C

2195 Front StreetLogan, Ohio 43138

CX*MState of Ohio Environmental Protection Agency

Southeast District OfficeTELE: (740) 385-8501 FAX: (740) 385-6490

www.ea.state.oh.usTed Strickland. Governor

Lee Fisher, Lieutenant GovernorChris Korieski, Director

August 6, 2009

Mr. Greg DicksonShop ManagerMarietta Ignition321 Second StreetMarietta, OH 45750

Dear Mr. Dickson:

WASHINGTON COUNTYMARIETTA IGNITIONDHWM/SEDOOHDO1 8155374

On August 3, 2009, Ohio EPA conducted a compliance evaluation inspection at MariettaIgnition located at 321 Second Street in Marietta to determine compliance with Ohio'shazardous waste laws and regulations as found in the Ohio Revised Code (ORC) andthe Ohio Administrative Code (OAC). During the inspection, I helped Marietta Ignitionidentify ways to prevent pollution by reducing waste. This letter will explain theviolations I found, and the actions that Marietta Ignition has taken to respond to theviolations.

I found the following violations of Ohio's hazardous waste laws:

OAC Rule 3745-279-22(C)(1), Used Oil Storage Requirements forGenerators:

Containers and aboveground tanks used to store used oil at generator facilitiesmust be labeled or marked clearly with the words "used oil."

Two aboveground 250-gallon tanks of used oil outside the shop were not labeled"used oil", in violation of this rule. Marietta Ignition submitted e-maildocumentation on August 5, 2009, in the form of photographs, showing thetanks have been properly labeled. No further action is necessary.

OAC Rule 3745-273-13(D)(1), Waste Management - Standards for SmallQuantity Handlers of Universal Waste:

A small quantity handler of universal waste must contain any lamp in containersor packages that are structurally sound, adequate to prevent breakage, andcompatible with the contents of the lamps. Such containers and packages mustremain closed and must lack evidence of leakage, spillage, or damage that couldcause leakage under reasonably foreseeable conditions.

(1)

(2)

Printed on Recyded Paper Ohio EPA is an Equal Opporlunily Employer

Mr. Greg DicksonMarietta IgnitionAugust 6, 2009Page 2

Several spent fluorescent bulbs were lying against the wall in the shop, notcontained in a box or other suitable container, in violation of this rule. MariettaIgnition submitted e-mail documentation on August 5, 2009, in the form ofphotographs, showing the bulbs have been placed into a suitable box. No furtheraction is necessary.

(3)

OAC Rule 3745-27-14(E), Labeling/Marking - Standards for SmallQuantity Handlers of Universal Waste:

Each lamp or a container or package in which such lamps are contained must belabeled or marked clearly with one of the following phrases: "Universal Waste-Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)."

Spent fluorescent bulbs we e not contained properly in a box or other suitablecontainer. Marietta Ignition submitted e-mail documentation on August 5, 2009,in the form of photographs, showing the box has been properly labeled. Nofurther action is necessary.

GENERAL COMMENTS

(a) For your information, I have enclosed a fact sheet regarding fluorescent bulbs.As we discussed, fluorescent bulbs are a universal waste and must be managedunder the universal waste rules in OAC 3745-273.

As discussed during the inspection, you may be able to reduce the waste your companygenerates. If you find ways to recycle, reduce, or altogether eliminate the amount ofwaste that your company generates, you may be able to reduce treatment and disposalcosts, and you may possibly reduce your regulatory requirements. The Ohio EPAstrongly encourages pollution prevention as the preferred approach for wastemanagement. The first priority of pollution prevention is to eliminate the generation ofwastes and pollutants at the source (source reduction). For wastes or pollutants thatare generated, the second priority is to recycle or reuse them in an environmentallysound manner. You may benefit economically, help preserve the environment, andimprove your public image by implementing pollution prevention programs. You canfind more information about pollution prevention, including fact sheets, at the followingweb address: http//www.epa.state.oh.us/ocapp recycle.html. If you would like to beconsidered for an in-depth on-site pollution prevention assessment, or if you would likemore information about pollution prevention assessments, please contact me.

Mr. Greg Dickson S

.Marietta IgnitionAugust 6, 2009Page 3

Enclosed, you will find a copy of the checklists that were completed during theinspection. Should you have any questions, please feel free to contact me at (740) 380-5288. You can find copies of the rules and other information on the division's web pageat htti:/Iwww.epa.state.oh.us/dhwm.

Sincerely,

Scott N. BergreenEnvironmental SpecialistDivision of Hazardous Waste Management

SNB/mlm

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

your company from having to comply with all applicable regulations.

S

.For Ohio EPA use onlyOhio Environmental Protection Agency

RCRA SUBTITLE C SITEIDENTIFICATION/VERIFICATION FORM

E-mail this completed form to kristina .durneIl(äepa .state.oh. usor mail it to Kristina Durnell, Central Office

Site EPA ID No. EPA ID Number: 0HD018155374Site Name Name: Marietta Ignition Website:

(Optional)Site Location Information Street Address: 321 Second Street

City, Town, or Village: Marietta State: OHCounty Name: Washington Zip Code: 45750

Site Land Type Private County District Federal Indian Municipal State Other(check only one) Z E Lii LI LI LI LI 0NAICS code(s)wwwcensusgov/ecd/www/naics.htmlFacility Representative First Name: Greg Ml: Last Name: Dickson

Phone Number: (740) 374-6758 Phone Number Extension:Additional names can be E-Mail Address: s716mariettaignstoreuniseIectusa.comrecorded in number 12 Fax Number: (740) 374-6758 Fax Number Extension:

Street or P.O. Box: 321 Second StreetOnly provide address City, Town or Village: Mariettainformation if it is different State: OH Zip Code: 45750than the site addressLegal Owner And Name of Site's Legal Owner:Operator of the Site. Uni-Select USA Date Became Owner (n'imfddlyyyy):List Additional Owners Owner Private County District Federal Indian Municipal State Otherand/or Operators in the Type: Z LII LI LI LI LI LI LIComment Section or on Street or P.O. Box:another copy of this form City, Town or Village: Owner Phone #:page State: Country: Zip Code:

Name of Site's Operator: Date Became OperatorMarietta Ignition (mmldd/yyyy):Operator Private County District Federal Indian Municipal State Other

Type: 1K LI LI LI 0 0 LI 0Street or P0. Box: 321 Second StreetCity, Town or Village: Marietta Operator Phone #: (740) 374-6758State: OH United States Zip Code: 45750

VIOLATIONS CITED? 0 Yes DNo

TYPE OF HANDLER— A MINIMUM OF ONE BOX MUST BE CHECKEDNot a HW Generator LJUNKNOWN : LilLarge Quantity Generator (LQG)

Cited for violation of 3745-52-11OSmalI Quantity Generator (SQG)DConditionally Exempt Small Quantity GeneratorflU S. Importer of Hazardous Waste[—]Mixed Waste (Hazardous and Radioactive)

Generator

S .TYPE OF REGULATED WASTE ACTIVITY (MARK "X" IN ALL OF THE APPROPRIATE BOXES)D Recycler of Hazardous Waste Iii Exempt Boiler and/or Industrial Furnace0 Underground Injection Control Facility LI Small Quantity On-Site Burner Exemption

Hazardous Waste Transporter LI Smelting, Melting, Refining Furnace ExemptionEl Treater, Storer or Disposer of Hazardous Waste

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

Small Quantity Handler of Universal Waste Destination Facility for Universal WasteO Large Quantity Handler of Universal Waste

(accumulates 5,000 kg. or more)CHECK ALL BOXES BELOW THAT APPLY FOR THE TYPES OF UNIVERSAL WASTE THE FACILITY MANAGES

BatteriesO Pesticides

Mercury containing equipmentLamps . -

USED OIL ACTIVITIES (INDICATE TYPE(S) OF ACTIVITY(S)Used Oil Generator

fl Used Oil TransporterD Used Oil Transfer Facility0 Used Oil ProcessorO Used Oil Re-refinerO Off-Specification Used Oil BurnerO Used Oil Fuel Marketer Who Directs Shipment of Off-Spec. OilO Used Oil Fuel Marketer to Off-Specification Used Oil BurnerWaste Codes for Federally Regulated Hazardous Wastes. Please list the codes for the federally regulated hazardous waste handled at the site. Listthem in the order they are presented in the regulations (e.g., DOOl, D003, F007, U112). Use an additional page if more space is needed. If there aremore than 7 waste codes and they are the same as listed in the most recent RCRAInfo source , record. you do not need to list them all. Instead justindicate the date of the most recent source record.

COMMENTS: USE THIS AREA TO DESCRIBE WHETHER THE INSPECTION WAS ANNOUNCED, WHETHER THEWASTE IS STORED IN TANKS OR CONTAINERS, ETC.Announced Yes No Additional Facility Representatives:Tanks Yes No Other Comments:Containers Yes EJ No

Date of Inspection/TimeName of Inspector(s) Name of Inspector(s) (mmfdd/yyyy) (hh:mm)Scott Bergreen 81312009 1015 - 11:30 amOPTIONAL 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,including the possibility of fine and imprisonment for knowing violations.

Signature of Owner, Operator, or an Authorized -Representative Name and Title (Print) Date (mm/dd/yyyy)

Revised it 03.08.SiteVerilyForm.doc

PROCESS, WASTE, P2 SUMMARY SHEETFacility Name: Marietta Facility Type: Non-generator Date of Inspection: EPA ID #: 0HD018155374Ignition 8/3/09

Waste Generated On- or Off-Site P2 ActivitiesManagement

Process/Activity Waste QTY Generated Type of On-Site Name, state, and Current P2 P2 OpportunitiesGenerating Waste 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 waste

Waste Code if applic, accumulation area

I Maintenance Used Oil Small quantities N/A N/A Burn used oil ingenerated from space heater

Stored in two motors, parts, inside shop275 g. tanks and equipmentoutside theshop

2 Maintenance Fluorescent Small quantities N/A Spent bulbs Recycle spentBulbs generated recycled through bulbs

Spent bulbs are Washington Co.Universal stored inside Solid Waste Mgt.Waste shop District

3 Battery Returns Spent Lead Number of N/A Exide Recycle spentAcid Batteries batteries recycled Charleston, WV batteries Svaries

Stored on a palletinside auto partsstore

4 Parts Washing Bag Filters Filters are located N/A Solid wastein each of 5 parts disposal through

non- washers Rumpkehazardous

PSS Table Format Handwritten UseJune 2007 Page 1 of 3

5 Jet Washing Liquid/Sludge Jet washers are N/A Envirotank Cleanpumped out 1 Belpre, OH

non- time/year (600+hazardous gallons ea. time)

6 Cleanup Shop Rags Quantities vary N/A Vogue Swift Launder dirtyCleaners rags

non- Soiled rags stored Marietta, OHhazardous inside shop

7 Maintenance Scrap Metal Quantities vary N/A American Car Scrap metalCrushing recycledMarietta, OH

8 Parts Cleaning Dust Collector Quantities vary N/A Solid wasteFines

disposal throughRum pke

non-hazardous

9 Parts Cleaning Spent Quantities vary N/A Solid wastesandblast disposal throughmaterial Rumpkenon-hazardous

PSS Table Format Handwritten UseJune 2007 Page 2of3

%MARKS-GENERAL INFORMATSI

General Process Information:

Marietta Ignition, located at 321 Second Street in Marietta, consists of a retail AutoValue auto parts store and an attached machine shop. The business has been inMarietta for close to 90 years. The machine shop performs a variety of engine andparts services and engine rebuilding operations. The machine shop uses 5 partswashers for general parts cleaning purposes and a jet washing and drying system forlarger parts. The parts washers use non-hazardous Mobil odorless mineral spirits,equipped with a bag filtration system to remove solids and contaminants such as oil andgrease. No liquid solvent is disposed of; when solvent evaporates, new solvent isadded. Solids removed from the units as bag filters have tested non-hazardous and aredisposed of in the trash after drying. The jet washing system uses a powder consistingof sodium metasilicate, sodium carbonate, and monosodium phosphate to clean theparts. Sludges generated from this unit have tested non-hazardous. Envirotank Cleanpumps the liquids and sludges out of this system approximately every year for treatmentat their Belpre facility as a non-hazardous waste. The drying system consists of a largeoven where parts are heated to remove any moisture and a pellet shot impact systemwhere auto parts are further cleaned to remove contaminants. TCLP results of the dustcollector fines from the pellet shot system indicate non-hazardous levels. The machineshop uses a methylene chloride based carburetor cleaner to soak parts in, however, nosolvent is disposed of, only new solvent added when necessary. A small sandblast unitis used to clean rust, scale, and small amounts of paint off parts. The spent sand isdisposed of as a solid waste. Fluorescent bulbs generated at Marietta Ignition arerecycled through the Washington County Solid Waste Management District's annualspring collection event at Solvay in Marietta.

Regulatory/Enforcement History:

The last compliance evaluation inspection was conducted at Marietta Ignition onDecember 12, 2001.

Additional P2 remarks and information:

Would this facility be interested in a P2 assessment? Yes* NoX

PSS Table Format Handwritten UseJune 2007 Page 3of3

daCONDITIONALLY EXEMPT SMALL QUANTITY GENERAT3R REQUIREMENTS

COMPLETE AND ATTACH A PROCESS, WASTE, P2 SUMMARY SHEET

CESQG: 00Kg. (Approximately 25-30 gallons) of waste in a calendar month or < 1 Kg. of acutely hazardous waste.SQG: Between 100 and 1,000 Kg. (About 25 to under 300 gallons) of waste in a calendar month.LQG: Z:1,000 Kg. (-300 gallons) of waste in a calendar month or A Kg. of acutely hazardous waste in a calendar month.NOTE: To convert from gallons to pounds: Amount in gallons x Specific Gravity x 8.345 = Amounts in pounds.Safety Equipment Used:WASTE EVALUATION

1. Have all wastes generated at the facility been adequately evaluated? Yes No El N/A LI[3745-52-11] -

GENERATOR CLASSIFICATION2. Does the generator produce <100 kg. of hazardous waste per month? Yes U No N/A Z

[conditionally exempt small quantity generator (rCESQG)]NOTE: If quantities of hazardous waste accumulated on-site at any one time exceed 1.000 Kg. - or the generator producesbetween 100 and 1,000 Kg. of hazardous waste per month, it/s operating as a Small Quantity Generator (SQG. if so,complete the Small Quantity Generator Requirements checklist.

OFF-SITE SHIPMENT OF HAZARDOUS WASTE3. Does the CESQG ensure delivery of hazardous waste(s) to an off-site Yes El No 0 N/A

permitted TSD? [3734.02(F))TREATMENT OF HAZARDOUS WASTE

4. Does the generator treat hazardous waste in a:a. Container that meets 3745-66-70 to 3745-66-77? Yes 0 No N/A

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

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

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

NO TE: Complete appropriate checklist for each unit.NOTE: lf the CESQG conducts treatment they are subject to the LOG requirements.NOTE: if waste is treated to meet LORs, use LDR checklist.MIX HAZARDOUS WASTE WITH USED OIL

5. Does the CESQG mix its hazardous waste with used oil for the purpose of Yes El No 0 N/A Elburning for energy recovery? 3745-51-05(J)J If so:a. Does the CESQG manage the mixture in accordance with 3745-279- Yes LI No 0 N/A

121?

CESQG/February 2009Page 1 of 1

USED OIL INSPECTION CHECKLISIWGENERATORS, COLLECTION CENTERS AND AGGREGATION POINTS

NOTE: A facility is subject to the federal SPCC regulations (40 CFR 112) if it is non-transportation (elated (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.PROHIBITIONS __________________1. Does the generator manage used oil in a surface impoundment or waste pile? Yes 0 No Z N/A U

If yes:a. Is the surface impoundment or waste pile regulated as a hazardous Yes LI No 0 N/A Z

waste _management _unit? _{3745-279-1 2(A)]NOTE: For example, used oil contaminated scrap metal stored in a pile.2. 1 Is used oil used as a dust suppressant? [3745-279-12(B)] Yes 0 No X N/A U3. JIs off-specification used oil fuel burned for energy recovery in devices specified Yes D No EJ N/A

in 3745-279-12(C)? NOTE., Multiple used oil checklists may be applicable if used oil handler is performing multiple tasks (e.g., If generatingused 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 D No 0 N/A U- a. I Is the mixture managed as specified in 3745-279-10(B)? [3745-279- Yes LI No [I N/A

21(A)]NOTE: Used Oil mixed with listed (3745-51-30 to 3745-51-35) or characteristic (3745-51-20 to 3745-51-24) hazardouswaste 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 D No 0 N/A

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

NOTE: If used oil contains greater than 1000 ppm total halogens, it is presumed to be listed hazardous waste until thepresumption is successfully rebutted.6. Does the generator store used oil in tanks; or containers; or a unit(s) subject to Yes Z No LI NIA LI- regulation as a hazardous waste management unit? [3745-279-22(A)]7. Are containers and aboveground tanks used to store used oil in good condition Yes M No 0 N/A 0

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

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: Yes No El N/A LI

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

- b. Contained the release? Yes 0 No fl N/A DC. Cleaned up and properly managed the used oil and other materials? Yes E No LI N/A LI

d. Repaired or replaced the containers or tanks prior to returning them to Yes No 0 N/Aservice, if necessary?

ON-SITEBURNING IN SPACE HEATER10. Does the generator burn used oil in used-oil fired space heaters? [3745-279-

23) If so:a. Does the heater burn only used oil that owner/operator generates or Yes C9 No 0 N/A LI

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

Marietta Ignition/8/3109 Inspection Date][OHDO181 55374]

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

b. Is the heater designed tO ye a maximum capacity of not more that Yes Z No LI N/A Eli0.5 million BTU per hour?

C. Are the combustion gases from heater vented to the ambient air? Yes 0 No fl N/A El

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

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

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

generator or an employee of the generator? [3745-279-24]- b. Does the generator transport more than 55 gallons of used oil at any Yes fl No El N/A

time? [3745-279-24] NOTE: Used oil generators may arrange for used oil to be transported by a transporter without a U.S. EPA ID # if theused oil is reclaimed under a contractual agreement (i.e., tolling arrangement).COLLECTION CENTERS AND AGGREGATION POINTS13. Is the DIY used oil collection center in compliance with the generator Yes 0 No N/A

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? 13745-279- Yes 0 No N/A

31115. Is the used oil aggregation point in compliance with the generator standards in Yes E1 No N/A Z

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

[Marietta Ignition/8/3109 Inspection Date][0HD018155374]

Used Oil Checklist for Generators/June 2008Page 2 012

aAM

SMALL QUANTITY UNIXTIRSAL WASTE HANDLER REQUIREME - BATTERIES AND LAMPSLarge Quantity Universal Waste Handler (LQUWH) = 5,000 Kg or moreSmall Quantity Universal Waste Handler (SQUWH) = 5,000 Kg or lessPROHIBITIONS1. Did the SQUWH dispose of universal waste? [3745-273-11(A)] Yes LI No 0 N/A LI

2. Did the SQUWH dilute or treat universal waste, except when responding to Yes No j N/Areleases as provided in OAC rule 3745-273-17 or managing specific wastesas provided in OAC rule 3745-273-13? [3745-273-11(8)]

WASTE MANAGEMENT AND LABELING/MARKINGUNIVERSAL WASTE BATTERIES3. Are batteries that show evidence of leakage, spillage or damage that could Yes 0 No Li N/A

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

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

5. Are the casings of the batteries breached, not intact, or open (except to Yes LI No LI N/Aremove the electrolyte)? [3745-273-13(A)]

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

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

b, lf the electrolyte or other waste is not hazardous, is it managed in Yes fl No LI N/Acompliance with applicable law? [3745-273-13(A)(3)(b)]

7. - Are the batteries or containers of batteries labeled with the words Yes No fl N/A 0"Universal Waste - Batteries" or "Waste Battery(ies)" or Used Battery(ies)?"[3745-273-14(A)]

UNIVERSAL WASTE LAMPS8. Does the SQUWH contain lamps in containers or packages that are Yes No 0 N/A El

structurally sound, adequate to prevent breakage, and compatible withcontents of the lamps? Are containers or packages closed and do they lackevidence of leakage, spillage or damage that could cause leakage? [3745-273-13(0)(1)]

9. Are lamps that show evidence of breakage, leakage or damage that could Yes LI No LI N/A 0cause a release of mercury or hazardous constituents into the environmentimmediately cleaned up? Are they placed into a container that is closed,structurally sound, compatible with the contents of the lamps, and lackevidence of leakage, spillage or damage that could cause leakage orreleases of mercury or hazardous waste constituents to the environment?13745-273-13(D)(2)]

NOTE: Treatment (such as crushing) by a UWH is prohibited under this rule unless the facility is permittedfor such activities [3745-273-31(B)]. A generator crushing lamps must manage lamps according to hazardouswaste rules (OAC Chapter 3745-52). Lamp crushing is a form of generator treatment (OAC rule 3745-52-34).Crushed lamps must be transported by a registered hazardous waste transporter to a permitted hazardous wastefacility using a hazardous waste manifest.10. Are the lamps or containers or packages of lamps labeled with the words Yes LI No 0 N/A 0

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

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

SQUW H-B&L1 1-21 -OBrevisions

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

a. If not, is the waste accumulated over one year in order to facilitate Yes L1 No LI N/Aproper recovery, treatment or disposal? (Burden of proof is on thehandier _to_ demonstrate) _[3745-273-15(B)]

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

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

If yes, describe below: Marietta Ignition recycles spent bulbs during theannual spring collection event at Solvay in Marietta.

EMPLOYEE TRAINING13. Are employees who handle or have the responsibility for managing Yes 0 No D N/A 0

universal waste informed of waste handling/emergency procedures, relativeto their responsibilities? [3745-273-161

RESPONSE TO RELEASES14. Are releases of universal waste and other residues immediately contained? Yes El No N/A Z

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

16. If the material released is a hazardous waste, was it managed as required Yes LI No El N/Ain OAC Chapters 3745-50 through 3745-69? (If the waste is hazardous, thehandler is considered the generator of the waste and is subject to OACChapter 3745-52)13745-273-17(B)]

OFF-SITE SHIPMENTS

NOTE: If a SQUWH self-transports waste, then the handler must comply with the Universal Waste transporterrequirements. ____17. Are universal wastes sent to either another handler, destination facility or Yes No El N/A 0

foreign destination? [3745-273-1 8(A)l18. Is the handler aware of DOT requirements for packaging and shipping? Yes Z No LI N/A 0

If no, make aware of 49 CFR 171-180.19. Prior to shipping universal waste off-site, does the originating handler Yes 0 No E N/A

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

another handler or destination facility?a. If yes, did the originating handler receive the waste back or agree to Yes II No El N/A

where the _shipment _was _sent? _[3745-273-18(E)(2)]21. If a handler rejects a partial or full load from another handler, does the Yes LI No LI N/A

receiving handler contact the originating handler and discuss and do one ofthe following:a. Send the waste back to the originating handler or send the shipment Yes No 0 N/A

to a destination facility (If both the originating and receiving handleragree?J3745-273-1 8(F)(2)]

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

EXPORTS

RCRA SMALL QUANTITY UNIVERSAL WASTE HANDLER - BATTERIES & LAMPS INSPECTION CHECKLISTPage 2of3

SQUWH-B&L1 1-21-08revisions

I 23. 1 is waste being sent to a foreign destination? if so: Yes fl No 0 N/A 0

a

C.

Does the small quantity handler comply with primary exporterrequirements in OAC rules 3745-52-53, 3745-52-56, and 3745-52-57? [3745-273-20(A)]Is waste exported only upon consent of the receiving country and inconformance with the U.S. EPA "Acknowledgment of Consent" asdefined in OAC rules 3745-52-50 to 3745-52-57? [3745-273-20(B)]Is a copy of the U.S. EPA "Acknowledgment of Consent" provided tothe transporter? 3745-273-20(C)]

Yes No Li N/A

Yes LI No LII N/A

Yes LI No [] N/A

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

SQUWR-B&L1 1-21 -08revisions