OItEState of Ohio Environmental Protection Agency

Northwest District Office

347 North Dunbridge Road TELE: (419) 352.8461 FAX (419) 352-8468 Ted Strickland, GovernorBowling Green, OH 43402-9398 wv.epa.sla.le.oh.us

Lee Fisher, Lieutenant GovernorChris Korleski, Director

- Re: SK Hand Tool CorportationLarge Quantity Generator0HD045247350Defiance County, NWDONOV

August 14, 2008

Mr Bill Zirkle5K Hand Tool Corporation135 Hickory StreetDefiance, Ohio 43512

Dear Mr. Zirkle:

Thank you for accompanying Wendy Miller and me during Ohio EPA's July 25, 2008, inspection ofSK Hand Tool Corporation's facility in Defiance, Ohio. We inspected 5K Hand Tool Corporation todetermine its 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). During theinspection we also helped you identify ways to prevent pollution by reducing waste

5K Hand Tool Corporation is a manufacturer of hand held tools including wrenches, ratchets andsockets. Hand tools are forged from steel bar stock, trimmed, annealed, broach sized, vibratorypolished, heat treated, plated and packaged. Wastes generated include: scrap metal, used oil;universal waste lamps, spent batteries, 0002 Hydrochloric Acid, DOOT Chromic Acid, D007Chromium/Nickel, D002/D007 Chromic/Nitric Acid and F006 Chrome Plating Sludge and filter cake:5K Hand Tool Corporation is a large quantity generator of hazardous waste.

We found the following violations of Ohio's hazardous waste laws. In order to correct theseviolations you must do the following and send me the required information within 30 days of yourreceipt of this letter

OAC Rule 3745-273-13(D)(1) , Storage of Universal Waste Lamps: A small quantityhandler of universal waste must contain any lamp in containers or packages that arestructurally sound, adequate to prevent breakage, and compatible with the contents of thelamps. Such containers and packages must remain closed and must lack evidence ofleakage, spillage, or damage that could cause leakage under reasonably foreseeableconditions.

5K Hand Tool Corporation failed to store universal waste metal halide lamps in a containeror package that is structurally sound, adequate to prevent breakage, and compatible with thecontents of the lamps.

19 -Printed on Recycled Paper Ohio EPA is an Equal Opportunity Employer

.

SPage 2

Mr. Bill ZirkleAugust 14, 2008

To abate this violation, SK Hand Tool Corporation must immediately place the metal halidelamps in a container or package that is structurally sound, adequate to prevent breakage,and compatible with the contents of the lamps. In accordance with OAC Rule 3745-273-14(E), the container or package must be labeled with the words 'Universal Waste Lamps","Waste Lamps", or "Used Lamps." 5K Hand Tool Corporation should photograph thecontainer or package and send a copy of the photograph to me.

2. OAC Rule 3745-65-52(D), Content of Contingency Plan - Emergency Coordinators: Acontingency plan must contain a current list of names, addresses and telephone numbers(office and home) of all persons qualified to act as emergency coordinator.

5K Hand Tool Corporation failed to maintain a current list of employees who are qualified toact as an emergency coordinator.

a- To abate this violation, 5K Hand Tool Corporation must update the facility contingency planJo include a current list of employees who are qualified to act as a facility emergency -coordinator- 5K Hand Tool Corporation should submit a copy of the current list ofemergency coordinators listed in the facility contingency plan to me. H

3. OAC Rule 3745-65-54, Maintenance of Contingency Plan: A contingency plan must berevised in response to rule changes, facility, equipment and personnel changes, or failure ofthe contingency plan.

The contingency plan reviewed during the inspection was last updated on August 4, 2000.Since that time facility personnel listed as emergency coordinators no longer work at thisfacility. Therefore, SK Hand Tool Corporation failed to revise the contingency plan tomaintain a current list of employees who are qualified to act as an emergency coordinator.

a- To abate this violation, 5K Hand Tool Corporation must update the facility contingency planto include a current list of employees who are qualified to act as a facility emergencycoordinator. 5K Hand Tool Corporation should submit a copy of the current list ofemergency coordinators listed in the facility contingency plan to me.

General Comments

During the inspection, we observed a former underground waste water treatment pit outside of thevibratory room. You stated that this pit is no longer used but does accumulate rain water from timeto time. The rainwater that collects in this pit is discharged to the City of Defiance public ownedtreatment works (POTW). Previously, the removal and disposal of waste sludge from this pit resultedin an enforcement action by this agency as the waste was not properly evaluated prior to disposal.Ohio EPA recommends that you properly close this pit to prevent the accumulation of additionalwaste.

.

Page 3

Mr. Bill ZirkleAugust 14, 2008

As we discussed during the inspection, you may be able to reduce the waste your companygenerates. If you find ways to recycle, reduce or eliminate the amount of waste that your companygenerates you may be able to reduce treatment and disposal costs as well as regulatoryrequirements.

The Ohio Department of Development's Office of Energy Efficiency may be able to help with energyefficiency issues. Their website is at: http://www.ododstate.oh.us/cdd/oee/

If you would like a free, non-regulatory on-site pollution prevention assessment or if you would likemore information about pollution prevention, please contact me at (419)373-3056. Ohio EPA hashelpful information about this at the following web address: http:/Iwww.epastate.oh.usiocapp/ocapp/

Enclosed you will find a copy of the checklists that we completed as a result of the inspection.Should you have any questions, please feel free to call me at (419)-373-3056. You can find copiesof the rules and other information on the divisions web page at: http:IIwviw.epa.state.oh.usldhwmL

Sincerely,

GaryCX?schmanEnvironmental Specialist IIINorthwest District OfficeDivision of Hazardous Waste Management

/csl

cc: Cindy Lohrbach, DHWM, NWDOColleen Weaver, DHWM, NWDOCSK:Handtool ! File, Defiance County,iDHWM,NWDO'

PC: Gary Deutschman, DHWM, NWDO

• S __Ohio Environmental Protection Agency For Ohio EPA use only

RCRA SUBTITLE C SITEIDENTIFICATIONNERIFICATION FORM

E-mail this completed form to kristina.durnelkepa.state.oh.usor mail it to Kristine Durnell, Central Office

Sl waste generated and/or accumula

:d U Large Quantity Handler

(accumulates 5,000 kg. or

d Oil Activities (Indicate Type(s) of)Used Oil Generator I0 Off-SpaUsed Oil Transporter I 0 Used 0

SUniversal Waste Activities (Indicate types of

Small Quantity Handler of Universal VE Destination Facility for Universal Wasi(Check all boxes below that apply for each

the three types of facilities above)Managei

Batteries 0

Pesticides D

Mercury containing 0

Waste Codes for Federally Regulated Hazardous Wastes. Please list the codes for the federally regulated hazardouswaste handled at the site. List them in the order they are presented in the regulations (e.g., DOOl, D003, F007, Ui 12). Usean additional page if more space is needed. If there are more than 7 waste codes and they are the same as listed in themost recent RCRAInfo source record, you do not need to list them all. Instead just indicate the date of the most recentsource record.

area was [.11

Other Comments:

Name oflnsoector(s) I Name oflnsoector(s)

OPTIONAL CERTIFICATION. I certify under penalty of law that this document and all attachments were prepared undermy direction or supervision in accordance with a system designed to assure that qualified personnel properly gather andevaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or thosepersons directly responsible for gathering the information, the information submitted is, to the best of my knowledge andbelief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information,

Signature of Owner, Operator, or an AuthorizedName and Title (Print) I Date

Revised May 2007

PROCESS, WASTE, P2 SUMMARY SHEET IFacility Name: Facility Type:çQc78GQICESQG/TSD Date of Inspection: EPA ID #: c4) o c4c )1fl3Sc

Waste Generated On- or Off-Site P2 ActivitiesManaoement

Process/Activity Generating Waste QTY Generated Type of On-Site Name, state, and Current P2 P2 OpportunitiesWaste Description per Month, Type of Treatment type of activity Activities(e.g. plating bath, machining. (e.g. sludge, solvent, Accumulation (recycle, wwt, etc) occurring at thebaghouse, painting, general ash, used oil, spent (container, tank, etc) and off-site facility.maintenance etc)

lamps, etc.) and EPA location of wasteWaste Code, if applic. accumulation area

Re Il

LCL

2 yHRAnt tV1 1 N c. /

0 ?y r" /\ ;)0c / hc

3 4,Lir

Oki

0i1U. L1c%A 5i

1/;fl):'J L/ ' '

N

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5 L.(\kJ,. ''

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PSS Table Format Handwritten Use,liinn 2007 Poe 1 of 2

6 roU-S

4-Y- ' ma-LA Ltsscc

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8

II

REMARKS-GENERAL INFORMATIONGeneral Process Information:

Regulatory/Enforcement History (if applicable):

.Additional P2 remarks and information:

Would this facility be interested in a P2 assessment? Yes ______ No_____*lf yes, refer promptly to your district P2 coordinator. Office of Compliance Assistance and Pollution Prevention - 1-800-329-7518 or p2mail(epa. state. on. us orwwwepa.state.oh.us/ocapø/ocapp.html

Other:

PSS Table Format Handwritten Use.Iiinn2007 Pann2nf2

LARVE QUANTITY GENERATOR REQUIREM114111lCOMPLETE AND ATTACH A PROCESS DESCRIPTION SUMMARY

CESOG: 100Kg. (Approximately 25-30 gallons) of waste in a calendar month or c 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 gallbns) of waste in a calendar month or ^t 1 Kg. of acutely hazardous waste in a calendar month.

NOTE: To convert from gallops to pounds: Amount in g allons x Specific Gravity x 8.345 = Amounts in pounds.Safety Equipment Used:GENERAL REQUIREMENTS

1. Have all wastes generated at the facility been adequately evaluated? [3745- Yes ly No Q N/A D52-11] 11%

2. Are records of waste determination being kept for at least 3 years? [3745-52- Yes No [I N/A 040(C)]

3. Has the generator obtained a U.S. EPA identification number? (3745-52-121 Yes t No 0, 04. Were annual reports filed with Ohio EPA on or before March 1') [3745-52- Yes No 0 N/A [__1

41(A)]5. Are annual reports kept on file for at least 3 years? [3745-52-40(B)] Yes % No 0 N/A 06. Has the generator transported or caused to be transported hazardous waste Yes 0 No K N/A 0

to other than a facility authorized to manage the hazardous waste? [ORC3734.02(F)]

7. es the generator disposed of hazardous waste on-site without a permit or Yes 0 No N/A 0Idt another facility other than a facility authorized to dispose of the hazardous -waste? [ORC 3734.02(E) & (F)1

8. Does the generator accumulate hazardous waste? Yes 3 No 0 N/A 0NOTE: 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. 1

Has the generator accumulated hazardous waste on-site in excess of 90 days Yes fl No N N/A 0without 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 D No 0 N/A

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

C. Drip pads that meet 3745-69-40 to 3745-69-45? Yes 0 No 0 N/A []

d. Containment -building that meets 3745-256-100 to 3745-256-102? Yes 0 No 0 N/A

NOTE., Complete appropriate checklist for each unitNOTE: If waste is treated to meet LOPs, use LOP checklist11. Does the generator export hazardous waste? If so: Yes 0 No N/A 0

a. Has the generator notified U.S. EPA of export activity? [3745-52- Yes 0 No 0 N/A53(A)]

b. Has the geneEator complied with special manifest requirements? Yes 0 No 0 N/A[3745-52-541

C. For manifests that have not been returned to the generator has an Yes 0 No 0 N/Aexception rert been filed? [3745-52-551

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

[Facility Name/Inspection Date][ID number]

LOG/June 2008Page 1 of

e. I Are export related docurñènts being

MANIFEST REQUIREMENTS12. 1Have all hazardous wastes shipped off-site been accompanied by a

manifest? (U.S. EPA Form 8700-22) [3745-52-20(A)]

Yes D No DN/A

Yes R No H N/A

13.

1Have items (1) through (20) of each manifest been completed? [3745-52- Yes 1 No 0 N/A Q20(A))

NOTE: U. S. EPA Form 8700-22(A) (the continuation form) may be needed in addition to Form 8700-22. In these

14. Does each manifest designate at least one facility which is permitted to Yes No 0 N/A Qhandle the waste? [V45-52-20(B)]

NOTE: The generator may designate on the manifest one alternate facility to handle the waste in the eventof an emergency which preGènts 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 E No fl N/A

designated facility diw"the generator designate an alternate TSD facility or - -give the transporter instructions to return the waste? [3745-52-20(D)]

16. Have the manifests keen signed by the generator and initial transporter? Yes ES No 0 N/A 0[3745-52-23(A)(1) & (2)j

NOTE: Remind $e 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 they

17. If the gen ,rator did not receive a return copy of each completed manifest I Yes 0 No 0 N/Awithin 35 days of the waste being accepted by the transporter did thegenerator contact the transporter and/or TSD facility to check on the status of

18. If the generator has not received the manifest within 45 days, did the Yes No 0 N/Agenerator 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 0 N/A Qfor at leasj.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 transfpr facility or have a permit because this is considered to be "off-site." For additional information see the definitionof "on1 ite" in OAC rule 3745-50-10.PERSONNEL TRAINING20. boes the generator have a training program which teaches facility personnel Yes No 0 N/A 0

hazardous waste management procedures (including contingency plan

21. Does the personnel training program, at a minimum, include instructions to Yes NJ No Lj NIA 0\nsure 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)? [3745-65-16(A)(3)(a-f)]

22. Is the pernnel training program directed by a person trained in hazardous Yes No 0 N/A 0waste mdTagement procedures? [3745-65-16(A)(2)]

23. JDo new employees receive training within six months after the date of hire (or Yes I1 iNo 0 N/A 0assignment to a new position)? [3745-65-16(8)]

24. ,,Does the generator provide annual refresher training to employees? [3745- Yes N NO 0 N/A 0

Job titles? [37456516D(1)] I Yes 91 No 0 N/A

Yes N No 0 N/A 0(Facility Name/Inspection Date)

[ID number]LQG/June 2008

Page 2 of 6

Type and amount of tralWg given to each person? 13745-65-1613(30 Yes V No fl N/A El

d. Completed training or job experience required? [3745-65-16D(4)] Yes S No fl N/A D

26. Are training records for current personnel kept until closure of the facility and Yes NJ No fl 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)J

NOTE: The following sectioVi 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 a' Name of Em ployee Date Trained

- ?oLvA \&1I.-..

-€ I-lU) 9-i ak. c/ -)o7

IRS \Ftvj.ur Vcy.a ¶rI QcflCONTINGENCY PLAN u27. Does the owner/opertor have a contingency plan to minimize hazards to Yes N No fl N/A El

human 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 fires, explosions or any unplanned Yes J No ElI, N/A El

release of hazrdous waste? [3745-65-52(A)]b. Arrangements with emergency authorities? [3745-65-52(C)] Yes N No LI N/A

C. A current list bVi names, addresses and telephone numbers (office and Yes 0 No N N/A 0home) of all persons qualified to act as emergency coordinator?[3745-65-52(9)]

d. A list of all emergency equipment, including: location, a physical Yes IN No 0 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 X1 No El N/A 0evacuation my be necessary? [3745-65-52(F)]

NOTE: If the facility already has a "Spill Prevention, Control and Countermeasures Plan" under CFR Part 112 or 40 CFRPart 1510, or some other emergency plan, the facility can amend that plan to incorporate hazardous waste managementprovisions that are sufficient to comply with 01cC requirements. [3745-65-52(8)]29. tv a copy of the plan (plus revisions) kept on-site and been given to all Yes 6Q No 0 N/A fl

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 0 No 9 N/A fl

Ti-_ equipment and personnel changes, or failure of the plan? [3745-65-54]3. .! an emergency coordinator available at all times (on-site or on-call)? [3745- Yes Ej No D N/A

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 allrecordtwithin the facility; (e) facility layout; and (f) shall have the authority to commit the resources needed to implementprovisions of the contingency plan.EMERdNCY PROCEDURES32. Ps there been a fire, explosion or release of hazardous waste or hazardous Yes Q No N/A 0

waste constituents since the last inspection? If so:Was the contingency plan implemented? [3745-65-51(B)] Yes 0 No 0 N/A IN

b. Did the facility follow the emergency procedures in 3745-65-56(A) Yes No 0 N/Ai( through (H)?

[Facility Name/Inspection Date][ID number]

LQG/June 2008Page 3 of 6

C. Did the facilitpsubmit a report to the Director within 15 days of the Yes Q 'No D N/A

incident as required by 3745-65-56(J)?

NOTE: OAC 3745-65-51(b7requires that the contingency plan be implemented immediately whenever there is a fire,explosion, or release of hazardous waste or hazardous waste constituents, which could threaten human health and theenvironment.PREPAREDNESS AND PREVENTION33. Is the facility operated to minimize the possibility of fire, explosion, or any Yes N iNo 0 N/A 0

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 tjj No 0 N/A Db. Emergency communication device? [3745-65-32(B)l Yes No 0 N/A 0C. Portable fire control, spill control and decon equipment? [3745-65- Yes No 0 N/A 032(C)]

d. Water of adeqUate volume/pressure per documentation or facility rep? Yes 59 No 0 N/A 0[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 L No 0 -. N/A 0

operation in time of ethergency? [3745-65-33]36. Are emergency equipment tests (inspections) recorded in a log or summary? Yes M No 0 N/A 0

[3745-65-33]37. Do personnel have immediate access to an internal alarm or emergency Yes Ij No N/A 9

communicttion 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 No 9 I N/A 0device (eg.,phone, hind held two-way radio) capable of summoning externalemergency assistance (unless not required under 3745-65-32)? [3745-65-34(B)] 11C

39. Is adequate aisle space provided for unobstructed movement of emergency Yes SQ No 9 N/A 0or spill control equipment? [3745-65-35]

40, Has the generator attempted to familiarize emergency authorities with Yes EK No 0 N/A 0possible hazards and facility layouts? [3745-65-37(A)]

41. Where authorities hre declined to enter into arrangements or agreements, Yes 0 No 9 'N/Ahas the generator documented such a refusal? [3745-65-37(B)]

SATELLITE ACUMUTILAON AREA REQUIREMENTS42. Does the bnerator ensure that satellite accumulation area(s):

a. Are at or near a point of generation? [3745-52-34(C)(1)] Yes 0 No 9 N/A

b. Are under the control of the operator of the process generating the Yes 0 No 0 N/Awaste? [3745-52-34(C)(1)]

C. Do not exceed a total of 55 gallons of hazardous waste per waste Yes 0 No 0 N/Astream? [3745-52-34(C)(1)]

d. Do not exceed one quart of acutely hazardous waste at any one time? Yes 0 No 9 N/A 1[3755-52-34(C)(1)]

e. Containers are closed, in good condition and compatible with wastes Yes 0 No 9 N/Astored in them? [3745-52-34(C)(1)(a)J

I Containers are marked with words "Hazardous Waste" or other words Yes 0 No 0 ' N/A 13identifying the contents? [3745-52-34(C)(1)(b)]

43. is the generator accumulating hazardous waste(s) in excess of the amounts Yes fl No 0 N/Alisted in the preceding question? If so:

[Facility Name/Inspection Date][ID number]

LOG/June 2008Page 4 of 6

a. Did the generator corn th 3745-52-34(A)(1) through (4) 01 othe Yes D No E N/Aapplicable geërator requirements within three days? [3745-52-34(C)(2)]

b. Did the gene9tor mark the container(s) holding excess with the Yes 0 No N/Aaccumulation date when the 55 gallon (one quart) limit wasexceeded?[3745-52-34(C)(2)]

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 AREAS

44. Has the generator marked containers with the words "Hazardous Waste?" Yes 29 No El N/A 0[3745-52-34(A)(3)]

45. Is the accumulation date on each container? [3745-52-34(A)(2)] Yes M No C N/A 0

46. Are hazardous wastes stored in containers which are:a. Closed (except when adding/removing wastes)? [3745-66-73(A)] Yes R No 0 N/A 0

b. In good condition? [3745-66-71] Yes No El N/A 0

C. Compatible with wastes stored in them? [3745-66-72] Yes MU No 0 N/A 0

d. Handled in a manner which prevents rupture/leakage? [3745-66-73(8)] Yes No E] 0

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 A No 0 N/A 0

ORC1.44(A) "Week" means 7 consecutive days.a. Are inspections recorded in a log or summary? [3745-66-74] Yes PK No 0 N/A 0

48. Are containers of ignitable or reactive wastes located at least 50 feet (15 Yes 5k No 9 N/A 9meters) from the facility's property line? [3745-66-76]

49. Are containers of incompatible wastes stored separately from each other by Yes No 9 N/A 0means of a dike, berm, wall or other device? [3745-66-77(C)]

50. If the generator places incompatible wastes, or incompatible wastes and Yes 9 No LI N/Amaterials in the same container, is it done in accordance with 3745-65-17(B)?[3745-66-77(A)]

51. If the generator places hazardous waste in an unwashed container that Yes 0 No 0 N/Apreviously held an incompatible waste, is it done in accordance with 3745-65-17(B)? [3745-66-77(B)]

NOTE: OAC 3745-65-17(8) 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 environment

52. If the generator has closed a <90 day accumulation area does the closure Yes 0 - No 9 N/Aappear 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 OAC 3745-66-97 (except for para graph C of this rule). (3745-52-34)PRE-TRANSPORT REQUIREMENTS53. 1 Does the generator package/label its hazardous waste in accordance with the Yes hU No 9 N/A 0

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

[Facility Name/Inspection Date][ID number]

LOG/June 2008Page 5 of 6

54. 1 'Does each container <110 gallons have a completed hazardous[3745-52-32(B)]

55. • efore off-site transportation, does the generator placard or offerappropriate DOT placards to the initial transporter? [3745-52-33]

Yes SJ No El NIA U

Yes jJ No U! NIA

I"a

V

-fr

'P

)

'C

'V

fttø

p

)4

[Facility Name/Inspection Date][ID number]

LQG/June 2008Page 6 of 6

TIERIES AND LAMPS

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

PROHIBITIONS

1. Did the SQIJWH dispose of universal waste? [3745-273-11(A)]

2. Did the SQUWH dilute or treat universal waste,except when responding to releases as provided in3745-273-17 or managing specific wastes asprovided in 3745-273-13? [3745-273-11(B)]

Yes U NoK N/A RMK#

Yes U No'>: N/A _RMK#

WASTE MANAGEMENT & LABELING/MARKING

UNIVERSAL WASTE BATTERIES

3. Are battery(ies) that show evidence of leakage,spillage or damage that could cause leakscontained? [3745-273-13(A)(1)]

Yes _NoD N/A)LRMK#

N/A XRMK#4. If batteries are contained, are the containers closed Yes - No Uand structurally sound, compatible with the contentsof the battery and lack evidence of leakage, spillageor damage that could cause leakage? [3745-273-1 3(A)(1)]

5. Does the SQUWH conduct any of the followingactivities:

a.

b.

C.

d.

e.

f.

9.

Sort batteries by type?

Mix battery types in one container?

Discharge batteries to remove the electriccharge?

Regenerated used batteries?

Remove batteries from consumer products?

Remove the electrolyte from the battery?

Yes_ No_ N/A'RMK#

Yes_ No_ N/A'L..RMK#

Yes_ No_ N/A .ILRMK#

Yes No N/A LRMK#

Yes No N/A )LRMK#

Yes_ No_ N/A LRMK#

Yes No N/A RMK#

Disassemble them into individual batteries orcells?

.If so, are the casings of the batteries breached, notintact, or open (except to remove the electrolyte)?[3745-273-13(A)(2)]

If the electrolyte is removed or other wastegenerated, has it been determined whether it is ahazardous waste? [3745-273-13(A)(3)]

If the electrolyte or other waste is characteristic,is it managed in compliance with 3745-50 through3745-69? [3745-273-1 3(A)(3)(a)]

If the electrolyte or other waste is not hazardous,is it managed in compliance with applicable law?[3745-273-1 3(A)(3)(b)]

Are the battery(ies) of container(s) of batterieslabeled with the words "Universal Waste - Batteries"or "Waste Battery(ies)" or "Used Battery(ies)?"[3745-273-14(A)]

Yes U No_ N/ALRMK#

Yes -No U N/A RMK#

Yes — No D N/Aj...RMK#

Yes -No U N/A .LRMK#

Yes -No U N/A )RMK#

UNIVERSAL WASTE LAMPS

8. Does the SQGUHW contain lamps in containers orpackages that are structurally sound, adequate toprevent breakage, and are compatible with contentsof the lamps? Are containers or packages closedand do they lack evidence of leakage, spillage ordamage that could cause leakage? [3745-273-1 3(D)(1)]

9. Are lamps that show evidence of breakage, leakageor damage that could cause a release of mercury orhazardous constituents into the environmentimmediately cleaned up? Are they placed into acontainer that is closed, structurally sound,compatible with the contents of the lamps, and lackevidence of leakage spillage or damage that couldcause leakage or releases of mercury or hazardouswaste constituents to the environment? [3745-273-1 3(D)(2)]

10. Are the lamps or containers or packages of lampslabeled with the words "Universal Waste - Lamp(s)"or "Waste Lamp(s)" or "Used Lamp(s)?" [3745-273-14(E)]

Yes_No'N/A_RMK# /

Yes _NoD N/AXRMK#

Yes NoU N/A_RMK# /

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER INSPECTION CHECKLISTPage 2 of 5

UWR.SQG.11.2004

. I

NOTE: Treatment (such as crushing) by a UWH is prohibited under this rule unless the facility ispermitted for such activities [3745-273-31(B)]. A generator crushing lamps must managelamps according to hazardous waste rules (OAC Chapter 3745-52). Lamp crushing is a form ofgenerator treatment (OAC 3745-52-34). Crushed lamps must be transported by a registeredhazardous waste transporter to a permitted hazardous waste facility under a hazardous wastemanifest.

ACCUMULATION TIME

11 Is the waste accumulated for less than one year?[3745-273-15(A)] If not:

a. Was the waste accumulated over one year inorder to facilitate proper recovery, treatment ordisposal? (Burden of proof is on the handler todemonstrate) [3745-273-15(8)]

Yes No_ N/A RMK#

Yes - No U N/A RMK#

NOTE:

Accumulation is defined as date generated or date received from another handler.

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER INSPECTION CHECKLISTPage 3 of 5

UWR.SQG.11.2004

.12. Is the length of time the universal waste is stored

documented by one of the following: [3745-273-15(C)]

il)a No I] N/A RMK#

a. Marking or labeling the container with the earliestdate when the universal waste became a wasteor was received? [3745-273-15(C)(1)]

b. Marking or labeling individual item(s) of universalwaste with the earliest date that it became awaste or was received? [3745-273-15(C)(2)]

c. Maintaining an inventory system on-site thatidentifies the date the universal waste became awaste or was received? [3745-273-15(C)(3)]

Yes No_ N/A RMK#

Yes_ No-)ON/A RMK#

Yes_ No-)qN/A RMK#

Maintaining an inventory system on-site that Yes_ No1 N/A RMK#identifies the earliest date that any universalwaste in a group of universal waste items or agroup of containers became a universal waste orwas received? [3745-273-15(C)(4)]

YesN No N/A _RMK#e. Placing the universal waste in a specificaccumulation area and identifying the earlieststart date or date received? [3745-273-15(C)(5)]

Any other method, which clearly demonstrates,the length of time the universal waste has beenaccumulated from the date it became a waste orwas received? [3745-273-15(C)(6)]

EMPLOYEE TRAINING

Yes No_ N/A _RMK#

13. Are employees who handle or have the responsibility Yes .24 No 13 N/A _RMK#for managing universal waste informed of wastehandling/emergency procedures, relative to theirresponsibilities? [3745-273-16]

RESPONSE TO RELEASES

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER INSPECTION CHECKLISTPage 4 of 5

UWRSQG.11.2004

14: Are releases of univers aste and other residues YSN0D N/ARMK#immediately contained? [3745-273-17(A)]

15. Is the material released characterized? [3745-273- Yes - No U N/A ..M$MK#17(B)]

16. If the material released is a hazardous waste, is it Yes -No 0 N/Amanaged as required in OAC Chapters 3745-50through 3745-69? (If the waste is hazardous, thehandler is considered the generator of the waste andis subject to Chapter 3745-52) [3745-273-17 (B)1

OFF-SITE SHIPMENTS

NOTE: If a SQUWH self-transports waste, then they must comply with the Universal Wastetransporter requirements.

17. Are universal wastes sent to either another handler, Yes No 0 N/A RMK#destination facility or foreign destination? [3745-273-18(A)]

NOTE: SQUWHs are prohibited to send waste to any other facility.

18. If the universal waste meets the definition of Yes No 0 N/A _RMK#hazardous material under 49 CFR 171-180, are DOTrequirements met with regard to package, labels,placards and shipping papers? [3745-273-18(C)]

19. Prior to shipping universal waste off-site, does the Yes2K0 No U N/A _RMK#receiver agree to receive the shipment? [3745-273-18(D)]

20. If the universal waste shipped off-site is rejected byanother handler or destination facility does theoriginating handler do one of the following:

a. Receive the waste back? [3745-273-18(E)(1)] Yes_ No_ N/A RMK#

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER INSPECTION CHECKLISTPage 5 of 5

UWR.SQG.11.2004

.b. Agree to where the shipment will be sent? [3745-

273-1 8(E)(2)]

If a handler rejects a partial or full load from another

21. handler, does the receiving handler contact theoriginating handler and discuss one of the following:

a. Sending the waste back to the originatinghandler? [3745-273-18(F)(1)]

b. Sending the shipment to a destination facility? (Ifboth the originating and receiving handler agree)[3745-273-18(F)(2))

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

23. If the handler received a shipment of nonhazardous,non-universal waste, was the waste managed inaccordance with applicable law? [3745-273-18(H)]

EXPORTS

24. Is waste being sent to a foreign destination? If so:

a. Does the small quantity handler comply withprimary exporter requirements in OAC 3745-52-53, 3745-52-56, and 3745-52-57? [3745-273-20(A)]

b. Is waste exported only upon consent of thereceiving country and in conformance with U.S.EPA's "Acknowledgment of Consent" as definedin 3745-52-50 to -52-57? [3745-273-20(B)]

Yes No_ N/A

Yes _NoD N/AgRMK#

Yes_ No N/A@RMK#

Yes_ No_ N/A IIRMK#

Yes No U N/ARMK#

Yes NoD N/A\RMK#

Yes-No-'Y N/A RMK#

Yes -No U N/A YRMK#

Yes _NoD N/A X RMK#

Yes - No U N/A .RMK#c. Is a copy of U.S. EPA's Acknowledgment ofConsent" provided to the transporter? [3745-273-20(C)]

REMARKS*1 - " loL.e5 loib.t' 0_ft4rJOQ'rd

n-€)-&\ \olt

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER INSPECTION CHECKLISTPage 6of5

UWR.SQG.11.2004

to1jD$ oe a 5 k "°Jovie )CPpo'y

"USED OIL INSPECTION CHECKLIST WGENERATORS, 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 a total underground storage capacitygreater than 42,000 gallons of oil (including used oil), and there is reasonable expectation of a discharge to navigablewaters.

Yes D No K N/A

Yes D No 0 N/A

Yes fl No X N/A LI

Yes H No flN/A171

1. Does the generator manage used oil in a surface impoundment or waste piIf 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 pile.2. Is used oil used as a dust suppressant? [3745-279-12(B)]

3. Is off-specification used oil fuel burned for energy recovery in devices specin 3745-279-12(C?

NOTE: Multiple used oil checklists may be applicable if used oil handler is performing multiple tasks (e.g., If genera titused 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 El No VJ N/A LI

a. Is the mixture managed as specified in 3745-279-10(6)? [3745-279- Yes 0 No fl N/A21(A)]

NOTE: Used Oil mixed with listed (3745-51-30 to 3745-51-35) or characteristic (3745-51-20 to 3745-51-24) hazardou.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 LI No 0 N/A

halogens manage the used oil as a hazardous waste unless the presumptionis rebutted successfull y? F3745-279-21(B)1

NOTE: If used oil contains greater than 1000 ppm total halogens ) it is presumed tcpresumption is successfully rebutted.6. Does the generator store used oil in tanks; or containers; or a unit(s) subject to

regulation as a hazardous waste management unit? [3745-279-22(A)1T Are containers and aboveground tanks used to store used oil in good condition

with no visible leaks? [3745-279-22(B)]8. Are containers, above ground tanks, and fill pipes used for underground tanks

clearly labeled or marked 'Used Oil?" [3745-279-22(C)]9. Has the generator, upon detection of a release of used oil, done the following:

hazardous waste until the

Yes No 0 N/A 0

Yes X1 No 0 N/A 0

Yes tZ No 0 N/A LI

Yes LI No 0 N/A -[3745-279-22(D)]a. Stopped the release?

b. Contained the release?

C. Cleaned up and proper

d. I

Repaired or replaced the containers or tanks prior toservice, if necessary?

10. Does the generator burn used oil in used-oil fired space heaters? [3745-27923] If so:a. Does the heater burn only used oil that owner/operator generates or

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

Yes H No H N/A

Yes 0 No 0 N/A

Yes 0 No Li N/A

to Yes LI No 0 N/A

- Yes H No H N/A

[Facility Name/Inspection Date][ID Number)

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 ID#?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]a, Does the generator transport used oil in a vehicle owned by the

generator or an employee of the generator?[3745-279-24]b. Does the generator transport more than 55 gallons of used oil at any

time?[3745-279-24]NOTE: Used oil generators may arrange for used oil to be transported by a tran,used oil is reclaimed under a contractual agreement (i.e., tolling arrangement).COLLECTION CENTERS AND AGGREGATION POINTS13. Is the DIV used oil collection center in compliance with the 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 EPA? [3745-271

31]15. Is the used oil aggregation point in compliance with the generator standards i

3745-279-20 to 3745-279-24? [3745-279-32]NOTE: Complete Used Oil Generator and any other applicable used oil handler chiused oil collection centers and aqorecation noints.

Yes 0 No 0 N/A

Yes 0 No 0 N/A

Yes No ON/A UYes U No O . N/A '

Yes U No 0 N/A ,J

Yes U No 0 N/A

er without a U.S. EPA ID it

Yes U No 0 N/A

Yes U No U N/A

Yes 0 No U N/A

[Facility Name/inspection Date][ID Number]

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

CHECKLISTDOES NOT

GENERAL REQUIREMENTS1. If LDRs do not apply, does the generator have a statement that lists how Yes 0 No U N/A

the HW was generated, why LDRs don't apply and where the HW went?[3745-270-07 (A)(7)]

2. Did the generator determine if the HW/soil must be treated to meet the LDR YesNo U N/A 0treatment standard prior to disposal? Generator knowledge or testing may

NOTE: This is done by determining if the HW/soil contains levels of constituents greater than the levels given in itsLDR treatment standard in 3745-270-40. However, ifa specific treatment method is given in 3745-270-40 for theHIM!, no determination is required (3745-270-07 (A)(1)(b)j If soil, generator can choose to have soil treated to LDRlevels given in 3745-270-49 (alternative treatment levels for soils).3. Does the generator have documentation of how he determined whether the Yes No U N/A fl

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

4. Does the generator keep the documentation required in #2, above, on-site Yes No Q N/A 0for at least three years from the last date the HW/soil was sent on-site/off-

generator generate a listed HW that exhibits a characteristic? If I Yes t9l No El N/A 0yes, ___________________________a- Did the generator determine if the listed HW exhibits a characteristic Yes U No N/A

that is not treated under the LDR treatment standard for the listedHW? 13745-270-09(A) ___________________________

FOR EXAMPLE: F006 that exhibits the characteristic for silver or K062 that is corrosive, D002. Review LDRtreatment standard in 3745-270-40 to determine what constituents the listed HW is treated for.6. Did the generator determine if its characteristic HW contains underlying Yes R No U N/A

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 HW at levels above theuniversal treatment standards given in 3745-270-48. This requirement does not apply to high total organic carbon(i.e., contains >10% TOC) DOOl wastes or listed HW5.NOTE: Written documentation of this determination is not required.7. Did the generator treat his HW /soil on-site to meet the LDR treatment Yes U No N/A 0

standard?

If fl'es"see question #16.Did the generator send a one-time LDR notification form to the TSD withthe first shipment to that facility?[3745-270-07(A)(2)]Did the generator resubmit the LDR notification form to the TSD when theHW changed or the generator used a new TSD? [3745-270-07(A)(2)]Does the generator have a copy of the LDR notification form on file?[3745

Does the LDR Notification form contain the following information:a. I Manifest number of the first waste shipment to the TSD?r

b. Applicable waste codes (includes characteristic codes for a listedHW if applicable)? [3745-270-07(A)(2)]

C. A statement that conveys that the HW is subject to LDRs and mustbe treated to meet LDR treatment requirements? [3745-270-

Yes

Yes

Yes

No 0 N/A UNo LI N/A UNo U N/A UNo U N/A 0

Yes No U N/A UYes No U N/A UYesNo U N/A 0

a. Is the form kept on file for three years after last HW shipped? [3745- Yes270-07(A)(8)]

NOTIFICATION FORM

a wastewater or Yes No 0 N/A 0Generator LDR checklist

(Facility Narnellnspection Date)[ID Number]

May 2006Page 1 of 3

NOTE: A wastewater contains <1% by wt. total suspended solids(TSS) and <1% by wt. TOC If you doubt the HWisa wastewater or non-wastewater, the HW can be tested using for example, Standard Methods (SM) 160.2 for TSS,SW-846 method 9060a for TOC.

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

NOTE: Subcategories are found on the LDR treatment standards table under the applicable waste code. Not allHWs have subcategories

f. A listing of the underlying hazardous constituents for which a Yes No D N/A Dcharacteristic waste must be treated? [3745-270-07(A)(2)1

NOTE: Not required if the waste is high TOO 0001 or the TSD tests its treatment residues for all underlyinghazardous constituents.

If the HW is F001-F005 or F039, did the generator note on the LDR Yes 0 No 0 N/A 1iform what solvents or constituents, respectively, the waste containsg. s

and _must _be_ treated _for?[3745-270-07(A)(2)]NOTE: Not required if the TS0 tests its treatment residues for all underlying hazardous constituents.PROHIBITED DILUTION

12. Is the HW treated by burning? Yes 0 No ' N/A 0If "No," goto#15.

13. Is the HW a metal-bearing HW? Yes 0 No Ej N/A

NOTE: Generally, metal-bearing HWs contain heavy metals above TCLP levels or were listed due to the presence ofmetals. A list of the restricted metal-bearing HWs are given in the Appendix to 3745-270-03.

14. a. Metal-bearing HWs cannot be incinerated, combusted or, blendedand burned for fuel unless one of the following conditions apply.[3745-270-03(c)]i. Contains> 1% TOC? Yes 0 No N/A

ii. Contains organic constituents or cyanide at levels greater Yes 0 No 0 N/Athan the UST levels?

iii. Is made up of combustible material e.g., paper, wood, Yes fl No 0 N/Aplastic?

iv. Has a reasonable heating value (e.g., > 5000 Btu)? Yes 0 No 0 N/A 11N

V. Co-generated with a HW that must be combusted? Yes 0 No N/A

b. If all responses to 14 a.i. through 14 am. are "No", HW is being Yes 0 No 0 N/Aimproperly treated by dilution, violation of 3745-270-03(C). Is NWbeing treated by dilution?

15. Was the NW treated by wastewater treatment? Yes 0 No 'J N/A 0a. Is a LDR treatment method, other than DEACT or a numerical value. Yes 0 No 0 N/A VJ

specified for the waste? (3745-270-03(6) and 3745-270-40(A)(3)]

NOTE: If Yes, HIM is improperly being treated by dilution.b. Does the waste carry the 0001 code and contain 10% TOC? Yes 0 No 'fZj N/A 0C. Does the wastewater treatment process include a process to Yes 0 No 0 N/A

separate/recover the organic phase of the waste?

NOTE: If the answers to b & c are 'yes "and 'w " respectively, waste is improperly being treated by dilution andgenerator is in violation of (3745-270-03(8) and 3745-270-40(A)(3)1.NOTE: A list of separation/recovery processes are given in 3745-270-42 under RORG.

Generator LOS Checklist{Facility Name/Inspection Date}

[ID Number]May 2008

Page 2 of 3

GENERATOR TREATMENT NW 1W

16. Does the generator treat to meet LDR5 on-site [3745-270-40(A)]? Yes No N/A E

Did the generator treat his hazardous waste/soil on-site in a tank! container, Yes fl No N/A Qdrip pad or containment building to meet the LDR treatment standard?If "Yes"...complete the rest of the checklist. If No"...stop ... you are done.a. Does the generator have a written waste analysis plan (WAP) that Yes 0 No 0 N/A

describes the procedures he will follow to treat the HW/soil to theLDR treatment standard? [3745-270-07(A)(5)]

b. Did the generator use a detailed chemical and physical analysis of Yes LI No J NIAthe 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 the 11W/soil Yes Q No fl N/A

to the LDR treatment standard? (3745-270-07(A)(5)(a)]d. Does the WAP include the testing frequency of the treated 11W/soil Yes No 0 N/A

to demonstrate that the LDR treatment standard is being met?[3745-270-07(A)(5)(a)]

e. Does the generator keep the WAP on-site? [3745-270-07(A)(5)(b)] Yes No 0 N/A m

f. Is the WAP available for the inspectors review during the Yes 0 No 0 N/Ainspection? (3745-270-07(A)(5)(b)]

NOTIFICATION FORM17. a. Contains all information in #11 a-g above and Yes No fl NIA 0

b. If the treated 11W/soil is listed ..... notification contains the following Yes No fl N/A LIcertification statement:

"I certify under penalty of law that I personally have examined andam familiar with the waste, through analysis and testing or troughknowledge of the waste, to support this certification that the wastecomplies with the treatment stands specified in rule 3745-270-40 to3745-270-49 of the Administrative Code. I am aware that there aresignificant penalties for submitting a false certification, including thepossibility of fine and imprisonment."

C. If the treated HW/soil no longer exhibits a characteristic and is nolonger a 11W, did the generator:1. Send a one-time notification to the director?[3745-270- 09 Yes LI No 0 N/A

(D)]ii. Maintain a copy of the notice onsite?[3745-270-09(D)] Yes 0 No Li N/A

Di. Include in the notification: [3745-270-09(D)(1)(a)]1. Name & address of receiving landfill? Yes J No 0 N/A

2. Description of 11W when generated? Yes Q No 0 N/A

3. 11W code when generated? Yes No fl N/A

4. Treatability group when generated? Yes fl No U N/A cr

5. Underlying hazardous constituents present when Yes Li No 0 N/Agenerated?

iv. Contain the right certification statement as required by Yes 0 No 0 N/A3745-70-07(b)(4)?

Generator LDR checklist(Facility Name/Inspection Date)

[ID Number]May 2008

Page 3 of 3