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Compliance Contacts and History

The following is a listing of the regulatory points of contact for Waste Express and a summary of our compliance history over the past several years.  Complete copies of each of these inspection reports are available for review at the facility.

Inspections

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

Annual Site Inspection                                                            
There were no Violations or problems identified during this Water Services Department inspection.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

Administrative  Review
No Violations, determined to be in full compliance for the second half of 1999.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

Annual Facility Inspection
There were no Violations or problems identified during this Water Services Department inspection.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

Administrative Review
No Violations, determined to be in full compliance for the first half of 2000.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.  

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.  

Administrative Review
No Violations, determined to be in full compliance for the second half of 2000.  

There were no Violations noted during this inspection. 

Unsatisfactory Feature -  Failure to document daily inspection of a permitted storage area.  Review of the daily inspection logs revealed the inspection log of for February 6, 2001,  was incomplete.

Answer/Corrective Action  -  The daily inspection log for February 6, 2001 was not filled out in its entirety.  The inspection was conducted as evidenced by the start and stop time and the inspector’s signature on the form.  The only explanation for the missing check marks is a lack of attention to detail on the inspector’s part.  In an effort to insure this type of administrative oversight does not happen again, the actual inspection log will be filled out as the inspection takes place.

Comment #1  -  The inspectors observed over half the drums in Room A did not have the generator’s accumulation start date on the Hazardous Waste (HW) mark.  HMRDI must work with the generators to ensure that the accumulation dates are placed on the HW marks.

Answer/Corrective Action  -  The generator’s accumulation start date is strictly a generator responsibility.  It would be improper and we believe against the law for HMRDI personnel to make this entry.  Our sales and customer service personnel work closely with generators and will inform them of the requirement and strongly suggest this date be entered on the hazardous waste label as required by law.  This particular problem would be more appropriately handled by the Regional MDNR enforcement personnel.

Comment #2  -  The  inspectors observed one drum of aerosol cans generated by HMRDI did not have an accumulation start date on the HW mark.  An accumulation start date of October 30, 2000 was on the tracking label.

Answer/Corrective Action  -  The particular drum in question did not have the HMRDI accumulation start date on the hazardous waste label.  The accumulation start date was however on the tracking label attached to this drum.  We believe this meets the requirements of 40 CFR 262.34.  In an effort to avoid confusion on this issue, HMRDI personnel have been advised to put the accumulation start date on each hazardous waste label when waste is first placed in the container. 

Annual Site Inspection                                                                          
There were no Violations or problems identified during this Water Services Department inspection.

There were no Violations, Unsatisfactory Features or Comments noted during this inspection.  

Administrative Review
No Violations, determined to be in full compliance for the first half of 2001.

There were no Violations, Unsatisfactory Features or Comments noted on this inspection.

Administrative Review
No Violations, determined to be in full compliance for the second half of 2001.  

Annual Facility Inspection                                                                    
There were no Violations or problems identified during this Water Services Department inspection. 

There were no Violations, Unsatisfactory Features or Comments noted on this inspection.

Notice of Violation #3461

Citation 40 CFR 268.50                     Storing waste longer than a period of one year on-site at facility

During the walk through the inspectors observed three 55-gallon drums of oxidizer that had been on site over one year.  One was over by three days and the other two were over by less than a month.  HMRDI explained that the outbound shipment of these drums was delayed in an effort to accumulate enough oxidizer waste to make it economically viable to arrange for shipment to an end disposer.  We believed this short delay was in full compliance with 40 CFR 268.50 (c).  The Missouri Department of Natural Resources did not concur with our interpretation of the regulation and issued the NOV.

There was no fine or penalty associated with this NOV and all oxidizer drums were shipped off site in late July.  

Administrative Review
There were no violations.  Determined to be in full compliance for the first half of 2002.

There were no Violations, Unsatisfactory Features or negative Comments noted on this inspection.

There were no Violations, Unsatisfactory Features or negative Comments noted on this inspection.

Compliance Determination
There were no violations or errors noted.  Determined to be in full compliance for the second half of 2002. 

There were no Violations, Unsatisfactory Features or negative Comments noted on this inspection.

Current as of 24 February 2003

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