pend dekeeerel Le Western Oregon UNIVERSITY ® ine March 30, 2015 Susan Sheweczyk Department of Environmental Quality 750 Front St NE #120 Salem, OR 97301-1039 RE: Pre-Enforcement Notice PEN-WR-HW-15-003 Western Oregon University orD035016978 Polk County Ms. Sheweczyk: This is to serve as our response to your letter dated January 26, 2015. We have listed below our responses to the issues that your inspection on December 9, 2014 brought up. 2012/2014 Large Quantity Generator reporting We are disputing that Western Oregon University (WOU) needed to register as a Large Quantity Generator (LOG) for both the 2012 and 2014 calendar years. There is a discrepancy in the figures that your letter indicated. On manifest #0168178, dated 5/29/12, you indicate that the manifest shows 10Ibs of P098/D003 waste (waste potassium cyanide) that was not accounted for in our reporting to DEQ. The actual weight of the PO98/0003 waste that was disposed of was 6-10 ounces total. On the packing list it shows one full container that contained 2 ounces of waste, and a quart container that was ¥ full, for an estimated 4-8 ounces of waste. The P098/D003 was placed in a Labpack with vermiculite for transport. On manifest #725665, dated 1/27/14, you indicate that the manifest shows 1lb of PO48 and Sibs of PO98 waste that was not reported to DEQ. The actual total weight of both PO48 and PO98 waste was 855 grams as indicated on the packing slip, The PO48 and PO98 waste was placed in three Labpacks with vermiculite for transport. I've attached copies of the packing slips for your review. Public Safety 345 Monmouth Ave, N. Monmouth, Oregon 97361 « 503-836 8481 + 503-838-8100 (fan *safety@wou.edu © wiw.wou.eduWe have entered our 2012 hazardous waste totals in DEQ's online Hazardous Waste reporting site, but with the information listed above, we feel that further review is necessary to see exactly where WOU falls in its generator status. Fees have not been assessed by DEQ yet, but once we receive that invoice we will pay the fee. Hazardous Waste was stored for over 90 days The Hazardous Waste building has been cleaned out, and the following have been disposed of properly. + Microfiche was recycled on March 13, 2015 with Garten Services + Mercury debris was disposed of on March 10”, 2015 with Veolia Environmental Services. + Asbestos was disposed of on January 28, 2015 with W.L. Thomas ‘+ Waste thinner residue for Physical Piant paint cabinet, approximately two quarts in each of the two blue plastic containers has been removed from the containers and placed in the waste traffic paint containers for disposal "ve attached copies of the manifests of disposal for the microfiche, mercury and asbestos. We have scheduled disposal of the waste thinner residue and waste traffic paint on April 20, 2015, with Veolia Environmental, Hazardous Waste training for management and employees (On March 25, 2015 the following WOU staff attended DEQ Hazardous Waste training at the Keizer location: Allen Risen, Occupational & Environmental Safety Officer Rebecca Chiles, Director, Campus Public Safety Tony Kment, Assistant Director, Physical Plant Services Tim Wallen, Painting Supervisor, Physical Plant Services Heather Gonzalez, Lab Prep, DeVolder Science building Kevin Hughes, Grounds Maintenance Supervisor, Physical Plant Services With the ebove primary people having received training, we will also be implementing a Hazardous Waste training program for all new faculty/staff/student workers who have the possibility of coming in contact with hazardous waste. Ihave discussed with Bart about putting on a campus wide hazardous waste training program. Each department will be responsible for providing hazardous waste training to their new employees within 30 days of hire, and will keep a log oftheir training in their own department's files. Sediment in sump/drains and oil/water separator, unusable containers in paint cabinet ‘The spray paint cans in the cabinet that were inoperable were disposed of in the aerosol can disposal drum. The remaining containers contain useable paint and solvents and are stil in the cabinet. I've attached a list of the containers that were disposed of. Tony Kment, Assistant Director, Physical Plant is currently working on having the sump/drain and oil/water separator analyzed, He has been in contact with you (Susan) for clarification as to what needs to be analyzed. After speaking with you, Tony believes that a “Self Analysis Assessment” form stating that the sump/drain/separator contains no hazardous waste is all that is needed, but he will be scheduling a vendor torun the analysis to ensure that no contaminants are in them pet your request. We will have the results to DEQ before June 30, 2015. Open hazardous waste containers were being evaporated off in DeVolder #207 and NS #124 | have spoken with each department and informed them that they cannot “evaporate off” their chemical wastes. All chemicals used by the department must be disposed of properly and quantities added to our monthly waste generation status reports. Label, date, and close all hazardous waste in storage areas. Inspect areas weekly. The solvent from the thirteen 5-gallon buckets was drained into two labeled 5-gallon cans to be reused by our paint program. The un-useable paint in the remaining cans were consolidated in to five of the original S-gallon traffic paint cans, sealed, labeled and inventoried for disposal on April 20, 2015 with Veolia Environmental. Standard Operating Procedures are being developed to ensure that the hazardous waste storage areas get inspected weekly, and the contents are labeled, dated and closed. Local police/fire/hospital notification of emergency response layout of the facility. WOU Planning Department is developing a litigable Campus overview map that shows the location of the hazardous waste building, Physical Plant, Natural Science, New Physical Education, and DeVolder bulldings. These are the locations on campus where hazardous chemicals/waste are generated and stored. Also showing is the easiest entry and exit points to these locations on campus. |1am currently working on developing additional documentation to provide to our local responders, Monmouth Police department, and Polk County Fire District #1. Further conversations will be held with each agency to further enhance the emergency response plan that they currently have in place. Toxic Use and Reduction Plan Currently WOU does not have a Toxic Use and Reduction Plan, but with the new Campus Public Safety director we anticipate a plan being completed by June 30, 2015. When the pian has been completed, a copy will be sent to DEQ. Universal Waste Lamp storage ‘A plywood containment box with a lid has been constructed, it holds two light tube boxes for staff to put used light tubes in. Once the box is ful, it will then be counted, totals added to the log, and then sealed shut, with a label attached to the exterior. I've attached pictures of the wood containment box. The boxes of bulbs that were seen at inspection have since been recycled with Veolia Environmental services and a manifest is attached.Under Issues & Concerns Aerosol can disposal - The aerosol can disposal drum has been clearly marked with it’s purpose. Picture is attached. Inspecting Hazardous Waste storage building ~ This area is now scheduled to be inspected as you requested to ‘once a week when waste is on inventory. A log is posted on the interior wall, with the last date of inspection, inspector name and a notes section. A “no smoking” sign has been posted in the building as well. Anyone having access to the Hazardous Waste storage building, always has a two-way radio to communicate any issues. Western Oregon University takes disposal of hazardous waste material seriously. Our goal has always been to dispose of waste properly. Being considered a large quantity generator was new for us, and we were unprepared for the additional requirements that DEQ mandated. We take this as@ learning opportunity to improve our current practices to ensure that we will meet DEQ standards for whatever type of generator we are, large, small or conditionally exempt. ook forward to hearing from you, CS8s_AD Allen Risen Occupational/Environmental Safety OfficerBlue containers w/o soilid solvent waste. Waste paint and some thinner for disposal Paint Room Physical Plant paint storage cabinet cleaned out.=FWestern Oregon University Mail - Fire cabinets Western Oregon Fire cabinets ‘1 message Timothy Wallen To: Allen Risen Allen, We removed a total of 21 spray cans from our fire cabinets. marking paint and regular spray paint. Thanks Tim hutps://mail.google.com/mail/w0/?ui=28ei Je8b54 1 b9c&view=ptéesearch=inbox&th= Page | of 1 Allen Risen Mon, Mar 30, 2015 at 9:54 AM This included ceiling tte paint, inverted tip 4c... 3/30/2015PACKING SLIP Combines Cammans . 2012 VP 1503344000 016 Dare CCOMTATED ARR | WESTERN OREGON UNIVERSITY “| | UN3413, WASTE POTASSIUM CYANIDE SOLUTION, | 346 NORTH MONMOUTH AVENUE | 6.450 | MONMOUTH, OR 97364 | | LEPA # ORDe95016978 GEN # 641382 | i GENERATOR- ADORESS EPA® aoe DOT PROPER SHIPPING NAME a z 6817 8VES 2 6 HENTWI836045 836045 e — RETUNE——s WASYEARER ‘DISPOSAL CODE Wik ® SIR ERG:157 W:836045 a“ R/D003, Pose AGVX4 CF 1 of LABPACK ADUITIONAL DESCRIPTION COMMON GRUMS EPA COOE FONTAINER TYPE [ENT [CANE [Con Fe | roLLNESS ‘CHECAL WANE Per egiranen sie” 4 2 POLY FULL ZINCOVER - CONTAINS ‘D003 BORON OXIDE Poss, POTASSIUM BIBORATE ‘SODIUM ASCORBATE POTASSIUM CYANIDE 4 4 at © GLASS “FULL! ZINCOVER - CONTAINS D003 . BORON OXIDE Pos POTASSIUM BIBORATE ‘SODIUM ASCORBATE POTASSHJM CYANIDE WATER: FEED SouRGE cB 008 Ome 22 et woot Hoao ToT, 7 weer | 6 P| _WEBROWN ae 46 OF 17 TECHNICAL SUPERVISORPACKING SL! (west IN OREGON UNIVERSITY | 345 NORTH MONMOUTH AVENUE | MONMOUTH, OR 97364 EPA ORD095016978 GEN #541382 | i || DOT BRGRER SHIPPING RK 1938284090 047 TNT | UN16B0, WASTE POTASSIUM CYANIDE, SOLID, 6.1, (0007 25665VES HENTWAS36045 336045 - CANT a 7 ~TWASTE BREA, DISPOSAL Code WIE SIR.H ERG: 57 W4:836045 4 RH / D003, Poss O51H2 DF 0.68 cf TSNMON ORUMS EPA CODE CONTSINER TYPE CREMIGAL NAME rr CONTAINER T WASTE 3 aes - iD Tee, 4 500gm GLASS “V4FULL POTASSIUM CYANIDE D003 Poss 3 100m GLASS 34FULL. POTASSIUM CYANIDE D003 098 COD ores Cee sic source FUR voae ca 00s Dae E LP 8274 ott woot ‘HO40 ara 7 pon | oP AARON SIMMONDS PAGE 18 OF 34 Tecr ‘SUPERVISORPACKING SLIP ines commens ait bia0 SECIS ~~ BATE SHTPRF SEN DRUM RK 1938264900 023 CONTAINER { WESTERN OREGON UNIVERSITY | [wa3077, HAZARDOUS WASTE, SOLID, nos. 9,41 | 345 NORTH MONMOUTH AVENUE 1 | | 1} | MONMOUTH, OR 97361 1 j [FPA #ORDO95018978 GEN #541282 PL RO a SCT ROR PTW 4 28 HENTW1836045 838045 eke | WATERERS SSPOSLCBDE we SIR,W ERG:171 We 045, 1 RH f D003, P630, 05112 DF 0.68 ct ACHENTWI1836045 D007, 0008 LABPACK i ~aBBTHIGEAL DESC PTR —~ SoRRERTORTNS ERC cE TRE [nT sme [eer TET INES ei ER SORTANER | Waste I sue 7 3 ee 2 269m GLASS 42FULL. COBALT THIOCYANATE 0903 O30 2 fom GLASS 1/2FULL COPPER CHROMATE 0007 2 250 mi POLY FULL CATALYST CE 407 RD DOO a igm GLASS FULL DPD FREE CHLORINE REAGENT POWDER NONE ab 4gm GLASS FULL SODIUM METABISULFITE NONE 2% 19m GLASS FULL. SODIUM SULFATE, ANHYDROUS NONE 4 400 mi POLY 1/2FULL GLUTATHIONE NONE 2 fom! GLASS FULL. REAGENT DILUENT CONCENTRATE 2 NONE 4 100mg GLASS FULL GLUTATHIONE NONE 1 50 mg GLASS FULL 5,5-DITHIOBIS(2-NITROBENZOIC ACID) NONE 2 5G POLY 1/2FULL GLUTATHIONE NONE 4 tpt POLY, FULL AMINO ACID F REAGENT NONE 1 tpt POLY FULL L-ASCORBIC ACID NONE 3 tpt POLY FULL CITRIC ACID NONE AF SSMS 4 tpt POLY, FULL = SUCCINIC ACID: NONE ELP & sounce FORM SYSTEM roue eB cos pa Li azz cit wood -HO4D AARON SIMMONDS PAGE 26 OF 34 TECHNICAL SUPERVISORRK 1938284000 052 ers ge | WESTERN OREGON UNIVERSITY | ['uN1320, WASTE DINTROPHENOL, WETTED Wit | 345 NORTH MONMOUTH AVENUE NOT LESS THAN 15% WATER, BY MASS, 4.1 (4.1), 1 \ MONMOUTH, OR 97361 LEPA#ORDORSO1S978 GEN # 541387 i “SOT BROEEF GHIBEIN TOME a HENTWI836045 936045 WASERRER— URFOSAL TONE we SIH ERG:413 12835045 1 H/ Peas, DO01 05112 DF 0.68 ct ALHENTWI636045, conranier | sue | COMME ORINS §=———ERR CODE ——_ CONTAINER TYPE CHEMICAL NAME [NER CONTAINER] WASTE 7 De | ie 4 4b POLY MEL 2, 4-DINITROPHENOL (WET >45% WATER) peas ‘DeOt 1 4th GLASS 1/4FULL 2,4-DINITROPHENOL (WET >15% WATER) Pes —— D001 4 sgm GLASS 1/2FULL 2,4-DINITROPHENOL (WET >15% WATER) Peas _ Deet REO eee sc SuRce rom svar poe Pca 20s om ELP 8224 Git W8e4 ‘HO40 AARON SIMMONDS PAGE 34 OF 34 TEGHNIGAL SUPERVISOR[GENERATOR SCHEDULING QUESTIONNAIRE ATE: Toa fr cusTowes eLLNG NFORMATION-WRERE DO We SEND THETNVORE [oiviSION NAME, iam Oregon Universly [CONTACT NAME | ‘Alen Fisen O Safoty Manager foes ou ORE SOSeSTEO booness a SOSRESTOO fare stare a Tamm Bape Te@uousdu BURCHASE GROER TFET ROOTES ETE DO WE PORUP TE WATER | bso CONTACT RANE JDORESS One DORESST FAK I STASI SL GENERATOR ADDRESS [SOMPLETE HL FO FERENT FTW ADDRESS NPE“ ROORENS TS WL PAT OW TE CATE] Brsomnan CONTACT AE faoess BONE frooness7 a lary srave TP I I EA [ex paoamer T AORUF STE CONDON CUGR ON WAR VES ONTO Te 8 YES [eNO (SAPALET ACK NEEDED fw ves [IS THE MATERIAL ON A LOADING DOCK YES i NO ISA DRUM DOLLY NEEDED ES iv 5 THE PRODUCT PALLETZED/ SECURED ey ISTHE cusTouen PaOnONGPAPERNOR | > ES [sive sre accescmeay ass THAEA eS Founs AvATABLE FOR POKIP Tania ALLOW 7-10 WOR ESE for CLOSE SVHRTERIL FOR PICKUP“ TYPE, Se GGUANTIY MATERIAL TYPE Laas Lane count of orUn [NOTES & ADDITIONAL COMMENTS SKID BOX DRUM WEIGHT PLEASE USE THE AREA BELOW TO COMMUNICATE ANY] TAPS AODMIONSL NFORWATION FOR YOUR PUP — PECIPYTYPESOF WASTE NOTED AS OTHER ERS Saae pto Taras erviaues SHATTERSHHELD NCANOESCENT uTube BE saa cu pense ToeTeR | eres Soules el pick. 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Actua unneeded a “upon receipt at the Designated Facility. LeadineTieis sient Ss Fe pe | tes owe we : ~ Ss inti gant untae See Tanger VECLIAES TECHUCAL SOLUTIONS, Le, ranger? a erases rane pare ate sumaice ate Sesunned TC Recaed slipc oe casa uno eae tne ett oft Bat Lane Be pe den sora apr 5 riers siete ate Tote aaaWESTERN OREGON UNIVERSITY REQUEST FOR HAZARDOUS WASTE DISPOSAL vinitiate disposal, please complete the following and contact the ‘Occupational / Environmental Safety Officer, Campus Public Safety, 8-8156. Apel 24 2012 Date of Pickup: P22 I-1S. Date of Disposal:, 3-13-45 Date of Reque: partment: !Wo\.c Dervices Building: U4 Room #:, Contact Person:_V Ct suai: ap xeapledy > Soc WASTE DISPOSAL Account to Chargt Material Type: SOLIDS Container Size Number of Containers. Five (5) pounds or more ak ‘Three (3) pounds One (1) pound Less than one pound Other ¥9 Ya xe 0 xe Tato 0 ox 19970, Liquips garter =" Container Size er el 2. Five (5) gallons or more fae esos Soe agers & Three (3) gallons Don Camichae! 2% One (1) gallon or less Dallas Branch Mena ccs se ennai Cut 2% Other eamvongaten 073 Sis one A majo poi regen geen wonton SF Released by_ 22 = —— Department Representative Released to, Allen Risen, Safety Officer Date p —, leased by_ CEU Allen Risen, Safety Officer