Environmental Protection Agency Re: CO-BAR Corporation OH ...chagrin.epa.ohio.gov/edoc/images/113800/1138000029.pdf · Overview for Ohio Businesses Who Generate Used Oil, and Used

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EnvironmentalProtection Agency

Ted Strickland, GovernorLee Fisher, Lt. GovernorChris Korteski, Director

Re: CO-BAR CorporationOH D077578 151Lucas CountyHazardous WasteNotice of Violation/RTC

October 13, 2010

Mr. David Niemic, Vice PresidentCO-BAR Corporation1700 Landis AvenueOregon, Ohio 43616

Dear Mr. Niemic:

Thank you for accompanying me during Ohio EPA's September 30, 2010, complianceevaluation inspection (CEI) of CO-BAR Corporation (CBC) located at 1700 LandisAvenue in Oregon, Ohio. I inspected CBC to determine its compliance with Ohio'shazardous waste laws as found in Chapter 3734. of the Ohio Revised Code (ORC) andChapter 3745. of the Ohio Administrative Code (OAC). My inspection includedobservations of facility operations and a review of written documentation. This letter willexplain the violations I found and what you need to do to correct the violations.

CBC manufactures steel bar from coiled 9254 steel. The coil is straightened and thesurface is removed. The bars are manufactured into coil springs for vehicles by otherfacilities. Steel chip and some hard scrap are recycled. The coolant used in thestraightening machines is filtered and recycled. When scale builds up the coolant ispumped out by DISC. CBC performs no coating, painting or pickling.

CBC does not appear to be generating hazardous waste. However, CBC generates oraccumulates the following wastes:

1. Universal Waste Lamps: CBC recycles its spent fluorescent lamps (and othertypes) through Safety-Kleen.

Used Oil: CBC generates used coolant from its straightening machines andaccumulates it in 55-gallon drums. Used oil is recycled through DISCEnvironmental Service, Inc.

3. Parts Washer Solvent: CBC operates four parts washers for cleaning parts withmineral spirits. The solvent is changed every 3-4 months. These parts washersare part of Safety-Kleen's Continued Use program. Therefore, the spent solventis not a waste.

Northwest District Office 419 1352 8461347 North Dunbridge Road 419 1352 8468 (fax)Bowling Green, OH 43402-9398 www.epa.ohio.gov

fl .

Mr. David Nliemic, Vice PresidentOctober 13, 2010Page 2

As a result of my inspection, I found the following violation of Ohio's hazardous wastelaws:

Used Oil Container LabelingOAC Rule 3745-279-22(C)(1)

Containers and aboveground tanks used to store used oil at generator facilitiesmust be labeled or marked clearly with the words 'Used Oil." On September 30,2010, I observed, at least, eight 55-gallon drums in the plant that were notlabeled with the words "Used Oil".

On October 4, 2010, Shawn Hendricks of CRC submitted a photograph ofproperly labeled drums of used oil. Therefore, this violation has beenabated.

As a used oil generator you are required to store used oil in containers or abovegroundtanks that are in good condition (no severe rusting, apparent structural defects ordeterioration) and not leaking. Containers, aboveground tanks and fill pipes forunderground tanks must be labeled with the words "Used Oil." If leaks are detected, thegenerator must stop the release; contain the release; clean up and manage properly thereleased used oil and other materials related to the release; and, if necessary, repair orreplace any leaking containers or tanks prior to returning them to service. I haveenclosed copies of the following used oil fact sheets: The Regulation of Used Oil: AnOverview for Ohio Businesses Who Generate Used Oil, and Used Oil Recyclers.Please review these carefully and contact me immediately if you have any questions.

Please be aware that incandescent, fluorescent, metal halide, neon, high-intensitydischarge, high-pressure sodium and mercury-vapor lamps could be hazardous wastewhen discarded. Fluorescent lamps may contain up to 40 milligrams (mg) of mercury,depending on the brand and manufacturer. Lamps may also contain lead andcadmium. Many lamps exhibit a characteristic of toxicity for heavy metals whendisposed. I have enclosed copies of the following documents to assist you in properlymanaging your spent lamps: Fluorescent Lamps: What You Should Know andCom puter, Fluorescent Lamp and Ballast Recyclers. I recommend that you reviewthese documents carefully and contact me if you have any questions. The firstdocument describes the rules you must follow in order to manage lamps as a universalwaste.

You may be able to further reduce the waste your company generates. If you find ways torecycle, reduce or altogether eliminate the amount of waste that your company generates youmay be able to reduce your treatment and disposal costs and you may possibly reduce yourregulatory requirements. I have enclosed copies of Pollution Prevention O pportunities, aworksheet that can help you recognize opportunities for reducing waste and conserving energyat your business, and the fact sheet Management of Electronic Waste from Businesses. Pleasereview this information and contact me if you have any questions.

n

Mr. David Niemic, Vice PresidentOctober 13, 2010Page 3

I encourage you to schedule a pollution prevention assessment for your businessbecause there are often many opportunities for businesses like yours to reduce wasteand save money. If you wish to talk about an assessment or if you have otherquestions about pollution prevention, please feel free to contact the Office ofCompliance Assistance and Pollution Prevention (OCAPP) at (614) 644-3469. There isno charge for an assessment.

The Division of Hazardous Waste Management has created an electronic news serviceto provide you with quick and timely updates on events and news related to hazardouswaste activities in Ohio. If you haven't already, we encourage you to sign-up for thisfree service. You can find more information at the following Web linkhttp://ohioepa.custhelp.com/cgi-bin/ohioepa.cfg/phg/enduser/doc serve.ghg?2=subscriptionpaqe. Please feel free toshare this information with your colleagues.

If you have any questions, please feel free to contact me at (419) 373-3074. Enclosedyou will find copies of all checklists completed during the inspection. You can findcopies of the rules and other information on the division's web page athttp://www.epa.ohio.gov . Ohio EPA also has helpful information about pollutionprevention at the following web address: http://www.epa.ohio.gov/ocapp.

Sincerely,

Don NorthDistrict RepresentativeDivision of Hazardous Waste Management

/llrPC: Colleen Weaver, DHWM, NWDO

Cindy Lohrbach, DHWM, NWDODHWM,,NWDO,iLucas County,-CO-BAR File (New)

ec: Don North, DHWM, NWDO

NOTICE:Ohio EPA's failure to list specific deficiencies or violations in this letter does not relieve your

company from having to comply with all applicable regulations.

.

Ohio Environmental Protection AgencySend to Central Office I RCRA SUBTITLE C SITE

IDENTIFICATION!VERIFICATION FORM

For Ohio EPA use only

verification forms to CO should be

Site EPA ID No.Site Name

Site Location Information

Site Land Type

Facility Representative

Additional names can berecorded in number 12

Only provide addressinformation if it is differentthan the site address

Legal Owner AndOperator of the Site.List Additional Ownersand/or Operators in theComment Section or onanother copy of this formpage

EPA ID Number: 0HD077578151

Name: CO-BAR Corporation Website.

--------------(ptjnaStreet Address: 1700 Landis AvenueCity, Town, or Village: OregonState: OHCounty Name: Lucas Zip Code: 43616

Private County-- District Federal- -- Indian Municipal State Otheru------u-----------------------------U------------U--------

I _Last Name:

Title: Vice PresidentoneNumber: i9l9 [!!!nio....................

-E-Ma-ii Address:Fax ExtensiFax -Number - 4-11 9:6937.22-52 [!!9:

Street or P.O. Box:City, Town or Village:State: 1 Zip Code:

of Site's Legal Owner:

Owner Private County DistrictType: 1 0 U 0Street or P.O. Box:City, Town or Village:State:Name of Site's Operator:

Operator Private County DistrictType: U U 1 U

Street or P.O. Box:City, Town or Village:State:

Date Became Owner(mmldd/yyyy):Federal Indian Municipal State OtherU I U I 0 U I DOwner Phone #:

Date Became Operator(mm/dd/yyyy):Federal Indian Municipal State I Other

0 U U U I UOperator Phone #:Country [Zip Code:

Yes

TYPE OF HANDLER- MARK "X"AS APPROPRIATEN Not a HW Generator I U UNKNOWN:

Generator (LOG)Cited for violation ofShort-Term/Temoor(generates from a short-term or I UConditionall y Exempt Small Quantity (ieneione-time event and not from on-going [ULJ.S. Importer of Hazardous Wasteprocesses). Check the box for the UMixed Waste (Hazardous and Radioactive)applicable generator status and providea comment.

I Generator

Pt UI- KE(3IJLATED WASTE ACTIVITY (MARK X"Hazardous Waste TransporterHazardous Waste Transfer FacilityTreater, Storer or Disposer of Hazardous WasteRecycler of Hazardous Waste

U Exempt Boiler and/or Industrial FurnaceEl Small Quantity On-Site Burner ExemptionU Smelting, Melting, Refining Furnace Exemption

J Underground Injection Control FacilityLII Receives Hazardous Waste from Off-site

UNIVERSAL WASTE ACTIVITIES (INDICATE TYPES OF UNIVERSAL WASTE MANAGED(CHECK ALL BOXES THAT APPLY) - -

Small Quantity Handler of Universal Waste fl Destination Facility for Universal WasteU Large Quantity Handler of Universal Waste

(accumulates 5,000 kg. or more)

CHECK ALL BOXES BELOW THAT APPLY FOR THE TYPES OF UNIVERSAL WASTE THE FACILITY MANAGESU Batterieso Pesticideso Mercury containing equipmentZ LampsUSED OIL ACTIVITIES (INDICATE TYPE(S) OF ACTIVITY(S)Z Used Oil GeneratorU Used Oil TransporterF-1 Used Oil Transfer FacilityU Used Oil ProcessorU Used Oil Re-refinerU Off-Specification Used Oil BurnerU Used Oil Fuel Marketer who directs shipment of Off-Spec Used OilLi Used Oil Fuel Marketer who first claims the Used Oil meets the specificationsEligible Academic Entities with Laboratories Facility has previously notified that they are opting into managing laboratory hazardous wastepursuant to oAc rules 3745-52-200 through 3745 52 216 cheik the box(es) below to indicate the laboratory type

O College or Universityo Teaching hospital that is owned by or has a formal written affiliation agreement with a college or universityEl Non-profit Institute that is owned by or has a formal written affiliation agreement with a college or universityWaste Codes for Federally ,.Regulated Hazardous Wastes. Please list the codes for the federally regulated hazardous waste handled at thesite List them in the order they are presented in the regulations (e .g,, 0001 D003 F007 U112). Use an additional page or list them in the comments ifmore space is needed If the waste codes are the same as listed in the most recent RCRAInfo source record you do not need to list them Instead justindicate the date of the most recent source record. . . .

COMMENTS: USE THIS AREA TO DESCRIBE WHETHER THE INSPEbTIONWAS 'ANNOUNCED WHETHER THEWASTE IS STORED IN TANKS OR CONTAINERS ETC.:' --.Announced U Yes Z No Additional Facility Representatives:Tanks U Yes MNoContainers Yes 0 No

Date of Inspection/TimeName of Inspector(s) Name of Inspector(s) (mrn/dd/yyyy) (hh:mrn)Don North 09130/2010

Comments:

Revised 07.26. 10

PROCESS, WASTE, P2 SUMMARY SHEET

Facility Name: CO-BAR Corporation Facility Type: flLQG LISOG LICESQG LITSD Date of Inspection: 9-30-10 EPA 10Th0HD077578151

Waste Generated On- or Off-Site P2 ActivitiesManagement

Process/Activity Waste QTY Generated Type of On.Name, state, and Current P2 P2 Opportunities

Generating 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, wwt, off-site facility.maintenance, etc) oil, spent lamps, waste accumulation area etc)

etc.) and EPAWaste Code, if

applic.

1 Facility lighting Universal waste Few occassionally None Safety-Kleen Recycledlamps Toledo, Ohio

Recycling

2 Machine coolant Used Oil Approximately 55 None DISC Environmental Recycledgallons Service, Inc.

Northwood, Ohio

Recycling

3 Cleaning parts Parts washer 30 gallons every 3-4 None Not a wastesolvent months

Part of Safety-KleenContinued Useprogram

4

5

6

PSS Table Format Electronic UseJune 2007 Page 1 of 2

7

8

9

REMARKSBGENERAL INFORMATION

General Process Information: Ll

Regulatory/Enforcement History (if applicable):

Additional P2 remarks and information:

Would this facility be interested in a P2 assessment? D Yes* fl No if yes, refer promptly to your district P2 coordinator.Office of Compliance Assistance and Pollution Prevention - 1-800-329-7518 or p2mailepa.state.ohus or www.epastate.oh.us/ocappfocapp.html

Other:

.

PBS Table Format Electronic UseJune 2007 Page 2of2

USED OIL INSPECTION CHECKLIS IGENERATORS, COLLECTION CENTERS AND AGGREGATION POINTS

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

1.

Does the generator manage used oil in a surface impoundment or waste pile? Yes 0 No 0 N/A 0If yes:a. Is the surface impoundment or waste pile regulated as a hazardous Yes 0 No J N/A

waste management unit? [3745-279-12(A)1pfflyp• Pnr nvmnie riced nil cnntaminated scrap metal stored in a aile.2— used oil used as a dust suppressant? [3745-279-12(B)j Yes fl No 0 N/A U

3— off-specification used oil fuel burned for energy recovery in devices specified Yes U No 0 NIA 0in 3745-279-12(C)?

NOTE: Multiple used oil checklists maybe applicable if used oil handler is performing multiple tasks (e.g., If generatinused oil and shipping directly to a burner, complete generator and marketer checklists at a minimum).

GENERATOR STANDARDS4. Does the generator mix hazardous waste with used oil? If so, ( Yes fl No 0 N/A U

re managed as specified

[3745-279- I Yes U No 0 N/A 021(A)] I

NOTE: Used Oil mixed with listed (3745-51-30 to 3745-51-35) or characteristic (3745-51-20 to 3745-51-24) hazard=waste are subject to regulation as a hazardous waste, unless the listed hazardous waste is listed solely because itexhibits a hazardous characteristic, and the resultant mixtures do not exhibit a characteristic. Mixtures of used oil andCESQG hazardous waste are subject to OAC Chapter 3745-279.5. Does the generator of a used oil containing greater than 1,000 ppm total Yes U No 0 N/A 0

halogens manage the used oil as a hazardous waste unless the presumptionis rebutted successfully? [3745-279-21(B)]

NOTE: If used oil contains greater than 1000 ppm total halogens, it is presumed to be listed hazardous waste untilpjumption is successfully rebutted.6. Does the generator store used oil in tanks; or containers; or a unit(s) subject to Yes 2 No U N/A 0

regulation as a hazardous waste management unit? [3745-279-22(A)]

7. Are containers and aboveground tanks used to store used oil in good condition Yes Z No E-] N/A 0with no visible leaks? [3745-279-22(B)]

8. Are containers, above ground tanks, and fill pipes used for underground tanks Yes 0 No M N/A Uclearly labeled or marked "Used Oil?" [3745-279-22(C)]

9. Has the generator, upon detection of a release of used oil, done the following: Yes 0 No U N/A

a. I Stopped the

Yes U No U N/A 0the release?

Yes U No 0 N/A 0C. Cleaned up and properly managed the used oil and other materials? Yes U No 0 N/A 0

d. Repaired or replaced the containers or tanks prior to returning them to Yes Lii No U N/A Zservice, if necessary?

TE BURNING IN SPACE HEATERDoes the generator burn used oil in used-oil fired space heaters? 13745-279-23] If so:a. Does the heater burn only used oil that owner/operator generates or Yes U No 0 N/A 0

used oil received from household do-it-yourself (DIY) used oil

CO-BAR corp./9-30-100HD077578151

Used Oil checklist for Generators/June 2008Page 1 of 2

b. Is the heater designed to have a maximum capacity of not more that0.5 million BTU per hour?

C. Are the combustion gases from heater vented to the ambient air?

NOTE: Ash accumulated in a space heater must be managed in accordance withGENERATOR TRANSPORTATION11. Does the generator have the used oil hauled only by transporters that have

obtained a U.S. EPA lD#? [3745-279-24]12. If the generator self-transports used oil to an approved collection site or to an

aggregation point owned by the generator: [3745-279-24]

Yes 0 No 0 N/A ZYes 0 No U N/A Z

Yes Zi No 0 N/A fl

a. Does the generator transport used oil in a vehicle owned by the Yes J No N/A Zgenerator or an employee of the generator? [3745-279-241

b. Does the generator transport more than 55 gallons of used oil at any Yes 0 No 0 N/Atime? [3745-279-241

NOTE: Used oil generators may arrange for used oil to be transported by a transporter without a U.S. EPA ID #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 generator Yes 0 No Q N/A Z

standards in 3745-279-20 to 3745-279-24? 13745-279-30]14. Is the non-DIY used oil collection center registered with Ohio EPA? [3745-279- Yes 0 No 0 N/A Z

31]15. Is the used oil aggregation point in compliance with the generator standards in Yes 0 No U N/A Z

3745-279-20 to 3745-279-24? [3745-279-32]NOTE: Complete Used Oil Generator and any other applicable used oil handler checklist (e.g., marketer, burner, etc.used oil collection centers and aocreaation ooints.

CO-BAR Oorp./9-30-100HD077578151

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

S

SMALL QUANTITY UNIVERSAL WASTE HANDLER REQIJIREMI - BATTERIES AND LAMPS

Quantity Universal Waste Handler (LQUWH) = 5,000 Kg or more2uantitv Universal Waste Handler (SQUWH) = 5,000 Kg or less

PROHIBITIONS1. I DidtheS

of universal waste?

2. Did the SQUWH dilute or treat universal waste, except when responding toreleases as provided in CAC rule 3745-273-17 or managing specific wastesas provided in OAC rule 3745-273-13? [3745-273-11(6)]

WASTE MANAGEMENT AND LABELING/MARKINGUNIVERSAL WASTE BATTERIES3. Are batteries that show evidence of leakage, spillage or damage that could

cause leaks contained? [3745-273-13(A)(1)]

If batteries are contained, are the containers closed and structurally sourcompatible with the contents of the battery and lack evidence of leakage,spillage or damage that could cause leakage? [3745-273-13(A)(1)]

Yes 0 No N N/A 0Yes 0 No N N/A

Yes 0 No 0 N/A N

Yes D No LI N/A

['1

Are the casings of the batteries breached, not intact, or open (except to Yes 0 No 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 0 N/A Ndetermined 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 9 No 9 N/A Ncompliance 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 9 No 0 N/A Ncompliance with applicable law? [3745-273-13(A)(3)(b)]

rA

Are the batteries or containers of batteries labeled with the words Yes 0 No 9 N/A N"Universal Waste - Batteries" or "Waste Battery(ies)" or "Used Battery(ies)?"

RSAL WASTE LAMPSDoes the SQUWH contain lamps in containers or packages that arestructurally 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))Are lamps that show evidence of breakage, leakage or damage that couldcause a release of mercury or hazardous constituents into the environmentimmediately cleaned up? Are they placed into a container that is closed,structurally sound, compatible with the contents of the lamps, and lackevidence of leakage, spillage or damage that could cause leakage orreleases of mercury or hazardous waste constituents to the environment?

Yes N No 0 N/A

Yes 0 No 9 N/A N

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 (QAC 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 N No 9 N/A 0

"Universal Waste - Lamp(s)" or "Waste Lamp(s)" or "Used Lamp(s)?" [3745-273-14(E)]

RCR4 SMALL QUANTITY UNIVERSAL WASTE HANDLER - BAITER/ES & LAMPS INSPECTION CHECKLISTPage 1 of 3

SQIJWH-B&L1 1-21 -OBrevisions

ACCUMULATION TIME11. Is the waste accumulated for less than one year? [3745-273-15(A)] Yes Z No 0 N/A El

a. If not, is the waste accumulated over one year in order to facilitate Yes 0 No 0 N/A Zproper recovery treatment or disposal? (Burden of proof is on thehandlerto_demonstrate)_[3745-273-15(B)]

NOTE: Accumulation is defined as date generated or date received from another handler.12. Is the handler able to demonstrate the length of time the universal waste Yes 0 No 0 N/A

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

If yes, describe below:

EMPLOYEE TRAINING13. Are employees who handle or have the responsibility for managingYes No 0 N/A El

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? Yes El No F] Z

[3745-273-17(A)]15. Is the material released characterized? [3745-273-17(8)] Yes El No 0 N/A Z

16. If the material released is a hazardous waste, was it managed as required Yes El No El N/A Zin 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 SHIPMENTSNOTE: If a SQUWH self-transports waste, then the handler must comply with the Universal Waste transporterrequirements.17. Are universal wastes sent to either another handler, destination facility or Yes 0 No El N/A fl

foreign destination? [3745-273-18(A)]18. Is the handler aware of DOT requirements for packaging and shipping? Yes N No El N/A 0

If no, make aware of 49 CFR 171-180,19. Prior to shipping universal waste off-site, does the originating handler Yes Z No 0 N/A 0

ensure that the receiver agrees to receive the shipment? [3745-273-18(D)]20. Has the originating handler ever had an off-site shipment rejected by Yes 0 No Z N/A 0

another handler or destination facility?a.

If yes, did the originating handler receive the waste back or agree to Yes 0 No 0 N/A Zwhere the _shipment _was sent? [3745-273-18(E)(2)]

21. If a handler rejects a partial or full load from another handler, does the Yes El No El N/A Zreceiving handler contact the originating handler and discuss and do one ofthe following:a.

Send the waste back to the originating handler or send the shipment Yes El No 0 N/A Zto a destination facility (If both the originating and receiving handleragree)?_[3745-273-18(F)(2)]

22. If the handler received a shipment of hazardous waste that was not a Yes El No 0 N/Auniversal waste, did the SQUWH immediately notify Ohio EPA? [3745-273-18(G)]

EXPORTS23. Is waste being sent to a foreign destination? If so: Yes 0 No M N/A LI

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER - BATTERIES & LAMPS INSPECTION CHECKLISTPage 2 of 3

SQUWH-B&L1 1-21 -O8revisions

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

b. Is waste exported only upon consent of the receiving country and in Yes 9 No 0 N/Aconformance with the U.S. EPA "Acknowledgment of Consent" asdefined in CAC rules 3745-52-50 to 3745-52-57? [3745-273-20(B)]

C. Is a copy of the U.S. EPA "Acknowledgment of Consent" provided to Yes 9 No 9 N/A Zthe transporter? [3745-273-20(C)]

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER - BAITER/ES & LAMPS INSPECTION CHECKLISTPage 3 of 3

SQUWH-B&L1 1-21-08revisions