Complete generator

Does the transporter receive SQG wastes for transport pursuant to a Yes No 0 N/A LIreclamation agreement?



UStLJ OIL INSI'tU I ION UMtI.Llb ITRANSPORTER AND TRANSFER FACILITIES

NOTE: A facility is subject to the federal SPCC regulations (40 CFR 112) if it is non-transportation related (e.g., fixed)and has an aggregate above ground storage capacity greater than 1,320 gallons or a total underground storagecapacity greater than 42,000 gallons of oil (including used oil), and there is reasonable expectation of a discharge tonavigable waters.

1. Does the transporter or transfer facility manage used oil in a surface Yes El No a N/A Elimpoundment or waste pile? If yes:a Is the surface impoundment or waste pile regulated as a hazardous Yes El No 13 N/A S

waste management unit? [3745 279-12(A)]

NOTE: For example, scrap metal contaminated with used oil or used oil managed in a surface impoundment (i.e.,pond).2 Is used oil used as a dust suppressant? [3745-279-12(8)] Yes 0 No f N/A 0

3 Is off-specification used oil fuel burned for energy recovery in devices Yes El No DiN/Aspecified in 3745-279-12(C)?

NOTE: Multiple used oil checklists may be applicable if used oil handler is performing multiple tasks (e.g., ifgenerating used oil and shipping directly to a burner, complete generator and marketer checklists at a minimum).TRANSPORTER AND TRANSFER FACILITIES4. Does the used oil transporter process used oil or store used oil for greater Yes El No N/A El

than 35 days? [3745-279-41(A)] If so: ______________Is the used oil transporter in compliance with the requirements for Yes El No Ell N/Aprocessors/re-refiners in 3745-279-50 to 3745-279-59 (except as providedin 3745-279-41(B) and (C))? [3745-279-41 (A)] (Complete Used OilProcessor/Re-refiner checklist.)

S Has the used oil transporter notified Ohio EPA or U S EPA and obtained a Yes No 13 N/A ElU S EPA lD# [3745-279-42(A)]

6 Has the used oil transporter delivered all used oil to Yes El No QNlA El

a. Another used oil transporter that has a U.S. EPA lD#? [3745-279- Yes El43(A)(1)]

b. A used oil processing/re-refining facility that has a U.S. EPA ID#? Yes[3745-279-43(A)(2)J

C. An off-spec used oil burning facility that has a U.S. EPA ID#? [3745 Yes El279-43(A)(3)]

d. An on-spec used oil burning facility? [3745-279-43(A)(4)] Yes El

7. Has the used oil transporter complied with all applicable USDOTregulations (49 CER 171 to 180)? [3745-279-43(B)]

8. Has the used oil transporter had a discharge of used oil? If yes: [OAC3745-279-43(C)] ______a. Did they take immediate action to protect human health and the

environment? [3745-279-43(C)(1)]

b. Did they give notice (phone call), if required, to the national Yes El Noresponse center? [3745-279-43(C)(3)(a)]

C. Did they report in writing to DOT per 49 CFR 171.16? [3745-279- Yes El No43(C)(3)(b)]

d. Did they give notice (phone call) to Ohio EPA - DERR? [3745-279- Yes El No: I

Yes % No

rule Yes El No

Yes El No

N/A El

N/A El

N/A El

N/A El

N/A El

N/A El

JN/A

N/A

N/A

N/A

e. IT did they give notice per 33 CFR 153.203? F Yes El No U I N/A

[Facility Name/inspection Date][ID Number]

Used Oil Checklist for Transporters/June 2008Page 1 of 3

f Did they clean up any used oil discharged during transportation or Yes EJ No LI N/Atake any necessary action so the discharge no longer presents ahazard _to_ human _health _or the _environment? _[3745-279-43(C)(S)j

9. Has the used oil transporter determined whether the total halogen content Yes No 0 N/A LIof the used oil being transported or stored at a transfer facility is above orbelow 1000 ppm? [3745-279-44(A)] If yes, then;a. How t

4 ,Porter determ; halogen level content: Yes E] No El N/A LI

i. Testing (approved S -846 method)? or Yes J No LI N/A LI

ii. Applying knowledge of the halogen content of the used oil in Yes No N/A LIlight of the materials or processes used?

NOTE: If determination was not made by one of the two methods, then determination is not valid.b. If halogens are equal to/above 1000 ppm, did the transporter Yes LI No 0 N/A S

successfully rebut the presumption the used oil was mixed with aA.L40Jlisted hazardous waste? J

If yes, what method did transporter use to rebut the presumption °-'- ' 1 000(e.g., testing, exclusion, generator process information, etc.)(describe below)If no, did the transporter manage the material as a hazardous Yes LI No LI N/Awaste? [ORC 3734.02(E) and/or (F)]

NOTE: If used oil contains greater than 1000 ppm total halogens, it is presumed to be listed hazardous waste untilthe presumption is successfully rebutted.

10. Does the transporter retain all records of analyses and information used to Yes No LI N/A LIcomply with 3745-279-44 for at least three years? [3745-279-44(D)]

11. Does the owner/operator of a used oil transfer facility:a. Store used oil in tanks; or containers; or a unit(s) subject to Yes fl No 0 N/A'

regulation as a hazardous waste management unit? [3745-279-45(B)]

b. Store used oil in containers and aboveground tanks that are in good Yes Na 0 N/A LIcondition, with no visible leaks? [3745-279-45(0)]

C. Provide secondary containment for containers used to store used oil Yes -,'ET No fl N/A 0as required by 3745-279-45(D)? [3745-279-45(D)]

d. Provide secondary containment for existing aboveground tanks Yes '1% No LI N/A LIrequired by 3745-279-45(E)? [3745-279-45(E)]

e. Provide secondary containment for new aboveground tanks as Yes 0 No LI N/A flrequired by 3745-279-45(F)? [3745-279-45(F)]

f. Label all containers, aboveground tanks, and fill pipes used for Yes No LI N/A LIunderground tanks with the words Used Oil [3745-27945(9)]

g. Upon detection of a release of used oil: [3745-279-45(H)]i. Stopped the release? Yes LI No LI N/A

ii, Contained the release? Yes LII No fl N/A

Ill. Cleaned up and managed the used oil and other materials? Yes Jj No LI N/A

V. Repaired or replaced the containers or tanks prior to Yes LI No 0 N/Areturning them to service, if necessary?

12. Does the used oil transporter keep a record of each shipment of used oil? Yes 4J No 0 N/A LI[3745-27946(A)]a. Does each record include the name and address of the generator, Yes No LI N/A LI

transporter or processor/re-refiner who provides the used oil fortransport? [3745-279-46(A)(1)]

[Facility Name/Inspection Date][ID Number]

Used on checklist for Transporters/June 2008Page 2 of 3

b. Does each record include the U.S. EPA lD# of the generator, Yes '1 No 0 N/A Utransporter or processor/re-refiner (if applicable) that provides theused oil for transport? [3745-279-46(A)(2)]

C. Does each record include the quantity of used oil accepted? [3745- Yes Nr No 0 N/A U279-46(A)(3)}

d. Does each record include the date of acceptance? [3745-279- Yes ' No 9 N/A LI46(A)(4)J

e. Does each record include the signature of a representative of the Yes No 0 N/A Ugenerator, transporter, processor/re-refiner that provided the used oilfor transport? [3745-279-46(A)(5)]

13. Does the used oil transporter keep a record of each shipment of used oil Yes No fl N/A Uthat is delivered to another used oil transporter, burner, processor/re-refiner, or disposal facility? [3745-279-46(B)]a. Does each record include the name and address of the receiving Yes No 0 N/A U

facility or transporter? [3745-279-46(B)(1)]b. Does each record include the U.S. EPA ID# of the receiving facility Yes No 9 N/A U

or transporter? [3745-279-46(B)(2)]

C. Does each record include the quantity of used oil delivered? [3745- Yes No 0 N/A U279-46(B)(3)]

d. Does each record include the date delivered? [3745-279-46(B)(4)] Yes No 0 N/A Ue. Does each record include the signature of a representative of the Yes "f9' No 0 N/A U

receiving facility or transporter (intermediate rail transporters are notrequired to sign a record of delivery)? [3745-279-46(B)(5)J

14. Does the used oil transporter who exports used oil to a foreign country Yes U No U N/Acomply with 3745-279-46(B)(1) to (B)(4)? [3745-279-46(C)]

15. Does the used oil transporter retain all records required under 3745-279-46 Yes t No 0 N/A Ufor at least three years? [3745-279-46(D)] ___________________

16. Does the used oil transporter generate residues from the storage or Yes No U N/A Utransportation of used oil?If so, are they managed as specified in 3745-279-10(E)? [3745-279-47] Yes No 0 N/A LI


Used Oil checklist for TransporterslJune 2008Page 3 of 3

USED OIL INSPECTION CHECKLISTGENERATORS, COLLECTION CENTERS AND AGGREGATION POINTS

NOTE: A facility is subject to the federal SPCC regulations (40 CFR 112) if it is non-transportationrelated (e.g., fixed) and has an aggregate above ground storage capacity greater than 1,320 gallonsor a total underground storage capacity greater than 42,000 gallons of oil (including used oil), andthere is reasonable ex pectation of a discharge to navigable waters. - -

Yes El No [A N/A LII

Yes LI] No N/A

Yes fl No IS N/A LII3. Is off-specification used oil fuel burned for energy recovery in Yes fl No [)N/AM

devices specified in 3745-279-12(C)?NOTE: Multiple used oil checklists may be applicable if used oil handler is performing multipletasks (e.g., If generating used oil and shipping directly to a burner, complete generator and marketerchecklists at a minimum).GENERATOR STANDARDS4. 1 Does the generator mix hazardous waste with used oil? If so, Yes fl No 'j N/A fl

a. Is the mixture managed as specified in 3745-279-10(B)? Yes fl No:IIJ N/A[3745-279-21 (A)]

NOTE: Used Oil mixed with listed (3745-51-30 to 3745-51-35) or characteristic (3745-51-20 to 3745-5 1-24) hazardous waste are subject to regulation as a hazardous waste, unless the listed hazardouswaste is listed solely because it exhibits a hazardous characteristic, and the resultant mixtures do notexhibit a characteristic. Mixtures of used oil and CESQG hazardous waste are subject to OACChap ter 3745-279.5. Does the generator of a used oil containing greater than 1,000 Yes fl No 9 N/A

ppm total halogens manage the used oil as a hazardous wasteunless the presumption is rebutted successfully? [3745-279-21(B1

NOTE: If used oil contains greater than 1000 ppm total halogens, it is presumed to be ilshazardous waste until the presumption is successfully rebutted.6—Does the generator store used oil in tanks, or containers, or a Yes X No LI N/A fl

unit(s) subject to regulation as a hazardous waste managementunit? 13745-279-22(A)l

1. Does the generator manage used oil in a surface impoundmentor waste pile? If yes:a. Is the surface impoundment or waste pile regulated as a

hazardous waste management unit? [3745-279-12(A)]NOTE: For example, used oil contaminated scrap metal stored in a p2. Is used oil used as a dust suppressant? [3745-279-12(B)]

rolL!2

Eti

Are containers and aboveground tanks used to store used oil ingood condition with no visible leaks? [3745-279-22(B)]Are containers, above ground tanks, and fill pipes used forunderground tanks clearly labeled or marked AUsed OiI?@ [3745-279-22(C)]Has the generator, upon detection of a release of used oil, donethe following: [3745-279-22(D)]a. I Stopped the release?

b. I Contained the release?

Yes No [III N/A [III

Yes LII No g'N/A LIII

Yes LII No[]N/A

Yes LI No[JN/A

Yes LII No El[Facility Name/Inspection Date]

[ID Number]Used Oil Checklist for Generators/June 2008

Page 1 of 2

c. Cleaned up and properly managed the used oil and other Yes LI No fl N/Amaterials?

d Repaired or replaced the containers or tanks prior to Yes LI No LI N/Areturning them to service, if necessary?

ON-SITE BURNING IN SPACE HEATER10. Does the generator burn used oil in used-oil fired space heaters?

[3745-279 -23] If so:a. Does the heater burn only used oil that owner/operator Yes LI No LI N/A

generates or used oil received from household do-it-yourself (DIY) used oil generators?

b Is the heater designed to have a maximum capacity of not Yes LI No LI N/Amore that 0.5 million BTU per hour?

C. Are the combustion gases from heater vented to the Yes LI No LI N/Aambient air?

NOTE: Ash accumulated in a space heater must be managed in accordance with 3745-279-10(E).GENERATOR TRANSPORTATION11. Does the generator have the used oil hauled only by transporters Yes WJ No LI N/A LI

that have obtained a U.S. EPA ID#? __12. If the generator self-transports used oil to an approved collection Yes El No El NIA

site or to an aggregation point owned by the generator: [3745-279-24]a. Does the generator transport used oil in a vehicle owned by Yes LI No LI N/A

the generator or an employee of the generator?[3745-279-241

b. Does the generator transport more than 55 gallons of used Yes LI No LI N/A 9oil at any time?[3745-279-24]

NOTE: Used oil generators may arrange for used oil to be transported by a transporter without aU.S. EPA ID # if the used oil is reclaimed under a contractual agreement (i.e., tolling arrangement).COLLECTION CENTERS AND AGGREGATION POINTS13 Is the DIY used oil collection center in compliance with the Yes LI No LII N/A 'Ri'

generator standards in 3745-279-20 to 3745-279-24? [3745-279-30]

14 Is the non-DIY used oil collection center registered with Ohio Yes LI No LI N/AEPA? [3745-279-31]

15. Is the used oil aggregation point in compliance with the generator Yes LI No LI N/Astandards in 3745-279-20 to 3745-279-24? [3745-279-32] 1

NOTE: Complete Used Oil Generator and any other applicable used oil handler checklist (e.g.,marketer, burner, etc.) for used oil collection centers and aggregation points.


Used Oil Checklist for Generators/June 2008Page 2 of 2

SMALL QUANTITY UNIVERSAL WASTEHANDLER REQUIREMENTS - BATTERIES AND LAMPSLarge Quantity Universal Waste Handler (LQUWH)_=5,000 Kg or moreSmall QqpjJt Universal Waste Handier (SQUWH) = 5,000 Kg or lessPROHIBITIONS

1. Did the SQUWH dispose of universal waste? [3745-273-11(A)] Yes 0 No N/A 02. Did the SQUWH dilute or treat universal waste, except when responding to Yes 0 No N/A LII

releases as provided in OAC rule 3745-273-17 or managing specific wastesas provided in OAC rule 3745-273-13? [3745-273-11(B)]

WASTE MANAGEMENT AND LABELING/MARKING UNIVERSAL WASTE BATTERIES 7jra '6eI tic.. /\Jü j Qait.1,y

3. Are batteries that show evidence of leakage, spillage or damage that couJ Yes No 0 N/Acause leaks contained? [3745-273-13(A)(1)]

4. If batteries are contained, are the containers closed and structurally sound, Yes Q No D N/Acompatible with the contents of the battery and lack evidence of leakage,spillage or damage that could cause leakage? [3745-273-13(A)(1)]

5. Are the casings of the batteries breached, not intact, or open (except to Yes 0 N 0 N/Aremove the electrolyte)? [3745-273-13(A)]

6. If the electrolyte is removed or other wastes generated, has it been Yes 0 No 9 N/Adetermined whether the electrolyte or other wastes exhibit a characteristicof hazardous waste? [3745-273-13(A)(3)]

a. If the electrolyte or other waste is characteristic, is it managed in Yes 0 No D N/Acompliance with OAC Chapters 3745-50 through 3745-69? [3745-273-1 3(A)(3)(a)]

b. If the electrolyte or other waste is not hazardous, is it managed in Yes 0 No 0 N/A 'Mcompliance with applicable law? [3745-273-13(A)(3)(b)]

7. Are the batteries or containers of batteries labeled with the words Yes No LI N/A"Universal Waste - Batteries" or "Waste Battery(ies)" or 'Used Battery(ies)?'[3745-273-14(A)]

UNIVERSAL WASTE LAMPS6. Does the SQUWH contain lamps in containers or packages that are Yes No 0 N/A 0

structurally sound, adequate to prevent breakage, and compatible withcontents of the lamps? Are containers or packages closed and do they lackevidence of leakage, spillage or damage that could cause leakage? [3745-273-13(D)(1)]

9. Are lamps that show evidence of breakage, leakage or damage that could Yes 0 No 0 N/Acause a release of mercury or hazardous constituents into the environmentimmediately cleaned up? Are they placed into a container that is closed, Alstructurally sound, compatible with the contents of the lamps, and lack IVOevidence of leakage, spillage or damage that could cause leakage orreleases of mercury or hazardous waste constituents to the environment?[3745-273-13 '21)

NOTE: Treatment (such as crushing) by a UWH is prohibited under this rule unless the facility is permittedfor such activities [3745-273-31(8)]. A generator crushing lamps must manage lamps according to hazardouswaste rules (OAC Chapter 3745-52). Lamp crushing is a form of generator treatment (OAC rule 3745-52-34).Crushed lamps must be transported by a registered hazardous waste transporter to a permitted hazardous wastefacility using a hazardous waste manifest.

10, Are the lamps or containers or packages of lamps labeled with the words Yes No 9 N/A 0"Universal Waste - Lamp(s)" or 'Waste Lamp(s)' or 'Used Lamp(s)?" [3745-273-14(E)]

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER— BATTERIES & LAMPS INSPECTION CHECKLISTPage 1 of 3

SOUWH-B&L1 1 -21-O8revisions

ACCUMULATION TIME11. Is the waste accumulated for less than one year?

a. if not, is the waste accumulated over one year in order to facilitateproper recovery, treatment or disposal? (Burden of proof is on thehandler to demonstrate) [3745-273-15(B)] (this change makes it likethe LQUWH checklist)

NOTE: Accumulation is defined as date generated or date received from another12. Is the handler able to demonstrate the length of time the universal waste

has been accumulated? [3745-273-15(C)]

I

Yes X No LI N/A LI

Yes LI No 0 N/A

dler.

Yes $j. No D N/A LI

Yes JR No fl N/A LI

Yes LI No fl N/A

If yes, describe below:

EMPLOYEE TRAINING13. Are employees who handle or have the responsibility for managing

universal waste informed of waste handling/emergency procedures, relativeto their responsibilities? [3745-273-16]

RESPONSE TO RELEASES14. Are releases of universal waste and other residues immediately contained?

[3745-273-17(A)]15.1 Is the material released characterized? [3745-273-17(6)]

16. If the material released is a hazardous waste, was it managed as required Yes LI No £in OAC Chapters 3745-50 through 3745-69? (If the waste is hazardous, thehandler is considered the generator of the waste and is subject to OACChapter 3745-52) [3745-273-17(B)}

OFF-SITE SHIPMENTS

NOTE: If a SQUWH self-transports waste, then the handler must comply with the Universal Waste transporterrequirements.177 Are universal wastes sent to either another handler, destination facility or Yes ,j' No 0 N/A LIforeign destination? [3745-273-18(A)]18. Is the handier aware of DOT requirements for packaging and shipping? Yes )J No fl N/A LI

Yes LI F N/A II

F N/A

If no, make aware of 49 CFR 171-180.19. Prior to shipping universal waste off-site, does the originating handler

ensure that the receiver agrees to receive the shipment? [3745-273-18(D)](this change makes it like the LQUWH checklist)

20. Has the originating handler ever had an off-site shipment rejected byanother handler or destination facility?a. If yes, did the originating handler receive the waste back or agree to

where the shipment was sent? [3745-273-18(E)(2)]21. If a handler rejects a partial or full load from another handler, does the

receiving handler contact the originating handler and discuss and do one of

Yes R No LI N/A LI

Yes LI No N/A LI

Yes LI No LI N/A

Yes LI No 0 N/A a

a. Send the waste back to the originating handler or send the shipment Yes LIto a destination facility (If both the originating and receiving handleragree)? [3745-273-18(F)(2)] (this change makes it like the LQUWH

22. If the handler received a shipment of hazardous waste that was not a Yesuniversal waste, did the SQUWH immediately notify Ohio EPA? [3745-273-18(G)]

U N/A

No 0 N/A

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EXPORTS23. Is waste being sent to a foreign destination? If so: Yes fl No Ea N/A LI

a. Does the small quantity handler comply with primary exporter Yes fl No H N/Arequirements in OAC rules 3745-52-53. 3745-52-56, and 3745-52-57? [3745-273-20(A)]

b. Is waste exported only upon consent of the receiving country and in Yes fl No LI N/Aconformance with the U.S. EPA Acknowledgment of Consent" asdefined in OAC rules 3745-52-50 to 3745-52-57? [3745-273-20(8)]

C. Is copy of the U.S. EPA "Acknowledgment of Consent" provided to Yes J No El N/A 2the transoorter? 13745-273-20(C)]

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER - BA TTERIES & LAMPS INSPECTION CHECKLISTPage 3 of 3

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RE: SAFETY-KLEEN SYSTEMS, INC., OHD …chagrin.epa.ohio.gov/edoc/images/111700/1117000001.pdf ·...

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