LQG# LQG_Citation SQG# SQG_Citation SQG / LQG CITA
Recomendation
A1 Did not register as a hazardous waste A1 Did not register as a hazardous waste Complete a Notificatio
generator. Section 260.380.1(1), generator. Section 260.380.1(1), form indicate that a ch
RSMo, and 10 CSR 25-5.262(2)(A). RSMo, and 10 CSR 25-5.262(2)(A). with the needed check
Resources, Hazardous
Jefferson City, MO 65
the form. Section 260
A2 <company> did not determine if its A2 <company> did not determine if its Ensure that all waste t
waste was hazardous. 10 CSR 25- waste was hazardous. 10 CSR 25- hazardous. <company
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR generates the waste. I
262.11. 262.11. waste characterization
uses process knowledg
determined whether or
waste codes apply, if a
A3 <company> did not use a licensed A3 <company> did not use a licensed Make arrangements to
hazardous waste transporter. Section hazardous waste transporter. Section shipments of hazardou
260.380.1(5), RSMo. 260.380.1(5), RSMo. provide a written, sign
transporter for all futu
this statement, please i
taken to ensure that a l
shipments. Section 26
A4 <company> did not use an authorized A4 <company> did not use an Change procedures to
hazardous waste treatment, storage, or authorized hazardous waste authorized hazardous w
disposal facility or an authorized treatment, storage, or disposal facility. In your respo
resource recovery facility. Section facility or an authorized resource <company> will ship h
260.380.1(7), RSMo. recovery facility. Section storage or disposal fac
260.380.1(7), RSMo. please include a descri
hazardous waste will b
RSMo.
A5 <company> operated as a hazardous A5 <company> operated as a hazardous Stop treating, storing o
waste treatment,storage or disposal waste treatment,storage or disposal facility permit from th
facility without having a permit. facility without having a permit. this inspection, provid
Section 260.390.1(1), RSMo. Section 260.390.1(1), RSMo. or dispose of hazardou
Along with this statem
will be taken to ensure
site. Section 260.390.
1
ATION GUIDE
Violation Citation
Type
on of Regulated Waste Activity form. The instructions for the XXS 260.380.1(1) RSMo
heck for $100 must accompany the form. The completed form,
k, should be mailed to the Missouri Department of Natural
s Waste Program, Budget and Planning Section, P.O. Box 176,
5102-0176. In your response to this inspection, provide a copy of
0.380.1(1), RSMo, and 10 CSR 25-5.262(2)(A).
that <company> generates is characterized to determine if it is 262A 5.262inc. 40-262.11
y> may do so by testing or through knowledge of the process that
In your response to this inspection, provide a description of the
n, including a list of the waste codes that apply. If <company>
ge to characterize the waste, please describe in detail how it was
r not the waste is hazardous and how it was determined what
any. 10 CSR 25-5.262(1), incorporating 40 CFR 262.11.
o use a licensed hazardous waste transporter for all future XXS 260.380.1(5) RSMo
260.380.1(7) RSMo
us waste from the property. In your response to this inspection,
ned statement that <company> will use a licensed hazardous waste
ure shipments of hazardous waste from the property. Along with
include a description of the actions that have been or will be
licensed hazardous waste transporter will be used for all
60.380.1(5), RSMo.
ensure that <company> will ship hazardous waste only to an XXS
waste treatment, storage or disposal facility or resource recovery
onse to this inspection, provide a written, signed statement that
hazardous waste only to an authorized hazardous waste treatment,
cility or resource recovery facility. Along with this statement,
iption of the actions that have been or will be taken to ensure that
be sent only to authorized facilities. Section 260.380.1(7),
or disposing of hazardous waste unless <company> obtains a XXS 260.390.1(1) RSMo
he department's Hazardous Waste Program. In your response to
de a written, signed statement that <company> will not treat, store
us waste at its facility without first obtaining a facility permit.
ment, please include a description of the actions that have been or
e that hazardous waste will not be treated, stored or disposed on-
.1(1), RSMo.
1
LQG# LQG_Citation SQG# SQG_Citation Recomendation
A6 <company> did not update its A6 <company> did not update its Complete an updated N
notification as required. 10 CSR 25- notification as required. 10 CSR 25- form should be mailed
5.262(2)3.B. 5.262(2)3.B. Waste Program, Budg
65102-0176. 10 CSR
A7 <company> accumulated materials A7 <company> accumulated materials Ship speculatively acc
speculatively. 10 CSR 25-4.261, speculatively. 10 CSR 25-4.261, storage, or disposal fac
incorporating 40 CFR 261.1(c)(8). incorporating 40 CFR 261.1(c)(8). 40 CFR 261.1(c)(8).
A8 <company> could not demonstrate A8 <company> could not demonstrate Be able to demonstrate
legitimate recycling. 10 CSR 25-4.261, legitimate recycling. 10 CSR 25- known market or dispo
incorporating 40 CFR 261.2(f). 4.261, incorporating 40 CFR that <company> believ
261.2(f). CFR 261.2(f).
B1 <company> stored hazardous waste for Ship all hazardous was
more than 90 days. 10 CSR 25- <company>'s procedu
5.262(1), incorporating 40 CFR In your response to thi
262.34(a). ship the hazardous wa
disposal facility. Also
stored, documenting th
store hazardous waste
regulations. 10 CSR 2
B10 Run-on onto the containment system Prevent run-on onto th
was not prevented and excess capacity ensure excess containm
was not provided. 10 CSR 25- system. 10 CSR 25-5.
5.262(2)(C)2.D(III)(c).
Remove liquids that ac
B11 Accumulated liquids were not removed 5.262(2)(C)2.D(III)(e)
to prevent overflow of containment. 10
CSR 25-5.262(2)(C)2.D(III)(e).
B12 Containers of ignitable or reactive B6 Containers of ignitable or reactive Store ignitable and rea
waste were stored less than 50 feet waste were stored less than 50 feet 25-5.262(2)(C)6, refer
from the property line. 10 CSR 25- from the property line. 10 CSR 25- 7.265(2)(I)7&8.
5.262(2)(C)6, referencing 40 CFR 5.262(2)(C)6, referencing 40 CFR
265.176, as amended by 10 CSR 25- 265.176, as amended by 10 CSR 25-
7.265(2)(I)7&8. 7.265(2)(I)7&8.
B13 Hazardous waste containers were not B10 Hazardous waste containers were not Clearly mark containe
clearly marked as 'Hazardous Waste.' clearly marked as 'Hazardous Waste.'
10 CSR 25-5.262(1), incorporating 40 10 CSR 25-5.262(1), incorporating
CFR 262.34(a)(3). 40 CFR 262.34(d)(4), referencing 40
CFR 262.34(a)(3).
2
Violation Citation
Type
Notification of Regulated Waste Activity form. The completed XXS 5.262(2)3.B
d to the Missouri Department of Natural Resources, Hazardous
get and Planning Section, P.O. Box 176, Jefferson City, Missouri
25-5.262(2)3.B.
cumulated materials to an authorized hazardous waste treatment, 261A 4.261inc. 40-261.1(c)(8)
cility or a legitimate recycler. 10 CSR 25-4.261, incorporating
e that materials that are believed to be recyclable actually have a 261A 4.261inc. 40-261.2(f)
osition and that they meet the terms of the exclusion or exemption
ves apply to the materials. 10 CSR 25-4.261, incorporating 40
ste that has been stored for more than 90 days. Change 262C 5.262inc. 40-262.34(a)
ures to ensure that waste is not stored for longer than these limits. 5.262(2)(C)2.D(III)
5.262(2)(C)2.D(III)
is inspection, provide a copy of each manifest that was used to
aste to an authorized hazardous waste treatment, storage or
o, please provide a photograph of the area where the wastes were
hat they have been removed, and a written statement that will not
for a period longer than allowed by the hazardous waste
25-5.262(1), incorporating 40 CFR 262.34(a).
he containment system for the hazardous waste storage area or XXS
ment system capacity to accommodate the water that enters the
.262(2)(C)2.D(III)(c).
ccumulate in the containment system. 10 CSR 25- XXS
).
active wastes more than 50 feet from the property line. 10 CSR 265I 7.265inc. 40-265.176
rencing 40 CFR 265.176, as amended by 10 CSR 25-
ers of hazardous waste with the words 'Hazardous Waste.' 262C 5.262inc. 40-262.34(d)(4)
2
LQG# LQG_Citation SQG# SQG_Citation Recomendation
B14 Hazardous waste was not B7 Hazardous waste was not Package, mark and lab
packaged/labeled/marked per packaged/labeled/marked per Transportation require
Department of Transportation Department of Transportation
requirements during the entire on-site requirements during the entire on-site
storage period. 10 CSR 25- storage period. 10 CSR 25-
5.262(2)(C)1. 5.262(2)(C)1.
B15 <company> did not mark hazardous B8 <company> did not mark hazardous Mark containers of haz
waste containers with the date of waste containers with the date of
accumulation. 10 CSR 25-5.262(1), accumulation. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(a)(2). incorporating 40 CFR 262.34(d)(4),
referencing 40 CFR 262.34(a)(2).
B16 <company> did not inspect and B11 <company> did not inspect and Conduct weekly inspe
maintain its facility weekly. 10 CSR 25- maintain its facility weekly. 10 CSR findings of those inspe
5.262(2)(C)2.C(I) and (II), referencing 25-5.262(2)(C)2.C(I) and (II), CFR 265.174.
40 CFR 265.174. referencing 40 CFR 265.174.
B17 <company> did not inspect areas B12 <company> did not inspect areas Conduct daily inspecti
subject to spills, such as waste subject to spills, such as waste the findings of those in
handling areas, daily. 10 CSR 25- handling areas, daily. 10 CSR 25-
5.262(2)(C)2.C(II). 5.262(2)(C)2.C(II).
B18 <company> did not provide adequate B13 <company> did not provide adequate Provide adequate aisle
aisle space for its hazardous waste aisle space for its hazardous waste
containers. 10 CSR 25-5.262(1), containers. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(a)(4), incorporating 40 CFR 262.34(d)(4),
referencing 40 CFR 265.35. referencing 40 CFR 265.35.
B19 <company> did not make placards B14 <company> did not make placards Provide placards for h
available for transporters. 10 CSR 25- available for transporters. 10 CSR 25- 40 CFR 262.33.
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR
262.33. 262.33.
B2 Hazardous waste containers were in B2 Hazardous waste containers were in Arrange for movemen
poor condition. 10 CSR 25-5.262(1), poor condition. 10 CSR 25-5.262(1), condition, using appro
incorporating 40 CFR 262.34(a)(1), incorporating 40 CFR 262.34(d)(2), provide a photograph o
referencing 40 CFR 265.171. referencing 40 CFR 265.171. documenting that they
<company> will main
3
bel containers of hazardous waste according to Department of Violation Citation
ements. 10 CSR 25-5.262(2)(C)1. Type
262C 5.262(2)(C)1inc. 40-262.30-32
zardous waste with the date that they were placed in storage. 262C 5.262inc. 40-262.34(d)(4)
ections of the facility and maintain the facility based on the XXS 5.262(2)(C)2.C(I)&(II)
ections. 10 CSR 25-5.262(2)(C)2.C(I) and (II), referencing 40
ions of areas subject to spills and maintain the facility based on XXS 5.262(2)(C)2.C(II)
nspections. 10 CSR 25-5.262(2)(C)2.C(II).
e space between containers of hazardous waste. 262C 5.262inc. 40-262.34(d)(4)
hazardous waste transporters. 10 CSR 25-5.262(1), incorporating 262C 5.262inc. 40-262.33
nt of waste from damaged containers to containers that are in good 262C 5.262inc. 40-262.34(d)(2)
opriate safety measures. In your response to this inspection,
of the hazardous wastes that are currently stored at <company>,
y are in good condition. Also, please send a written statement that
ntain hazardous waste containers in good condition.
3
LQG# LQG_Citation SQG# SQG_Citation Recomendation
B20 <company> did not take precautions to B15 <company> did not take precautions Take precautions to pr
prevent accidental ignition or reaction to prevent accidental ignition or CSR 25-5.262(2)(C)2.
of ignitable or reactive wastes, reaction of ignitable or reactive
including confining smoking and open wastes, including confining smoking
flam to specially designated locations and open flam to specially
and conspicuously placing 'No designated locations and
Smoking' signs by ignitable or reactive conspicuously placing 'No Smoking'
wastes. 10 CSR 25-5.262(2)(C)2.F(II). signs by ignitable or reactive wastes.
10 CSR 25-5.262(2)(C)2.F(II).
B3 Hazardous waste was incompatible B3 Hazardous waste was incompatible Arrange for movemen
with its container. 10 CSR 25- with its container. 10 CSR 25- measures. In your resp
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR <company> has taken
262.34(a)(1), referencing 40 CFR 262.34(d)(2), referencing 40 CFR containers that hold th
265.172. 265.172. not store hazardous wa
B4 Containers of hazardous waste were B4 Containers of hazardous waste were Keep containers of haz
open. 10 CSR 25-5.262(1), open. 10 CSR 25-5.262(1), your response to this i
incorporating 40 CFR 262.34(a)(1), incorporating 40 CFR 262.34(d)(2), has taken to ensure tha
referencing 40 CFR 265.173(a). referencing 40 CFR 265.173(a). adding or removing w
store hazardous wastes
B5 Containers of incompatible wastes B5 Containers of incompatible wastes Protect containers that
were not separated or protected from were not separated or protected from response to this inspec
each other by a dike, berm or wall. 10 each other by a dike, berm or wall. taken to ensure that co
CSR 25-5.262(1), incorporating 40 10 CSR 25-5.262(1), incorporating from each other. Also
CFR 262.34(a)(1), referencing 40 CFR 40 CFR 262.34(d)(2), referencing 40 area, documenting tha
265.177(c).
CFR 265.177(c). written statement that
wastes from each othe
B6 Container storage areas holding more Provide a containment
than 1000 Kg of liquid hazardous Kg of liquid hazardous
waste did not have a containment photograph that demon
systems. 10 CSR 25- containment system du
5.262(2)(C).2.D(I). system. Alternatively,
been shipped to a treat
5.262(2)(C).2.D(I).
B7 The base of a containment system was Repair the base of the
not impervious and free of cracks or the system impervious
gaps. 10 CSR 25-
5.262(2)(A)2.D(III)(a)
4
revent accidental ignition or reaction of hazardous wastes. 10 Violation Citation
.F(II). Type
XXS 5.262(2)(C)2.F(II)
nt of waste to compatible containers, using appropriate safety 262C 5.262inc. 40-262.34(d)(2)
ponse to this inspection, provide a description of the actions that 5.262inc. 40-262.34(d)(2)
to ensure that hazardous wastes are compatible with the 5.262inc. 40-262.34(d)(2)
hem. Also, please send a written statement that <company> will 5.262(2)(C)2.D(I)
astes in incompatible containers. 5.262(2)(C)2.D(III)
zardous waste closed, except when adding or removing waste. In 262C
inspection, provide a description of the actions that <company>
at containers of hazardous waste are kept closed, except when
waste. Also, please send a written statement that <company> will
s only in closed containers.
t hold incompatible hazardous wastes from each other. In your 262C
ction, provide a description of the actions that <company> has XXS
ontainers that hold incompatible hazardous wastes are protected
o, please provide a photograph of the hazardous waste storage
at incompatible wastes are protected from each other, and a
<company> will separate or otherwise protect incompatible
er.
t system for all container storage areas that hold more than 1000
s waste. In your response to this inspection, provide a
nstrates that the hazardous waste identified as needing a
uring the inspection has been moved to an area with such as
, you may provide documentation that the hazardous waste has
tment, storage or disposal facility. 10 CSR 25-
containment system, eliminating any cracks or gaps and making XXS
s. 10 CSR 25-5.262(2)(A)2.D(III)(a)
4
LQG# LQG_Citation SQG# SQG_Citation Recomendation
B8 Hazardous waste containers were not B9 Hazardous waste containers were not Protect containers of h
protected from contact with protected from contact with 25-5.262(2)(C)2.D(II)
accumulated liquids. 10 CSR 25- accumulated liquids. 10 CSR 25-
5.262(2)(C)2.D(II). 5.262(2)(C)2.D(II).
B9 The capacity of the containment Limit the volume of ha
system did not equal at least ten the containment system
percent of the waste volume or volume the largest container, w
of the largest container, whichever is
greater. 10 CSR 25-
5.262(2)(C)2.D(III)(c).
C1 Satellite accumulation containers of C1 Satellite accumulation containers of Keep satellite containe
hazardous waste were open. 10 CSR hazardous waste were open. 10 CSR waste. In your respon
25-5.262(1), incorporating 40 CFR 25-5.262(1), incorporating 40 CFR <company> has taken
262.34(c)(1)(i), referencing 40 CFR 262.34(c)(1)(i), referencing 40 CFR waste are kept closed.
265.173(a). 265.173(a). storage area, documen
statement that <compa
CSR 25-5.262(1), inco
265.173(a).
C2 Satellite containers of hazardous waste C2 Satellite containers of hazardous Arrange for movemen
were in poor condition. 10 CSR 25- waste were in poor condition. 10 in good condition, usin
5.262(1), incorporating 40 CFR CSR 25-5.262(1), incorporating 40 inspection, provide a p
262.34(c)(1)(i), referencing 40 CFR CFR 262.34(c)(1)(i), referencing 40 satellite accumulation
265.171. CFR 265.171. condition. Also, pleas
hazardous waste satell
5.262(1), incorporating
C3 Hazardous waste was incompatible C3 Hazardous waste was incompatible Arrange for movemen
with its satellite accumlation container. with its satellite accumlation safety measures. In yo
10 CSR 25-5.262(1), incorporating 40 container. 10 CSR 25-5.262(1), actions that <company
CFR 262.34(c)(1)(i), referencing 40 incorporating 40 CFR the satellite accumulat
CFR 265.172. 262.34(c)(1)(i), referencing 40 CFR a photograph of the ha
265.172. currently in use are co
statement that <compa
accumulation containe
referencing 40 CFR 26
5
hazardous waste from contact with accumulated liquids. 10 CSR Violation Citation
). Type
XXS 5.262(2)(C)2.D(II)
azardous waste in each containment system so that the capacity of XXS 5.262(2)(C)2.D(III)
m equals at least ten percent of the waste volume or the volume of
whichever is greater. 10 CSR 25-5.262(2)(C)2.D(III)(c).
ers of hazardous waste closed, except when adding or removing 262C 5.262inc. 40-262.34(c)(1)(i)
nse to this inspection, provide a description of the actions that 5.262inc. 40-262.34(c)(1)(i)
5.262inc. 40-262.34(c)(1)(i)
to ensure that satellite accumulation containers of hazardous
Also, please provide a photograph of the hazardous waste
nting that the containers have been closed and send a written
any> will store hazardous wastes only in closed containers. 10
orporating 40 CFR 262.34(c)(1)(i), referencing 40 CFR
nt of waste from damaged satellite containers to containers that are 262C
ng appropriate safety measures. In your response to this
photograph of each of the hazardous wastes that are currently in
areas at <company>, documenting that they are in good
se send a written statement that <company> will maintain
lite accumulation containers in good condition. 10 CSR 25-
g 40 CFR 262.34(c)(1)(i), referencing 40 CFR 265.171.
nt of waste to compatible satellite containers, using appropriate 262C
our response to this inspection, provide a description of the
y> has taken to ensure that hazardous wastes are compatible with
tion containers in each area that holds them. Also, please provide
azardous waste storage area, documenting that the containers
ompatible with the waste that is generated and send a written
any> will not store hazardous wastes in incompatible satellite
ers. 10 CSR 25-5.262(1), incorporating 40 CFR 262.34(c)(1)(i),
65.172.
5
LQG# LQG_Citation SQG# SQG_Citation Recomendation
C4 Quantities of hazardous waste in C4 Quantities of hazardous waste in Remove containers of
satellite accumulation exceeded 55 satellite accumulation exceeded 55 than 55 gallons and pl
gallons (1 quart of acutely hazardous gallons (1 quart of acutely hazardous shipment to an approp
waste). 10 CSR 25-5.262(1), waste). 10 CSR 25-5.262(1), description of the actio
incorporating 40 CFR 262.34(c)(1). incorporating 40 CFR 262.34(c)(1). accumulation areas do
stream. Also, please p
accumulation area, doc
written statement that
area to 55 gallons. 10
C5 Satellite accumulation hazardous waste C5 Satellite accumulation hazardous Remove full container
containers were not moved to storage waste containers were not moved to hazardous waste storag
within three days of filling. 10 CSR 25- storage within three days of filling. response to this inspec
5.262(1), incorporating 40 CFR 10 CSR 25-5.262(1), incorporating taken to ensure that ha
262.34(c)(2). 40 CFR 262.34(c)(2). within three days of th
that <company> will r
three days of the conta
262.34(c)(2).
C6 Containers were not marked C6 Containers were not marked Mark satellite accumu
identifying the contents and beginning identifying the contents and accumulation and cont
date of accumulation. 10 CSR 25- beginning date of accumulation. 10 262.34(c)(1)(ii),
5.262(1), incorporating 40 CFR CSR 25-5.262(1), incorporating 40
262.34(c)(1)(ii), as modified by 10 CFR 262.34(c)(1)(ii), as modified by
CSR 25-5.262(2)(C)3. 10 CSR 25-5.262(2)(C)3.
C7 <company> stored hazardous waste in C7 <company> stored hazardous waste Remove hazardous wa
a satellite area for more than one year. in a satellite area for more than one beginning date of accu
10 CSR 25-5.262(2)(C)3. year. 10 CSR 25-5.262(2)(C)3.
C8 Satellite accumulation containers of C8 Satellite accumulation containers of Store satellite containe
hazardous waste were not stored at or hazardous waste were not stored at operator of the process
near the point of generation and/or or near the point of generation and/or CFR 262.34(c)(1).
were not under the control of the were not under the control of the
operator of the process that generated operator of the process that
the waste. 10 CSR 25-5.262(1), generated the waste. 10 CSR 25-
incorporating 40 CFR 262.34(c)(1). 5.262(1), incorporating 40 CFR
262.34(c)(1).
6
Violation Citation
Type
hazardous waste from satellite accumulation areas that hold more 262C 5.262inc. 40-262.34(c)(1)
lace them in a hazardous waste storage area or arrange for
priate facility. In your response to this inspection, provide a
ons that <company> has taken to ensure that satellite
o not hold more than 55 gallons of any one hazardous waste
provide a photograph of each hazardous waste satellite
cumenting that it currently holds less than 55 gallons, and and a
<company> will limit hazardous waste in a satellite accumulation
0 CSR 25-5.262(1), incorporating 40 CFR 262.34(c)(1).
rs of waste from satellite accumulation areas and place them in a 262C 5.262inc. 40-262.34(c)(2)
ge area or arrange for shipment to an appropriate facility. In your
ction, provide a description of the actions that <company> has
azardous waste is removed from satellite accumulation areas
he container being filled. Also, please provide a written statement
remove hazardous waste from satellite accumulation areas within
ainer being filled. 10 CSR 25-5.262(1), incorporating 40 CFR
ulation containers of hazardous waste with the beginning date of 262C 5.262inc. 40-262.34(c)(1)(ii)
tents. 10 CSR 25-5.262(1), incorporating 40 CFR
aste from satellite accumulation areas within one year of the XXS 5.262(2)(C)3
umulation. 10 CSR 25-5.262(2)(C)3.
ers at the point of waste generation and under the control of the 262C 5.262inc. 40-262.34(c)(1)
s that generates the waste. 10 CSR 25-5.262(1), incorporating 40
6
LQG# LQG_Citation SQG# SQG_Citation Recomendation
D1 <company> did not operate and D1 <company> did not operate and Review operation and
maintain the facility to minimize the maintain the facility to minimize the emergency is minimiz
possibility of an emergency. 10 CSR possibility of an emergency. 10 CSR the actions that <comp
25-5.262(1), incorporating 40 CFR 25-5.262(1), incorporating 40 CFR CSR 25-5.262(1), inco
262.34(a)(4), referencing 40 CFR 262.34(a)(4), referencing 40 CFR
265.31. 265.31.
D2 Adequate and proper spill control, D2 Adequate and proper spill control, Provide safety and em
decontamination and safety equipment decontamination and safety etc.)
(such as fire blankets, respirators, equipment (such as fire blankets,
SCBA, absorbents, etc.) were not respirators, SCBA, absorbents, etc.)
available. 10 CSR 25-5.262(1), were not available. 10 CSR 25-
incorporating 40 CFR 262.34(a)(4), 5.262(1), incorporating 40 CFR
referencing 40 CFR 265.32, as 262.34(d)(4), referencing 40 CFR
amended by 10 CSR 5.262(2)(C)2.G. 265.32, as amended by 10 CSR
5.262(2)(C)2.G.
D3 <company> did not have an adequate D3 <company> did not have an adequate Provide an adequate w
water supply or fire control equipment. water supply or fire control
10 CSR 25-5.262(1), incorporating 40 equipment. 10 CSR 25-5.262(1),
CFR 262.34(a)(4), referencing 40 CFR incorporating 40 CFR 262.34(d)(4),
265.32(c) and (d). referencing 40 CFR 265.32(c) and
(d).
D4 <company> had no device in the D9 <company> had no device in the Provide a device in the
hazardous waste operation area hazardous waste operation area emergency assistance.
capable of summoning emergency capable of summoning emergency
assistance. 10 CSR 25-5.262(1), assistance. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(a)(4), incorporating 40 CFR 262.34(d)(4),
referencing 40 CFR 265.34(a). referencing 40 CFR 265.34(a).
D5 <company> did not have a telephone D10 <company> did not have a telephone Provide a communicat
or two-way radio on-site and capable or two-way radio on-site and capable department or emergen
of summoning the local fire or police of summoning the local fire or police
department, or local or state department, or local or state
emergency response teams. 10 CSR 25- emergency response teams. 10 CSR
5.262(1), incorporating 40 CFR 25-5.262(1), incorporating 40 CFR
262.34(a)(4), referencing 40 CFR 262.34(d)(4), referencing 40 CFR
265.32(b). 265.32(b).
7
Violation Citation
Type
maintenance procedures to ensure that the possibility of an 262C 5.262inc. 40-262.34(a)(4)
zed. In your response to this inspection, provide a description of
pany> has taken to minimize the possibility of an emergency. 10
orporating 40 CFR 262.34(a)(4), referencing40 CFR 265.31.
mergency equipment (fire blanket, respirator, SCBA, absorbents, 262C 5.262inc. 40-262.34(d)(4)
water supply and fire control equipment. 262C 5.262inc. 40-262.34(d)(4)
e hazardous waste operation area capable of summoning 262C 5.262inc. 40-262.34(d)(4)
.
tion device on-site that can summon the local fire or police 262C 5.262inc. 40-262.34(d)(4)
ncy response team.
7
LQG# LQG_Citation SQG# SQG_Citation Recomendation
D6 Communication and emergency D4 Communication and emergency Test and maintain com
equipment were not tested and equipment were not tested and demonstrate that this r
maintained. 10 CSR 25-5.262(1), maintained. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(a)(4), incorporating 40 CFR 262.34(d)(4),
referencing 40 CFR 265.33. referencing 40 CFR 265.33.
E1 <company> did not use the manifest Use the hazardous was
system. Section 260.380.1(6), RSMo, response to this inspec
and 10 CSR 25-5.262(2)(B). has taken to ensure tha
waste manifest. Also,
that have been made a
5.262(2)(B).
E10 Manifests were not signed and dated. E12 Manifests were not signed and dated. Sign and date all mani
10 CSR 25-5.262(1), incorporating 40 10 CSR 25-5.262(1), incorporating
CFR 262.20(a)(1) 40 CFR 262.20(a)(1)
E12 <company> did not complete and E13 <company> did not complete and Provide copies of the e
submit an exception report when submit an exception report when inspection. 10 CSR 25
manifests were not returned within 35 manifests were not returned within
days. 10 CSR 25-5.262(2)(D)2.C. 35 days. 10 CSR 25-5.262(2)(D)2.C.
E2 Manifests were not maintained for a E4 Manifests were not maintained for a Keep manifests on-site
three-year period. 10 CSR 25-5.262(1), three-year period. 10 CSR 25- CFR 262.40(a).
incorporating 40 CFR 262.40(a). 5.262(1), incorporating 40 CFR
262.40(a).
E3 Manifests did not include the E5 Manifests did not include the Include the generator's
generator's Environmental Protection generator's Environmental Protection incorporating 40 CFR
Agency identification number. 10 CSR Agency identification number. 10
25-5.262(1), incorporating 40 CFR CSR 25-5.262(1), incorporating 40
262.20(a)(1) CFR 262.20(a)(1)
E5 Manifests did not include the E7 Manifests did not include the Include the generator's
generator's name, address, and generator's name, address, and 25-5.262(2)(B)1.
telephone number. 10 CSR 25- telephone number. 10 CSR 25-
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR
262.20(a)(1) 262.20(a)(1)
E6 Manifests did not include all E8 Manifests did not include all Include all transporter'
transporter's names and Environmental transporter's names and numbers, and license p
Protection Agency identification Environmental Protection Agency Need this added.
numbers. 10 CSR 25-5.262(1), identification numbers. 10 CSR 25-
incorporating 40 CFR 262.20(a)(1) 5.262(1), incorporating 40 CFR
262.20(a)(1)
8
mmunication and emergency equipment. Keep records to Violation Citation
routine maintenance is completed. Type
262C 5.262inc. 40-262.34(d)(4)
ste manifest system for all shipments of hazardous waste. In your 262C 5.262inc. 40-262.34(b)
ction, provide a written description of the actions that <company> 5.262(2)(B)
at all shipments of hazardous waste from the site use a hazardous
, please provide copies of any manifests that document shipments
after the inspection. Section 260.380.1(6), RSMo, and 10 CSR 25-
ifests. 10 CSR 25-5.262(2)(B)1. XXS
exception reports for the shipments identified during the XXS 5.262(2)(D)2.C.
5-5.262(2)(D)2.C.
e for at least three years. 10 CSR 25-5.262(1), incorporating 40 262D 5.262inc. 40-262.40(a)
s identification numbers on all manifests. 10 CSR 25-5.262(1), 262B 5.262inc. 40-262.20(a)
262.20(a), as amended by 10 CSR 25-5.262(2)(B)1.
s name, address, and telephone number on all manifests. 10 CSR 262B 5.262inc. 40-262.20(a)
's names, telephone numbers, Missouri and EPA identification 262B 5.262inc. 40-262.20(a)
plate numbers on all manifests. 10 CSR 25-5.262(2)(B)1 and 2.
8
LQG# LQG_Citation SQG# SQG_Citation Recomendation
E7 Manifests did not include the E9 Manifests did not include the Include the designated
designated facility's name, address, designated facility name, address, EPA identification num
telephone number, and Environmental telephone number and
Protection Agency identification Environmental Protection Agency
number. 10 CSR 25-5.262(1), identification number. 10 CSR 25-
incorporating 40 CFR 262.20(a)(1) 5.262(1), incorporating 40 CFR
262.20(a)(1)
E8 Manifests did not include the E10 Manifests did not include the Include the Departmen
Department of Transportation shipping Department of Transportation identification number
name, hazardous class, and waste shipping name, hazardous class, and
identification number (RQ, if waste identification number (RQ, if
required). 10 CSR 25-5.262(1), required). 10 CSR 25-5.262(1),
incorporating 40 CFR 262.20(a)(1) incorporating 40 CFR 262.20(a)(1)
E9 Manifests did not designate the E11 Manifests did not designate the Include the number of
containers and quantity. 10 CSR 25- containers and quantity. 10 CSR 25- 5.262(2)(B)1 and 2.
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR
262.20(a)(1) 262.20(a)(1)
F1 <company> did not test the waste or E2 <company> did not test the waste or Characterize <compan
use knowledge of the waste to use knowledge of the waste to disposal. In your resp
determine if the waste is restricted determine if the waste is restricted actions that <company
from land disposal. 10 CSR 25- from land disposal. 10 CSR 25- characterized to determ
7.268(1), incorporating 40 CFR 7.268(1), incorporating 40 CFR copies of any manifest
268.7(a). 268.7(a). shipments that have be
incorporating 40 CFR
F2 Waste was diluted to meet land Immediately cease the
disposal restriction treatment treatment standards. I
standards. 10 CSR 25-7.268(1), actions that your facili
incorporating 40 CFR 268.3(a). 7.268(1), incorporating
F3 'Land-Ban' notification/certification E15 'Land-Ban' notification/certification Include correct EPA h
did not include the correct did not include the correct manifest numbers and
Environmental Protection Agency Environmental Protection Agency 7.268(1), incorporating
hazardous waste number, hazardous waste number,
corresponding treatment standards, corresponding treatment standards,
manifest number, and waste analysis manifest number, and waste analysis
data. 10 CSR 25-7.268(1), data. 10 CSR 25-7.268(1),
incorporating 40 CFR 268.7(b). incorporating 40 CFR 268.7(b).
9
d facility's name, address, telephone number, and Missouri and Violation Citation
mbers on all manifests. 10 CSR 25-5.262(2)(B)1 and 2. Type
262B 5.262inc. 40-262.20(a)
nt of Transportation shipping name, hazardous class, and waste 262B 5.262inc. 40-262.20(a)
on all manifests. 10 CSR 25-5.262(2)(B)1 and 2.
f containers and the specific gravity on all manifests. 10 CSR 25- 262B 5.262inc. 40-262.20(a)
ny>'s hazardous waste to determine if it is restricted from land 268A 7.268inc. 40-268.7(a)
ponse to this inspection, provide a written description of the
7.268inc. 40-268.3(a)
y> has taken to ensure that its hazardous waste has been 7.268inc. 40-268.7(b)
mine if it is restricted from land disposal. Also, please provide
ts, including land disposal restriction documentation, for
een made after the inspection. 10 CSR 25-7.268(1),
268.7(a).
e dilution of hazardous waste to meet land disposal restriction 268A
In response to this inspection, provide a written description of the
ity has taken to ensure that this practice has stopped. 10 CSR 25-
g 40 CFR 268.3(a).
hazardous waste numbers, corresponding treatment standards, 268A
d waste analysis data on 'Land Ban' notifications. 10 CSR 25-
g 40 CFR 268.7(b).
9
LQG# LQG_Citation SQG# SQG_Citation Recomendation
G1 Personnel were not trained to respond Provide training to per
to emergencies including the use of should address the use
alarm systems, emergency equipment contingency plan. Do
and contingency plan. 10 CSR 25- facility. Documentatio
5.262(1), incorporating 40 CFR sign-in sheet, and a de
262.34(a)(4), referencing 40 CFR incorporating 40 CFR
265.16(a)(3).
Restrict employees to
G2 Employees worked in unsupervised waste training. 10 CSR
positions before having completed the CFR 265.16(b).
training - 10 CSR 25-5.262(1)
incorporating 40 CFR 262.34(a)(4) Ensure that employees
referencing 40 CFR 265.16(b). least annually. 10 CSR
CFR 265.16(c).
G3 Training was not reviewed annually -
10 CSR 25-5.262(1) incorporating 40 Ensure that the progra
CFR 262.34(a)(4) referencing 40 CFR with hazardous waste
265.16(c). 262.34(a)(4) referencin
G4 Program director was not trained in Maintain the hazardou
hazardous waste management incorporating 40 CFR
procedure - 10 CSR 25-5.262(1)
incorporating 40 CFR 262.34(a)(4)
referencing 40 CFR 265.16(a)(2).
G5 Personnel training plan was not on-site -
10 CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(4) referencing 40 CFR
265.16(d).
10
rsonnel to enable them to respond to emergencies. The training Violation Citation
e of the facilities alarm systems, emergency equipment and Type
ocument the training and maintain that documentation at the 262C 5.262inc. 40-262.34(a)(4)
on should include a list of employes who participated, such as a
escription of the topics that were covered. 10 CSR 25-5.262(1),
262.34(a)(4), referencing 40 CFR 265.16(a)(3).
supervised positions until they have completed their hazardous 262C 5.262inc. 40-262.34(a)(4)
R 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40
s that handle hazardous waste review hazardous waste training at 262C 5.262inc. 40-262.34(a)(4)
R 25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40
am director attends training concerning the procedures associated 262C 5.262inc. 40-262.34(a)(4)
management.10 CSR 25-5.262(1) incorporating 40 CFR
ng 40 CFR 265.16(a)(2).
us waste personnel training plan on-site. 10 CSR 25-5.262(1) 262C 5.262inc. 40-262.34(a)(4)
262.34(a)(4) referencing 40 CFR 265.16(d).
0
LQG# LQG_Citation SQG# SQG_Citation Recomendation
Revise the personnel t
G6 The personnel training plan did not the employee filling ea
provide the job title, job description 262.34(a)(4) referencin
and name of employee filling each
position - 10 CSR 25-5.262(1) Revise the personnel t
incorporating 40 CFR 262.34(a)(4) continuing training tha
referencing 40 CFR 265.16(d)(1) & incorporating 40 CFR
(2).
Ensure that each empl
G7 The personnel training plan did not identified in the person
provide a written description of documented. 10 CSR
introductory and continuing training CFR 265.16(d)(4).
that will be given to each position - 10
CSR 25-5.262(1) incorporating 40 Maintain hazardous w
CFR 262.34(a)(4) referencing 40 CFR facility. Maintain haz
265.16(d)(3). three years after they l
incorporating 40 CFR
G8 Personnel did not complete the training
identified in the personnel training plan Maintain the contingen
or the training was not documented. - incorporating 40 CFR
10 CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(4) referencing 40 CFR Provide a copy of the c
265.16(d)(4). including police depar
teams. 10 CSR 25-5.2
G9 The facility did not maintain records of 265.53(b).
current personnel until facility closure
or maintain records of former 11
employees for at least three years - 10
CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(4) referencing 40 CFR
265.16(e).
H1 The contingency plan was not
maintained on-site - 10 CSR 25-
5.262(1) incorporating 40 CFR
262.34(a)(4) referencing 40 CFR
265.53(a).
H2 The contingency plan was not provided
to local emergency response agencies -
10 CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(4) referencing 40 CFR
265.53(b).
training plan to provide the job title, job description and name of Violation Citation
ach position. 10 CSR 25-5.262(1) incorporating 40 CFR Type
ng 40 CFR 265.16(d)(1) & (2). 262C 5.262inc. 40-262.34(a)(4)
training plan to provide a written description of introductory and 262C 5.262inc. 40-262.34(a)(4)
at will be given to each position. 10 CSR 25-5.262(1)
262.34(a)(4) referencing 40 CFR 265.16(d)(3).
loyee completes the training for his or her position that is 262C 5.262inc. 40-262.34(a)(4)
nnel training plan. Also ensure that the training is properly
25-5.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40
waste training records of current employees until closure of the 262C 5.262inc. 40-262.34(a)(4)
zardous waste training records of former employees for at least
leave employment with the facility. 10 CSR 25-5.262(1)
262.34(a)(4) referencing 40 CFR 265.16(e).
ncy plan for the facility on-site. 10 CSR 25-5.262(1) 262C 5.262inc. 40-262.34(a)(4)
262.34(a)(4) referencing 40 CFR 265.53(a).
contingency plan for the facility to local emergency agencies, 262C 5.262inc. 40-262.34(a)(4)
rtments, fire departments, hospitals, and emergency response
262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR
1
LQG# LQG_Citation SQG# SQG_Citation Recomendation
H3 Emergency coordinators were not on D12 Emergency coordinators were not on Ensure that an emerge
the property or on call. 10 CSR 25- the property or on call. 10 CSR 25-
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR
262.34(a)(4), referencing 40 CFR 262.34(d)(5)(i).
265.55.
H4 The contingency plan does not Revise the contingenc
describe actions personnel must take in in response to fires, ex
response to fires, explosions or other 5.262(1) incorporating
releases of hazardous waste - 10 CSR
25-5.262(1) incorporating 40 CFR
262.34(a)(4) referencing 40 CFR
265.52(a).
H5 The contingency plan does not Revise the contingenc
describe arrangements with emergency made with emergency
response agencies - 10 CSR 25- 262.34(a)(4) referencin
5.262(1) incorporating 40 CFR
262.34(a)(4) referencing 40 CFR
265.52(c).
H6 The contingency plan does not list Revise the contingenc
names, addresses and phone numbers numbers and office ph
(home and office) of emergency facility. 10 CSR 25-5.
coordinator(s) - 10 CSR 25-5.262(1) 265.52(d).
incorporating 40 CFR 262.34(a)(4)
referencing 40 CFR 265.52(d).
H7 The contingency plan does not Revise the contingenc
designate the primary emergency coordinator for the fac
coordinator - 10 CSR 25-5.262(1) referencing 40 CFR 26
incorporating 40 CFR 262.34(a)(4)
referencing 40 CFR 265.52(d). Revise the contingenc
description of each pie
H8 The contingency plan does not lists 5.262(1) incorporating
emergency equipment including
description, location and capabilities -
10 CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(4) referencing 40 CFR
265.52(e).
12
ency coordinator is on the property or on call at all times. Violation Citation
Type
262C 5.262inc. 40-262.34(d)(5)(i)
cy plan for the facility to describe the actions personnel must take 262C 5.262inc. 40-262.34(a)(4)
xplostions or other releases of hazardous waste. 10 CSR 25-
g 40 CFR 262.34(a)(4) referencing 40 CFR 265.52(a).
cy plan for the facility to describe arrangements that have been 262C 5.262inc. 40-262.34(a)(4)
response agencies. 10 CSR 25-5.262(1) incorporating 40 CFR
ng 40 CFR 265.52(c).
cy plan for the facility to list the names, addresses, home phone 262C 5.262inc. 40-262.34(a)(4)
hone numbers of the current emergency coordinators for the
.262(1) incorporating 40 CFR 262.34(a)(4) referencing 40 CFR
cy plan for the facility to designate the current primary emergency 262C 5.262inc. 40-262.34(a)(4)
cility. 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4)
65.52(d).
cy plan for the facility to list emergency equipment, including a 262C 5.262inc. 40-262.34(a)(4)
ece of equipment, its location and its capabilities. 10 CSR 25-
g 40 CFR 262.34(a)(4) referencing 40 CFR 265.52(e).
2
LQG# LQG_Citation SQG# SQG_Citation Recomendation
H9 The evacuation plan, if applicable, Develop an evacuation
does not designate primary and primary and secondary
secondary routes and evacuation signal evacuation of the facil
- 10 CSR 25-5.262(1) incorporating 40 referencing 40 CFR 26
CFR 262.34(a)(4) referencing 40 CFR
265.52(f). <company> did not manage used oil Properly manage used
I1 <company> did not manage used oil F1 properly and/or disposed of used oil a public nuisance. Rem
properly and/or disposed of used oil
into the environment or caused a into the environment or caused a disposal. In your resp
public nuisance. 10 CSR 25-
11.279(2)(B)4.B. public nuisance. 10 CSR 25- actions that <company
11.279(2)(B)4.B. Also, please provide c
contaminated soil from
photograph of the area
showing that the area h
I2 Used oil containers were in poor F2 Used oil containers were in poor Arrange for movemen
condition. 10 CSR 25-11.279(1), condition. 10 CSR 25-11.279(1), good condition, using
incorporating 40 CFR 279.22(b)(1). incorporating 40 CFR 279.22(b)(1). provide a photograph o
documenting that they
<company> will main
incorporating 40 CFR
I3 Containers of used oil were leaking. 10 F3 Containers of used oil were leaking. Arrange for movemen
CSR 25-11.279(1), incorporating 40 10 CSR 25-11.279(1), incorporating good condition, using
CFR 279.22(b)(2). 40 CFR 279.22(b)(2). provide a photograph o
documenting that they
<company> will take a
11.279(1), incorporatin
I4 Containers/aboveground tanks of used F4 Containers/aboveground tanks of Clearly mark or label c
oil were not labeled or marked clearly used oil were not labeled or marked 11.279(1), incorporatin
as 'Used Oil.' 10 CSR 25-11.279(1), clearly as 'Used Oil.' 10 CSR 25-
incorporating 40 CFR 279.22(c)(1). 11.279(1), incorporating 40 CFR
279.22(c)(1).
I5 Fill pipes that are used to transfer used F5 Fill pipes that are used to transfer Clearly mark or label f
oil into underground storage tanks are used oil into underground storage 10 CSR 25-11.279(1),
labeled or marked clearly as 'Used Oil.' tanks are labeled or marked clearly
10 CSR 25-11.279(1), incorporating as 'Used Oil.' 10 CSR 25-11.279(1),
40 CFR 279.22(c)(2). incorporating 40 CFR 279.22(c)(2).
13
n plan for the facility or revise the existing plan to designate Violation Citation
y routes of evacuation and to establish a signal that will initiate Type
lity. 10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(4) 262C 5.262inc. 40-262.34(a)(4)
65.52(f).
d oil; do not dispose of it into the environment or otherwise cause XXS 11.279(2)(B)4.B.
move any used oil-contaminated soil and arrange for proper
ponse to this inspection, provide a written description of the 11.279inc. 40-279.22(b)(1)
y> has taken to ensure that used oil will be managed properly. 11.279inc. 40-279.22(b)(2)
copies of shipping papers for transportation of used oil- 11.279inc. 40-279.22(c)(1)
m cleanup efforts at the area described above and provide a
a where the used oil had been disposed into the environment,
has been cleaned up. 10 CSR 25-11.279(2)(B)4.B.
nt of used oil from damaged containers to containers that are in 279C
appropriate safety measures. In your response to this inspection,
of the used oil containers that are currently stored at <company>,
y are in good condition. Also, please send a written statement that
ntain used oil containers in good condition. 10 CSR 25-11.279(1),
279.22(b)(1).
nt of used oil from damaged containers to containers that are in 279C
appropriate safety measures. In your response to this inspection,
of the used oil containers that are currently stored at <company>,
y are not leaking. Also, please send a written statement that
action to ensure that used oil containers do not leak. 10 CSR 25-
ng 40 CFR 279.22(b)(2).
containers of used oil with the words 'Used Oil.' 10 CSR 25- 279C
ng 40 CFR 279.22(c)(1).
fill pipes for underground storage tanks with the words 'Used Oil.' 279C 11.279inc. 40-279.22(c)(2)
, incorporating 40 CFR 279.22(c)(2).
3
LQG# LQG_Citation SQG# SQG_Citation Recomendation
I6 Containers/tanks of used oil which F6 Containers/tanks of used oil which Close used oil tanks an
were exposed to rainfall were open. 10 were exposed to rainfall were open. 11.279(2)(C)6.
CSR 25-11.279(2)(C)6. 10 CSR 25-11.279(2)(C)6.
I7 <company> did not clean up spills or F7 <company> did not clean up spills or Clean up spilled oil an
leaks of used oil. 10 CSR 25- leaks of used oil. 10 CSR 25- 11.279(1), incorporatin
11.279(1), incorporating 40 CFR 11.279(1), incorporating 40 CFR
279.22(d). 279.22(d).
I8 Mixtures of used oil and hazardous F8 Mixtures of used oil and hazardous Manage mixtures of us
waste were not managed according to waste were not managed according waste regulations. 10
state hazardous waste regulations. 10 to state hazardous waste regulations.
CSR 25-11.279(2)(B)2. 10 CSR 25-11.279(2)(B)2.
J1 <company> did not burn only its own G1 <company> did not burn only its Burn only <company>
used oil or used oil from do-it- own used oil or used oil from do-it- farmers. In your respo
yourselfers or exempt farmers. 10 CSR yourselfers or exempt farmers. 10 <company> will burn
25-11.279(1), incorporating 40 CFR CSR 25-11.279(1), incorporating 40 farmers. Along with t
279.23(a), as amended by 10 CSR 25- CFR 279.23(a), as amended by 10 been or will be taken t
11.279(2)(A)1. CSR 25-11.279(2)(A)1. it-yourselfers or exemp
40 CFR 279.23(a), as
J2 <company> did not burn only in space G2 <company> did not burn only in Burn used oil only in a
heaters with a design capacity of less space heaters with a design capacity per hour. In your resp
than 0.5 million BTU per hour. 10 of less than 0.5 million BTU per <company> will burn
CSR 25-11.279(1), incorporating 40 hour. 10 CSR 25-11.279(1), 0.5 million BTU per h
CFR 279.23(b). incorporating 40 CFR 279.23(b). the actions that have b
criteria. 10 CSR 25-11
J3 Combustion gases from the heater were G3 Combustion gases from the heater Vent used oil combust
not vented to the ambient air. 10 CSR were not vented to the ambient air. provide a written, sign
25-11.279(1), incorporating 40 CFR 10 CSR 25-11.279(1), incorporating gases to the ambient a
279.23(c). 40 CFR 279.23(c). actions that have been
criteria. 10 CSR 25-11
14
nd containers that are exposed to rainfall. 10 CSR 25- Violation Citation
Type
XXS 11.279(2)(C)6
nd ship it to an appropriate disposal facility. 10 CSR 25- 279C 11.279inc. 40-279.22(d)
ng 40 CFR 279.22(d).
sed oil and hazardous waste according to Missouri's hazardous XXS 11.279(2)(B)2
CSR 25-11.279(2)(B)2.
>'s own used oil or used oil from do-it-yourselfers or exempt XXS 5.262(2)(A)
11.279inc. 40-279.23(b)
onse to this inspection, provide a written, signed statement that
only its own used oil or used oil from do-it-yourselfers or exempt
this statement, please include a description of the actions that have
to ensure that only <company>'s own used oil or used oil from do-
pt farmers will be burned. 10 CSR 25-11.279(1), incorporating
amended by 10 CSR 25-11.279(2)(A)1.
a space heater with a design capacity of less than 0.5 million BTU 279C
ponse to this inspection, provide a written, signed statement that
used oil only in a space heater with a design capacity of less than
hour. Along with this statement, please include a description of
been or will be taken to ensure that the space heater meets the
1.279(1), incorporating 40 CFR 279.23(b).
tion gases to the ambient air. In your response to this inspection, 279C 11.279inc. 40-279.23(c)
ned statement that <company> will vent used oil combustion
air. Along with this statement, please include a description of the
n or will be taken to ensure that the space heater meets this
1.279(1), incorporating 40 CFR 279.23(c).
4
LQG# LQG_Citation SQG# SQG_Citation Recomendation
K1 Used oil was transported by H1 Used oil was transported by Use a licensed hazardo
transporters who had not obtained EPA transporters who had not obtained transports the used oil
identification numbers and had not met EPA identification numbers and had directly to an authorize
other criteria. 10 CSR 25-11.279(1), not met other criteria. 10 CSR 25- company also owns or
incorporating 40 CFR 279.24. 11.279(1), incorporating 40 CFR In your response to thi
279.24. will use a licensed haz
property, unless it mee
please include a descri
a licensed hazardous w
incorporating 40 CFR
L1 <company> did not obtain a valid I1 <company> did not obtain a valid Immediately cease ope
resource recovery certification for resource recovery certification for obtained a valid resour
energy recovery or reclamation of energy recovery or reclamation of provide a written, sign
hazardous waste. 10 CSR 25- hazardous waste. 10 CSR 25- resource recovery unit
9.020(1)(A)3. 9.020(1)(A)3. 25-9.020(1)(A)3.
L10 R2 facility does not maintain a daily Maintain a daily log o
log of manifest number, wastes and corresponding sam
received, disposition of waste and 9.020(3)(C)2.
corresponding sampling data - 10 CSR
25-9.020(3)(C)2.
L11 R2 facility does not have a written Prepare a written closu
closure plan which meets 40 CFR requirements of 40 CF
264.112 requirements - 10 CSR 25- 7.264(2)(G).
9.020(3)(C)3 referencing 10 CSR 25-
7.264(2)(G).
L12 R2 facility does not provide financial Arrange for financial a
assurance for closure - 10 CSR 25- facility. 10 CSR 25-9.
9.020(3)(C)4 referencing 10 CSR 25-
7.264.
L13 Storage of still bottoms in satellite If still bottoms from th
accumulation does not comply with containers, ensure that
state regulations - 10 CSR 25- 9.020(3)(E)7.B.
9.020(3)(E)7.B.
Storage of hazardous waste destined Store hazardous waste
L14 Storage of hazardous waste destined I9 for resource recovery was not in regulations.
for resource recovery was not in accordance with all applicable state
accordance with all applicable state hazardous waste regulations. 10 CSR
hazardous waste regulations. 10 CSR 9.020(1)(A).
9.020(3)(E)7.C.
15
Violation Citation
Type
ous waste transporter for shipments of used oil unless <company> 279C 11.279inc. 40-279.24
in its own vehicle or an employee's vehicle (55 gallons or less
ed facility), transports the used oil aggregation point that the
r operates, or reclaims the used oil under a contractual agreement.
is inspection, provide a written, signed statement that <company>
zardous waste transporter for future shipments of used oil from the
ets one of the alternative criteria. Along with this statement,
iption of the actions that have been or will be taken to ensure that
waste transporter will be used. 10 CSR 25-11.279(1),
279.24.
eration of the resource recovery unit until <company> has XXS 9.020(1)(A)3
rce recovery certification. In your response to this inspection,
ned statement that the company has stopped operating the
t or has obtained a valid resource recovery certification. 10 CSR
of the manifest number, wastes received, disposition of the wastes XXS 9.020(3)(C)2.
mpling data for the R2 resource recovery facility. 10 CSR 25-
ure plan for the R2 resource recovery facility, meeting the XXS 9.020(3)(C)3.
FR 264.112. 10 CSR 25-9.020(3)(C)3 referencing 10 CSR 25-
assurance to ensure proper closure of the R2 resource recovery XXS 9.020(3)(C)4.
.020(3)(C)4 referencing 10 CSR 25-7.264.
he resource recovery facility are kept in satellite accumulation XXS 9.020(3)(E)7.B.
t these containers comply with state regulations. 10 CSR 25-
e that is destined for resource recovery according to Missouri XXS 9.020(1)(A)
5
LQG# LQG_Citation SQG# SQG_Citation Recomendation
L2 Still bottoms or resource recovery I2 Still bottoms or resource recovery Ship still bottoms that
residues were not disposed of properly. residues were not disposed of treatment, storage or d
Section 260.380.1(7), RSMo. properly. Section 260.380.1(7), written, signed stateme
RSMo. authorized facility. Al
actions that have been
will be sent only to au
document any shipmen
L3 Hazardous waste received from off-site I3 Hazardous waste received from off- Receive only manifest
was not manifested by the hazardous
waste transporter. 10 CSR 25- site was not manifested by the response to this inspec
9.020(1)(A)2.
hazardous waste transporter. 10 CSR receive hazardous was
25-9.020(1)(A)2. manifest. Along with
have been or will be ta
accompanied by a haz
9.020(1)(A)2.
L4 The facility was not accurately I4 The facility was not accurately Verify that resource re
classified as U, R1, or R2. 10 CSR
9.020(3)(A). classified as U, R1, or R2. 10 CSR classification, if neede
9.020(3)(A).
L5 <company> did not meet the operating I5 <company> did not meet the Operate the resource r
conditions of certification. 10 CSR
9.020(3). operating conditions of certification. CSR 9.020(3).
10 CSR 9.020(3).
L6 <company> has not submitted a written I6 <company> has not submitted a Pursue approval of cha
request and received approval from the written request and received unit. 10 CSR 9.020(3)
department for all changes in approval from the department for all
operation, including closure. 10 CSR changes in operation, including
9.020(3)(E)1 and 2. closure. 10 CSR 9.020(3)(E)1 and 2.
L7 <company> does not maintain a I7 <company> does not maintain a Maintain a written ope
written operating record. 10 CSR written operating record. 10 CSR 9.020(3)(E)5, referenc
9.020(3)(E)5, referencing 40 CFR 9.020(3)(E)5, referencing 40 CFR 7.264(2)(E)2.
264.73(b)(1) and (2), as modified by 264.73(b)(1) and (2), as modified by
10 CSR 25-7.264(2)(E)2. 10 CSR 25-7.264(2)(E)2.
16
are hazardous waste only to an authorized hazardous waste Violation Citation
disposal facility. In your response to this inspection, provide a Type
ent that <company> will ship the still bottoms only to an XXS 260.380.1(7) RSMo
long with this statement, please include a description of the
n or will be taken to ensure still bottoms that are hazardous waste
uthorized facilities. Also, include copies of manifests that
nts after the inspection. Section 260.380.1(7), RSMo.
ted hazardous waste from off-site for resource recovery. In your XXS 9.020(1)(A)2
ction, provide a written, signed statement that <company> will
ste from off-site only if it is accompanied by a hazardous waste
this statement, please include a description of the actions that
aken to ensure that only shipments of hazardous waste that are
zardous waste manifest will be accepted. 10 CSR 25-
ecovery activities are accurately classified. Change the XXS 9.020(3)(A)
ed. 10 CSR 9.020(3)(A).
recovery unit according to the conditions of the certification. 10 XXS 9.020(3)
anges that has made in the operation of the resource recovery XXS 9.020(3)(E)1&2
)(E)1 and 2.
erating record for the resource recovery activities. 10 CSR XXS 9.020(3)(E)5
cing 40 CFR 264.73(b)(1) and (2), as modified by 10 CSR 25-
6
LQG# LQG_Citation SQG# SQG_Citation Recomendation
L8 <company> has not notified the I8 <company> has not notified the Notify the Environmen
Environmental Protection Agency and Environmental Protection Agency Resources that <comp
the state that it qualifies for a small and the state that it qualifies for a your business does not
quantity on-site burner exemption, or small quantity on-site burner operate under interim
has interim status or a permit if it burns exemption, or has interim status or a 40 CFR 266.108 and 4
hazardous waste on-site. 10 CSR permit if it burns hazardous waste on-
7.266(1), incorporating 40 CFR site. 10 CSR 7.266(1), incorporating
266.108 and 40 CFR 266.103. 40 CFR 266.108 and 40 CFR
266.103.
L9 R2 facility does not use an adequate Revise the sampling an
sampling and analysis plan to access
incoming shipments - 10 CSR 25- adequate evaluation of
9.020(3)(C)1.
Install spill prevention
M1 Spill prevention controls, such as the controls are operat
check valves and dry discount dry discount couplings
couplings were not in place and such as photographs to
operating. - 10 CSR 25-5.262(1) the facility's hazardous
incorporating 40 CFR 262.34(a)(1) 262.34(a)(1) referencin
referencing 40 CFR 265.194(b)(1).
M10 Required secondary containment Provide a secondary co
system was not provided for tanks and In your response to thi
equipment. - 10 CSR 25-5.262(1) and associated contain
incorporating 40 CFR 262.34(a)(1) place. 10 CSR 25-5.2
referencing 40 CFR 265.193(a). 265.193(a).
Modify the secondary
M11 The secondary containment system was to ensure that it is cons
not constructed of or lined with waste waste that is stored an
compatible material of sufficient CSR 25-5.262(1) inco
strength and thickness - 10 CSR 25- 265.193(c)(1).
5.262(1) incorporating 40 CFR
262.34(a)(1) referencing 40 CFR Modify the secondary
265.193(c)(1). to ensure that it is supp
compression or uplift.
M12 The containment system was not referencing 40 CFR 26
supported by a base capable of
preventing failure due to settlement,
compression or uplift. - 10 CSR 25-
5.262(1) incorporating 40 CFR
262.34(a)(1) referencing 40 CFR
265.193(c)(2).
17
ntal Protection Agency and the Missouri Department of Natural Violation Citation
pany> qualifies for a small quantity on-site burner exemption. If Type
t qualify, then it must obtain a hazardous waste permit or must 266H 7.266inc. 40-266.108
status to burn hazardous waste. 10 CSR 7.266(1), incorporating
40 CFR 266.103.
nd analysis plan for the R2 resource recovery facility to ensure XXS 9.020(3)(C)1.
f incoming hazardous waste shipments. 10 CSR 25-9.020(3)(C)1.
n controls on hazardous waste tanks or make repairs to ensure that 262C 5.262inc. 40-262.34(a)(1)(ii)
ting properly. Spill prevention controls include check valves and 5.262inc. 40-262.34(a)(1)(ii)
s. In your response to this inspection, provide documentation 5.262inc. 40-262.34(a)(1)(ii)
o demonstrate that a spill prevention controls are in operation on
s waste tanks. 10 CSR 25-5.262(1) incorporating 40 CFR
ng 40 CFR 265.194(b)(1).
ontainment system for every hazardous waste tank at the facility. 262C
is inspection, provide a photograph of each hazardous waste tank
nment, documenting that a secondary containment system is in
262(1) incorporating 40 CFR 262.34(a)(1) referencing 40 CFR
containment system for the hazardous waste tanks at the facility 262C
structed of or lined with material that is compatible with the
nd is of sufficient strength and thickness to contain the waste. 10
orporating 40 CFR 262.34(a)(1) referencing 40 CFR
containment system for the hazardous waste tanks at the facility 262C 5.262inc. 40-262.34(a)(1)(ii)
ported by a base capable of preventing failure due to settlement,
10 CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(1)
65.193(c)(2).
7
LQG# LQG_Citation SQG# SQG_Citation Recomendation
M13 The containment system did not have a Install a leak detection
leak detection system capable of at the facility or modif
detecting a release within 24 hours - 10 within 24 hours. 10 C
CSR 25-5.262(1) incorporating 40 40 CFR 265.193(c)(3)
CFR 262.34(a)(1) referencing 40 CFR
265.193(c)(3). Modify the secondary
to ensure that it is slop
M14 The containment system was not Alternatively, the tank
sloped or designed to drain and remove liquids. 10 CSR 25-5.2
liquids and the tanks were not elevated
or otherwise protected from contact Modify the secondary
with liquids - 10 CSR 25- to ensure that it is capa
5.262(2)(C)2.E referencing 10 CSR 25- or the volume of the la
5.262(2)(C)2.D(III)(b). referencing 10 CSR 25
M15 The containment system was not Repair the base of the
capable of containing 10% of the the system impervious
capacity of the waste volume or the 5.262(2)(C)2.D(III)(a)
volume of the largest tank, whichever
is greater - 10 CSR 25-5.262(2)(C)2.E Prevent run-on onto th
referencing 10 CSR 25- excess containment sy
5.262(2)(C)2.D(III)(c). 10 CSR 25-5.262(2)(C
M16 The containment system had cracks or
gaps - 10 CSR 25-5.262(2)(C)2.E
referencing 10 CSR 25-
5.262(2)(C)2.D(III)(a).
M17 The facility did not prevent run-on
onto the containment system or
provide excess capacity. - 10 CSR 25-
5.262(2)(C)2.E referencing 10 CSR 25-
5.262(2)(C)2.D(III)(d).
18
Violation Citation
Type
n system in the containment system for the hazardous waste tanks 262C 5.262inc. 40-262.34(a)(1)(ii)
fy the leak detection system to ensure that it can detect a release
CSR 25-5.262(1) incorporating 40 CFR 262.34(a)(1) referencing
).
containment system for the hazardous waste tanks at the facility XXS 5.262(2)(C)2.Einc. (2)(C)2.D(III)(b)
ped or otherwise designed to drain and remove liquids.
ks may be elevated or otherwise protected from contact with
262(2)(C)2.E referencing 10 CSR 25-5.262(2)(C)2.D(III)(b).
containment system for the hazardous waste tanks at the facility XXS 5.262(2)(C)2.Einc. (2)(C)2.D(III)(c)
able of containing ten percent of the capacity of the waste volume
argest tank, whichever is greater. 10 CSR 25-5.262(2)(C)2.E
5-5.262(2)(C)2.D(III)(c).
containment system, eliminating any cracks or gaps and making XXS 5.262(2)(C)2.Einc. (2)(C)2.D(III)(a)
s. 10 CSR 25-5.262(2)(C)2.E referencing 10 CSR 25- 5.262(2)(C)2.Einc. (2)(C)2.D(III)(d)
).
he containment system for the hazardous waste tank area or ensure XXS
ystem capacity to accommodate the water that enters the system.
C)2.E referencing 10 CSR 25-5.262(2)(C)2.D(III)(d).
8
LQG# LQG_Citation SQG# SQG_Citation Recomendation
M18 The facility did not remove spilled or Remove spilled or leak
leaked waste and precipitation from hazardous waste tank a
secondary containment within 24 hours incorporating 40 CFR
or as soon as possible - 10 CSR 25-
5.262(1) incorporating 40 CFR Hazardous waste tanks were not Clearly mark or label h
262.34(a)(1) referencing 40 CFR clearly labeled or marked as CSR 25-5.262(1), inco
265.193(c)(4). 'Hazardous Waste.' 10 CSR 25- 262.34(a)(3).
5.262(1), incorporating 40 CFR
M19 Hazardous waste tanks were not clearly J9 262.34(d)(4), referencing 40 CFR Install overfill prevent
labeled or marked as 'Hazardous 262.34(a)(3). that the controls are op
Waste.' 10 CSR 25-5.262(1), alarms and automatic f
incorporating 40 CFR 262.34(d)(4), documentation such as
referencing 40 CFR 262.34(a)(3). in operation on the fac
40 CFR 262.34(a)(1) r
M2 Overfill prevention controls, such as
high level alarms and automatic feed
cutoff, were not in place and operating.
- 10 CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(1) referencing 40 CFR
265.194(b)(2).
M20 The facility was not conducting daily Conduct daily inspecti
inspections of overfill/spill control waste tanks, abovegro
equipment, aboveground portions of hazardous waste tanks
tank system, secondary containment, 5.262(1) incorporating
and data gathered from monitoring
equipment. - 10 CSR 25-5.262(1) <company> did not conduct daily Conduct daily inspecti
incorporating 40 CFR 262.34(a)(1) inspections of areas subject to spills, 5.262(2)(C)2.C(II), ref
referencing 40 CFR 265.195(a). such as waste handling areas. 10
CSR 25-5.262(2)(C)2.C(II),
M21 <company> did not conduct daily J12 referencing 40 CFR 265.195.
inspections of areas subject to spills,
such as waste handling areas. 10 CSR
25-5.262(2)(C)2.C(II), referencing 40
CFR 265.195.
M22 The facility did not maintain an Maintain an inspection
inspection log. - 10 CSR 25-5.262(1) 5.262(1) incorporating
incorporating 40 CFR 262.34(a)(1)
referencing 40 CFR 265.195(c).
19
Violation Citation
Type
ked waste and precipitation from the containment system for the 262C 5.262inc. 40-262.34(a)(1)(ii)
area within 24 hours or as soon as possible. 10 CSR 25-5.262(1)
262.34(a)(1) referencing 40 CFR 265.193(c)(4).
hazardous waste tanks with the words 'Hazardous Waste.' 10 262C 5.262inc. 40-262.34(d)(4)
orporating 40 CFR 262.34(d)(4), referencing 40 CFR
tion controls on hazardous waste tanks or make repairs to ensure 262C 5.262inc. 40-262.34(a)(1)(ii)
perating properly. Overfill prevention controls include high level 5.262inc. 40-262.34(a)(1)(ii)
fee cutoff. In your response to this inspection, provide
s photographs to demonstrate that a spill prevention controls are
cility's hazardous waste tanks. 10 CSR 25-5.262(1) incorporating
referencing 40 CFR 265.194(b)(2).
ions of overfill/spill control equipment associated with hazardous 262C
ound portions of the tanks system, secondary containment for
s, and data gathered from tank monitoring equipment. 10 CSR 25-
g 40 CFR 262.34(a)(1) referencing 40 CFR 265.195(a).
ions of hazaradous waste tank areas subject to spills. 10 CSR 25- XXS 5.262(2)(C)2.C(II)
ferencing 40 CFR 265.195.
n log for the hazardous waste tanks at the facility. 10 CSR 25- 262C 5.262inc. 40-262.34(a)(1)(ii)
g 40 CFR 262.34(a)(1) referencing 40 CFR 265.195(c).
9
LQG# LQG_Citation SQG# SQG_Citation Recomendation
Inspect cathodic protec
M23 The facility did not annually inspect impressed current sour
cathodic protection systems or inspect CFR 262.34(a)(1) refe
impressed current sources every other
month. - 10 CSR 25-5.262(1) Arrange for a detailed
incorporating 40 CFR 262.34(a)(1) engineer for tanks inst
referencing 40 CFR 265.195(b). CSR 25-5.262(1) inco
M24 The facility did not have a detailed Arrange for a written a
written assessment by an independent, for tanks lacking secon
qualified, professional engineer for 5.262(1) incorporating
tanks installed after July 14, 1986, and
keep the assessment on-site - 10 CSR Arrange for a leak test
25-5.262(1) incorporating 40 CFR and documented, perfo
262.34(a)(1) referencing 40 CFR tanks lacking secondar
265.192. 262.34(a)(1) referencin
M25 The facility did not have a written
assessment by an independent,
qualified, professional engineer for
tanks lacking secondary containment
and keep the assessment on-site - 10
CSR 25-5.262(1) incorporating 40
CFR 262.34(a)(1) referencing 40 CFR
265.191.
M26 The facility did not have a leak test,
internal inspection or tank integrity
exam performed annually and
documented, performed by an
independent, qualified, professional
engineer for tanks lacking secondary
containment - 10 CSR 25-5.262(1)
incorporating 40 CFR 262.34(a)(1)
referencing 40 CFR 265.193(i).
20
ction systems for hazardous waste tanks annually or inspect Violation Citation
rces every other month. 10 CSR 25-5.262(1) incorporating 40 Type
erencing 40 CFR 265.195(b). 262C 5.262inc. 40-262.34(a)(1)(ii)
written assessment by an independent, qualified, professional 262C 5.262inc. 40-262.34(a)(1)(ii)
talled after July 14, 1986, and keep the assessment on-site - 10
orporating 40 CFR 262.34(a)(1) referencing 40 CFR 265.192.
assessment by an independent, qualified, professional engineer 262C 5.262inc. 40-262.34(a)(1)(ii)
ndary containment and keep the assessment on-site - 10 CSR 25-
g 40 CFR 262.34(a)(1) referencing 40 CFR 265.191.
t, internal inspection or tank integrity exam performed annually 262C 5.262inc. 40-262.34(a)(1)(ii)
ormed by an independent, qualified, professional engineer for
ry containment - 10 CSR 25-5.262(1) incorporating 40 CFR
ng 40 CFR 265.193(i).
0
LQG# LQG_Citation SQG# SQG_Citation Recomendation
M27 The facility did not accomplish the Whenever hazardous w
following in response to a leak or spill: hazardous waste, remo
waste flow stopped immediately; waste and remove any visibl
removal; containment and removal of of the leak or spill, and
visible releases to the environment; 5.262(1) incorporating
notification and report; and repair or
closure - 10 CSR 25-5.262(1)
incorporating 40 CFR 262.34(a)(1)
referencing 40 CFR 265.196.
M3 The facility did not provide sufficient Manage the facility's u
freeboard in uncovered tanks to to prevent overtopping
prevent overtopping - 10 CSR 25- actions that the facility
5.262(1) incorporating 40 CFR incorporating 40 CFR
262.34(a)(1) referencing 40 CFR
265.194(b)(3). The waste or the treatment method Use tanks that are com
M4 The waste or the treatment method was J3 was not compatible with the tank. 10 methods that are used.
not compatible with the tank. 10 CSR
25-5.262(1), incorporating 40 CFR CSR 25-5.262(1), incorporating 40 actions that <company
262.34(a)(1), referencing 40 CFR
265.194(a). CFR 262.34(d)(3), referencing 40 methods are compatib
CFR 265.201(b)(2). statement that <compa
M5 <company> placed incompatible J4 <company> placed incompatible Do not place incompat
wastes in the same tank. 10 CSR 25- wastes in the same tank. 10 CSR 25- inspection, provide a d
5.262(1), incorporating 40 CFR 5.262(1), incorporating 40 CFR incompatible hazardou
262.34(a)(1), referencing 40 CFR 262.34(d)(3), referencing 40 CFR written statement that
265.199(a). 265.201(f)(1). same tank.
M6 <company> did not render ignitable or J5 <company> did not render ignitable Render safe any ignita
reactive wastes safe or protect them or reactive wastes safe or protect this inspection, provid
from sources of ignition or reaction. 10 them from sources of ignition or that ignitable and reac
CSR 25-5.262(1), incorporating 40 reaction. 10 CSR 25-5.262(1), of ignition.
CFR 262.34(a)(1), referencing 40 CFR incorporating 40 CFR 262.34(d)(3),
265.198(a)(1) & (2). referencing 40 CFR 265.201(e)(1).
21
Violation Citation
Type
waste leaks or spills from a tank, immediately stop the flow of 262C 5.262inc. 40-262.34(a)(1)(ii)
ove the waste from the secondary containment system, contain
le releases to the environment, make the appropriate notifications
d repair or properly close the hazardous waste tank. 10 CSR 25-
g 40 CFR 262.34(a)(1) referencing 40 CFR 265.196.
uncovered hazardous waste tanks to provide sufficient freeboard 262C 5.262inc. 40-262.34(a)(1)(ii)
g. In your response to this inspection, provide a description of the
y has taken to ensure prevent overtopping. 10 CSR 25-5.262(1)
262.34(a)(1) referencing 40 CFR 265.194(b)(3).
mpatible with the hazardous wastes that they hold and treatment 262C 5.262inc. 40-262.34(d)(3)
. In your response to this inspection, provide a description of the 5.262inc. 40-262.34(d)(3)
y> has taken to ensure that hazardous wastes and treatment 5.262inc. 40-262.34(d)(3)
ble with the tanks that hold them. Also, please send a written
any> will not store hazardous wastes in incompatible tanks.
tible hazardous wastes in the same tank. In your response to this 262C
description of the actions that <company> has taken to ensure that
us wastes are not stored in the same the tank. Also, please send a
<company> will not store incompatible hazardous wastes in the
able and reactive hazardous wastes in tanks. In your response to 262C
de a description of the actions that <company> has taken to ensure
ctive hazardous wastes are rendered safe or protected from sources
1
LQG# LQG_Citation SQG# SQG_Citation Recomendation
M7 <company> did not treat or store J6 <company> did not treat or store Store and treat ignitab
ignitable or reactive wastes in covered ignitable or reactive wastes in with NFPA's buffer zo
tanks in accordance with the National covered tanks in accordance with the description of the actio
Fire Protection Association's buffer National Fire Protection reactive hazardous wa
zone requirements. 10 CSR 25- Association's buffer zone accordance with NFPA
5.262(1), incorporating 40 CFR requirements. 10 CSR 25-5.262(1), statement that <compa
262.34(a)(1), referencing 40 CFR incorporating 40 CFR 262.34(d)(3),
265.198(b). referencing 40 CFR 265.201(e)(2).
M8 Volatiles with a vapor pressure of J7 Volatiles with a vapor pressure of Do not place hazardou
more than 78 millimeters of mercury at more than 78 millimeters of mercury mercury at 25 degrees
25 degrees Celsius were placed in open at 25 degrees Celsius were placed in provide a description o
tanks. 10 CSR 25-5.262(2)(C)2.F(I). open tanks. 10 CSR 25- wastes with a vapor pr
5.262(2)(C)2.F(I). Celsius are not placed
<company> will not st
millimeters of mercury
M9 Wastes and residues were not removed J8 Wastes and residues were not 5.262(2)(C)2.F(I).
from the tank and equipment upon Remove and properly
closure or the wastes and residues were
not handled properly. 10 CSR 25- removed from the tank and tank. In your response
5.262(1), incorporating 40 CFR
262.34(a)(1), referencing 40 CFR equipment upon closure or the <company> has taken
265.197(a).
wastes and residues were not handled closed hazardous wast
properly. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(d)(3),
referencing 40 CFR 265.201(d).
B1 <company> stored hazardous waste Ship all hazardous was
for more than 180 days, (or more must ship the waste m
than 270 days if the waste is that waste is not stored
transported further than 200 miles). provide a copy of each
10 CSR 25-5.262(1), incorporating authorized hazardous w
40 CFR 262.34(d) or 40 CFR a photograph of the are
262.34(e). been removed, and a w
for a period longer tha
5.262(1), incorporating
D11 <company> had not made Make arragements wit
arrangements with local emergency 5.262(1), incorporating
agencies. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(d)(4),
referencing 40 CFR 265.37.
22
Violation Citation
Type
ble and reactive hazardous wastes in covered tanks in accordance 262C 5.262inc. 40-262.34(d)(3)
one requirements. In your response to this inspection, provide a
ons that <company> has taken to ensure that ignitable and
astes that are stored in covered tanks are treated and stored in
A's buffer zone requirements. Also, please send a written, signed
any> will meet the NFPA buffer zone requirements.
us wastes with a vapor pressure of greater than 78 millimeters of XXS 5.262(2)(C)2.F(I).
s Celsius in open tanks. In your response to this inspection, 5.262inc. 40-262.34(d)(3)
of the actions that <company> has taken to ensure that hazardous
ressure of greater than 78 millimeters of mercury at 25 degrees
in open tanks. Also, please send a written, signed statement that
tore hazardous waste with a vapor pressure of greater than 78
y at 25 degrees Celsius in an open tank. 10 CSR 25-
manage wastes and residues from the closed hazardous waste 262C
e to this inspection, provide a description of the actions that
to remove and properly manage wastes and residues from the
te tank.
ste that has been stored for more than 180 days (270 days if you 262C 5.262inc. 40-262.34(d)(3)
more than 200 miles). Change <company>'s procedures to ensure 5.262inc. 40-262.34(d)(4)
d for longer than these limits. In your response to this inspection,
h manifest that was used to ship the hazardous waste to an
waste treatment, storage or disposal facility. Also, please provide
ea where the wastes were stored, documenting that they have
written statement that <company> will not store hazardous waste
an allowed by the hazardous waste regulations. 10 CSR 25-
g 40 CFR 262.34(d) or 40 CFR 262.34(e).
th local agencies to respond to emergencies. 10 CSR 25- 262C
g 40 CFR 262.34(d)(4), referencing 40 CFR 265.37.
2
LQG# LQG_Citation SQG# SQG_Citation Recomendation
D5 The emergency coordinator's name Post the emergency co
and telephone number were not CSR 25-5.262(1), inco
posted near the telephone. 10 CSR
25-5.262(1), incorporating 40 CFR
262.34(d)(5)(ii)(A).
D6 The telephone number of the fire Post the fire departmen
department was not posted near the incorporating 40 CFR
telephone. 10 CSR 25-5.262(1),
incorporating 40 CFR
262.34(d)(5)(ii)(C).
D7 The location of the fire extinguisher Post the location of the
and spill control equipment were not 10 CSR 25-5.262(1), i
posted near the telephone. 10 CSR
25-5.262(1), incorporating 40 CFR
262.34(d)(5)(ii)(B).
D8 Employees were not familiar with Train employees to en
waste handling and emergency procedures. 10 CSR 2
procedures. 10 CSR 25-5.262(1),
incorporating 40 CFR
262.34(d)(5)(iii).
E1 <company> did not use the manifest Use the hazardous was
system or reclaim wastes under a of hazardous waste. In
contractual agreement. Section of the actions that <co
260.380.1(6), RSMo, and 10 CSR 25- from the property use
5.262(2)(B) or 10 CSR 25-5.262(1), a contractual agreemen
incorporating 40 CFR 262.20(e)1. shipments that have be
10 CSR 25-5.262(2)(B
E14 'Land-Ban' notification/certification Provide copies of the '
was not sent with manifests or with during the inspection.
the first shipment. 10 CSR 25-
7.268(1) incorporating 40 CFR
268.7(a).
23
oordinator's name and telephone number near the telephone. 10 Violation Citation
orporating 40 CFR 262.34(d)(5)(ii)(A). Type
262C 5.262inc. 40-262.34(d)(5)(ii)(B)
nt's telephone number near the telephone. 10 CSR 25-5.262(1), 262C 5.262inc. 40-262.34(d)(5)(ii)(C)
262.34(d)(5)(ii)(C).
e fire extinguisher and spill control equipment near the telephone. 262C 5.262inc. 40-262.34(d)(5)(ii)(B)
incorporating 40 CFR 262.34(d)(5)(ii)(B).
nsure that they are familiar with waste handling and emergency 262C 5.262inc. 40-262.34(d)(5)(iii)
25-5.262(1), incorporating 40 CFR 262.34(d)(5)(iii).
ste manifest system or a contractual agreement for all shipments 262B 5.262inc. 40-262.20(e)1
n your response to this inspection, provide a written description 7.268inc. 40-268.7(a)
ompany> has taken to ensure that all shipments of hazardous waste
a hazardous waste manifest or that the wastes are reclaimed under
nt. Also, please provide copies of any manifests that document
een made after the inspection. Section 260.380.1(6), RSMo, and
B) or 10 CSR 25-5.262(1), incorporating 40 CFR 262.20(e)1.
'Land Ban' notifications/certifications for the shipments identified 268A
10 CSR 25-7.268(1) incorporating 40 CFR 268.7(a).
3
LQG# LQG_Citation SQG# SQG_Citation Recomendation
E3 <company> did not maintain a copy Keep the reclamation a
of the reclamation agreement on-site 25-5.262(1), incorpora
for at least three years after
expiration of the agreement. 10 CSR
25-5.262(1), incorporating 40 CFR
262.20(e)(2).
J1 Uncovered hazardous waste tanks Maintain at least two f
did not have two feet of freeboard or tanks. In your respons
a containment system. 10 CSR 25- tanks that are currently
5.262(1), incorporating 40 CFR freeboard or a containm
262.34(d)(3), referencing 40 CFR <company> will take a
265.201(b)(3). with two feet of freebo
incorporating 40 CFR
J10 Inspections of waste feed cut off, Conducting daily insp
bypass system, monitoring data and data, and freeboard. 1
freeboard were not conducted each referencing 40 CFR 26
operating day. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(d)(3),
referencing 40 CFR 265.201(c).
J11 <company> did not conduct weekly Conducting weekly in
inspections of confinement construction materials
structures, construction materials and 5.262(1), incorporating
general area for leaks, corrosion or
discharges. 10 CSR 25-5.262(1),
incorporating 40 CFR 262.34(d)(3),
referencing 40 CFR 265.201(c)5.
J2 Continuously fed tanks were not Provide a feed cut-off
equipped with a feed cut-off system your response to this i
or a proper by-pass system. 10 CSR that are currently in us
25-5.262(1), incorporating 40 CFR cut-off system or a pro
262.34(d)(3), referencing 40 CFR 262.34(d)(3), referenc
265.201(b)(4).
24
Violation Citation
Type
agreement on-site for at least three years after it expires. 10 CSR 262B 5.262inc. 40-262.20(e)1
ating 40 CFR 262.20(e)(2).
feet of freeboard or a containment system for hazardous waste 262C 5.262inc. 40-262.34(d)(3)
se to this inspection, provide a photograph of the hazardous waste 5.262inc. 40-262.34(d)(3)
y in use at <company>, documenting that they have two feet of
ment system. Also, please send a written statement that
action to ensure that hazardous waste tanks will be maintained
oard or a containment system. 10 CSR 25-5.262(1),
262.34(d)(3), referencing 40 CFR 265.201(b)(3).
pections of the tank's waste feed cut off, bypass system, monitoring 262C
10 CSR 25-5.262(1), incorporating 40 CFR 262.34(d)(3),
65.201(c).
nspections of the hazardous waste tank's containment structure, 262C 5.262inc. 40-262.34(d)(3)
s, and general area for leaks, corrosion, or discharges. 10 CSR 25-
g 40 CFR 262.34(d)(3), referencing 40 CFR 265.201(c)5.
system or a proper bypass system for hazardous waste tanks. In 262C 5.262inc. 40-262.34(d)(3)
inspection, provide a photograph of the hazardous waste tanks
se at <company>, documenting that they are equipped with a feed
oper bypass system. 10 CSR 25-5.262(1), incorporating 40 CFR
cing 40 CFR 265.201(b)(4).
4
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LQG# LQG_Citation SQG# SQG_Citation Recomendation Violation Type Citation B14 Hazardous waste was not packaged/labeled/marked per Department of Transportation
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