UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/9-89-003-R
MULTI-MEDIA COMPLIANCE
AUDIT PROCEDURES
March 1989
— Agency
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
INTRODUCTION '. 1
PURPOSE 1
OBJECTIVES 2
SCOPE 2
PLANNING THE AUDIT 4
THE AUDIT TEAM 6
KNOWLEDGE AND SKILLS REQUIRED 6
INVESTIGATOR RESPONSIBILITIES 6
AUDIT PREPARATION 9
COMPILATION AND REVIEW OF BACKGROUND INFORMATION 9
Technical Information 9
Legal Information 11
Information Sources 12
NOTIFYING THE FACILITY 14
CONDUCTING THE AUDIT 16
ENTRY 16
OPENING CONFERENCE 20
GENERAL AUDIT PROCEDURES '. 21
Process Operations 21
Pollution Control, Treatment, and Disposal 23
Operation and Maintenance (O&M) 25
AUDIT PROCEDURES FOR SPECIFIC MEDIA OR SPECIAL AREAS... 26
Air. 26
Water 29
Solid/Hazardous Waste 31
. Toxic Substances 46
Pesticides 55
Water Supply 58
Community Right-to-Know Requirements 59
Laboratory and Data Quality Audits 61
Computerized Information Systems 64
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CONTENTS (cont.)
CLOSING CONFERENCE 68
THE AUDIT REPORT AND FOLLOWUP 69
BIBLIOGRAPHY
ACRONYMS
APPENDICES
A SUMMARY OF POLLUTION CONTROL LEGISLATION
B SAFETY PLAN
C EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
D AIR POLLUTION CHECKLISTS
E WATER POLLUTION CHECKLISTS
F RCRA CHECKLISTS
G LAND DISPOSAL RESTRICTIONS CHECKLIST
H CERCLA CHECKLIST
I TSCA FORMS
J TSCA PCB CHECKLIST
K TSCA SECTIONS 5 AND 8 CHECKLIST
L PESTICIDE (FIFRA) CHECKLIST
M WATER SUPPLY CHECKLIST
N UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST
0 COMMUNITY RIGHT-TO-KNOW CHECKLIST
P LABORATORY AUDIT CHECKLISTS
TABLES
1 Federal Statutes/Regulations for Multi-Media Compliance Audits 13
2 Background Review Information Sources 15
3 Inspection Authority Under the Major Environmental Acts 17
4 Summary of Federal Environmental Acts Regarding Right of Entry,
Inspections, Sampling, Testing, Etc 18
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INTRODUCTION
PURPOSE
This manual is intended as a guide for investigators who conduct multi-
media compliance audits of facilities that discharge, emit, prepare, -manage,
store, or dispose of pollutants controlled by Federal, State or local
environmental laws and regulations. Investigative methods are presented that
integrate the enforcement programs for air, water, solid waste, pesticides, and
toxic substances. This manual describes general activities and functions and
focuses on special features of specific media and associated statutes.
The purposes of a facility multi-media compliance audit are to:
Review a facility's pollution control practices
Evaluate operation, safety, and waste management equipment
Determine status of compliance with applicable laws and
regulations.
The environmental laws which EPA administers and enforces are
summarized in Appendix A. Emphasis is given to identifying violations of
regulations, permits, approvals, orders and consent decrees, and the
underlying causes of such violations. Due to the complexity of laws and
regulations, a comprehensive, in-depth review is not always possible.
Investigators should conduct a thorough review so that violations and problems
that have an existing or potential effect on the environment are identified and
properly documented.
Pollution sources may vary in complexity depending on facility size,
process operations and extent and efficiency of existing pollution controls. Time
and personnel resources required to conduct compliance audits will vary. A
large industrial facility with multiple process operations may require evaluation
under several environmental statutes, such as the Clean Water Act (CWA),
Clean Air Act (CAA), Resource Conservation and Recovery Act (RCRA), Toxic
Substances Control Act (TSCA), Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), and the Federal Insecticide,
(03/89)
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Fungicide and Rodenticide Act (FIFRA). A multi-media compliance audit of this
magnitude requires an audit team with combined experience in the various
environmental media to effectively determine the pollution potential and/or
compliance of the facility.
OBJECTIVES
This guide provides protocols for multi-media compliance audits.
Specific objectives of such audits are to:
Document facility noncompliance with environmental laws,
regulations, orders, permits, consent decrees, and approvals
• Determine ability of a facility to maintain "continuous compliance"
across all environmental areas
Identify need for remedial measures and enforcement action(s) to
correct the causes of violations
SCOPE
The multi-media compliance audit approach is designed to minimize the
number of visits to a single facility. This manual addresses audit team activities
before, during, and following the on-site audit.
In performing compliance audits, investigators should follow established
Agency policies and procedures for:
Chain-of-custody and document control
Receipt and handling of confidential information
Employee conduct, responsibilities, and ethics
Quality assurance and quality control
Safety rules
When established policies and procedures do not exist, common sense,
professional judgment and experience should be applied. Investigators need to
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collect valid, factual information and supporting data which are adequately
documented to ensure that these will be admissible as evidence in any
subsequent enforcement action(s).
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PLANNING THE AUDIT
The success of an audit depends on thorough, up-front planning.
Coordination with all interested and knowledgeable parties (e.g., Region, State,
audit team members, NEIC supervisory staff) is essential to ensure a smooth
operation. All concerned parties should be identified and informed as soon as
possible to ensure necessary coordination.
A comprehensive plan (project plan) provides a means for informing all
involved parties of the upcoming activities and ensuring an effective compliance
audit. The project plan describes the project objectives, tasks required to fulfill
these objectives, methods and procedures to be followed, resources required
and schedules. The plan generally addresses the following:
Objectives - The plan defines what the audit is to accomplish (e.g., to
assess environmental compliance with the regulations that apply to the
source-water, air, et al.).
Tasks - The plan defines tasks for accomplishing the objectives and
spells out procedures for obtaining the necessary information and
evaluating facility compliance. The tasks usually involve an evaluation of
process operations, pollution control/treatment and disposal practices,
operation and maintenance practices, self-monitoring, recordkeeping
and reporting practices, and pollution abatement/control needs.
Procedures - The plan provides or references policies and procedures
for document control, chain-of-custody, quality assurance, and handling
and processing of confidential information. Specific instructions for the
particular audit may be provided.
Safety - The plan includes the written safety procedures which the EPA
audit team must follow [Appendix B]. Additional safety procedures may
be considered for extensive or prolonged investigations.
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Resources - The plan describes personnel needs and equipment
requirements. Experienced and knowledgeable personnel shall com-
pose the compliance audit team.
Schedules - The plan provides schedules for the audit activities. This
information is important to the participants as well as the Headquarters,
Regional and/or State officials who requested the project. The dates for
(a) starting and finishing the field activities, (b) analytical work, and
(c) draft and final reports should be established and agreed upon by the
participants.
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THE AUDIT TEAM
KNOWLEDGE AND SKILLS REQUIRED
The audit team should possess a good working knowledge of the various
environmental pollution control statutes. Team members should understand the
rules, regulations and other provisions, including permits, registrations, author-
izations, limitations, monitoring requirements, etc., as they pertain to the facility.
The investigators should have knowledge of Agency policies and procedures,
inspection authority, manufacturing and production processes, applicable pol-
lution control technology and the nature of pollution problems and possible
solutions, including available treatment and controls.
Individual team members may have more specific knowledge of a pro-
cess, monitoring system, control equipment, environmental media, regulation,
etc. than others. The team, as a whole, however, should have collective knowl-
edge and background to efficiently and effectively conduct all aspects of a facil-
ity audit. They should also understand the techniques for evidence gathering
and possess skill in collecting information and in interviewing officials of the
public and regulated communities.
INVESTIGATOR RESPONSIBILITIES
Investigators represent the Agency when they deal with the regulated
community and the public. They should conduct themselves in a professional
manner and maintain their composure and credibility at all times. Cooperation
and good working relations with facility personnel should be established and
maintained. EPA investigators must adhere to the provisions described in the
EPA handbook "Responsibilities and Conduct for EPA Employees."
Safety plans must be prepared in advance for audits where field
sampling is conducted or where potential exists for exposure to hazardous sub-
stances or conditions [Appendix B]. Applicable safety provisions and precau-
tions are to be followed throughout the audit. EPA field certification at basic,
intermediate or advanced levels is required by Agency Order 1440.2, Health
and Safety Requirements for Employees Engaged in Field Activities. If work at
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7
hazardous waste sites is involved, training and other requirements of the OSHA
Hazardous Waste Site Worker Rule (29 CFR 1910.120) may also apply.
Audit team members will dress appropriately, including wearing protec-
tive clothing or equipment. Safety requirements must be identified before the
on-site audit so that no delays occur. Investigators should provide their own
safety equipment and should not rely on the facility, except in unique situations
where special equipment is required. Required respirator "fit" testing, field
certifications, and medical monitoring physicals must be completed in advance.
In general, company safety requirements must be met in addition to the
appropriate EPA requirements and guidelines addressed in the following
documents:
Agency Safety Manual - Chapters 1 through 10
Agency Orders -1000.18 Transportation of Hazardous Materials
- 1440.2 Health and Safety Requirements for
Employees Engaged in Field Activities
- 1440.3 Respiratory Protection
- 1440.4 Health and Safety Training Requirements
for Mine Safety
- 1440.6 Motor Vehicle Occupant Restraint Systems
- 1440.7 Hazard Communication
- 3100.1 Uniforms, Protective Clothing and Protective
Equipment
- 3100.3 Authorization of Performance of Hazardous
Duty
Agency Guidelines - Standard Operating Safety Guides
- Eye Protection Program Guideline
- Respiratory Protection Program Guideline
- Selection Guide for Chemical Protective Clothing
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- Interim Health and Safety Guidelines for EPA
Asbestos Inspectors
- Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities
Information which is claimed or requested to be held confidential must be
handled properly to prevent disclosure to unauthorized persons. Investigators
must have specific authorization for accessing and handling TSCA Confidential
Business Information (TSCA Section 14). Other environmental media have
confidentiality provisions and the inspector is referred to these statutes and
regulations. Inspectors must be familiar with the confidentiality regulations to
ensure that information is handled properly.
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AUDIT PREPARATION
COMPILATION AND REVIEW OF BACKGROUND INFORMATION
Collection and analysis of background information on the facility to be
inspected are essential to the effective planning and overall success of a com-
pliance audit. Information can be obtained from the files of Federal, State and
local agencies, technical libraries, EPA databases and other sources. The
background review will enable investigators to become familiar with facility
operations; clarify technical and legal issues before entry; and develop a sound,
factual audit report.
During a properly conducted background review, the investigator should
identify both the technical and legal information needed and available. The
types of information which may be acquired and reviewed are discussed below.
Technical Information
Facility Background
Maps showing facility location and environmental and geographic
features (stacks, discharge pipes, and solid waste disposal sites)
Geology/hydrogeology of the area
Aerial photographs
Names, titles, phone numbers of responsible facility officials
Process description, process flow charts and major production
areas
Records reflecting changes in facility conditions since previous
- audit/permit application
Production levels - past, present and future
Audit Reports. Records and Files
Federal and State compliance files
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10
Correspondence between the facility and the local, State and
Federal agencies
Citizens' complaints and reports, follow-up studies, findings
Audit records, reports, correspondence on past incidents or
violations
Emissions inventory
Self-monitoring data and reports
EPA, State, and consultant studies and reports
Annual reports by the facility (e.g., PCB annual documents and
inventories, Securities Exchange Commission §10K reports)
Records, applications, reports, manifest files, etc. (e.g., RCRA
reports, CERCLA submittals)
Laboratory audit reports, QA/QC activities
Records of previous hazardous substances spills
Pollutant and Waste Generation. Control. Treatment, and Disposal
Systems
• Description and design data for pollution control systems and
process operations
• Sources and characterization of wastewater discharges,
hazardous wastes, emissions, types of treatment, and disposal
operations
Type and amount of waste generated which is discharged,
emitted, stored, treated, and disposed
Waste storage, treatment, and disposal areas
Waste/spill contingency plans
• - Available bypasses, diversions, and spill containment facilities
Industrial process, pollution control, treatment and disposal
methods, monitoring systems
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11
Legal Information
Requirements. Regulations, and Limitations
Permit applications, draft or existing permits, registrations,
approvals, and applicable Federal, State and local regulations
and requirements
Application certificates, EPA identification numbers
Information on draft permits which is different from current
conditions
• Exemptions and waivers
Receiving stream water quality standards, ambient air standards,
State Implementation Plans, protected uses
• RCRA notification and Part A and Part B applications
Pesticide labels
Grant applications for publicly owned treatment works, research
and development demonstration projects and progress reports on
these projects
Federal and State classification of facility (e.g., Interim Status,
Small Quantity Generator)
. forcement History
Status of current and pending litigation against the facility*
Deficiency notices issued to facility and responses by the facility
Status of administrative orders, consent decrees and other
regulatory corrective actions, if any, and compliance by the facility
• Penalties imposed against the company
Coordination should occur prior to the audit (in conjunction with the EPA Regional Office)
with the local Assistant United States Attorney or Justice Department attorney responsible
for the civil or criminal case and any consent decree.
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12
Information Sources
Laws and Regulations - Federal laws and regulations establish
procedures, controls and other requirements applicable to a facility
[Table 1], In addition, State laws and regulations and sometimes even
local ordinances may be applicable, or take precedence.
Permits and Permit Applications - Permits provide information on the
limitations, requirements, and restrictions applicable to discharges,
emissions and disposal practices; compliance schedules; and
monitoring, analytical, and reporting requirements. Applications provide
technical information on facility size, layout, and location of pollution
sources; waste and pollutant generation, treatment, control and disposal
practices; contingency plans and emergency procedures; and pollutant
characterization - types, amounts, and locations of discharge, emissions
or disposal.
Regional and State Files - These files often contain grant records,
applications, facility self-monitoring data, and audit reports, as well as
permits and permit applications pertaining to individual facilities. These
information sources can provide compliance, enforcement, and litigation
history; special exemptions and waivers applied for and granted or
denied; citizen complaints and action taken; process operating
problems/solutions; pollution problems/solutions; and laboratory
capabilities. Consultant reports can provide design and operating data
and recommendations for processes; pollutant sources; treatment,
control, and disposal systems; and remedial measures.
Technical Reports. Documents, and References - These sources provide
information on industrial process operations, data on available treatment,
control and disposal techniques, such as their advantages or drawbacks,
limits of application, etc. Such sources include Effluent Guideline and
New Source Performance Standard development documents and EPA's
Treatability Manual. Similar guidance documents on hazardous waste
generation, treatment/disposal are also available.
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Table 1
FEDERAL STATUTES/REGULATIONS FOR MULTI-MEDIA COMPLIANCE AUDITS
Air
CAA
Inspection Authority 114,* 21 1 a
[80, 86*)
Recof dkeeping 114, 208
Authority [51,57.58,60,
61,79,85.86]
Confidential 208, 307
Information (2.201-2.215,
2.301,53.57.
80)
Emergency 303
Authority
Employee 322
Protection
Permits
Basic requirements
include applications.
standard permit
conditions, moni-
toring, reporting
EPA procedures [124]
for permit issuance
Technical [52]
requirements
Specific NSPS'
References NESHAP* [61 ]
CEuf(60\
SIP/p]
PSD* [50]
Superfund
Water CERCLA and
CWA EPCRTKA
308,402 104
[122.41]
308,402 103
[122.41. 372.10
122.48]
308 104
[2.201-2.215, [2.201-2.215]
2.302, 122.7] 322
[350]
504 104,106
[300.53.300.65]
507 110
[122, 125]
124]
[129,133,
136,302°)
BMP'* [125]
SPCC* [11 2]
Waivers [125, 130]
Effluent guidelines
[400-460]
BMP [125],
SPCC [112],
Pretreatment
[125.403],
Toxic [129]
a Statute (e.g.. Clean Air Act, Section 114 or 211)
b [80, 86] - 40 CFft, Pans BO and 86; Cffl refers ID Code ol Federal Regulations
c Reportable quantities
d BMP - Best Management Practices
e SPCC - Spill Prevention Control and Countermeasures Plan
Pesticides Solid Waste
FIFRA RCRA
8,9 3007,9005
[160.15, 169.3] [270.30]
4,8 3001.3002,3003.
[160.63,169, 3004,9003
1 60. 1 85- 1 95] (262.40, 263.22,
264.74. 264.279,
264.309. 265.74,
264.309, 270.30]
7,10 3007,9005
(2.201-2.215 [2.201-2.215,
2.307] 2.305, 260.2,
270.12]
27 7003
[164.166]
7001
[270]
[124]
[260-266]
Generators [262],
Transporters [263],
TSryi265l.Stds.for
TSD Permits (264).
Intenm Stds [265],
Storage <90 days [262],
Exemptions [261]
Drinking Water
SDWA
1445
[142.34, 144,51]
1445
[141.31-33,
144.51,144.54]
1445
[2201-2.215,
2.304.144.5]
1431
1450
[144, 147]
[124]
[146, 264]
Toxics
TSCA
11
(717 t/. 792 15]
6
[704.710.
717 15, 72078, 761 180,
76280,763 114.
792 185-195]
14
[2.201-2215,2306,
7047,70775,7107,
712 15,717.19,
720.8095,
750 16, 750.36,
762.60, 763.74]
7
23
PCBs (76 1]
Dioxin [775]
1 NSPS - New Source Performance Standards
g NESHAP - National Emission Standards lor Hazardous Air Pollutants
h CEM - Continuous Emission Monitoring
i TSD - Treatment, Storage and Disposal
j SIP- State Implementation Plan
k PSD - Prevention ol Significant Deterioration
(03/89)
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14
The background information sources for overall program areas and those
that apply specifically to the water, air, solid waste, pesticides, and toxic
substances programs are listed in Table 2.
NOTIFYING THE FACILITY
In most cases, notification for routine audits is given to the facility, but are
not required. In cases where there is concern that physical conditions may be
altered prior to the audit or that records may be destroyed, an unannounced
audit should be conducted. The initial contact is usually by phone with follow-
up written confirmation of the anticipated audit period. The notification letter
specifies the authority for the audit and outlines the areas to be covered during
the audit and the information to be provided. This approach improves the
chances that responsible facility officials will be present and that necessary
information will be readily available.
Typical information requested in a notification letter for availability during
the audit may include the following:
Raw materials, imports, intermediates, products, byproducts,
production levels-
Facility maps identifying process areas, discharge and emission
points, waste disposal sites
Flow diagrams or descriptions of processes and waste control,
treatment and disposal systems showing where wastewater, air
emission, and solid waste sources are located
Description and design of pollution control and treatment systems
and normal operating parameters
Operations and maintenance procedures and problems
Appropriate packaging and shipping labels
Self-monitoring reports and inventories of discharges and
emissions
• Self-monitoring equipment in use, normal operating levels, and
available data
Required plans and records
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Table 2
BACKGROUND REVIEW INFORMATION SOURCES
Overall Program Areas
Water Pollution
CWA
Air Pollution
CAA
Solid Wastes
Pollution
RCRA
Toxic Substances
Pollution
TSCA
FIFRA/CERCUV
NEIC Information Retrieval
System data on corporate
structure, financial con-
ditions, pollution control
history, environmental and
health impacts of pollutants
of interest.
EPA grants (R&D,
constructing, planning)
Information available on
process operations; pol-
lutants of interest; existing
treatment, control and
disposal practices; raw
material
Administrative Orders
issued for environmental
non compliance
Applicable local ordinances
on environmental control
Compliance history and
present compliance status
Available correspondence
between regulating officer
and facility officials
Available contractor/
consultant report on facility
environmental control
matters
Environmental compliance
schedules and present
status
Available aerial
photography
NPDES permits/permit
applications/draft permits
Applicable effluent
guidelines
Compliance inspection
reports (Federal/State/
local)
Laboratory performance
reports
Self-monitoring require-
ments and self-reporting
data
Best Management
Practices Plan
Spill Prevention Control and
Countermeasure Plan
Pretreatment requirements
if facility discharges to
POTW
Applicable Federal/State
regulations related to water
pollution control at facility
Technical manuals and
references on pollution
treatment/control technol-
ogy, process operation,
monitoring inspection
procedures
Interstate Commission
water quality data (Ohio
River Sanitary Commission,
Delaware River Basin
Commission, Interstate
Commission on the
Potomac River
Air permits and permit applications
(Federal/State/local)
Self-monitoring requirements and
self-reported data
Compliance inspection reports
(Federal/State/local)
Applicable NESHAP
Applicable NSPS
Applicable air quality standards
State Implementation Plan
Ambient air quality reports for
AQCR
Stack test reports
Air pollutants emission inventories
Continuous monitoring practices
and facility and applicable
performance inspections
Available contractor/consultant
reports
Technical manuals and references
on applicable pollution treatment/
control technology, process
operators, air pollution monitoring,
inspection procedures
Part A of permit application
(TSDs only) to designate type
and volume of wastes
handled, type and design
capacity of treatment, storage
and/or disposal processes
Part B of permit application, if
available
Draft/final RCRA permit
Applicable regulations for
source designations
Groundwater monitoring
plans/data
UIC permit and present status
Hydrogeologic reports on local
area relative to UIC permit
Self-monitoring requirements
and self-reported data
Applicable regulation on
manifest requirements
Inspection reports
(Federal/State/local)
Technical manual and
references on applicable
treatment/control and
disposal technology,
inspection and monitoring
procedures and techniques
Available information on
chemical substances produced
by facility
Applicable regulations regarding
manufacture, identification, self-
reporting requirements, con-
cerning toxic materials (e g ,
PCB rules)
Inspection reports (Federal/
State/local)
Technical manuals and
references on applicable
treatment/control and disposal
technology, inspection and
monitonng procedures and tech-
niques
FIFRA
Establishment num-
bers, Certified
Applicator numbers
Applicable labels
Inspection reports
(Federal/State)
EPA Pesticide
Inspection Manual
State Facility Permits
for procedures, bulk
storage
CERCLA
Preliminary Assess-
ment (PA) reports
Site Inspection
(SI) reports
Remedial Investiga-
tion/Feasibility Study
(RI/FS) reports
Records of Decision
(RODs)
Remedial Design (RD)
reports
Removal Action
reports
(03/89)
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16
CONDUCTING THE AUDIT
The compliance audit will consist of the following phases:
Entry
Opening conference
The on-site inspection
Closing conference
ENTRY
The team should arrive at the facility during normal working hours, unless
special circumstances, such as suspected illegal activity at night, are being
investigated. The investigators shall identify themselves to the owner, agent in
charge, or other responsible facility official; present their official Agency
credentials to the facility official, whether requested or not; and explain the
purpose of the audit. Tables 3 and 4 outline the various Federal environmental
statutes which give Agency employees the authority to enter facilities, review
records, and collect samples.
If the audit is conducted at a Federal facility that has national security
information, restricted or classified areas, special procedures may be required
for entry. For example, a military installation regulation may stipulate that
investigators shall provide proof of appropriate security clearance before entry
is approved into restricted areas. When this occurs, the investigators should
refer such special cases to their appropriate legal staff (e.g., Office of Regional
Counsel).
When the facility provides a blank sign-in sheet, log or visitor register, it is
acceptable for investigators to sign it. Note, however, that EPA employees must
not sign any type of "waiver" or "visitor release" that would relieve the facility of
responsibility for injury or which would limit the rights of the Agency to use data
obtained from the facility. When such a waiver or release is presented, team
members should politely explain they cannot sign such a document and request
a blank sign-in sheet. If they are refused entry because they do not sign such a
release, the team should immediately report all pertinent facts to the appropriate
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Tabte3
INSPECTION AUTHORITY UNDER THE MAJOR ENVIRONMENTAL ACTS
CAA-§
" . .the Administrator or his authorized representative, upon presentation of his credentials - shall have a right of entry to, upon, or
through any premises of such person or in which any records required to be maintained. . are located, and may at reasonable times have
access to and copy any records, inspect any monitonng equipment and method. . .and sample any emissions. . ."
CWA - § 308(a)(4)(B)
". . .the Administrator or his authorized representative. . upon presentation of his credentials - (i) shall have a right of entry to, upon, or
through any premises in which an effluent source is located or in which any records required to be maintained.. .are located, and (li) may
at reasonable times have access to and copy any records, inspect any monitonng equipment or method. . . any sample any effluents
which the owner or operator of such source is required to sample....'
RCRA-§3007(a)
". . .any such person who generates, stores, treats, transports, disposes of or otherwise handles or has handled hazardous wastes shall
upon request of any. . .employee or representative of the Environmental Protection Agency.. .furnish information relating to such wastes
and permit such person at all reasonable times to have access to, and to copy all records relating to such wastes."
".. .such employees or representatives are authorized.. .to enter at reasonable times any establishment or other place where hazardous
wastes are or have been generated, stored, treated or disposed of or transported from; to inspect and obtain samples from any person of
any such wastes and samples of any containers or labeling for such wastes.'
-§9005(a)(1)
".. .representatives are authorized.. .to enter.. .inspect and obtain samples...
TSCA-§11(a)(b)
".. .any duly designated representative of the Administrator, may inspect any establishment. . .in which chemical substances or mixtures
are manufactured, processed, stored or held before or after their distribution in commerce and any conveyance being used to transport
chemical substances, mixtures or such articles in connection with distribution in commerce. Such an inspection may only be made upon
the presentation of appropriate credentials and of a written notice to the owner, co-operator or agent in charge of the premises or
conveyance to be inspected.*
RFRA-§8and9
".. .any person who sells or offers for sale, delivers or offers for delivery any pesticide.. .shall, upon request of any officer or employee of
the Environmental Protection Agency. . .furnish or permit such person at all reasonable times to have access to, and to copy: (1) all
records showing the delivery, movement or holding of such pesticide or device, including the quantity, the date of shipment and receipt,
and the name of the consignor and consignee...."
". . .officers or employees duly designated by the Administrator are authorized to enter at reasonable times, any establishment or other
place where pesticides or devices are held for distribution or sale for the purpose of inspecting and obtaining samples of any pesticides or
devices, packaged, labeled and released for shipment and samples of any containers or labeling for such pesticides or devices.'
'Before undertaking such inspection, the officers or employees must present to the owner, operator or agent in charge of the
establishment... appropriate credentials and a written statement as to the reason for the inspection, including a statement as to whether
a violation of the law is suspected.'
". . .employees duly designated by the Administrator are empowered to obtain and to execute warrants authorizing entry. . .inspection
and reproduction of all records.. .and the seizure of any pesticide or device which is in violation of this Act*
SDWA-§1445
". . .the Administrator, or representatives of the Administrator. . .upon presenting appropriate credentials and a written notice to
any. . .person subject to. . .any requirement. . .is authorized to enter any establishment, facility or other property. . .in order to
determine.. .compliance with this title, including for this purpose, inspection, at reasonable times, of records, files, papers, processes,
controls and facilities or in order to test any feature of a public water system, including its raw water source.*
CERCLA (Superfund) - § 104(e)
'Any officer, employee or representative of the President. .is authorized to...
require any person.. .to furnish. . .information or documents relating to. . .identification, nature and quantity of material. . .generated,
treated, stored, or disposed.. .or transported.. .nature or extent of a release.. .ability of a person to pay..."
".. .access.. .to inspect and copy all documents or records.. .*
*. . .to enter. . .place or property where any hazardous substance or pollutant or contaminant may be or has been generated, stored,
treated, disposed of, or transported from.. .needed to determine the need for response.. .*
".. .to inspect and obtain samples...'
(03/89)
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Table 4
SUMMARY OF FEDERAL ENVIRONMENTAL ACTS REGARDING RIGHT OF ENTRY, INSPECTIONS, SAMPLING, TESTING, ETC.
Act/Section
Clean Water
Act - § 308(a)
FIFRA - § 8(b)
(Books and
Records)
FIFRA - § 9(a)
(Inspections of
Establishments)
Clean Air Act -
§114(a)
RCRA-
§ 3007(a)
§ 9005(a)
SDWA-
§1445(b)
TSCA-
§H(a.b)
CERCLA -
§104(e)
Designated
Representative
Yes, auth. by
Administrator i
Yes, designated
by Administrator
Yes, designated
by Administrator
Yes, auth. by
Administrator
Yes, designated
by Administrator
Yes, designated
by Administrator
Yes, designated
by Administrator
Yes, designated
by President
Presentation
of Credentials
Required
Required
Required
Required
Not required
Required
Required
Not required
Notice of
Inspection
Not required
Written notice required
with reason and sus-
pected violation note
Written notice required
with reasons for
for inspection
Not required except
notify State for SIP
sources
Not required
Written notice required,
must also notify State
with reasons for entry if
State has primary
enforcement
responsibility
Written notice
required
Upon reasonable
notice for information
Sampling Inspection
Permitted of Records
Yes (effluents Yes
which the owner
is required to
sample)
Access and copy Yes
records
Yes See § 8
Yes Yes
Yes Yes
Yes Yes
(The Act does Yes
not mention sam-
ples or sampling
in this section. It
does state an
inspection shall
extend to all things
within the premise
of conveyance.)
Yes Yes
Sample
Splits
Not required
N/A
Required, if
requested
Not required
Required, if
requested
Not required
N/A
Required, if
requested
Receipt Return of
for Agency's Analytical
Samples Results
Not required Not required
N/A N/A
Required Required,
promptly
Not required Not required
Required Required,
promptly
Not required Not required
N/A
Required Required,
promptly
(03/89)
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supervisory and legal staff, and leave the facility if the matter cannot be
resolved. All events surrounding the refused entry should be fully documented,
including the name of the person refusing entry.
Various Federal environmental statutes give Agency investigators the
authority to enter facilities, review records and collect environmental samples
[Tables 3 and 4]. The audit should be made with the consent of the facility
owner and/or authorized person, unless the audit is conducted under a warrant.
When the investigator is allowed to enter, entry is considered voluntary and
consensual by the facility operator or owner, unless the investigator is expressly
told to leave the premises. Consent to enter can, however, be revoked at any
time during the audit. If this occurs, all information collected during the
consensual phase remains in possession of the investigators. When
withdrawal of consent takes place, the same procedures apply as for denial of
entry.
Because audits may be considered adversary proceedings, investigators
may be challenged as to their legal authority, techniques and competency.
Facility personnel may also display antagonism to Agency personnel. In all
cases, the investigators must courteously explain the authorities and the
reasons for the protocols followed. If explanations are not satisfactory or
disagreements cannot be resolved, the team should leave and obtain further
direction from the appropriate Agency supervisory or legal staff.
In certain circumstances, audits will be conducted under authority of
search warrants. A warrant is a judicial authorization for appropriate persons to
enter specifically described locations and to perform certain audit functions. It is
possible that a pre-audit warrant could be obtained when there is reason to
believe that entry will be denied or when violations are expected which could
be hidden during the time a search warrant was obtained. When authorized by
a judge or magistrate, administrative search warrants can be served by a team
member. Criminal search warrants, once obtained, are to be served by
designated Federal law enforcement officials (e.g., EPA OCI Special Agents)
and not by an audit team member.
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OPENING CONFERENCE
At the opening conference with facility officials, the project coordinator
presents his or her credentials; provides names and credentials of the other
team members, purpose of the audit and laws under which the audit is being
conducted; and outlines procedures and proposed schedule to be followed. If
not previously done, any required notices should also be presented to facility
representatives at this time.* A cooperative working relationship is encouraged
between the investigators and the facility officials; this arrangement will simplify
assignments and contribute to the success of the compliance audit.
Major topics discussed at the opening conference should include: audit
objectives, processes and areas to be inspected, anticipated audit schedules
within various areas of the facility, types of records to be reviewed, safety
requirements, handling of confidential data (which should be obtained only if
absolutely necessary), manner of handling questions during the course of the
audit and the closing conference. Facility officials should be informed of their
right, under RCRA, CERCLA/Superfund and FIFRA, to receive duplicates,
replicates, or splits of any samples taken and receive the results of analyses. If
team members desire to take photographs or copies of records during the audit,
this should also be discussed in the opening conference.
Photographs are used to prepare a thorough and accurate investigation
report, as evidence in enforcement proceedings and to explain conditions found
at the plant. The facility, however, may object to the use of cameras in their
facility and on their property. If a mutually acceptable solution cannot be
reached and photographs are considered essential to the audit, Agency
supervisory and legal staff should be contacted for advice.
Facjlity personnel may also request that photographs taken during the
visitation be considered confidential, and the Agency is obliged to comply,
pending further legal determination. Self-developing film, although often of less
Under FIFRA, TSCA, and SDWA, written notification is required before entry. For
"unannounced audits," this notification can be provided at the time of entry. Under TSCA,
the investigator presents a TSCA Inspection Confidentiality Notice which informs the facility
of their right to claim certain materials as Confidential Business Information (CBI).
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satisfactory quality, is useful in these situations. A facility may refuse permission
to take photographs unless they can see the finished print. Duplicate
photographs (one for the investigator and the other for the facility) should satisfy
this need. When taking photographs considered TSCA Confidential Business
Information (CBI), self-developing film eliminates processing problems,
otherwise, the film processor must also have TSCA CBI clearance. Note,
however, that some self-developing film may contain disposable negatives
which must also be handled in accordance with the TSCA CBI requirements.
Giving the facility the option of developing the film may resolve problems when
self-developing film is not satisfactory.
Photographs must be fully documented, following procedures for
handling evidentiary materials [Appendix C].
GENERAL AUDIT PROCEDURES
The general elements that are common to all environmental compliance
areas which are process operations, pollution control, treatment and disposal,
and operation and maintenance are discussed below. Specific guidelines that
complement the general elements are contained in the following section, orga-
nized by environmental media - air, water, solid/hazardous wastes, and toxic
substances, pesticides, etc. Checklists, although not'necessarily comprehen-
sive can be helpful, and several are provided in the appendices.
On-site audit activities include reviewing records, reports, and data;
observing and evaluating equipment, monitors, devices and operations; and
interviewing facility personnel. Therefore, it is important to have a knowledge-
able facility representative(s) accompany the investigators during the audit.
Process Operations
Collectively, the audit team must have a basic understanding of the
physical plant under investigation and the general processes used at the
facility. This knowledge is necessary to aid in determining the substances (e.g.,
raw materials, products, byproducts, and waste materials) and how these are
managed, including release as pollutants into the environment. The
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compliance audit team is not required to have an in-depth understanding of the
industrial processes, but investigators should have sufficient understanding to
conduct a thorough and efficient audit.
The compliance audit team may perform the following:
Determine if changes have occurred since the last audit, permit
issuance, etc. in process units, their operation and flow diagrams
by comparison with available information. Determine the present
production level and rate of product, byproduct, and waste
generation. Determine the rate of raw material usage. Determine
production process unit mode (e.g., continuous or batch).
Information on production is essential if pollution control limits are
based on production rates or products. Process modifications may
have changed the types and loads of pollutants emitted,
discharged or disposed. Different production levels could cause
higher emission mass loadings or gas flow rates. Varying
operating conditions can cause pollutant collection and control
problems.
Identify those processes or physical elements of the facility which
contribute to sources of pollution (air, water, solid/hazardous
waste). Identify the sources, characterization, flow rates, etc. at
points where wastewater, gaseous emissions, and solid wastes
are generated. Determine fate of byproducts (e.g., do they
discharge or emit directly to the environment or to storage facilities
or to a treatment facility). Determine types and amounts of
pollutants being discharged.
• Determine the variability of process controls and production rates
and their relationship to pollutant emission discharges. Determine
if production upsets are tied to pollution incidents, exceedences,
etc., and the facility response to these upsets.
• Determine if process or facility modifications are proposed or
planned. Obtain information on these modifications, including
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schedules, and certainty of the modifications (e.g., is the change
proposed or planned, have funds been reserved). Obtain
documentation or facility estimates on wastes generated and
discharged.
Pollution Control, Treatment and Disposal
After investigators have determined which processes generate wastes
and how much, they should determine how the waste materials are handled
and ultimately released, treated, or disposed. This includes tracking the waste
from generation to final disposition, using process flow diagrams, physical
audits, and facility records.
The compliance audit team may perform the following:
Determine which waste streams are regulated by Federal, State or
local regulations, licenses and approvals. In doing so, the
investigators will be able to tailor their audit activities to the
handling, disposal and treatment requirements of the appropriate
regulations. Identify the various items regulated under the
established Federal regulations as shown in Table 1. Although it
is desirable to obtain information on all waste streams generated
(both those that are and those that are not specifically regulated),
the emphasis must be placed on the handling of regulated wastes.
This will ensure that the audit team accomplishes the major
objective of determining compliance with applicable regulations in
a reasonable period.
Obtain updated descriptions and schematics of major pollution
control equipment and waste storage/treatment/disposal areas.
Visually inspect equipment and storage/treatment/disposal areas.
Locate points of pollutant emission or discharge and waste
disposal or storage, including alternative locations, such as
diversions, bypasses and overflows.
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Obtain design information and startup dates for pollution control/
treatment devices and waste disposal areas. Observe disposal
areas and equipment during operation. Locate and observe
indicating and recording instrumentation for monitoring
control/treatment devices; compare operating levels to design
specifications to determine if devices are operating normally.
Review operations maintenance and inspection records. Identify
any operating problems and their probable causes.
Evaluate sampling techniques, equipment, and locations used for
collection of representative samples. Identify recycle and dilution
streams and other flow characteristics and relate to the sampling
locations. Determine if samples are being collected consistently
with permit/regulation requirements (e.g., grab vs. composite) and
frequency of sample collection. Observe monitoring procedures
such as flow measurement, sample collection and preservation,
calibration procedures, in-stack monitors, etc. Determine if proper
parameters are being monitored, if the methods and records are
consistent with permits and regulations, and if results are properly
calculated and reported. Evaluate quality assurance/quality
control procedures followed by the company.
Determine facility plans to expand existing treatment facilities and
install new treatment units. Obtain copies of design criteria,
consultants' reports, etc. Based on these data and first-hand
observations, determine what additional treatment may be
required to meet existing permit limits, regulations, and other
requirements.
Evaluate compliance with schedules, including status of
engineering plans and equipment design, procurement,
fabrication, installation and testing and startup of equipment.
Determine if the final requirements can be achieved on time, and
verify if structures are in place. Identify any delays associated with
particular construction schedule and possible violations. If
schedules are not being met, determine if the facility has
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rescheduled activities (e.g., corporate resolutions, financing
agreements, contracts, equipment orders and engineering
services documents). Verify dates when documents were
completed. Determine if recruitment and training of new
personnel (and potential new hires) for new pollution control
activities have been initiated.
Review laboratory analytical methods, procedures, recordkeeping,
and quality control measures. Determine if the methods conform
to permit and regulatory requirements. Determine if laboratory
quality assurance and quality control are sufficient to evaluate
data (e.g., proper and timely calibration, fresh chemical reagents,
and scheduled equipment maintenance). In some cases,
laboratory evaluations may involve off-site (company or contract)
laboratories. In these cases, determine if the off-site labs have
already been evaluated by EPA as part of the contract laboratory
program, other compliance, etc.
Operation and Maintenance (O&M)
Knowledge of the operation and maintenance practices for the process
and control facilities provides the investigator insight into plant management
and problems including frequency of breakdowns, malfunctions, upsets,
outages, diversions, spills and leaks, bypasses, and waste variability. It is
important to determine the causes of these incidents and if they can be
corrected. O&M review includes preventive, routine, and remedial maintenance
programs; spare parts inventory; emergency operating and response programs;
training and certification of plant personnel; alarm systems for power and
equipment failures; backup systems; and housekeeping practices throughout
the plant. The O&M review also includes review of facility and corporate
policies and protocols and schedules for such items as reading and calibrating
instrumentation, examining recording charts and logs, and updating O&M
manuals, engineering drawings and specifications, supplier manuals, and
equipment data cards.
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The compliance audit team may determine major factors which affect
process discharge, emissions, disposal, controls and changes in operation.
O&M practices should be evaluated as to whether they are adequate for the
proper management of pollution control equipment. Abnormal releases can be
due to progressive equipment deterioration or lack of repair. Also, as
equipment ages, efficiency drops and original removal rates may not be
achieved. Startup and shutdown of process and control facilities can create
problems of surge waste releases which may be alleviated by improved plant
management.
AUDIT PROCEDURES FOR SPECIFIC MEDIA OR SPECIAL AREAS
Air
Air pollution audit items are divided into four groups:
• Operating conditions
Control equipment
Continuous monitoring
Compliance records and testing.
The team should be prepared to observe, review, and document these audit
items so that factual information can later be evaluated and compliance
determined.
Before the audit, State air pollution control regulations that are part of the
approved State Implementation Plan (SIP) and State operating permits should
be reviewed. In addition, the checklists in Appendix D, which address the New
Source Performance Standards (40 CFR Part 60) and the National Emission
Standards for Hazardous Air Pollutants (40 CFR Part 61) including asbestos,
should be compared to an updated emissions inventory to determine if the
facility has any sources subject to these Standards. An updated emissions
inventory will also provide a list of regulated point sources within the facility.
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Operating Conditions
Determine if construction and operating permits are current.
Review records to determine if facility is operating within the
limitations of the permit.
Review records for abnormal operations, shutdowns,
malfunctions. Determine cause, frequency, and potential
impact on emissions.
Determine if any operational changes (feedstock, fuel flow
rate, temperature changes, etc.) have been made that could
potentially affect emissions.
Observe evidence of air pollution effects on premises,
especially over surrounding areas (e.g., odors, dusting,
deposits on cars, vegetation damage). Fugitive emissions
may require special attention. Odor problems may best be
characterized outside the plant because of olfactory fatigue
inside the plant.
Control Equipment
Compare observed operating conditions with baseline
values obtained from compliance stack tests or from
manufacturer's specifications.
Compare control equipment monitoring values (pressure
drop, flow rates, primary and secondary currents, etc.) with
permit and/or regulatory requirements.
• Conduct control system evaluation. Review instrumenta-
tion, design and operational flow rates, temperatures,
pressure drops, and emission monitors. From these data,
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the investigator should be able to determine if the plant is
achieving compliance under normal operating conditions.
Review control equipment maintenance procedures,
malfunctions and corrective actions taken.
Check number of emissions violations and any complaints
filed since the last audit.
Continuous Emission Monitoring (GEM)
Review operational (calibration, span, checks, etc.) and
maintenance practices.
Review records for excess emission reports (EERs) and
determine cause.
Review Performance Specification Tests and compare with
40 CFR 60, Appendix B requirements.
Correlate the opacity monitor readings with VEOs.
Compliance Records and Testing
Check source records for compliance with applicable
regulations, including NESHAP, NSPS.
Review source test reports. For most large sources
(potential emissions of any pollutant greater than 100 tons
per year) the facility should have a source test that shows
compliance with regulated limits. The test method should
be one specified in the SIP - usually an EPA reference test
method (40 CFR Part 60, Appendix A). The test report
should-contain process conditions at the time of the test and
enough data to determine if the test was conducted
properly.
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Determine if on-site visible emission observations are
warranted; an investigator doing CAA audits must be
certified for visible emissions observations; otherwise, the
readings will not be enforceable.
Water
Water pollution audit components can be categorized into five groups:
Control and treatment systems
Self-monitoring systems (including both field and laboratory
measurements)
Operation and maintenance
Best Management Practices (BMP)
Spill Prevention Control and Countermeasure (SPCC) Plan
Before the audit, the investigators should review the checklists in Appendix E,
and obtain and review copies of the discharge permit, permit application,
discharge monitoring reports (DMRs), and any additional required plans (Spill
Prevention Control and Countermeasure Plan, etc.).
Control and Treatment Systems
Determine if all wastewaters generated by the facility are adequately
controlled, recycled, directed to the wastewater treatment plant (on or off site),
discharged through an outfall regulated by a National Pollutant Discharge
Elimination System (NPDES) permit, etc. Identify any wastewater discharges
directly to a receiving waterbody that are not included in a facility NPDES
permit.
If the facility discharges to an off-site treatment plant, determine if the
discharge is required to meet pretreatment standards. Review these standards
and appropriate wastewater characterization data, as necessary.
If the facility has an on-site wastewater treatment plant (WWTP),
determine if the plant has the appropriate unit processes and is properly sized
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to effectively treat the quality and quantity of wastewater generated by the
facility. Review operations records and DMRs and visually inspect the facility.
Assess the ability of the WWTP to withstand low temperatures, excess storm
flows, peak process flows, shock loads, and infiltration. If past or proposed
process modifications have/will result in changed wastewater characteristics,
determine what has/will be undertaken to ensure that this wastewater is
adequately treated.
Self-monitoring Systems
Self-monitoring consists of flow and water quality measurements and
sampling by the facility in addition to the laboratory which analyzes water
samples required by the NPDES permit program.
Field - Confirm that acceptable sampling and flow measurement, as
specified by the NPDES permit, are conducted at the correct locations,
with the proper frequency, and by acceptable methods. Determine if all
necessary calibrations and O&M are performed. Samples must be
collected at prescribed locations. Flow rating and calibration must use
standardized techniques. Clean and properly prepared containers must
be used in sampling. Approved procedures are to be used in the
handling, preserving, and transporting of samples [Appendix E].
Laboratory - Evaluate procedures affecting final reported results
including:
Sample preservation methods and holding times
Chain-of-Custody
Use of approved procedures (40 CFR 136 or approved
alternatives)
Adequacy of personnel, equipment, and other components
of laboratory operations
Adequacy of quality assurance/quality control program
Recordkeeping and calculations
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Evaluate how the data are entered into lab notebooks; the sign-off
procedures used; analysis of spikes, blanks and reference samples; how
the lab data are transposed onto the official, self-monitoring report forms
sent to the enforcement agency; and the extent and capability of outside
contract laboratories, if used.
Operation and Maintenance
Determine if wastewater treatment processes are operated properly.
Observe the presence of solids, scum, grease, and floating oils or suspended
materials (pinpoint floe, etc.), odors, and weed growth in the treatment units.
Note appearance of wastewater in all units. Identify all out-of-service processes
and determine cause. Determine level of maintenance by observing condition
of equipment (pumps, basins, etc.) and reviewing records (outstanding work
orders, spare parts inventories). Assess handling, treatment and disposal of
sludges and other residues generated from processes and wastewater
treatment system.
Best Management Practices (BMP] Plan
Determine if the facility handles toxic materials and if a BMP Plan is
required (40 CFR 125, Subpart K or by NPDES permit). If applicable, review
facility BMP Plan or BMP Permit requirements. Determine if facility is following
required provisions. Review any records required by the plan for adequacy.
SPCC Plan
Determine if the facility is required to develop and implement an SPCC
Plan (40 CFR 112). Obtain a copy of the plan and required records to assess
compliance with the plan provisions. Visually inspect containment and run-off
control systems and procedures. Investigate any evidence of spilled materials.
Solid/Hazardous Waste
The compliance evaluation for solid/hazardous wastes managed at a
facility generally includes:
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Obtaining, reviewing, and evaluating information from Federal,
State, and local regulatory agency files
Interviewing facility personnel
• Examining facility records, including any internal waste
tracking/storage/disposal logs and audit records
Visually inspecting the waste management units.
An integral part of any evaluation is compiling facility background information
including facility size, operating unit dimensions (area, depth, volume, etc.) and
construction methods (presence/absence of liners, special compacting, etc.).
s
The investigator must determine how extensive a records review must be
to meet the audit objectives. Factors such as the number of documents
available, resource allocation, and time constraints determine whether the
objectives are realistic and can be achieved; however, in all cases, the records
review must be sufficient to demonstrate facility compliance or noncompliance.
Often, because of time constraints, documents may be copied (either microfilm
or photocopies) for future off-site review and evaluation. To ensure effective
use of resources, documents reviewed/copied while onsite should be limited to
those containing information within the audit scope.
A RCRA Inspection Manual (OSWER 9938.2A - March 1988) is available
to assist investigators evaluating hazardous waste generators, transporters, and
treatment, storage, and disposal (TSD) facilities. Investigators may also use the
various RCRA evaluation checklists in Appendix F during the audit to
supplement their knowledge of the RCRA regulations and ensure that all items
are adequately addressed. RCRA Land Disposal Restrictions evaluation
checklists are given in Appendix G.
The investigator should also be aware of the requirements of CERCLA,
including a owner/operator's responsibilities to notify the proper regulatory
authorities of former hazardous substance releases and sites (non-interim
status) where hazardous substances have been stored, treated, or disposed
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[CERCLA, Section 103(a) and (c)]. Military installations are also responsible for
conducting site assessments through remedial action programs to identify past
hazardous substance releases and handling facilities [40 CFR 300.64-68]. The
investigator should determine, through records review, interviews, etc., whether
all RCRA and CERCLA [Appendix H] sites have been reported to the proper
authorities. The investigator should also evaluate assessment and response
programs at a facility, if this objective is within the scope of the audit.
Additionally, the facility should be evaluated concerning State and local
requirements controlling past and current disposal of municipal waste,
nonhazardous industrial waste, and construction debris. The information
concerning such past disposal activities may lead to unreported RCRA and
CERCLA sites.
The initial step in evaluating compliance with solid/hazardous waste
requirements is to identify all waste streams generated at the facility and
determine which are regulated by Federal,* State" or local regulations, licenses
and approvals. Preferably, this determination is initiated during background
document review before the on-site facility audit and supplemented/modified
using information obtained while onsite. All waste streams generated (even
those that the generator claims are not regulated) must be evaluated for
regulatory inclusion. This will allow the investigator to determine whether the
generator has properly identified all regulated waste streams.
Once regulated waste is identified, the investigator can track the material
from generation to final on-site disposition (on-site treatment/disposal) or
storage and transport for off-site disposal and determine compliance with
applicable regulations. Throughout the audit, the investigator must keep in
mind that both past and present activities need to be evaluated for compliance
with applicable regulations.
Definitions, identification, and listing of Federally regulated waste are given in 40 CFR 260
and 261 and CERCLA § 101.
Nonhazardous solid waste is usually regulated by the State and these regulations must be
obtained to evaluate applicable facility activity.
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Information obtained during the audit inspection will be used, with the
applicable regulations, licenses, approvals, etc., to evaluate the waste handling
activities and determine status of compliance, as outlined in the following
sections. Areas of potential facility noncompliance must be documented as
thoroughly as possible. Document copies and photographs should be included
for future reference and evidence.
Facility Status Under RCRA
The investigator should determine if the facility has notified EPA of its
hazardous waste handling activities (waste generation, transport, treatment,
storage, or disposal) and if it has a required EPA identification number (40 CFR
262.12).
TSD facilities must apply for a RCRA permit [Section 2010(e) of RCRA].
Determine if RCRA Part A and B permit applications have been submitted (40
CFR 270), and whether the facility has been issued a RCRA permit. If a RCRA
permit has been issued, the facility must comply with both specific permit
provisions and 40 CFR Part 264. If no RCRA permit has been issued, the facility
is subject to the interim status provisions of 40 CFR Part 265. In both cases, the
facility may also be subject to requirements of State/local regulations, permits,
licenses and/or approvals. Before the audit, the investigator should determine if
State/local regulations apply. The investigator should have a copy of the
current Part A application (with amendments), the Part B application (if
available) and the RCRA permit (if applicable) during the audit so that the
accuracy of the Part A and Part B applications can be verified and compliance
with the permit determined.
Hazardous Waste Generators
Generators, as defined in 40 CFR 260.10, are subject to the requirements
of 40 CFR 262 and any additional State/local regulations, licenses, and
approvals. In general, determine if the waste is properly identified and the
waste containers are properly marked, including the date when waste accumu-
lation was initiated. Also, ensure that the generator has obtained an EPA
identification number (40 CFR 262.12). Because generators are not authorized
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to accumulate waste longer than 90 days, or 180 or 270 days for conditionally
exempt small quantity generators, the length of accumulation of all waste in
storage should be determined.* Determine if the generator has maintained
signed hazardous waste shipping manifests for waste shipped offsite for the last
3 years and evaluate if these manifests were completed/handled properly
(40 CFR 262, Subpart B). The facility "Contingency Plan and Emergency
Procedures," "Preparedness and Prevention Plans," and "Personnel Training
Program" should also be evaluated (40 CFR 265, Subparts C and D and CFR
265.16).
The investigator should determine whether the facility is properly
managing containers and tanks (40 CFR 264/265, Subparts I and J ). All
containers onsite during the audit should be inspected for general condition
(leaks, corrosion, etc.) and proper packaging, labeling, and marking
(40 CFR 262, Subpart C). The investigator should determine if all storage
area inspections are performed regularly and documented. The investigator
should review the checklists in Appendix F, Table F-6 before conducting an
audit of hazardous waste tank systems and should follow the guidance
provided in the Tank Systems Inspection Manual (OSWER 9938.4, September
1988).
The investigator should determine whether the-facility is in compliance
with technical requirements for underground storage tanks (40 CFR Part 280).
Inspections conducted under these parts should assure that the following forms
are completed and accurate:
Notification for Underground Storage Tanks
Description of Underground Storage Tanks (complete for each
tank at each facility)
Certification of Compliance (complete for all new tanks at each
facility)
If a generator has stored waste for more than 90 days [262.34(a), (b), and (c)J, waste
management is subject to the Federal requirements of 40 CFR 264/265 and 40 CFR 270
or the comparable State requirements in authorized states. Small quantity generators are
subject to different requirements [261.5, 262.34(d), (e), and (f)].
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Copies of these forms are reproduced in Appendix F, and appear in the
Federal Register, Vol. 53, No. 185 dated September 23, 1988, pages 37208
through 37210.
The investigator should determine whether the owner/operator manages
wastes that are burned for energy recovery, recycled, or disposed of in a
manner such that they are subject to 40 CFR Part 266 (Standards for the
Management of Specific Hazardous Wastes and Specific Types of Hazardous
Waste Management Facilities). These regulations contain standards for
generators, transporters, marketers, and users that recover energy from
hazardous waste and used oil. The regulations also contain standards for lead-
acid battery reclaimers, and recyclable materials used for precious metal
recovery or in a manner constituting disposal. Table F-14 [Appendix F] is a
checklist for evaluating compliance with Part 266 requirements.
The investigator should determine if the generator is managing a waste
subject to the land disposal prohibitions of 40 CFR Part 268. If the waste is a
restricted waste the investigator should determine whether the waste is
restricted as a result of constituent concentrations and if one of several
extensions or exemptions apply. Generators of restricted wastes are required
to:
Determine whether they generate restricted wastes
Determine waste treatment standards
Determine whether waste exceeds treatment standards
Provide for appropriate treatment and/or disposal
• Satisfy documentation, recordkeeping, notification, certification,
packaging, and manifesting requirements
• Meet applicable requirements if the generator is or becomes a
TSDF
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Appendix G contains checklists for specific land disposal requirements
placed on generators.
Hazardous Waste Transporters
Hazardous waste transporters, as defined in 40 CFR 260.10, are
required to comply with the Federal requirements of 40 CFR 263 and any
State/local regulations, licenses, and approvals. The transporter must also
meet applicable requirements of 49 CFR 171-179.
The investigator should ensure that the transporter has obtained an EPA
identification number (40 CFR 263.11) and is completing and handling the
waste shipping manifests properly, including maintaining a copy of each
manifest for at least 3 years. If a transporter stores waste in a transfer facility
(40 CFR 263.12), determine length of waste storage.* Any containers of waste
in a storage facility should be inspected for proper condition and proper
marking and labeling. If loaded trucks are present, proper placarding should be
checked.
Treatment. Storage, and Disposal Facilities
The investigator should determine if present facility operations and types
and quantities of waste handled are the same as those authorized by the origi-
nal Part A permit application (and approved amendments) or the final RCRA
permit, as applicable. Ensure that the TSD facility has obtained an EPA
identification number (40 CFR 265.11/264.11). Operations at all TSD facilities
must be evaluated for compliance with the general requirements of Subparts A
through H of either 40 CFR 265 or 40 CFR 264. The investigator should deter-
mine which subparts are applicable to each facility. Compliance evaluation of
general facility standards includes, but is not limited to evaluation of:
Waste Analysis Procedures (40 CFR 265/264.13, Subpart B)
Under Federal regulations (40 CFR 263.12), transporters can only store waste at a transfer
facility 10 days or less. State regulations may differ.
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Written waste analysis plan
Analytical/sampling procedures including laboratory
evaluation
Recordkeeping
Facility Security (40 CFR 265/264.14)
Access to the facility
Display of warning signs
General Facility Audit Requirements (40 CFR 265/264.15)
Written audit plan
Remedial action
Recordkeeping
Personnel Training (40 CFR 265/264.16)
Written training plan
Recordkeeping
Facility Preparedness and Prevention (40 CFR 265/264, Sub-
part C)
General maintenance
Communications/alarm system
Fire control equipment
Arrangements with local authorities
Contingency Plan and Emergency Procedures (40 CFR 265/264,
Subpart D)
Written contingency plan
Availability of emergency coordinator
Manifest System, Recordkeeping (40 CFR 265/264, Subpart E)
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Use, handling, and maintenance of shipping manifests
Facility operating record (including waste characterization/
quantity, waste tracking, disposal and treatment location)
Groundwater Protection (40 CFR 265/264, Subpart F)
Monitoring system (well location, design, operation)
Sampling and analysis including laboratory evaluation
Data recordkeeping
Characterization of site hydrogeology
Preparation, evaluation, and response
Waiver request (if any)
Detection vs. assessment monitoring
Corrective action plan(s)
Closure and Post-Closure (40 CFR 265/264, Subpart G)
Written closure/post-closure plans
Financial Requirements (40 CFR 265/264, Subpart H)
Financial assurance
Closure costs
All facility written plans (waste analysis, facility audits, contingency,
training, closure), should be copied to allow for in-depth evaluation. By
observing facility operations, such as self-inspection procedures, the
investigator can determine whether the facility is actually following the plans. In
many cases, a facility may have used several modifications of these plans, all
with different effective dates. All current plans must be evaluated. Out-of-date
plans should also be reviewed for compliance with applicable regulations in
effect at the time those plans were in place.
The investigator must also evaluate facility records required to be
maintained by the regulations (operating records, manifests, waste analysis
results, etc.). The extent of the record review must be sufficient to determine
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patterns of compliance/noncompliance with the recordkeeping requirements.
The investigators must decide on the minimum number of records necessary to
identify patterns of compliance/noncompliance. Documentation (investigators'
notes, copies of documents, and photographs) of noncompliance must be
retained for future use and evidence.
The investigator should determine whether the TSD facility is handling a
waste subject to the land disposal prohibitions of 40 CFR Part 268 and as set
forth in the revisions to 40 CFR Parts 260 to 265 and 270 (51 Federal Register
40635 et seq). Appendix G contains a checklist that highlights the land disposal
prohibitions for storage, treatment and disposal facilities. A review of the
checklist before the inspection is recommended because the requirements are
dependent upon the type of facility being inspected.
In addition to the general requirements specified above, the investigators
must evaluate the facility for compliance with the specific requirements for each
type of hazardous waste management activity. This includes, but is not limited
to, an evaluation of:
Use and Management of Containers (40 CFR 265/264, Subpart I)
General operation procedures
Condition of containers (leaks, corrosion, etc.)
Marking and labeling of containers
Compatibility of waste with containers
Management of containers
Inspection records
Tanks (40 CFR 265/264, Subpart J)
General operating procedures
Compatibility of waste with tank construction material
Integrity of tanks
Corrosion rate of tank materials
Compatibility between waste treated/stored in tanks
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Inspection records
Closure procedures
Surface Impoundments (40 CFR 265/264, Subpart K)
General operating procedures
Freeboard levels
Protective coverings of dikes
Inspection records
Closure/post-closure provisions
Waste Piles (40 CFR 265/264, Subpart L)
General operating procedures
Protection from wind dispersal of waste
Compatibility between various wastes within the pile
Run-on protection
Runoff characteristics, containment, and handling
Closure/post-closure provisions
Land Treatment (40 CFR 265/264, Subpart M)
General operating procedures
Run-off/run-on control provisions
Waste analysis
Waste loading
Protection of food chain crops
Unsaturated zone (zone of aeration) monitoring
Recordkeeping
Closure/post-closure provisions
Landfills (40 CFR 265/264, Subpart N)
General operating procedures
Run-on/run-off control and management
Protection from wind dispersal
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Recordkeeping
Required treatment of ignitable/reactive waste and liquid
material (prior to landfilling)
Leachate collection/handling procedures
Closure/post-closure provisions
Incinerators (40 CFR 265/264, Subpart O)
General operating procedures
Waste analysis
Startup/shutdown procedures
Monitoring/control equipment and provisions (combustion
and emission control)
Monitoring and inspection records
Closure procedures
Thermal Treatment (40 CFR 265, Subpart P)
General operating conditions
Waste analysis
Monitoring/control equipment and procedures (combustion
and emission controls)
Open burning/waste explosives procedures
Monitoring and inspection records
Closure
Other Chemical/Physical Treatment (40 CFR 265, Subpart Q)
General operating procedures
Waste analysis
Monitoring/control equipment
Inspection records
Closure
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Underground Injection (40 CFR Part 265, Subpart R)
Requirements of Part 265, Subparts A through E apply
Miscellaneous units (40 CFR Part 264, Subpart X)
Performance standards
Monitoring, analysis, inspection, response, reporting, and
corrective action
Post-closure care
Land Disposal Restrictions Program
The Land Disposal Restrictions program (40 CFR Part 268) is a
Congressionally mandated series of regulatory deadlines imposed on EPA for
restricting land disposal of hazardous wastes. If EPA does not propose
treatment standards for hazardous wastes by the deadlines imposed by
Congress, then the wastes are automatically banned from land disposal.
Land disposal is defined as the placement in or on the land and includes
the following disposal techniques:
Landfills
Surface impoundments
Waste piles
Injection wells
Land treatment facilities
Salt domes
Salt beds
Underground mines or caves
Concrete bunkers or vaults
The deadlines imposed are as follows:
Novembers, 1986
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Spent solvents with waste codes of F001 through F005 and Dioxin
wastes with waste codes F020 through F023 and F026 through
F028
JulyS, 1987
"California List" including wastes with a pH less than or equal to 2,
hazardous waste liquids containing RGBs >50 ppm, liquid, and
non-liquid halogenated organic carbons (HOCs), free cyanides,
and some metals
Augusts, 1988
First third of the listed hazardous wastes
June 8, 1989
Second third of the listed hazardous wastes
May8, 1990
Third third of the listed hazardous wastes
Refer to Appendix G for an inspection checklist.
CERCLA Off-Site Policy
The inspector should determine whether the facility is accepting CERCLA
response action wastes (CERCLA Sections 104 and 106) for treatment, storage,
or disposal. If so, the facility must:*
• ' Have no relevant violations at or affecting the unit or units
receiving CERCLA wastes [40 CFR 300.440(b)(1)].
See 40 CFR 300.440 on "Procedures For Planning and Implementing Off-site Response
Actions' for the full text of EPA's Off-Site Policy.
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Have no receiving units which are releasing any hazardous waste,
hazardous constituent, or hazardous substance into the ground
water, surface water, soil, or air (if facility is a RCRA Subtitle C
facility and is receiving post-SARA decision document* CERCLA
wastes).
Have no non-receiving units releasing any hazardous waste,
hazardous constituent, or hazardous substance into the ground
water, surface water, soil, or air, unless the release is addressed
by an enforceable agreement for corrective action under Subtitle
C of RCRA or other applicable Federal or State authority (if a
RCRA Subtitle C land disposal facility).
If the facility is a RCRA Subtitle C treatment, storage, and permit-
by-rule facility, then releases of any hazardous waste, hazardous
constituent, or hazardous substance from non-receiving units must
be evaluated to determine if they pose a significant threat to public
health or the environment.
CERCLA wastes resulting from a post-SARA decision document
should not be transferred to any unit at a non-Subtitle C facility if
the responsible agency has information indicating that an
environmentally significant release of hazardous substance has
occurred at that facility.
Pre-SARA decision document* resulting CERCLA wastes shall not
be transferred to an off-site facility if there are environmental
conditions at that facility which pose a significant threat to public
health, welfare, or the environment, or affect the satisfactory
operation of the facility.
Post-SARA decision documents are those CERCLA decision documents signed (such as
RODs) or consent decrees lodged after October 17, 1986.
Pre-SARA decision documents are those CERCLA decision documents signed or consent
decrees lodged prior to October 17, 1986.
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Have received an appropriate facility compliance inspection within
6 months prior to receiving the CERCLA wastes. A RCRA Facility
Assessment (RFA) or equivalent facility wide investigation should
have been completed if the facility is being considered to receive
wastes resulting from post-SARA decision documents. RCRA
Subtitle C land disposal facilities must have received a compre-
hensive ground-water monitoring evaluation (CME) or operation
and maintenance (O&M) inspection within the year preceding the
determination of acceptability.
Toxic Substances
This section describes those specific aspects of toxic chemical control
that are addressed by the Toxic Substances Control Act (TSCA) and its
associated rules and regulations (40 CFR Parts 702 to 799).
The regulation of toxics under TSCA is subdivided into two components
for Agency enforcement program management purposes.
"Chemical control" covers enforcement aspects related to specific
chemicals regulated under Section 6 of TSCA, such as polychlori-
nated biphenyls (PCBs), chlorofluorocarbons (CFCs) and
asbestos.
• "Hazard evaluation" refers to the various recordkeeping, reporting,
and marketing submittal requirements specified in Sections 5, 8,
12 and 13 of TSCA; although, some elements of what might be
termed "chemical control" are also addressed in these sections.
Sections 12 and 13 of TSCA, which pertain to chemical exports
. and imports, respectively, will not be covered in this manual due to
their special nature and unique requirements.
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Prior to discussing TSCA activities* at a facility, the investigator must
present appropriate facility personnel with copies of the following two TSCA
audit forms [Appendix I]:
Notice of Inspection - Shows purpose, nature, and extent of TSCA
audit
TSCA Inspection Confidentiality Notice - Explains a facility's rights
to claim that some or all of the information regarding toxic
substance handling at the facility is to be considered as TSCA
Confidential Business Information (CBI)
Before leaving the site, the following two forms must be completed, as
appropriate.
Receipt for Samples and Documents - Itemizes all documents,
photos and samples received by the investigator during the audit
Declaration of CBI" - Itemizes the information that the facility
claims to be TSCA CBI
Inspection considerations related to the chemical control and hazard
evaluation compliance are given in the following two subsections.
Chemical Control
Although the controlled substances most frequently encountered during
multi-media investigations are polychlorinated biphenyls (PCBs), the
investigator should determine if other regulated toxic substances are present at
the facility. Currently these include metal working fluids (Part 747), fully
halogenated chlorofluoroalkanes (40 CFR 762) and asbestos (40 CFR 763);
All personnel handling material claimed as Confidential Business Information under TSCA
must be cleared for access to that material in accordance with Agency procedures. An
annual update is required.
These forms are generally completed during the closing conference. During the opening
conference, facility personnel should be made aware that the latter form is used to itemize
TSCA CBI material.
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additional toxic substances may be regulated in the future. Because the
probability of finding PCBs and PCB items at a facility is greater than finding
other TSCA-regulated substances, the following discussion is directed toward
an evaluation of compliance with proper PCB and PCB item handling
procedures. Should other TSCA-regulated substances be present, the
investigator should consult the regulations for appropriate requirements.
Management of PCBs/PCB items is regulated under 40 CFR 761. In
general, these regulations address recordkeeping, marking and labeling,
audits, storage and disposal. The investigator is encouraged to use TSCA audit
checklists, such as the ones provided in Appendix J.
Facilities which store and/or dispose of PCBs and PCB items often have
EPA-issued Letters of Approval which contain facility operating and
recordkeeping requirements in addition to those specified in 40 CFR 761. The
investigator must obtain a copy of these approvals and any subsequent
notifications to evaluate facility compliance. The inspector should review Part
761.30 to identify uses of PCB transformers which are prohibited beginning
October 1, 1990, but with effective dates extending to October 1, 1993. The
inspector should also review the requirements found in Part 761.30 which allow
the installation of PCB transformers for emergency use.
In general, the compliance evaluation includes obtaining and reviewing
information from Federal, State, and local regulatory agency files; interviewing
facility personnel regarding material handling activity; examining facility records
and inspecting material handling units.
Recordkeeping
Every facility using or otherwise handling PCBs/PCB items is required to
maintain specific records. Records regarding use, storage, transport, and
disposal must be reviewed for accuracy, completeness, and compliance with
applicable regulations. This includes a determination of the accuracy of the
PCB inventory and annual document (40 CFR 761.180). An inventory checklist
is provided in Appendix J. in general, the investigator should visually inspect all
PCB items in service and in storage to verify completeness/accuracy of the
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records. Also, current records should be compared with past records to ensure
that all items have been adequately accounted for (40 CFR 761, Subpart J).
Marking/Labeling
Observe PCB and PCB suspect units in service and in storage and
determine if items are properly marked/labeled. (40 CFR 761, Subpart C).
Audits (Items in Use or in Storage for Reuse)
Review records to determine if items in use or stored for reuse have been
inspected, as required. Determine whether all audit and maintenance records
are being maintained, as required. Review these records to determine if
problems identified during the internal audit are being addressed properly.
PCB items should be inspected to verify that they are not leaking [40 CFR
761.30(a)(1)].
Servicing and Use of Various PCB Items
Determine whether the facility is servicing PCB items or using PCBs for
any of the following uses: Heat transfer agent, hydraulic fluid, research
purposes, in capacitors or in any other special authorized use category listed in
40 CFR 761.30. If PCBs are used in these services, determine if their use
complies with the special requirements for each use category (40 CFR 761.30).
Storage for Disposal
Identify all areas where PCBs/PCB items are stored for disposal.
Determine the adequacy of these storage facilities, including proper marking,
walls, roof, continuous floor with containment (ensure that containment is
adequate), and location (above/below 100-year floodplain). Visually inspect all
items in storage to determine if they are being stored properly (i.e., non-leaking,
marked/labeled and dated with storage date). Review storage area records
(including the required PCB annual document) for accuracy and adequacy.
Determine whether or not the storage area is being properly inspected and that
remedial action is being taken, as required (40 CFR 761.65).
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If PCBs/PCB items are stored outside of the designated storage facilities
(i.e., temporary storage), determine whether (1) items are leaking, (2) liquids
stored in containers have greater than 500 ppm PCBs [liquids with PCB
concentrations greater than 500 ppm cannot be stored in temporary areas
(except for transformers)], and (3) items are properly marked and labeled and
show dates removed from service and placed into storage (determine length of
time items have been in temporary storage). If liquids with PCBs have been or
are being stored in temporary storage, evaluate the required Spill Prevention
Control and Countermeasure (SPCC) plan, as described in 40 CFR 112, for
adequacy and accuracy. If the facility stores, in any permanent or temporary
storage areas, liquid PCBs in any containers larger than those described in 40
CFR 761.65(c)(6), the facility SPCC plan must also be reviewed/evaluated.
As of October 1, 1985, installation of PCB transformers (which have been
placed into storage for reuse or have been removed from another location) in or
near commercial buildings, is prohibited.
Disposal
Incineration - If the facility incinerates PCBs/PCB items, determine if the
facility has applied for and received the required EPA approval.
Determine if the facility meets required monitoring, control, and
recordkeeping requirements of the approval and of 40 CFR 761.
Observe monitoring and control equipment and review the required
records (including the PCB annual document) for adequacy and
accuracy and to ensure that the incinerator meets the specified feed rate,
combustion criteria, and combustion efficiency. Evaluate the required
annual document for completeness and accuracy (40 CFR 761.70).
Landfilling - If the facility landfills PCBs/PCB items, determine if the facility
has applied for and received the required EPA and State approvals.
Determine if the facility meets the specified siting, liner, and geological
conditions. Determine if the landfill is in the 100-year floodplain. If so,
inspect for proper water diversion structures. Evaluate general landfill
operating conditions to determine if waste is being handled properly (as
stated in the EPA Approval Letter and/or 40 CFR 761). This includes, but
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is not limited to, evaluation of (1) incompatibles being landfilled with the
PCBs/PCB items, (2) required facility maintenance records (including
concentration of liquids disposed of and three-dimensional burial
coordinates of waste), (3) adequacy of site security, (4) solidification of
liquids prior to disposal, and (5) proper preparation of transformers and
other PCB items (drained/triple-rinsed, etc.) prior to disposal. Evaluate
the required PCB annual document for adequacy and accuracy (40 CFR
761.75).
Determine if the facility is monitoring surface water, ground water and
leachates, as required by 40 CFR 761.75(b)(6). This includes identifying,
locating, and evaluating operation of ground water monitoring wells, and
reviewing ground water sampling and analysis procedures and sample
analysis results (for adequacy of monitoring frequency and proper
chemical constituents). Determine, by audit and records review, if the
facility has an operating leachate collection system. Review laboratory
data on leachate characterization to determine if leachate is being
adequately monitored and disposed of properly (40 CFR 761.75).
Hazard Evaluation
Establishing compliance with the various hazard evaluation aspects of
TSCA is best accomplished through review and evaluation of the recordkeep-
ing, reporting and submittal data required by the various regulatory components
of Sections 5 and 8. In general, Section 5 addresses "new chemicals" (i.e.,
those not in commercial production when TSCA was passed in 1977) and
Section 8 generally provides for control of "existing chemicals'* (i.e., those
chemicals that were in commercial production during 1977).
Much of the information to be obtained and reviewed under these two
sections of TSCA will likely be, or have been, declared as TSCA Confidential
Business Information (CBI) by company officials and, thus, requires special
control procedures.
The glossary [Appendix K, Table K-1] and 40 CFR Parts 703 to 723
should be consulted for an explanation of TSCA terms and definitions. The
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following list summarizes the different compliance objectives of the key TSCA
Section 5 and 8 components. Specific checklists for the important areas to
review, evaluate, and document for each pertinent section are given in
Appendix K, Table K-2.
1. Premanufacture Notification (PMN1
a. Verify that commercial manufacture or import did not begin
prior to the 90-day review date and not more than 30 days
before the Notice of Commencement (NOC) date. Verify
that no NOC has been submitted if commercial manufacture
or import has not begun.
b. Verify the accuracy and documentation of the contents of
the PMN itself.
c. Verify that all commercially manufactured or imported
chemicals are either on the TSCA 8(b) inventory, covered
by an exemption, or not subject to TSCA.
2. Research and Development (R&D) Exemption
a. Verify that the recordkeeping and notification requirements
are being met for all R&D chemicals.
b. Verify that "Prudent Laboratory Practices" and hazardous
data searches are adequately documented.
3. Test Marketing Exemption (TMEi
a. Verify that the conditions spelled out in the TME application
are being met, particularly with respect to dates of
production, quantity manufactured or imported, number of
customers and use(s).
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b. Verify that the TME recordkeeping requirements are being
met.
4. Low Volume Exemption (LVE) and Polymer Exemption (PE)
a. Verify that specific contents of the exemption application are
being met, and that all test data have been submitted.
b. For an LVE, verify that the 1,000-Kg limit per 12-month
period has not been exceeded. For a PE, assure that the
chemical structure and monomer composition(s) are
accurate.
c. Verify that recordkeeping requirements for both LVEs and
PEs are being met.
5. 5(eV5(ti Order. Rule, or Injunction
a. Verify that all conditions of the order, rule, or injunction are
being followed, including use of protective equipment,
glove testing, training, and recordkeeping.
b. If testing trigger is specified, verify production volume and
status of testing activity.
6. Significant New Use Rule (SNUR)
a. Verify that no commercial production has occurred prior to
the 90-day review date.
b. Verify that SNUR notices have been submitted for all
applicable manufactured, imported, or processed
chemicals.
c. Verify technical accuracy of SNUR submittal and complete-
ness of required recordkeeping.
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7. Bona Fide Submittals
Determine the commercial production (or import) status and R&D
history of those bona fide chemicals not found on the confidential
8(b) inventory. Verify findings against applicable PMN, TME or
other exemption.
8. Section 8fal Level A PAIR and CAIR Report
a. Determine if Preliminary Assessment Information Rule
(PAIR) and Comprehensive Assessment Information Rule
(CAIR) reports have been submitted for all 8(a) Level A
listed chemicals manufactured or imported by the facility.
b. Verify the accuracy of submitted PAIR information,
particularly the reported figures for total production volume
and worker exposure levels.
c. Verify the accuracy of submitted CAIR information and if the
report meets the date specified in the regulation.
9. Section 8fb) Inventory Update Rule (INUR^
a. Verify the accuracy of the information submitted in response
to the INUR.
b. Determine that required information was submitted by the
prescribed deadline for all chemicals subject to INUR.
10. Section B(c) Recordkeepino:
a. Determine if the facility has a Section 8(c) file and that
allegations of significant health and environmental harm on
record are properly filed and recorded.
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b. Determine that all applicable allegations have been
recorded and filed.
c. Determine if the facility has a written Section 8(c) policy and
if the policy includes outreach to the employees.
11. Section 8fd) Reporting
Determine if copies (or lists) of all unpublished health effects
studies have been submitted by manufacturers, importers, and
processors for any Section 8(d) listed chemical.
12. Section 8fe) Reporting
a. Verify that all Section 8(e) substantial risk reports to the
Agency were accurate and submitted within the required
time frames.
b. Verify that all substantial risk incidents and/or test results
have been reported to EPA.
c. Determine that the company has an adequate written policy
addressing Section 8(e), and that it relieves employees of
individual liability.
Pesticides
Pesticides are regulated by the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA).
The following list is for use in conjunction with the checklist in Appendix L
and specific storage/use/disposal requirements found on pesticide labels.
FIFRA requires a written notice of inspection and written receipt for samples and
documents collected. Additional information is available in the EPA Pesticides
Inspection Manual which has been revised and is being reprinted in 1989.
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Determine types and registration status of all pesticides produced,
sold, stored, and used at the facility, particularly if any are
restricted or experimental use pesticides
Determine use(s) of each pesticide
Determine certification status of facility/handlers
Verify who certifies facility/pesticide handlers (EPA, State,
DOD)
Determine if commercial or private application
If restricted-use pesticides are used, check if pesticide
applicators are authorized to use these pesticides
Check expiration dates on licenses/certificates
Review applicable records
Check previous audit records and complaints
Check application records
Check restricted-use pesticides records (must be kept at
. least 2 years). Document suspected violations accordingly
Check inventory records
Check training records
Check equipment repair records
Inspect storage, mixing/loading and container disposal areas
Check bulk storage areas for compliance with Federal/State
rules
Check location, ventilation, segregation, shelter, and
housekeeping of pesticide storage/handling areas. Check
security, fire protection, and warning signs, as may be
required by State regulations
Check mixing equipment/procedures for reducing handlers'
exposures to pesticides
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Check for safety equipment/procedures/use
Check container cleanup and disposal procedures
Pesticide waste disposal
Check to see that pesticides are disposed of in accordance
with applicable label and RCRA requirements
Determine measures taken to ensure worker safety
Check pesticide use records for re-entry time limit notation
Check pesticide use records for record of informing farmer
or warning workers and/or posting fields
Provide farmer and/or applicator copy of current worker
protection standards
Observe actual pesticide application
Observe mixing/loading and check calculations for proper
use dilution.
Observe when spray is turned on/off with respect to ends of
field.
Watch for drift or pesticide mist dispersal pattern.
Note direction of spraying pattern and trimming techniques.
Record wind speed and direction, air temperature, and
relative humidity.
Observe application with respect to field workers, houses,
cars, power lines, and other obstacles.
Determine if applicator and assisting personnel are wearing
safety gear required by the label.
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Water Supply
Public drinking water supply systems (i.e., serve at least 25 people) are
regulated by the Safe Drinking Water Act (SDWA), as amended October 31,
1988.
The water supply checklist in Appendix M should be reviewed for those
items of information necessary to determine monitoring requirements for water
supply systems and whether or not the system can be reasonably expected to
routinely provide safe potable water. Many facilities purchase their potable
water supply from a nearby municipality. If no further treatment is provided (e.g.,
chlorination by the facility), the facility may not be directly covered by the SDWA.
Nevertheless, the facility does have a responsibility to assure that their actions
do not result in contamination of the municipal water supply (e.g., through cross-
connection). The audit team should be alert to these possibilities.
There are five classes of injection wells defined in the Underground
Injection Control program (40 CFR Part 146.5). Generally, they can be defined
as:
Class I Industrial, Municipal or Hazardous waste disposal beneath
the lowermost underground source of drinking water
(USDW)
Class II Oil and gas related wells used for produced fluid disposal,
enhanced recovery
Class III Mineral extraction wells
Class IV Hazardous or radioactive waste disposal above or into a
USDW
Class V All other wells
The UIC program for Class I wells is also regulated under 40 CFR
Parts 124, 144, 146, and 148, as amended. The new part 148 is effective
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July 26, 1988. All other amendments are effective August 25, 1988. These
amendments include:
Hazardous Waste Disposal Injection Restrictions
Amendments to Technical Requirements for Class I Hazardous
Waste Injection Wells
Additional Monitoring Requirements applicable to all Class I wells
The UIC Checklists in Appendix N should be used when inspecting a
facility operating injection wells. The SDWA requires a written notice of
inspection.
Community Right-to-Know Requirements
The Emergency Planning and Community Right-to-Know Act (EPCRTKA)
of 1986 is a free-standing law contained within the Superfund Amendments and
Reauthorization Act (SA :A) of 1986. EPCRTKA is also commonly known as
SARA Title III. EPCRT? •> requires dissemination of information to State and
community groups and health professionals on chemicals handled at regulated
facilities.
An EPCRTKA audit verifies that the facility owner/operator has notified
State and local agencies of regulated activities; has submitted information to
specific State and local agencies; and has prepared and submitted all other
required reports. The inspector should review the checklist shown in
Appendix O.
Emergency Planning (Sections 301 through 303)
EPA promulgated regulations which identify extremely hazardous
substances and the levels to be regulated under EPCRTKA. The inspector
should determine whether the facility is subject to EPCRTKA regulation. If the
facility does meet the requirements, the inspector should verify whether the
facility owner/operator:
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Notified the State emergency response agency and the local
emergency planning committee that the facility is regulated under
EPCRTKA
Designated a facility emergency coordinator to assist the local
emergency planning committee in the planning process
Notified the local emergency planning committee of the
emergency coordinator's identity
Emergency Notification (Section 304)
The owner/operator of a facility subject to EPCRTKA must immediately
report releases of hazardous substances. Substances subject to this
requirement are the extremely hazardous substances listed in 40 CFR Part 355
and substances subject to the emergency notification requirements under
CERCLA Section 103(a) or (c). The inspector should verify whether an
immediate notification was made to the:
State emergency response commission
Local emergency planning committee ' •
Community Right-to-Know Requirements (Sections 311 through 312)
Manufacturing facilities subject to the Occupational Safety and Health Act
(OSHA) Hazardous Communication Regulation (29 CFR Part 1910) are
required to prepare Material Safety Data Sheets (MSDS) for each hazardous
chemical handled at the facility. Manufacturing facilities covered are contained
within Standard Industrial Classification (SIC) Codes 20 through 39. OSHA
revised its Hazardous Communication Regulation, effective September 23,
1987, to require that MSDSs be prepared by non-manufacturing facilities. The
inspector should verify that the facility owner/operator has sent to the State
emergency response commission, the local emergency planning committee
and the local fire department the following:
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61
MSDS or a list of chemicals covered by MSDS found at the facility
An annual inventory of hazardous chemicals found at the facility
Toxic Chemical Release Reporting (Section 313)
Covered facilities (40 CFR Part 372.22) that manufacture, import,
process, or use certain chemicals must annually report releases to the
environment. The inspector should determine whether the facility owner/
operator is required to submit a report (Form R). All of the following conditions
must apply at the facility in order to meet the reporting requirements:
The facility has ten (10) or more full-time employees
An operation(s) identified in SIC Codes 20 through 39 is present
The amount of chemical(s) handled exceeds the applicable
threshold quantity
Laboratory and Data Qualify Audits
The purpose of laboratory evaluations and data quality assessment is to
determine if all analytical and monitoring requirements have been met and to
characterize data usability.
Two approaches are used: Performance and systems audits.
Performance audits are independent checks made to evaluate the quality of
data produced by the total measurement system. This type of audit assesses
the results and usually does not examine the intermediate steps to achieve
these results. One example is the performance evaluation check sample which
is used to validate calibration accuracy but usually not the overall effectiveness
of the methodology. Another example is an audit of a particular measurement
device using a reference device with known operational characteristics.
A systems audit typically involves an inspection of the components
comprising the total measurement system. The Agency has certain
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62
expectations of the process used to sample, analyze, and report results. The
systems audit is designed to objectively examine each important part of that
process to determine deviations from required or recommended practice. The
systems audit is more qualitative than the performance audit. A systems audit
assesses such items as equipment, personnel, physical aspects, analytical and
quality control procedures, quality assurance procedures, and other laboratory
or measurement procedures. From a regulatory perspective, this type of audit
may find noncompliance with equipment or procedural requirements, or even
fraud.
Typically, a systems audit combined with performance audits will be
conducted in order to extract the maximum amount of information.
General
A detailed list of items should be requested from the company and
contract laboratory. This list should include:
Standard Operating Procedures (SOPs)
• Quality Assurance Plan
• Personnel resumes
Instrument maintenance and calibration records
Monitoring data to be looked at
If performance evaluation samples are to be analyzed, these should be
forwarded to the company at the earliest possible time. If preliminary data is
available, it should be carefully examined for problems and if problems are
found, a more careful examination of these areas can be made onsite.
During the on-site visit, every component of sample handling, sample
analysis and data reduction should be examined. The auditor starts with the
laboratory supervisor and QA officer to verify that the information supplied on
personnel training, quality assurance/quality control, and SOPs is correct. For
each parameter determined, the individual or individuals who actually make
that determination are interviewed. The analyst is asked to detail exactly what
happens to each sample and demonstrate the use of equipment including
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63
instrument calibration. Checklists are prepared as an aid to the inspector.
Examples are shown in Appendix P. Bench data (initially recorded numbers,
strip charts, etc.) is selected. Final results are calculated from the bench data by
the inspector and compared with the results reported to the agency. On-site
personnel will be asked to explain any discrepancies at this time. Other
documents necessary to the case or as potential evidence are copied.
The final assessment and data quality determination is normally
performed following the on-site audit. Critical data are re-examined for trends
and anomolies. Where necessary, data is computerized and analyzed using
statistical software packages. Techniques such as mass balance, solubility
product determination, oxidation-reduction state consistency are used, where
applicable, to indicate data problems. A propagation of error treatment may be
used to establish data quality. Performance audit results are evaluated against
reference data base statistics.
NPDES (Water!
* Determine that the exact date, time, and person who takes each
sample are recorded
Determine that the exact date, time, person, and method used for
each type of determination are recorded
• Inspect permit carefully to ensure that the permittee adheres to
specified conditions
• Ensure that methods used are in conformance with 40 CFR 136
unless alternate approval has been obtained
RCRA Waste Handling
• ' Determine which parts of the regulations are applicable to the site
Determine which waste analysis plans (WAPs) were in effect
during the time of records and evaluation
• Determine that the WAPs meet the specifications of the regulation.
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64
Determine that each type of analysis specified in the WAPs is
performed in accordance with the methodology specified and
under the circumstances required
Determine that the methodology specified is adequate
RCRA Ground Water
Determine that the sampling and analysis plan (SAP) is adequate
Determine that the laboratory follows the methodology specified in
the SAP
Determine that this methodology is adequate
Calculate detection limits to ensure that they are adequate for
ground-water protection
Computerized Information Systems
NEIC has developed various computerized information systems to assist
NEIC inspectors in their search of background information on selected facilities,
and also to support data needs of users outside of NEIC, especially other EPA
offices. Three listings are given below for information systems accessed by,
and used by NEIC.
A. EPA Internal Systems Accessible Bv NEIC
Aerometric Information Retrieval System (AIRS)
Chemicals in Commerce Information System (CICIS)
Compliance Data System (CDS)
Comprehensive Environmental Response, Compensation and
Liability Information System (CERCLIS)
Consent Decree Tracking System
Docket System
Emergency Response Notification System (ERNS)
Enforcement Document Retrieval System (EDRS)
Facility Index System (FINDS)
Hazardous Waste Data Management System (HWDMS)
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65
NPDES Industrial Permit Ranking System
Permit Compliance System (PCS)
Potentially Responsible Parties System
Records of Decision System (RODS)
Site Enforcement Tracking System (SETS)
STORET
Superfund Financial Assessment System (SFFAS)
TECHLAW Evidence Audit System
Toxic Release Inventory System (TRIS)
B. Public Information Systems Accessible Bv NEIC
Bibliographic Retrieval Service (BRS)
Chemical Information System (CIS)
Data Times
DIALOG Information Services, Inc.
Dun and Bradstreet
Groundwater On-Line (GWOL)
Justice Retrieval and Inquiry System (JURIS)
NEWSNET
NEXIS/LEXIS
National Library of Medicine (NLM)
VU/TEXT
WESTLAW
C. Restricted Access Information Systems
Criminal Docket
Criminal Investigative Index System (Cll)
National Crime Information Center (NCIC)
National Law Enforcement Teletype System (NLETS)
This Manual does not afford the opportunity to define each of these
information systems. Six example systems are briefly described as follows
together with NEIC application of these systems.
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66
System
Description
Application
Compliance Data
System (CDS)
Comprehensive
Environmental
Response, Com-
pensation, and
Liability Information
System (CERCLIS)
Consent Decree
Tracking System
A national system contain-
ing compliance informa-
tion including compliance
status, agency actions
(e.g., inspections), etc. for
major sources of the five
primary air pollutants.
A national system con-
taining names and loca-
tions of uncontrolled
hazardous waste sites in
the U.S., summary
response event status
information, alias names
and site characteristic
data. Recent modifica-
tions include provisions
for tracking enforcement
activities, and technical
and chemical information
at CERCLA sites.
A national system con-
taining a computerized
inventory of consent
decrees to which EPA is a
party, and computerized
summaries of the contents
of decrees by facility.
NEIC maintains a hard-
copy library of all consent
decrees within the system.
NEIC can acquire the
Significant Violators list
and compliance event
data for individual
sources, whole facilities,
sources within a certain
geographical area and
sources of a specific
industrial classification.
NEIC can generate site
inventory listings for geo-
graphical area, the
National Priorities List,
and technical event status
reports for any uncon-
trolled hazardous waste
site and cleanup expendi-
ture reports.
NEIC can produce hard
copies of all decrees in
the inventory, and pro-
duce computer reports of
the inventory, the entire
contents of decrees, the
milestones to be met in
specific decrees or for
decrees within a Region
and the contents of all
decrees for a specific
issue (e.g., groundwater
monitoring).
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67
System
Description
Application
Permit Compliance
System (PCS)
Records of Deci-
sion System
(RODS)
WESTLAW
A national computerized
management information
system containing an
inventory of NPDES per-
mits, milestone forecasts,
inspection events, effluent
measurement data, efflu-
ent and compliance viola-
tions and enforcement
actions.
A full-text national data-
base of over 2,000 Super-
fund Records of Decision
The WESTLAW system
contains legal informa-
tion, including the full text
of cases from the
Supreme Court, U.S.
Court of Appeals, U.S.
District Courts, and State
Courts. It contains
Shepards' Citations, reg-
ulatory information from
the Code of Federal
Regulations, Federal
Register, U.S. Code and
the expert witness infor-
mation from Forensic
Services Directory.
NEIC can acquire limit/
measurement data for
individual discharges or
whole facilities, facilities
within a geographic area,
sources of a specific
industrial classification
and the Quarterly Non-
Compliance Report
(QNCR) by Region or
State. Information on
effluent and compliance
schedule violations and
enforcement actions/
tracking can be obtained.
NEIC can retrieve a speci-
fic ROD by searching on-
site name or ID number or
can identify all RODS
having selected media,
contaminants or remedies.
NEIC uses WESTLAW to
identify precedent cases,
to locate all cases decided
by a certain judge or all
cases decided by a cer-
tain attorney and to locate
possible expert witnesses.
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69
THE AUDIT REPORT AND FOLLOWUP
The audit report organizes and coordinates all evidence gathered during
the audit in a usable manner. It is the compilation of factual information and
professional judgment resulting from the compliance audit. Information in the
report must be accurate, relevant, complete, objective, and clear. The report
serves to record the procedures used in gathering the data and gives factual
observations and evaluations from the audit. It is the basis for any follow-up
activities/enforcement that might occur.
Many different formats are possible for the audit report. A typical report
can be structured in two main sections; the Executive Summary and the
Technical Report. The Executive Summary establishes the objectives of the
audit and presents succinct conclusions which are supported by relevant
findings; recommendations are made if appropriate. Topics in the summary
may include:
• Overall environmental compliance
Adequacy of pollution control and treatment systems
• Adequacy of operation and maintenance practices
Multi-media waste abatement needs
• Follow-up action
The Technical Report comprehensively describes the inspection by
discussing such topics as facility history, investigation methods, sampling
programs, and specific problem areas. The Technical Report correlates audit
findings with the conclusions contained in the Executive Summary.
Where potential criminal activities are discovered during the audit, the
audit team and Regional office should promptly notify the Office of Criminal
Investigations in Denver or the Regional/Special-Agent-in-Charge for a
determination on whether a criminal investigation should be initiated.
Administrative/civil enforcement (including informal negotiations with the
company) should be held in abeyance, pending a decision on the
appropriateness of a criminal referral or additional field investigation.
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BIBLIOGRAPHY
1. EPA Order 1000.18, Transportation of Hazardous Materials, February 16,
1979. Washington, D.C., Environmental Protection Agency.
2. EPA Order 1440.2, Health and Safety Requirements for Employees
Engaged in Field Activities , July 12, 1981. Washington, D.C.,
Environmental Protection Agency.
3. EPA Order 1440.3, Respiratory Protection, July 24, 1981. Washington,
D.C., Environmental Protection Agency.
4. EPA Order 1440.4, Health and Safety Training Requirements for Mine
Safety, August 17, 1982. Washington, D.C., Environmental Protection
Agency.
5. EPA Order 1440.6, Motor Vehicle Occupant Restraint Systems,
February 2, 1984. Washington, D.C., Environmental Protection Agency.
5. EPA Order 1440.7, Hazard Communication, May 30, 1986. Washington,
D.C., Environmental Protection Agency.
7. EPA Order 3100.1, Uniforms, Protective Clothing and Protective
Equipment, December 8, 1972. Washington, D.C., Environmental
Protection Agency.
8. EPA Order 3100.3, Authorization of Performance of Hazardous Duty,
October 31, 1977. Washington, D.C., Environmental Protection Agency.
9. G. William Frick, October 1981. Conducting an Environmental Audit,
Washington, D.C, Van Ness, Feldman, Sutcliffe, Curtis and Levenberg.
10. Industrial Environmental Research Laboratory, August 1979. A
Handbook of Key Federal Regulations and Criteria for Multimedia
Environmental Control. Interagency Energy/Environment R&D Program
Report, Research Triangle Park, North Carolina, Environmental
Protection Agency, EPA-600/7-79-175.
11. National Enforcement Investigations Center, July 1981. A Step-by-Step
Approach to Development of NPDES and RCRA Permits, Denver,
Colorado, Environmental Protection Agency, EPA-330/1-81-004.
12. National Enforcement Investigations Center, August 1979. Enforcement
Considerations for Evaluation of Uncontrolled Hazardous Waste
Disposal Sites by Contractors, Draft Report, Denver, Colorado,
Environmental Protection Agency.
-------
Bibliography (cont.)
13. National Enforcement Investigations Center, August 1979. Performance
Audit Inspections of Wastewater Sources, Denver, Colorado,
Environmental Protection Agency, EPA-300/1-79-004.
14. National Enforcement Investigations Center, March 1981. NEIC
Pesticide Sampling Guide, EPA 330/9-81 -001.
15. National Enforcement Investigations Center, (revised) May 1986. NEIC
Policies and Procedures Manual. Denver, Colorado: Environmental
Protection Agency, EPA-330/9-78-001-R.
16. National Enforcement Investigations Center, July 1981, RCRA Inspection
Manual, Denver, Colorado, Environmental Protection Agency.
17. National Institute for Occupational Safety and Health (NIOSH), et al.,
October 1985, Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities. Washington, D.C., United States
Government Printing Office.
18. Office of Administration, Occupational Health and Safety Staff, Eye
Protection Program Guideline. Washington, D.C., Environmental
Protection Agency.
19. Office of Administration, Occupational Health and Safety Staff, May 1987.
Interim Health and Safety Guidelines for EPA Asbestos Inspectors
(Revised). Washington, D.C., Environmental Protection Agency.
20. Office of Administration, Occupational Health and Safety Staff, March 18,
1986. EPA 1440, Occupational Health and Safety Manual, 1986 Edition.
Washington, D.C., Environmental Protection Agency.
21. Office of General Enforcement, February 1979. Enforcement Workshop
on Plant Inspection and Evaluation • Volume II, Inspection Procedures
and Performance Evaluation, Washington, D.C., Environmental
Protection Agency.
22. Office of General Enforcement, February 1979. Enforcement Workshop
on Plant Inspection and Evaluation - Volume III, Process and Control
Equipment Flow Charting Techniques, Washington, D.C., Environmental
Protection Agency.
23. Office of General Enforcement, February 1979. Inspection Procedures
for Evaluation of Electrostatic Predpitator Control System Performance,
Washington, D.C., Environmental Protection Agency, EPA-304/1-79-007.
-------
Bibliography (cont.)
24. Office of Planning and Management, April 1973, EPA Employee
Responsibilities and Conduct, Washington, D.C., Environmental
Protection Agency.
25. Office of Water Enforcement, Enforcement Division, June 1984. NPDES
Compliance Inspection Manual, Washington, D.C., Environmental
Protection Agency.
26. Office of Solid Waste and Emergency Response, Office of Waste
Programs Enforcement, September 1988, EPA Hazardous Waste Tank
Systems Inspection Manual, Washington, D.C., Environmental Protection
Agency, OSWER 9938.4.
27. Office of Water Enforcement, Enforcement Division, 1977. NPDES
Compliance Sampling Inspection Manual, Washington, D.C.,
Environmental Protection Agency.
28. Oregon State Health Division, Department of Human Resources, Small
Public Water Supply Sanitary Survey Report, 33-5 (revised January
1985).
29. PEDCO Environmental, Inc., 1980. Standards of Performance for New
Stationary Sources - A Compilation as of January 1, 1980. Cincinnati,
Ohio, Environmental Protection Agency, EPA-340/1-77-015, EPA-340/1 -
79-001, EPA-340/1-79-001 a, EPA-340/1-80-001.
30 Pesticides and Toxic Substances Enforcement Division, January 1980.
Toxic Substances Control Act Inspection Manual, Volume One : TSCA
Base Manual, Washington, D.C., Environmental Protection Agency.
31. Pesticides and Toxic Substances Enforcement Division, March 1981,
Toxic Substances Control Act Inspection Manual, Volume Two: PCB
Inspection Manual, Washington, D.C., Environmental Protection Agency.
32 A.D. Schwope, et a/., March 1985, Guidelines for the Selection of
Chemical Protective Clothing, 2nd Edition. Cambridge, MA, Arthur D.
Little, Inc.
33. Technology Transfer, 1978. Handbook, Industrial Guide for Air Pollution
Control, Environmental Protection Agency, EPA-625/6-78-004.
34. Thomas H. Truitt, et a/., 1971. Environmental Audit Handbook - Basic
Principles of Environmental Compliance Auditing, Washington, D.C.,
Wald, Harkrader & Ross and Resource Planning Corp.
-------
Bibliography (cant.)
35. Engineering Enterprises, Inc., February 1988: Underground Injection
Control Inspection Manual, for U.S. Environmental Protection Agency,
Washington, D.C.
36. EPA Office of Underground Storage Tanks, September 1988, Musts for
USTs: EPA/530/UST-88/008
37. "A Description of Automated Information Systems Accessible by NEIC,"
USEPA, OECM, National Enforcement Investigation Center, Information
Management Branch, Denver, Colorado, January 1989
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ACRONYMS
AQCR - Air Quality Control Region
BAT - Best Available Technology
BATEA - Best Available Technology Economically Achievable
BCT - Best Conventional Pollution Control Technology
BMP - Best Management Practices
BOD - Biochemical Oxygen Demand
BPT - Best Practicable Control Technology Currently Available
Btu - British thermal units
CAA - Clean Air Act
CBI - Confidential Business Information
CEM - Continuous Emission Monitoring
CERCLA - Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (Superfund)
CFR - Code of Federal Regulations
COD - Chemical Oxygen Demand
CWA - Clean Water Act [aka: Federal Water Pollution Control Act (FWPCA)]
DCO - Document Control Officer
DO - Dissolved Oxygen
DOT - Department of Transportation (Federal)
EPA - Environmental Protection Agency (Federal)
EPCRTKA - Emergency Planning and Community Right-to-Know Act
ESP - Electrostatic Precipitators
FIFRA - Federal Insecticide, Fungicide and Rodenticide Act
FIP - Final Implementation Plan
F/M - Food to Microorganism Ratio
HSWA - Hazardous Solid Waste Amendments
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ACRONYMS (cont.
HW-FW - Half Wave/Full Wave (electrical distribution)
INUR - Inventory Update Rule
ITC - Interagency Testing Committee
LAER - Lowest Achievable Emission Rate
MLVSS - Mixed Liquor Volatile Suspended Solids
MDSD - Material Safety Data Sheets
N/A - Not Applicable
NAA - Non-Attainment Areas
NAAQS - National Ambient Air Quality Standards
NEIC - National Enforcement Investigations Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NOC - Notice of Commencement
NPDES - National Pollutant Discharge Elimination System
NSPS - New Source Performance Standards
OECM - Office of Enforcement and Compliance Monitoring
O&M - Operation and Maintenance
ORM - Other Regulated Material
OSHA - Occupational Safety and Health Act
PAIR - Preliminary Assessment Information Rule
PCB - Polychlorinated Biphenyls
PMN - Premanufacture Notice
POTW - Publicly-Owned Treatment Works
PSD - Prevention of Significant Deterioration
QA/QC - Quality Assurance/Quality Control
RA - Regional Administrator
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ACRONYMS (cont.)
RCRA - Resource Conservation and Recovery Act (enacted as amendment to
the Solid Waste Disposal Act)
R&D - Research and Development
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act (enacted as amendment to the Public Health
Service Act)
SIC - Standard Industrial Classification (company description)
SIP - State Implementation Plan
SNUR - Significant New Use Rule
SPCC - Spill, Prevention, Containment and Countermeasures
SPDES - State Pollutant Discharge Elimination System
SSE - Stationary Source Enforcement
TME - Test Marketing Exemption
TOC - Total Organic Carbon
T-R - Transformer-Rectifier
TSCA - Toxic Substances Control Act
TSD - Treatment, Storage and Disposal
TSDF - Treatment, Storage and Disposal Facilities (hazardous waste)
TSS - Total Suspended Solids
UIC - Underground Injection Control
U.S.C. - United States Code
USDW - Underground Source of Drinking Water
VEO - Visible Emissions Observation
WLA-TMDL - Wasteload Allocation/Total Maximum Daily Load
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APPENDICES
A SUMMARY OF POLLUTION CONTROL LEGISLATION
B SAFETY PLAN
C EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
D AIR POLLUTION CHECKLISTS
E WATER POLLUTION CHECKLISTS
F RCRA CHECKLISTS
G LAND DISPOSAL RESTRICTIONS CHECKLIST
H CERCLA CHECKLIST
I TSCA FORMS
J TSCA PCB CHECKLIST
K TSCA SECTIONS 5 AND 8 CHECKLIST
L PESTICIDE (FIFRA) CHECKLIST
M WATER SUPPLY CHECKLIST
N UNDERGROUND INJECTION CONTROL (UlC) CHECKLIST
0 COMMUNITY RIGHT-TO-KNOW CHECKLIST
P LABORATORY AUDIT CHECKLISTS
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APPENDIX A
SUMMARY OF POLLUTION CONTROL LEGISLATION
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Appendix A
SUMMARY OF POLLUTION CONTROL LEGISLATION
This appendix is a synopsis of the Federal approach to environmental
regulation, EPA enforcement remedies and a summary of each of the major
pollution control acts: the Clean Air Act (CAA), the Clean Water Act (CWA), the
Resource Conservation and Recovery Act (RCRA), the Comprehensive
Environmental Response, Compensation and Liability Act
(CERCLA/Superfund), the Toxic Substances Control Act (TSCA), the Federal
Insecticide, Fungicide and Rodenticide Act (FIFRA), the Safe Drinking Water Act
(SDWA), and the Emergency Planning and Community Right-to-Know Act
(EPCRTKA). Because these laws and the regulations promulgated thereunder
typically are very complex and continually are being modified, the investigator
should carefully review the specific provisions which apply to the operations of
the facility before conducting an inspection.
GENERAL FEDERAL APPROACH TO ENVIRONMENTAL REGULATION
National standards are established to control the handling, emission,
discharge and disposal of harmful substances. Waste sources must comply
with these national standards whether the programs are implemented directly
by EPA or delegated to the States. In many cases, the national standards are
applied to sources through permit programs which control the release of
pollutants into the environment. The EPA establishes the Federal standards
and requirements and approves State programs for permit issuance.
The States can set stricter standards than those required by Federal law.
Some of the larger programs which have been delegated by EPA to qualifying
States arg the National Emissions Standards for Hazardous Air Pollutants
(NESHAP), the Prevention of Significant Deterioration (PSD) permits under the
CAA, the Water Quality Standards and the National Pollution Discharge
Elimination System (NPDES) programs under the CWA, the Hazardous Waste
Program under RCRA, and the Drinking Water and Underground Injection
Control (UIC) programs under the SDWA. Conversely, TSCA is administered
entirely by the Federal government.
(03/89)
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A-2
EPA ENFORCEMENT OPTIONS
1. issuance of an Administrative Compliance Order, sometimes preceded by
a Notice of Violation.* A Compliance Order will specify the nature of the
violation and give a reasonable time for compliance. The order, if
violated, can lead to enforcement action pursuant to the civil and/or
criminal process of environmental laws.
2. Issuance of an administrative complaint for civil penalties. Parties named
in such complaints must be given notice and an opportunity for a hearing
on the alleged violations before a penalty can be assessed by EPA.
3. Under certain statutes (e.g., SDWA) EPA may take whatever action is
necessary to protect the public health, in emergency situations, without
first obtaining a judicial order.
4. EPA generally may go directly to Federal court seeking injunctive relief or
a civil penalty without using administrative procedures. EPA also may
obtain an emergency restraining order halting activity alleged to cause
"an imminent and substantial endangerment" or "imminent hazard" to the
health of persons.
5. EPA may go directly to Federal court seeking criminal sanctions without
using administrative procedures. Criminal penalties are available for
"knowing" or for "willfull" violations.
In addition, EPA can also "blacklist" a company or party that fails to comply with
the CAA or CWA by preventing it from entering into Federal contracts, loans and
grants. In cases where the party had been convicted of certain criminal
offenses under the CAA or CWA, Federal agencies are expressly prohibited
from entering into contracts, etc., with that entity.
A concise written statement with factual basis for alleging a violation and a
specific reference to each regulation, act, provision or permit term allegedly
violated
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CLEAN AIR ACT
The Clean Air Act (CAA) cads for EPA to establish national ambient air
standards. These standards are expressed as concentrations of designated
hazardous pollutants called National Ambient Air Quality Standards (NAAQS).
These standards are to be achieved by the States through State
Implementation Plans (SIPs). EPA also sets the following national air emission
standards: New Source Performance Standards (NSPS), National Emissions
Standards for Hazardous Air Pollutants (NESHAP) and standards governing
mobile sources of air pollution (including motor vehicle fuels). Moreover,
special programs have been developed for prevention of significant
deterioration (PSD) in clean air areas and for stringent controls in
nonattainment areas (NAAs).
The SIP provides emission limitations, schedules arid timetables for
compliance by stationary sources, as well as transportation control plans for
mobile sources. The act focuses upon "major" stationary sources or major
modifications of existing sources. Major sources are defined as sources which
generally emit more than 100 tons per year of a designated pollutant.
National Ambient Air Quality Standards/State Implementation Plans
EPA designates harmful pollutants and publishes criteria documents
which discuss potential harmful effects of those pollutants. The Agency then
sets primary and secondary ambient air standards (CAA, Section 109). Primary
standards are intended to protect the health of the population, whereas,
secondary standards are meant to protect the esthetic values of the
environment.
Seven pollutants have been established as harmful and standards
established. These pollutants include: sulfur dioxides, particulates, carbon
monoxide, ozone, hydrocarbons, nitrogen oxides and lead. These standards
are implemented through SIPs, (CAA, Section 110).
EPA has designated 247 Air Quality Control Regions (AQCRs). These
have been rated as either "clean" or "non-attainment" for each of the criteria
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A-4
pollutants. SIPs must assure attainment of NAAQS by prescribed dates. SIPs
must meet Federal requirements, but each State may choose its own mix of
emissions for stationary and mobile sources to meet the NAAQS. Control
procedures may include stationary source emission limits, transportation plans,
preconstruction review of new sources, NAA and PSD permits for construction
of new sources, monitoring and inspection and testing of vehicles. Other
measures may include emissions charges, closing and relocation of plants,
changes in operations and ways to reduce vehicular traffic including taxes,
staggered work hours and mass transportation. The CAA prescribes that no
SIP will be adopted without a public hearing, and sources affected by the SIP
are expected to participate.
New Source Performance Standards
NSPS are established for specific pollutants in industrial categories,
based upon adequately demonstrated control technology. Many States have
been delegated the authority to enforce NSPS. When a State does not have
the authority, EPA enforces NSPS in that state. Waivers from NSPS for up to 7
years may be obtained, the purpose of which is to encourage use of innovative
technological systems (CAA, Section 111).
National Emissions Standards for Hazardous Air Pollutants
Section 112 of the CAA defines hazardous air pollutants as those for
which no air quality standard is applicable but which are judged to increase
mortality or serious irreversible or incapacitating illness. NESHAP standards
are based on health effects with strong reliance on technological capabilities.
They apply to both existing and new stationary sources. The eight substances
on the NESHAP list for which there are effective regulations currently are:
benzene, "beryllium, asbestos, mercury, vinyl chloride, radon, arsenic, and
radionuclide emissions. The NESHAP program can be delegated to any
qualifying State (CAA, Section 112).
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0o o* Sicn!*icant Deterioration
The purpose of PSD is to avoid significant future degradation of the
nation's clean air areas. A clean air area is one where the air quality is better
than the ambient primary or secondary standard. Designation is pollutant
specific so that an area can be non-attainment for one pollutant but clean for
another. PSD applies only to new and modified sources in clean air areas.
Clean air areas are divided into three categories: Class I - only minor air quality
degradation allowed, Class II - moderate degradation, and Class III - substantial
degradation. In no case would PSD allow air quality to deteriorate below
secondary air quality standards.
"Baseline" is the existing air quality for the area at the time the first PSD is
applied for. "Increments" are the maximum amount of deterioration that can
occur in a clean air area over baseline. Increments in Class I areas are smaller
than for Class II and Class II increments are smaller than Class III areas. For
purposes of PSD, a major emitting source is one of 26 designated categories
which emits or has the potential to emit 100 tons per year of the designated air
pollutant. A source that is not within the 26 designated categories is a major
source if it emits more than 250 tons per year.
New sources are required to obtain permits before construction. The
permit describes the level of control to be applied and what portion of the
increment may be made available to that source by the State (CAA, Part C).
Non-Attainment Areas (NAA1
Non-attainment areas are those which are not in compliance with
national air quality standards. New construction in an NAA is prohibited unless
the SIP has been amended and approved by EPA to reflect the following
conditions:
1. Total allowable emissions for the area will be less than emissions
from existing sources.
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^-o
2. The new source must comply with the lowest achievable emission
rate (LAER).
3. All other sources within the State owned by the subject company
are in compliance.
4. The SIP is being carried out for the area.
The applying source in an NAA must, therefore, obtain a greater than 1:1
reduction of the pollutant or pollutants for which the area has been designated
non-attainment. The source must undergo a relatively stringent pre-
construction review.
Emission offsets from existing sources may need to be obtained,
especially if the new source will have emissions that would exceed the
allowance for the NAA. In these situations, the source would need to obtain
enforceable agreements from other sources in the NAA or from its own plants in
the NAA.
Emission reductions can also be "banked" by an existing source to permit
future new source growth. Banked offsets may be sold or traded to other
sources.
Emission Standards for Mobile Sources/Fuel Standards
Section 202 of the CAA directs EPA to regulate air pollutants emitted by
motor vehicles which "cause, or contribute to, air pollution which may
reasonably be anticipated to endanger public health or welfare." In response,
the Agency has set standards governing motor vehicle emissions of carbon
monoxide, hydrocarbons, oxides of nitrogen and particulates. These standards
have given rise to the emission control systems that first appeared in
automobiles in the early 1970s. The CAA generally prohibits the removal (or
rendering inoperative) of any emission control device that was installed by the
vehicle manufacturer in order to meet the applicable emission standards. Most
states have enacted similar laws enforcing this prohibition and/or have
incorporated such prohibitions as part of SIP.
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T~e CAA provides EPA with the authority to control or prohibit the use of
fuels when pose a public health risk fir which "impair to a significant degree the
performance of any emission control device or system." The Agency's
regulations are based upon both of these rationales. (The best example of this
are the regulations governing the lead content of gasoline.) Enforcement of the
fuel standards is achieved through a combination of Federal and State efforts,
and is based, in part, upon SIP provisions and/or State laws.
CLEAN WATER ACT (FEDERAL WATER POLLUTION CONTROL AfTR
Through the 1950s and 1960s, emphasis was on the States setting
ambient water quality standards and developing plans to achieve these
standards. In 1972, the Federal Water Pollution Control Act was significantly
amended. These changes emphasized a new approach, combining water
quality standards and effluent limitations (i.e., technology-based standards).
The amendments called for compliance by all point-source discharges with the
technology-based standards. A strong Federal enforcement program was
created and substantial monies were made available for construction of sewage
treatment plants. The Federal Water Pollution Control Act was amended in
1977 to address toxic water pollutants and in 1987 to refine and strengthen
priorities under the Act as well as enhance EPA's enforcement authority. Since
the 1977 amendments, the Federal Water Pollution Control Act has been
commonly referred to as the Clean Water Act (CWA).
State Water Quality Standards and Water Quality Management Plans
Section 303 of the CWA authorizes the States to establish ambient water
quality standards and water quality management plans. If national technology
standards are not sufficient to attain desired stream water quality, the State shall
set maximum daily allowable pollutant loads (including toxic pollutants) for
these waters and, accordingly, determine effluent limits and compliance
schedules for point sources to meet the maximum daily allowable loads.
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The National Pollutant Discharge Elimination (NPDES) Program
This program was established by Section 402 of the CWA and, under it,
EPA and approved States have issued more than 50,000 NPDES permits.
Permits are required for all point sources from which pollutants are discharged
to navigable waters. An NPDES permit is required for any direct discharge from
new or existing sources. Indirect discharges through POTWs are regulated
under a separate program (see discussion of pretreatment standards below). In
1979 and 1980, the permit program was revised and one of the new features
was the use of Best Management Practices (BMPs^ on a case-by-case basis to
minimize the introduction of toxic and hazardous substances into surface
waters. BMPs are industry practices used to reduce secondary pollution (e.g.,
raw material storage piles shall oe covered and protected against rain and
runoff). BMPs do not have numerical limits and, therefore, are different from
effluent limits.
Section 304 of the CWA sets restrictions on the amount of pollutants
discharged at industrial plant outfalls. Amounts are usually expressed as
weight per unit of product (i.e., 0.5 lb/1,000 Ib product manufactured). The
standards are different for each industry. Effluent guidelines are applied to
individual plants through the NPDES permit program.
There are three levels of technology for existing industrial sources: Best
Practicable Control Technology (BPT), Best Conventional Technology (BCT)
and Best Available Technology Economically Achievable (BAT). Under the
1972 Act, BPT was intended to be put in place by industry in 1977 and BAT in
1983. These timetables have been modified by subsequent amendments.
The 1987 CWA Amendments modified the compliance deadlines for the
following:.
BPT limits requiring a substantially greater level of control based
on a fundamentally different control technology
• BAT for priority toxic pollutants
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3AT :or other toxic pollutants
BAT for nonconventional pollutants
BCT for conventional pollutants
For each technology the new deadline requires compliance "as expeditiously
as practicable, but in no case later than 3 years after the date such limitations
are promulgated.. .and in no case later than March 31, 1989."
New Source Performance Standards (NSPS) are closely related to BAT
for existing sources but are not quite the same. NSPS are different for each
industrial category. These standards must be achieved when the new industrial
source begins to discharge. NSPS permits will be effective for a period of 10
years vs. 5 years or less for the BPT and BAT-type permits. This 10-year
protection insulates against change in BCT or BAT requirements but does not
hold against Section 307(a) toxic pollutant standards or against "surrogate"
pollutants that are used to control hazardous or toxic pollutants.
A permit application must be made. Adequate information must be
submitted including basic facility descriptions, SIC codes, regulated activities,
lists of current environmental permits, descriptions of all outfalls, drawings,
flows, treatment, production, compliance schedules, effluent characteristics, use
of toxics, potential discharges and bio-assay toxicity tests performed.
Applicants must conduct analytical testing for pollutants for BOD, COD,
TOC, TSS, ammonia, temperature and pH. The applicant, if included within any
of the 34 "primary industry" categories, must sample for all toxic metals, cyanide
and phenols given in EPA Application Form 2C and for specified organic toxic
pollutant fractions.
The applicant must list hazardous substances believed to be present at
the industrial plant. Testing is not required but analytical results must be
provided, if available.
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NPDES
The NPDES permit, issued by EPA or the State, enforces Federal effluent
limitations promulgated for individual industrial categories; NSPS; toxic effluent
standards; State water quality standards under Section 303 of the CWA, if any
are applicable and hazardous substances otherwise regulated under Section
31 1 of the CWA that may be incorporated under the NPDES permit instead.
Permit elements include the amount of pollutants to be discharged expressed in
terms of average monthly and maximum daily loads; compliance schedules, if
applicable standards cannot be met now and monitoring, testing and reporting
requirements.
Retina Non-compliance Repnns - The Discharge Monitoring Form
The Discharge Monitoring Report (DMR) gives a summary of the
discharger's records on a monthly or quarterly basis for flow measurement,
sample collection and laboratory analyses. Noncompliance reports must be
submitted quarterly on the cause of noncomplying discharges, period of
noncompliance, expected return to compliance and plans to minimize or
eliminate recurrence of incident.
Emergency Reporting
Health: The EPA shall be notified within 24 hours of
noncompliance involving discharge of toxic pollutants, threat to
drinking water or injury to human health.
Bypass: Noncompliance due to intentional diversion of waste
shall be reported promptly to the permitting agency and may be
permissable if essential to prevent loss of life or serious property
damage.
Upset: Temporary noncompliance due to factors beyond the
reasonable control of the permittee shall be promptly reported to
the agency.
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The 1S87 CWA Amendments establish a schedule for the regulation of
municioal and industrial stormwater discharges under NPDES permits. Initially,
(before October 1, 1992), only major dischargers and those who are significant
contributors of pollutants will be required to obtain permits.
Pretreatment Standards for Indirect Discharges to Publiclv-Owned Treatment
Works
Coverage
New and existing industrial users who discharge to POTWs are subject to
general and categorial pretreatment standards. The categorical standards are
primarily directed to control of toxic pollutants in specific industries.
Requirements
General Pretreatment Standards
Prohibit fire or explosion hazards, corrosivity, solid or viscous
obstructions, "slug" discharges, and heat sufficient to inhibit
biological activity at POTWs.
• Categorical Standards
Standards to be expressed as concentration limits or mass
weight per unit of production.
Source must be in compliance 3 years after promulgation of
standards.
Variances can be obtained for fundamentally different
factors or if industrial pollutants are consistently being
removed by POTW.
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Reports
Users must provide appropriate agency (EPA, State or POTWs
having approved pretreatment programs) with basic information,
SIC code, average and maximum daily discharge, characteristics
or pollutants, applicable standards and certification whether
standards are being met and, if not, what pretreatment is
necessary and a compliance schedule.
Monitoring. Sampling and Analysis
Users shall submit sampling data for each regulated pollutant in
discharge.
Progress Reports
Reports and information shall be submitted at 6-month intervals.
Non-Point Source Pollution Control
Section 208 of the CWA provides for control of non-point source pollution
and directs States to establish planning bodies to formulate area-wide pollution
control plans. NPDES permits cannot be issued where the permit may conflict
with an approved Section 208 plan.
The 1987 CWA Amendments require States or EPA to develop nonpoint
source management programs under Section 319.
Dredge or Fill Discharge Permit Program
Section 404 of the CWA regulates the discharge of dredged or fill
material into waters of the United States. Dredged material is excavated or
dredged from a water body. Fill material is that material used to replace water
with dry land. The Section 404 permit program is administered by the U.S.
Army Corps of Engineers. EPA provides guidelines for the issuance of permits
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by the Corps of Engineers. States may assume responsibility for portions of ;ne
program
Discharge of Oil and Hazardous Substances
Section 311 of the CWA prohibits discharges of oil or hazardous
substances in quantities that may be harmful to waters of the United States.
The appropriate Federal agency must be immediately notified of any spill of a
"reportable quantity." Section 311 provides for cleanup of spills and requires
plans for preparation of Spill Prevention, Control and Countermeasures
(SPCC) plans.
Over 300 substances have been defined as hazardous under Section
311 and each of these substances has a "reportable quantity" (40 CFR, Parts
116 and 117, 1980).
A person or corporation who properly notifies the Agency of the
discharge of a reportable quantity of oil or hazardous substance is immune from
criminal prosecution but is liable for civil penalties. Additionally, those who
cause the spill are liable for the costs of cleanup and removal. If the Federal
government must clean up the spill, the discharger of the spill is liable for
cleanup costs. There are maximum liability limits depending upon the type of
facility and spill. These limits do not apply if the discharge resulted from willfull
negligence or willfull misconduct of the owner.
Certain discharges of oil and hazardous material that flow from a point
source may be excluded from Section 311 liability if, during preparation of the
NPDES permit covering that facility, conditions are added to the permit to avoid
the occurrence of a spill.
RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRAY
RCRA was signed on October 21, 1976 and subsequently amended in
1980 and 1984. The 1984 amendments to RCRA brought about dramatic
43 U.S.C. §§6901 et seq. and Solid Waste Disposal Act amendments of 1980, P.L. 96-
482, 94 Stat. 2334.
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A-M
changes n the coverage required by the Act. The first in a series of regulations
restricting the land disposal of hazardous wastes have been promulgated.
Regulations also have been proposed which will include expanded coverage in
such areas as waste oil, underground tanks, etc. The Act primarily deals with
current and future waste handling activities; however, one section of the act
(Section 7003), addresses problems which may have arisen prior to 1976. The
7003 provision allows EPA to take action against persons conducting past and
current activities that may present "an imminent or substantial endangerment to
health or to the environment." The 1984 amendments also provide for
corrective actions against contamination resulting from past releases of
hazardous waste even without an imminent hazard. A review of the Act and the
implementing regulations by the inspector is imperative before conducting an
inspection, due to these changes.
Solid wastes, if land disposed, are regulated through State programs
under Subtitle D of RCRA. Hazardous solid wastes are subject to regulation in
their generation, transport, treatment, storage and disposal under Subtitle C of
RCRA. Subtitle C of the statute authorizes a comprehensive Federal program to
regulate hazardous wastes from generation to ultimate disposal. A waste is
hazardous under Subtitle C if it is listed by EPA as hazardous, if it exhibits
hazardous characteristics (corrosivity, reactivity, ignitability and extraction
procedure toxicity) and if not delisted or excluded from regulation. There are
special management provisions for hazardous wastes created by small quantity
generators and hazardous wastes that are intended to be reused or recycled.
Solid waste includes garbage, refuse and sludge, other solid, liquid,
semi-solid or contained gaseous material which is discarded, has served its
intended purpose or is a mining or manufacturing byproduct. Most industrial
and commercial byproducts can qualify as a solid waste. Exclusions from solid
waste include domestic sewage, irrigation return flows, materials defined by the
Atomic Energy Act, in situ mining waste and NPDES point sources.
Solid wastes excluded from regulation as hazardous solid wastes are
household waste; crop or animal waste; mining overburden and wastes from
processing and benefication of ores and minerals; flyash, bottom ash waste,
slag waste and flue gas emission control waste and drilling fluids from energy
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development. A waste can be "delisted" from the hazardous waste listing or
excluded for other reasons. Some materials intended to be reused or recycled
are not fully regulated as solid/hazardous wastes, while others, depending
upon the type of waste generated and the recycling process used, are fully
regulated.
Statutory Restrictions/Prohibitions
November 8. 1984 - The placement of any bulk liquid hazardous
waste in salt domes, salt bed formations, underground mines or
caves is prohibited until the facility receives a permit.
Mav 8. 1985 - The landfilling of bulk or noncontainerized liquid
hazardous waste or free liquids contained in hazardous waste is
prohibited.
November 8. 1985 - The placement of any nonhazardous waste
liquid in a landfill operating under interim status or a permit, is
prohibited unless the only reasonable alternative is a landfill or
unlined surface impoundment which will not endanger
groundwater drinking sources. See Section 3004(b)(3) for full
graphics.
November 8. 1986 - The land disposal of solvents (codes F001
through F005) and dioxins (codes F020 through F023) is
prohibited unless human health and the environment will not be
endangered. (Wastes generated by Superfund and RCRA
enforcement actions are not affected until November 8, 1988.)
See final rule, 51 Federal Register 40572 (November 7, 1986), to
be codified at 40 CFR Part 268, with conforming amendments at
40 CFR Parts 260, 261, 262, 264, 265, 270 and 271.
July 8. 1987 - Land disposal of wastes listed in Section 3004(d)(2)
(the "California list") is prohibited unless human health or the
environment is not endangered (wastes generated by Superfund
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and RCRA enforcement actions not affected until November 8,
1988.) See proposed rule, 57 Federal Register 4471
(December 11, 1986).
May 8. 198$ - New units, lateral expansions and replacement of
existing units at interim status waste piles are to have single liners
and leachate collection systems.
New units, lateral expansions and replacement of existing units at
interim status landfills and surface impoundments are to have
double liners and leachate collection systems.
August 8. 1988 - Deep well injection of certain wastes is prohibited
unless deemed safe by EPA. See Section 3004(d)(2) and (e)(2)
for list of wastes.
List of Hazardous Wastes
Hazardous waste streams from specific major industry groups and some
generic sources (40 CFR, Part 261, Subpart D, §261.31 and 261.32) and well
over 200 toxic commercial chemical wastes (i.e., discarded commercial
chemical products and chemical intermediates) are- included on the list of
hazardous waste (40 CFR §261.33). If a commercial chemical substance is on
the list, its off-spec species is also considered hazardous when discarded, as
are spill residues. Some of the listed wastes are acutely toxic and are more
closely regulated than other hazardous wastes. See e.g., 40 CFR §§26l.33(e),
261.5(e)and261.7(b)(3).
Special Management Provisions
• Small Quantity Generators
Small quantity generators are those that generate less than 1,000
kg per month of hazardous waste. There are two classes of small
quantity generators:
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1. Generators of between 100 and 1,000 kg per month that are
subject to most of the requirements of 40 CFR Part 262
which apply to fully regulated generators, except that they
are allowed to accumulate up to 6,000 kg of hazardous
waste and to store waste for up to 180 to 270 days.
2. Generators of less than 100 kg per month that are exempt
from regulation under 40 CFR Part 262 so long as they do
not accumulate greater than 1,000 kg of hazardous waste,
properly identify their wastes and comply with the less
stringent waste treatment, storage and/or disposal
requirements of 40 CFR §261.5.
Note that the classification of the generator is a function of the total
wastes generated, not each waste stream. In addition, for acutely
toxic wastes, if more than 1 kg per month of waste or 100 kg per
month of spill residues are generated, all quantities of that waste
are fully regulated.
Recycling or Reuse
The type of waste generated and/or the recycling process
employed will determine whether recycled/reused materials are a
solid/hazardous waste. Some of these materials are not
considered solid wastes, some are solid wastes but not hazardous
wastes, while others are hazardous but are not subject to full
regulation, and still other of these materials are both solid and
hazardous wastes that are fully regulated. The circumstances
surrounding the apparent recycling/reuse of waste materials
should be thoroughly documented during and inspection.
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ReQuirgrrqn*s for Gene
Identification - Hazardous wastes must be identified by list, testing
or experience and assigned waste identification numbers.
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be filed
with EPA or an authorized State. An EPA identification number
must be received.
Manifest System - Implement the manifest system and follow
procedures for tracking and reporting shipments. Beginning
September 1, 1985, a waste minimization statement is to be
signed by the generator [see RCRA Section 3002(b)].
Packing - Implement packaging, labeling, marking and placarding
requirements prescribed by DOT regulations (40 CFR, Parts 172,
173, 178 and 179).
Annual Report - Submittal required March 1 using EPA Form
8700-13.
Exception Reports - When generator does not receive signed copy
of manifest from designated TSDF within 45 days, the generator
sends Exception Report to EPA including copy of manifest and
letter describing efforts made to locate waste and findings.
Accumulation - When waste is accumulated for less than 90 days,
generator shall comply with special requirements including
contingency plan, prevention plan and staff training (40 CFR, Part
265, Subparts C, D, J and 265.16).
40 CFR Part 262
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Per~it for Storage More Iran 90 Davs - If hazardous wastes are
retained onsite more than 90 days, generator is subject to all
requirements applicable to TSDFs and must obtain a RCRA
permit.
Requirements for Transporters'
Notification - No later than 90 days after a hazardous waste is
identified or listed in 40 CFR, Part 261, a notification is to be filed
with EPA or an authorized State. Receive EPA identification
number.
Manifest System - The transporter must fully implement the
manifest system. The transporter signs and dates manifest,
returns one copy of generator, assures that manifest accompanies
waste, obtains date and signature of TSDF or next receiver and
retains one copy of the manifest for himself.
Delivery to TSDF - The waste is delivered only to designated
TSDF or alternate.
Record Retention - Transporter retains copies of manifest signed
by generator, himself and accepting TSDF or receiver and keeps
these records for a minimum of 3 years.
Discharges - If discharges occur, notice shall be given to National
Response Center. Appropriate immediate action shall be taken to
protect health and the environment and a written report shall be
made to the DOT.
40 CFR Part 263
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s for Treatment. Storage or Disposal Facilities rrSDF?)'
Notification - No later than 90 days after a hazardous waste is
i^ntified or listed in 40 CFR, Part 261, a notification is to be filed
PA or an authorized State.
E
Interim Status - These facilities include TSDFs; onsite hazardous
waste disposal; onsite storage for more than 90 days; in transit
storage for greater than 10 days and the storage of hazardous
sludges, listed wastes, or mixtures containing listed wastes
intended for reuse. Interim status is achieved by:
Notification (see above)
Being in existence on November 19, 1980 or on the date of
statutory or regulatory changes which require the facility to
have a permit
Filing a Part A by the date specified in the regulation
covering the facility (40 CFR, Parts 261, 264 or 265)
Interim Status Facility Standards - The following standards and
requirements shall be met.
General information (Subpart B)
Waste analysis plan
Security
Inspection plan
Personnel training
Handling requirements
Preparedness and prevention
Contingency planning and emergency procedures
(Sub parts C and D)
Records and reports
40 CFR Pans 264 and 265
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Manifest system
Operating logs
Annual and other reports (Subpart E)
Groundwater Monitoring (Subpart F)
Closure and post-closure plans (Subpart G)
Financial requirements (Subpart H)
Containers, tanks, surface impoundments, piles (Subparts I,
J, K, L)
Land treatment, landfills, incinerators, thermal treatment,
chemical, physical and biological treatment (Subparts M, N,
0, P, Q)
Underground injection (Subpart R)
Permit - In order to obtain a permit:
Facilities with interim status must file a Part B RCRA permit
application when directed to do so by EPA or an authorized
State and final facility standards must be met or the facility
must be on an approved schedule to meet those standards.
The EPA-authorized States are to issue permits or deny the application
by November 8, 1988 for land disposal facilities; by'November 8, 1989 for
incinerators; and by November 8, 1992 for other facilities. The following is a
statutory schedule for termination of interim status.
Interim Status Unless Part B
Facility Terminates Submitted
.Land Disposal November 1985 November 1985
Incinerators November 1989 November 1986
Other facilities November 1992 November 1988
New facilities and facilities which do not qualify for interim
status are to receive a RCRA permit before construction can
begin or a hazardous waste can be handled.
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Used/Recvcled Oil - Used oil burned for energy recovery is
regulated under 50 CFR Part 266. Although a number of parallel
off-spec due to flashpoint, metal or halogen content. Additional
regulations governing used/recycled oil are being developed.
Underground Storage Tanks - The 1984 amendments also will
cause certain underground storage tanks to be regulated. By
May8, 1986, all owners of underground tanks are to notify the
designated State or local agency of the existence of the tank and
specify the following:
Age
Size
Type
Location
Uses
For tanks taken out of operation after January 1, 1974, the owner
is to also notify the designated State or local agency of the
existence of the tank and specify the following:
Date the tank was taken out of operation
Age at that time
Size
Type
Location
Type and quantity of substance left in the tank
Rules comprehensively regulating these tanks were proposed
April 17, 1987, 52 Federal Register 12662.
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COMPREHENSIVE ENVIRONMENTAL RESPONSE. COMPENSATION AND
LIABILITY ACT (SUPERFUNDl
The Super-fund Act was enacted December 11, 1980. The Federal
government is authorized to clean up toxic or hazardous contaminants at closed
and abandoned hazardous waste dumps and the government is permitted to
recover cost of this cleanup and associated damages by suing the responsible
parties involved. Cleanup monies will come out of a "superfund" created by
taxes on chemicals and hazardous wastes.
The act provides that, when there is a release of hazardous substance,
either real or threatened, the parties who operated the vessel or facility which
created the release are liable for the containment, removal, remedial action,
response and injury damages to natural resources under Section 107(a). The
act also establishes limitations on liability.
If claims are presented to the liable parties but are not satisfied, the act
then allows claims to be reimbursed from the Superfund.
Regulatory provisions under Sections 102 and 103 of the act require that
release of hazardous substances into the environment be reported unless the
release is in accordance with an established permit.-'Spills of any "reportable
quantity", established pursuant to regulations promulgated under the Act, must
be reported.
All owners or operators of any facility handling and disposing of
hazardous substances or that has handled hazardous substances in the past
(including previous owners and operators) were required to inform the EPA
Administrator by June 1981 of their facility activities unless they have a RCRA
permit or have been accorded "interim status". Failure of notification is a crime
and, if the party knowingly fails to provide these data, they are not entitled to the
prescribed limits and defenses of liability.
On October 17, 1986, the Superfund Act was amended under the
Superfund Amendments and Reauthorization Act (SARA). Those amendments
provide mandatory schedules for the completion of various phases of remedial
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A-24
response activities, establish detailed cleanup standards and generally
strengthen existing authority to effect the cleanup of superfund sites.
[An integral part of SARA, but not an amendment to the Superfund Act, is
the Emergency Planning and Community Right-to-Know Act of 1986. It
addresses the handling of extremely hazardous chemicals and requires:
(1) Emergency planning, (2) emergency notification, (3) community right-to-
know reporting and (4) an emissions inventory.]
TOXIC SUBSTANCES CONTROL ACT rTSCAl
TSCA regulates existing and new chemical substances. TSCA applies
primarily to manufacturers, distributors, processors and importers of chemicals.
TSCA can be divided into five parts as follows:
Inventory and Pre-manufacture Notification
EPA has published an inventory of existing chemicals. A substance that
is not on this list is considered "new" and requires Pre-manufacture Notification
(PMN) to EPA at least 90 days before the chemical can be manufactured,
shipped or sold (TSCA, Section 5). If EPA does not make a declaration within
90 days to restrict the product, then full marketing can begin and the chemical is
added to the inventory. In addition, a manufacturer may obtain a test marketing
exemption and distribute the chemical before the 90-day period has expired.
Conversely, EPA, in response, may reject PMN for insufficient data, negotiate
for suitable data, prohibit manufacture or distribution until risk data are available
or pending development of a Section 6 rule, completely ban the product from
the market or review the product data for an additional 90 days.
Testing
Under TSCA, Section 4, EPA can require product testing of any
substance which "may present an unreasonable risk of injury to health or to the
environment." Some testing standards are proposed, but no test requirements
for specific chemicals are yet in effect.
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3"d Recordkeeoing
TSCA, Section 8(a) deals with general reporting. The "first tier" rule
(PAIR) now in effect is a short form seeking production and exposure data on
over 2,300 existing chemicals. A "second tier" rule is expected to obtain more
detailed data on a relatively small group of chemicals that may become priority
candidates for regulation.
Section 8(c) calls for records of significant adverse effects of toxic
substances on human health and the environment. It requires that records of
alleged adverse reaction be kept for a minimum of 5 years.
Section 8(d) allows EPA to require that manufacturers, processors and
distributors of certain listed chemicals (designated under 40 CFR 716.13)
submit to the EPA lists of health and safety studies conducted by, known to or
ascertainable by them. Studies include individual files, medical records, daily
monitoring reports, etc.
Section 8(e) requires action upon discovery of certain data. Any person
who manufacturers, processes or distributes a chemical substance or mixture,
or who obtains data which reasonably supports the conclusion that their
chemical presents a substantial risk of injury to health or to the environment, is
required to notify EPA immediately. Personal liability can only be limited if the
company has a response plan in effect.
Regulation Under Section 6
EPA can impose a Section 6 rule if there is reason to believe that the
manufacture, processing, distribution or use or disposal of a chemical
substance" or mixture causes, or may cause, an unreasonable risk of injury to
health or to the environment. Regulatory action can range from labeling
requirements to complete prohibition of the product. Section 6 rules are
currently in effect for several chemicals including PCBs. A Section 6 rule
requires informal rulemaking, a hearing, and a cost-benefit analysis.
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This is defined as a chemical substance or mixture causing an imminent
and unreasonable risk of serious or widespread injury to health or the
environment. When such a condition prevails, EPA is authorized by TSCA,
Section 7, to bring action in U.S. District Court. Remedies include seizure of the
chemical or other relief including notice of risk to the affected population or
recall, replacement or repurchase of the substance.
FEDERAL INSECTICIDE. FUNGICIDE AND RODENTICIDE ACT fFIFRA)
A pesticide is defined as any substance intended to prevent, destroy,
repel or mitigate pests. FIFRA requires registration of all pesticides, restricts use
of certain pesticides, authorizes experimental use permits and recommends
standards for pesticide applicators and the disposal and transportation of
pesticides.
Pesticides are registered for 5 years and classified for either general or
restricted usage. Restricted means that they are to be applied either by or
under the direct supervision of a certified applicator. Pesticides must be labeled
and specify ingredients, uses, warnings, registration number and any special
use restrictions. Regulations also specify tolerance levels for certain pesticide
chemicals in or on agricultural commodities. These limits apply to 310 different
compounds and residue tolerances range from 0 to 100 ppm. A few pesticides
are also regulated as toxic pollutants under Section 307(a) of the CWA and by
Primary Drinking Water Standards under the SDWA.
SAFE DRINKING WATER ACT
The'SDWA of 1974 was established to provide safe drinking water to the
public. Both primary and secondary drinking water standards have been set by
EPA regulations which apply to water after treatment by public drinking water
systems. National interim Primary Drinking Water Regulations were adopted in
1975 to protect public health (40 CFR, Part 141). Regulations covering
radionuclides were added in 1976. Regulations for trihalomethanes were
promulgated in 1979. Secondary regulations were established in 1979 as
-------
guidelines *o States to protect the non-health-related-qualities of drinking water.
The 1936 amendments to the SDWA: (1) establish a mandatory schedule,
requiring the promulgation of primary drinking water regulations for 83
contaminants, (2) prohibit the use of lead in public water systems, (3) provide
civil and criminal penalties for persons who tamper with public water systems
and (4) require closer scrutiny of State programs, including the direct
enforcement of drinking water standards, if necessary.
The SDWA also provides for protection of underground sources of
drinking water. Final regulations have been issued whereby States are to
establish Underground Injection Control (UIC) waste disposal programs to
ensure that contaminants in water supplies do not exceed National Drinking
Water Standards and to prevent endangerment of any underground source of
drinking water. Injection wells are divided into five classes for regulatory
handling. Construction and disposal standards are established for the
permitting of Class I to III wells. Class I and IV wells are subject to RCRA
requirements. Class IV wells are those used by generators of hazardous or
radioactive wastes to dispose of hazardous wastes into formations within one-
quarter mile of an underground source of drinking water. New Class IV wells
are prohibited and existing Class IV wells must be phased out within 6 months
after approval or promulgation of a UIC program in the state. There are
numerous State regulatory requirements affecting groundwater which should
be consulted by multi-media compliance inspectors. In addition, the 1986
amendments to SDWA strengthen EPA's enforcement authority for UIC
programs.
-------
APPENDIX B
SAFETY PLAN
-------
Appendix B
The CSHA Hazardous Waste Site Worker Standards (29 CFR 1910.120), the
EPA Safety Manual, Chapter 9, and other EPA protocols require certain safety
planning efforts prior to field activities. The following format is aligned with
these requirements. Extensive training and certifications, and further planning
in the form of a more extensive Site Safety and Health Plan, may be required in
addition to the following plan.
NEIC
PRELIMINARY SITE PLAN
FOR
HAZARDOUS SUBSTANCES RESPONSES AND FIELD INVESTIGATIONS
PROJECT: NEIC Reporting Code:
Project Coordinator: Date:
Branch Chief: Date:
On Scene Coordinator or
Supervisor: Date:
Health and Safety Manager
Approval: Date:
DESCRIPTION OF ACTIVITY
If any of the following information is unavailable, mark "UA"; if covered in project
plan, mark "PP."
Site Name:
Location and approximate size:
Description of the response activity and/or the job tasks to be performed:
Duration of the Planned Employee Activity:
Proposed Date of Beginning the Investigation:
Site Topography:
Site Accessibility by Air and Roads:
(03/89)
-------
HAZARDOUS SUBSTANCES AND HEALTH HAZARDS INVOLVED OR
SUSPECTED AT THE SITE
Fill in any information that is known or suspected
Chemical and Identity of Substance
Areas of Concern Physical Properties and P"ecaut'OPS
Explosivity
Radioactivity:
Oxygen Deficiency:
(e.g., Confined Spaces)
Toxic Gases:
Skin/Eye Contact Hazards:
Heat Stress
Pathways from site for hazardous substance dispersion:
WORK PLAN INSTRUCTIONS
A. Recommended Level of Protection: A B.
Cartridge Type, if Level C:
-------
Safety Clothing/Equipment:
Monitoring Equipment to be Used:
CONTRACTOR PERSONNEL:
Number and Skills:
CONTRACTOR SAFETY CLOTH ING/EQUIPMENT REQUIRED:
Have contractors received OSHA required training and certification?
(29 CFR 1910.120) Yes Not Required '
(If "yes", copy of training certificate(s) must be obtained from contractor)
B. Field Investigation and Decontamination Procedures:
Decontamination Procedures (contaminated protective clothing instruments
equipment, etc.):
-------
Disposal Procedures (contaminated equipment, supplies, disposal items, wasr
water, etc./ ,
IV. EMERGENCY CONTACTS
Hospital Phone No.:
Hospital Location:
EMT/Ambulance Phone No.:
Police Phone No.:
Fire Assistance Phone No.:
NEIC Health and Safety Manager: Ken Fischer - (303)236-5111
FTS 776-5111
Radiation Assistance: Wayne Boliss, Director
Office of Radiation Programs
Las Vegas Facility (ORP-LVF)
(702)798-2476
FTS 545-2476
-------
APPENDIX C
EVIDENTIARY PROCEDURES FOR PHOTOGRAPHS/MICROFILM
-------
Appendix C
PHOTOGRAPHS
When movies, slides or photographs are taken which visually show the
effluent or emission source and/or any monitoring locations, they are numbered
to correspond to logbook entries. The name of the photographer, date, time,
site location and site description are entered sequentially in the logbook as
photos are taken. A series entry may be used for rapid sequence photographs.
The photographer is not required to record the aperture settings and shutter
speeds for photographs taken within the normal automatic exposure range.
Special lenses, films, filters or other image enhancement techniques must be
noted in the logbook. Chain-of-custody procedures depend upon the subject
matter, type of film and the processing it requires. Film used for aerial
photography, confidential information or criminal investigations require chain-
of-custody procedures. Adequate logbook notations and receipts may be used
to account for routine film processing. Once developed, the slides or
photographic prints shall be serially numbered corresponding to the logbook
descriptions and labeled.
MICROFILM
Microfilm is often used to copy documents that are or may later become
TSCA Confidential Business Information (CBI). This microfilm must be handled
in accordance with the TSCA CBI procedures (see Appendix I for additional
information and forms). Table C-1 is the NEIC procedure for processing
microfilm containing TSCA CBI documents.
(03/89)
-------
Table C-1
NEIC PROCEDURE FOR MICROFILM
PROCESSING OF TSCA CBI DOCUMENTS
1. Kodak Infocapture AHU 1454 microfilm shall be used for filming all TSCA CBI documents.
2. Obtain packaging materials and instructions from the NEIC Document Control Officer or
Assistant, including:
Preprinted shipping labels
Chain-of-custody records
Custody seals
Double envelopes
Green TSCA cover sheets
TSCA loan receipt
3. Prepare each roll of microfilm for shipment to the processor.
Enclose the film in double-wrapped pa: iqes
Place a green TSCA cover sheet in the inner package
Place a TSCA loan receipt in the inner package
Complete a Chain-of-Custody Record, place the white copy in the inner package
and keep the pink copy for the field files
Seal inner package with a custody seal and sign and date it
Mark the inner package:
"TO BE OPENED BY ADDRESSEE ONLY
TSCA CONFIDENTIAL BUSINESS INFORMATION"
4 Ship the film via Federal Express to the Springfield, Virginia Federal Express office and
instruct that it is to be held for pickup. USE SIGNATURE SECURITY SERVICE ONLY.
This practice requires the courier to sign, the station personnel to sign and the delivery
courier to sign.
Instruct the Springfield Federal Express office to hold the shipment for pickup and to
notify:
Mr. Vern Webb
U.S. EPA/EPIC
Vint Hill Farms Station
Warrenton, Virginia 22186
(730) 557-3110
5. Telephone Mr. Webb and inform him of the date shipped, the number of rolls of film, the
air bill number and your phone number.
6. Telephone the NEIC Document Control Officer or Assistant and inform them.
7. Telephone Mr. Webb the following day and verify film quality to determine if repeat
microfilming is necessary.
8 The pink copy of the Federal Express form, with the shipment cost and project number
indicated must be turned in to the Assistant Director, Planning and Management. If you
are in the field for an extended period of time (3 weeks or more), the pink copies must be
mailed to NEIC.
(03/89)
-------
APPENDIX D
AIR POLLUTION CHECKLISTS
-------
Appendix D
NEW SOURCE PERFORMANCE STANDARDS (NSPS)'
Soirees CoverQd
NSPS includes new and modified industrial stationary source categories
for which construction was started after the standard was proposed. The
categories are listed in Table D-1.
Requirements
Notification to Agency
Agency notified before construction Yes No
before startup Yes No
before testing Yes No
Emissions Testing
Performance tests of emission control equipment
conducted using prescribed reference methods Yes No
within 180 days of startup Yes No
written results sent to Agency Yes No
Monitoring
Continuous emission monitoring (CEM) to be conducted for 10
categories [Table D-2]
CEM recordkeeping kept in permanent form suit-
able for inspection . Yes No
Records of continuous monitoring system
maintained, including actual data Yes No
performance specification test reports Yes No
calibration checks Yes No
adjustments and maintenance Yes No
Control equipment operating parameters (flow
rates, pressure drops, currents, etc.) Yes No
Reports/Records
Excess reports filed Yes No
Date and time when control equipment was
repaired, adjusted or inoperative Yes No
Notification given to State/local agency Yes No
40 CFR, Part 60
(03/89)
-------
Appendix D (cont.)
Date and time when CEM was inoperative,
nature of repairs Yes No
Notification given to State/local agency. Yes No
-------
Taole D-1
SOURCES SUBPART (40 CFR Part SG)
EFFECTIVE DATE OF STANDARD AND POLLUTANTS SUBJECT TO NSPS
source
Suboart
Effective Date
Pollutant
Fossil-fuel-'ired steam generators
constructed after August 17, 1971
Fossii-fuel-fired steam generator
constructed after September 18, 1978
Industnal-Commercial-lnstitutional steam generat-
ing units constructed after June 19, 1984
Municipal incinerators
Portland cement plants
Nitric acid plants
Sulfuric acid plants
Asphalt concrete plants
Petroleum refineries
Storage vessels for petroleum liquids
Volatile organic liquid storage vessels
Secondary lead smelters
Secondary brass and bronze ingot production plants
Iron and steel plants (basic oxygen furnace)
Iron and steel plants (secondary emissions from
oxygen furnaces)
Sewage treatment plants (incinerators)
Primary copper smelters
Primary zinc smelters
Primary lead smelters
Primary aluminum reduction plants
Phosphate fertilizer industry
(listed as five separate categories)
Coal preparation plants
Ferro-alloy production facilities
Steel plants (electric arc furnaces)
Steel plants, electric arc furnaces and argon-
oxygen decarburization vessels
Kraft pulp mills
Glass plants
Grain elevators
Metal furniture surface coating
Stationary gas turbines
Lime plants
Lead acid battery plants
Metallic mineral processing plants
Auto and light-duty truck, surface coating operation
Phosphate rock plants
Ammonium sulfate plants
Graphic arts industry
Pressure sensitive tap* manufacturing
Appliance surface coating
Metal coil surface coating
Asphalt roofing plants
Synthetic organic chemicals
Beverage can surface coating
Bulk gasoline terminal
D August 17. 1971
Da September 18, 1978
Db June 19, 1984
E August 17, 1971
F August 17, 1971
G August 17, 1971
H August 17, 1971
I June 11, 1973
J June 11, 1973
K June 11, 1973
Ka May 18, 1978
Kb July 23, 1984
L June 11, 1973
M June 11, 1973
N June 11, 1973
Na January 20, 1983
O June 11, 1973
P October 16, 1974
Q October 16, 1974
R October 16, 1974
S October 23, 1974
TUV October 22, 1974
WX
Y October 24, 1974
Z October 21, 1974
AA October 21, 1974
AAa August 17, 1983
BB September 24, 1976
CC June 15, 1979
DO August3, 1978
EE November 28. 1980
GG September 24, 1976
m May 3, 1977
KK January 14, 1980
LL August 24, 1982
MM Octobers, 1979
NN September 21, 1979
PP February 4, 1980
QQ October 28, 1980
Pfl December 30,1980
SS December 24,1980
TT January 5, 1981
UU November 18,1980;
May 26, 1981
VV Januarys. 1981
WW November 26,1980
XX December 17, 1980
Part'Cuiate ra:ter, s^f..'
nitrogen ox.ces
Part:coiate -natter s^ ?„•
nitrogen cioxide
Participate matter, s^'^r
nitrogen oxices
Particulate matter
Particulate matter
Nitrogen oxides
Surtur dioxide, acid rrvst
(sulfunc acid)
Particulate matter
Particulate matter,
carbon monoxide,sulfur c.cx c«
voc
voc
voc
Particulate manor
Particulate matter
Particulate matter
Particulate matter
Particulate matter
Particulate manor, sulfur diox.de
Particulate matter, sulfur dioxide
Particulate matter, sulfur dioxide
Fluorides
Fluorides
Particulate matter
Particulate matter,
carbon monoxide
Particulate matter
Particulate matter
Particulate matter, TRS
Particulate matter
Particulate matter
VOC
Nitrogen oxides, sulfur dioxide
Particulate matter
Lead
Particulate matter
VOC
Particulate matter
Particulate matter
VOC
VOC
VOC
VOC
Particulate matter
Performance standards
VOC
VOC
(03/89)
-------
Table 0-1 'cont.)
SOURCES SUBPART (40 CFR Part 60)
EFFECTIVE DATE OF STANDARD AND POLLUTANTS SUBJECT TO NSPS
Source
New residual wood heaters
Rubber tire manufacturing industry
Vinyi/urethane coating
Petroleum refineries
Synthetic fiber plants
Petroleum dry cleaners
Onshore natural gas processing plants
Onshore natural gas processing plants
Nonmetallic mineral processing plants
Wool fiberglass insulation manufacturing plants
Magnetic tape coating
Industrial surface coating, plastic pans for
business machines
Subpart
AAA
BBB
FFF
GGG
t 1 ill
rTlrl
jjj
KKK
LLL
COO
PPP
SSS
TTT
Effective Date
July 1, 1988
January 20, 1983
January 18, 1983
January 4, 1983
November 23, 1 982
September 21, 1984
June 24, 1985
October 1 985
August 1, 1985
February 25, 1 985
January 22, 1 986
January 8, 1986
Pollutant
Paniculate matter
VOC
VOC
Performance stardarcs
VOC
VOC
VOC
SO2
Paniculate matter
Paniculate matter
VOC
VOC
-------
\'O
Check pressure drop
across each
compartment; also,
check condition of
lines and pressure
gauges.
Check cleaning system:
• Pulse jet pressure
• Solenoids
• Reverse air blowers
• Shakers
Check solids removal
equipment:
• Screw conveyor
• Pneumatic system
• Heaters
• Vibrators
Can Internal
Inspection be
Performed?
YES - ENTER L'MT
Are
there
indications o
nonoptimal
perfor-
ance2
Check condition of bags:
• Bag tears
• Bag deterioration
• Dropped bags
• Oily bags
• Wet bags
• Improper bag tension
• Deposits on floor
Enter results in report
Check clean air chamber for
possible leakage.
Check hoppers
Incomplete solids removal
Corrosion
END INTERNAL FABRIC
FILTER INSPECTION
YES Enter unit to confirm
evaluations. May
need to reschedule
inspection.
END FABRIC
FILTER
INSPECTION
Figure D-1
Fabric Filter Inspection Flowsheet
(03/89)
-------
Can Internal
Inspection be
Performed?
Reschedule
inspection for a time
when unit is
operational
Inspect internal parts:
Nozzle condition
Presence of corrosion
Presence of erosion
Presence of scaling
Check integrity of shell
retention grids, and
other parts
Check slurry
handling system.
END SCRUBBER INSPECTION -*-
NO
Check pumps on purge.
make-up, and
recirculation lines.
Read Flow meters if
available. Check liquor
temp on inlets and
outlets.
Check pressure gauges and
differential pressure monitors
across the following:
Spray nozzles
Scrubber beds
Venturi throat
. Demisters
Check pump and
recirculation tanks:
Liquor temperature
Liquor pH
Check inlet conditions:
Gas temperature
Presaturator water
flow rate
Figure D-2
Scrubber Inspection Flowsheet
(03/89)
-------
D-25
Table D-5 (cont.)
Is at least 15 centimeters (6 inches) of com-
pacted cover placed on the waste at the end
of each day or 24-hour period? Yes No
Is dust suppressant used that has been
approved by the Administrator? Yes No
If an alternate method is used, has it been
approved by the Administrator? Yes No
B. Is there a barrier restricting access to the site? Yes No
C. Are warning signs placed at 100-meter
(330-foot) or less intervals around the site? Yes No
1. Are they easily read? Yes No
2. Do they meet the size requirements of
61.153(b)(1)(ii)? Yes No
3. Do they meet the legend requirements
of 61.153(b)(1 )(jli)? Yes No
-------
Table D-5 (cont.)
E Has the Administrator authorized the use of
any other alternate cleaning equipment? Yes No
XIII. REPORTING REQUIREMENTS
Has the facility submitted the following information to
the Administrator by July 4, 1984 (90 days after
April 5, 1984?) Yes No
A. For all sources:
1. Description of the emission control
equipment for each process? Yes No
2. The pressure drop across the fabric
filter, if used? Yes No
3. The airflow permeability of a woven
fabric filter and of synthetic, if the fill
yarn is spun? Yes No
B. For sources subject to 61.151 and 152:
1. Description of each process that
generates asbestos-containing waste? Yes No
2. The average weight of material dis-
posed in kg. per day? Yes No
3. The emission control methods used? Yes No
4. The type of disposal method or site and
the name, location and operator of the
site? Yes No
C. For sources subject to 61.153:
1.. Description of the site? Yes No
2. Methods used to comply with the
standards? Yes No
XIV. ACTIVE WASTE DISPOSAL SITE STANDARDS
A. Are visible emissions possible from the site? Yes No
-------
Table D-5 (cont.)
Is a dust suppression agent applied that has
been recommended by the manufacturer and
approved by the Administrator? Yes No
B. Is there a Darrier restricting access to the site? Yes No
C. Are warning signs placed at 100-meter (330-
foot) or less intervals around the site? Yes No
1. Are they easily read? Yes No
2. Do they meet the size requirements
61.153(b)(1)(ii)? Yes No
3. Do th-: meet the legend requirements
of 61. 3(b)(1 )(iii)? Yes No
D. Has the Administrator approved an alternate
access control method? Yes No
XII. AIR CLEANING STANDARDS
A. Are fabric filter collection devices used? Yes No
If no, go to D.
1. Is the filter pressure drop no more than
.995 kilopascal (4 inches water
gauge)? Yes No
2. Does the air flow permeability meet the
requirements of 61.154(a)(1 )(ii)? Yes No
3. Does the fabric meet the requirements
of 61.154(a)(1)(iii)? Yes No
4. If a synthetic fabric is used, is the fill
yarn spun? Yes No
B. Is all equipment properly installed, used,
operated and maintained? Yes No
C. Are bypasses only used during suspect or
emergency conditions? Yes No
D. Has the Administrator authorized wet collec-
tors if fabric creates a fire or explosion
hazard? Yes No
-------
Table D-5 (cont.)
2. Was waste mixed with water to form a
slurry? Yes No
a. Are visible emissions possible to
the outside air? Yes No
(If yes, complete air cleaning standards
XIII and continue.)
b. Was all wet asbestos-containing
material in leak-tight containers? Yes No
c. Were the containers labeled with
appropriate warnings? Yes No
[See61.152(b)(1)(iv) or OSHA
29 CFR 1910.1001(g)(2)(ii) for
labeling requirements.]
3. Is waste processed into nonfriable pel-
lets or other shapes? Yes No
a. Are visible emissions possible
from the operation to the outside
air? Yes No
b. Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning
standards XIII and continue.)
4. If an alternate method is used, was it
approved by the Administrator? Yes No
XI. STANDARDS FOR INACTIVE WASTE DISPOSAL SITES FOR
ASBESTOS MILLS AND MANUFACTURING AND FABRICATING
OPERATIONS
A. Are visible emissions possible from the site? Yes No
Is the site covered with at least 15 centimeters
(6 inches) of clean compacted material? Yes No
Is a vegetation cover present? Yes No
Is the site covered with at least 60 centimeters
(2 feet) of clean compacted material? Yes No
-------
0-24
Table D-5 (cont.)
4. If an alternate method is used, was it
approved by the Administrator? Yes No
X. STANDARD FOR WASTE DISPOSAL FOR MANUFACTURING
DEMOLITION, RENOVATION, SPRAYING AND FABRICATING
OPERATIONS
A. Are wastes disposed at acceptable sites? Yes No
(See Active Waste Disposal Site XIV
requirements.)
B. Are visible emissions possible to the outside
air during collection, processing, incineration,
packaging, transporting of deposition of
waste? Yes No
1. Was the waste mixed with a wetting
agent prior to disposal? Yes No
a. Was the agent recommended by
the manufacturer for this use? Yes No
b. Was all asbestos containing
material adequately mixed with
the wetting agent? Yes No
c. Are visible emissions possible
to the outside air? Yes No
Were emissions cleaned before
discharge?
(If yes, complete air cleaning
standards XIII and continue.)
d. Was wetting suspended when
the ambient temperature at the
waste disposal site dropped
below -9.5 °C (15 °F)? Yes No
(1) Are hourly temperature
records kept during sus-
pension of wetting
operations? Yes No
(2) Are records kept for at
least 2 years? Yes No
-------
able D-5 (cont.)
d. Was wetting suspended when the
ambient temperature at the waste
disposal site dropped below
-9.5 3C (15 °F)? _ Yes _ No
(1) Are hourly temperature
records kept during
suspension of wetting
operations? _ Yes _ No
(2) Are records kept for at
least 2 years? _ Yes _ No
2. Was waste mixed with water to form a
slurry? _ Yes _ No
a. Are visible emissions possible
to the outside air? _ _ Yes _ No
Were emissions cleaned before
discharge? _ Yes _ No
(If yes, complete air cleaning
standards and continue XIII.) _ Yes _ No
b. Was all wet asbestos-containing
material in leak-tight containers? _ Yes _ No
c. Were the containers labeled with
appropriate warnings? _ Yes _ No
[See 61.152(b)(1)(iv) orOSHA 29
CFR 1910.1001(g)(2)(ii) for labeling
requirements.]
3. Is waste processed into nonfriable pel-
lets or other shapes? _ Yes _ No
a. Are visible emissions possible
from the operation to the outside
air? _ Yes _ No
b. Were emissions cleaned before
discharge? _ Yes _ No
(If yes, complete air cleaning
standards XIII and continue.)
-------
D-22
Table D-5 (cont.)
Wars emissions cleaned before discharge? Yes No
;if yes, complete air cleaning standards XIII and
continue.)
VIII. INSULATING MATERIALS
Was insulating material containing asbestos that was
molded and friable or wet applied and friable after
drying, installed or re-installed after April 5, 1984? Yes No
IX. WASTE DISPOSAL FOR ASBESTOS MILLS
A. Was asbestos-containing waste material
disposed at an acceptable site? Yes No
(See Active Waste Disposal Site requirements XIV.)
B. Are visible emissions possible to the outside
air? Yes No
Were emissions cleaned before discharge? Yes No
(If yes, complete air cleaning standards XIII
and continue.)
C. Identify the disposal method for wastes from control devices.
1. Was the waste mixed with a wetting
agent prior to disposal? Yes No
a. Was the agent recommended by
the manufacturer for this use? Yes No
b. Was all asbestos containing
material adequately mixed with
the wetting agent? Yes No
c. Are visible emissions possible to
the outside air? Yes No
Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning
standards XIII and continue.)
-------
Table D-5 (cont.)
9. Was the temperature at the point of
wetting below 0 °C (32 °F)? Yes No
(If yes, no other wetting requirements
apply and components are to be
removed as units or in sections to the
maximum extent possible.)
VI. SPRAYING
If sprayed on asbestos material is encapsulated and the material is not
friable after drying, go to 3.
A. Does material that is sprayed contain:
1 % or less asbestos on a dry weight basis? Yes No
B. If greater than 1%,
1. Was the Administrator notified at least
20 days prior to the spraying? Yes No
2. Did the notice include:
a. Name and address of owner or
operator? Yes No
b. Location of spraying operation? Yes No
c. Procedures to be followed to
comply with National Emission
Standards for Asbestos, 40
CFR 61, Subpart M? Yes No
3. Are visible emissions possible to the
outside air? Yes No
Were emissions cleaned before
discharge? Yes No
(If yes, complete air cleaning standards
XIII and continue.)
VII. FABRICATION (See 61.149 for applicability)
Are visible emissions to the outside air possible? Yes No
-------
Table 3-5 (cont.)
a. Was Administrator supplied with
sufficient information to deter-
mine that wetting would cause
unavoidable damage? Yes No
b. Was a local exhaust ventilation
and collection system used? Yes No
(1) Are visible emissions
possible to the outside
air? Yes No
(2) Was the system operated
according to air cleaning
requirements? Yes No
(If a system was used, complete
air cleaning standard XIII and
continue.)
7. After components were removed as
units or sections,
a. Were they adequately wetted
during stripping? Yes No
b. Was a local exhaust ventilation
and collection system used? Yes No
(If a system was used complete
air cleaning standards XIII and
continue.)
8. When friable material was stripped or
removed,
a. Had it been adequately wetted
until collected for disposal? Yes No
b. Had it been lowered, not drop-
ped, to the ground or lower floor? Yes No
c. Had it been transported via dust-
tight shutes or containers if more
than 50 feet above the ground
level? Yes No
-------
Table D-5 (corn.)
b. A description of the facility to be
demolished or renovated includ-
ing size, age and prior use? Yes No
c. The estimated amount of friable
asbestos? Yes No
d. The location of the facility to be
demolished/renovated? Yes No
e. A demolition/renovation
schedule? Yes No
f. The methods of demolition/
renovation to be used? Yes No
g. Procedures to be followed to
comply with National Emission
Standards for Asbestos, 40
CFR 61, Subpart M? Yes No
h. The name and location of the
asbestos disposal site? Yes No
4. Was friable asbestos material removed
prior to wrecking or dismantling? Yes No
If no, was material encased in concrete
or similar material and was material
adequately wetted? Yes No
5. When asbestos covered or coated were
facility components removed?
a. Were they adequately wetted? Yes No
b. Were they carefully lowered to
ground level? Yes No
6. If asbestos was stripped from facility
components, were they adequately
wetted? Yes No
If equipment would be damaged by
wetting during renovation,
-------
U-
Table D-5 (cont.)
(2) Was the system operated
according to air cleaning
requirements? Yes No
(If a system was used, complete
air cleaning standards XIII and
continue.)
5. When friable material was stopped or
removed,
a. Had it been adequately wetted
until collected for disposal? Yes No
b. Had it been lowered, not drop-
ped, to the ground or lower floor? Yes No
c. Had it been transported via dust-
tight shutes or containers if more
than 50 feet above the ground
level? Yes No
6. Was the temperature at the point of
wetting below 0 °C (32 °F)? Yes No
(If yes, no other wetting requirements
apply and components are to be •
removed as units or in sections to the
maximum extent possible.)
D. If the facility is to be renovated, is the amount of
friable asbestos to be stripped at least 80 linear
meters (260 linear feet) on pipes or at least 15
square meters (160 square feet) on other
components? Yes No
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or deliver-
ed at least 10 days before demolition/
renovation began? Yes No
3. Did the notice include
a. Name and address of owner or
operator? Yes No
-------
Table D-5 (cent.)
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or deliver-
ed as early as possible before the
demolition began? Yes No
3. Did the notice include
a. Name and address of owner or
operator Yes No
b. A description of the facility to be
demolished or renovated includ-
ing size, age and prior use Yes No
c. The estimated amount of friable
asbestos Yes No
d. The location of the facility to be
demolished/renovated Yes No
e. A demolition/renovation
schedule Yes No
f. The methods of demolition/
renovation to be used Yes No
g. Procedures to be followed to"
comply with national Emission
Standard for Asbestos, 40 CFR
61, Subpart M Yes No
h. The name and location of the
asbestos disposal site Yes No
4. After components were removed as
units or sections,
a. Were they adequately wetted
during stripping? Yes No
b. Was a local exhaust ventila-
tion and collection system used? Yes No
(1) Are visible emissions
possible to the outside
air? Yes No
-------
D-'5
Table D-5 (cont.)
9. Was the temperature at the point of
wetting below 0 °C (32 °F)? Yes No
(If yes, no other wetting requirements
apply and components are to be
removed as units or in sections to the
maximum extent possible.)
B. If the facility is to be demolished,
Is the amount of friable asbestos less than 80
linear meters (260 linear feet) or pipes and
less than 15 square meters (160 square feet)
on other components? Yes No
(If no, go to C below.)
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or deliver-
ed at least 20 days before demolition/
renovation began? Yes No
3. Did the notice include:
a. Name and address of owner or
operator? Yes No
b. A description of the facility to be
demolished or renovated
including size, age and prior
use? Yes No
c. The estimated amount of friable
asbestos? Yes No
d. The location of the facility to be
demolished/renovated? Yes No
e. A demolition/renovation
schedule Yes No
C. Has the demolition been ordered by State or
local government due to structurally unsound
conditions or danger of imminent collapse? Yes No
If no, go to 0 below.
-------
Table D-5 (com.)
ii. Was the system operated
according to air cleaning
requirements? Yes No
(If a system was used, complete
air cleaning standards XII and
continue.)
7. After components were removed as
units or sections,
a. Were they adequately wetted
during stripping? Yes No
b. Was a local exhaust ventilation
and collection system used? Yes No
(1) Are visible emissions
possible to the outside
air? Yes No
(2) Was the system operated
to air cleaning require-
ments? Yes No
(If a system was used complete
air cleaning standards XIII and
continue.)
8. When friable material was stripped or
removed,
a. Had it been adequately wetted
until collected for disposal? Yes No
b. Had it been lowered, not drop-
ped to the ground or lower floor? Yes No
c. Had it been transported via dust-
tight shutes or containers if more
than 50 feet above the ground
level? Yes No
-------
D-M
Table D-5 (cont.)
e. A demolition/renovation
schedule? Yes No
f. The methods of demolition/
renovation to be used? Yes No
g. Procedures to be followed to
comply with National Emission
Standards for Asbestos, 40
CFR 61, Subpart M? Yes No
h. The name and location of the
asbestos disposal site? Yes No
4. Was friable asbestos material removed
prior to wrecking or dismantling? Yes No
If no, was material encased in concrete
or similar material? Yes No
Was material adequately wetted? Yes No
5. When asbestos covered or coated,
were facility components removed? Yes No
a. Were they adequately wetted? Yes No
b. Were they carefully lowered to
ground level? Yes No
6. If asbestos was stripped from facility
components, were they adequately
wetted? Yes No
If equipment would be damaged by
wetting during renovation
a. Was Administrator supplied with
sufficient information to deter-
mine that wetting would cause
unavoidable damage? Yes No
b. Was a local exhaust ventilation
and collection system used? Yes No
i. Are visible emissions
possible to the outside
air? Yes No
-------
Table D-5 (cont.)
III. ROADWAYS
Is roadway surfaced with asbestos tailings or
asbestos-contained waste material? Yes No
(Surfacing of temporary roadway in area of
asbestos ore deposits is allowed.)
IV. MANUFACTURING [see 61.144{a) for applicability]
Are visible emissions possible to the outside air? Yes No
Are controls in place prior to discharge? Yes No
(If yes, complete air cleaning standards XII.)
V. DEMOLITION AND RENOVATION
A. If the facility is to be demolished, is the
amount of friable asbestos at least 80 linear
meters (260 linear feet) on pipes or at least
15 square meters (160 square feet) on other
components? Yes No
(If no, go to B below.)
1. Was a written notice provided to the
Administrator? Yes No
2. Was the notice postmarked or deliver-
ed at least 10 days before demolition/
renovation began? Yes No
3. Did the notice include:
a. Name and address of owner or
operator? Yes No
b. A description of the facility to be
demolished or renovated includ-
ing size, age and prior use? Yes No
c. The estimated amount of friable
asbestos? Yes No
d. The location of the facility to be
demolished/renovated? Yes No
-------
H-
Table D-5
EXAMPLE OF ASBESTOS EMISSION INSPECTION CHECKLIST
GENERAL INFORMATION
A.
B.
C.
D.
E.
Facility Location (mail address)
Chief Corporate Officer (name/phone).
Facility Manager (name/phone)
Environmental Contact (name/phone).
Sources Inspected
Production Status
F. Reasons for Inspection (check appropriate items)
Routine Inspection
Complaint lnvestigation_
Stack Testing Observed.
Special Studies ~
Other
Compliance Progress
Permit Review/Renewal.
Tax Certification ~
Emergency Episode
Equipment Malfunction.
Plant Representative Contacted (name and title).
H.
Inspection Procedures and Conditions
Prior Notice (check one) Yes_
Time/Date
No_
Duration Onsite
Type Inspection (check one) Counterflow_
Other
Weather Wind Direction,
II. ASBESTOS MILL
Does the facility discharge to the outside air?
Are controls in place prior to discharge that meet
air cleaning requirements?
(If yes, complete air cleaning standards XII.)
_Followup.
Yes
Yes
No
No
(03/89)
-------
Table D-4 (cont.)
Coerational Problems in Control Equipment (check appropriate items
Electrostatic
P^ecipitators
Resistivity
TR Sets
Insulators
Discharge Wires.
High Velocity
Gas Distribution.
Rappers
Solids Handling
Plate Warpage
Mass Overload
Other
Fabric
Filters
Tears/pinholes.
Blinding
Bleedinq
Cleaning System
Hopper Overflow
Corrosion
Tray Collapse
Corrosion
Wet
Scrubber^
Low Liquor Flow
Gas Flow Rate Low.
Bed Plugging
Nozzle Erosion
Demisters
Throat Adjustment.
C.
Samples Taken (Describe).
D.
Comments/Recommended Action
Inspector
Date.
-------
Table D-4 (cont.)
INSPECTION RESULTS
A. Preliminary Conclusions
All sources in compliance with:
Mass Emission Regulations Yes No N/A
Visible Emission Regulations Yes No N/A.
Fuel Quality Regulations Yes No N/A_
Continuous Monitoring Regulations Yes No N/A_
Sampling/Testing Requirements Yes No N/A_
Recordkeeping Requirements Yes No N/A_
Special Orders Yes No N/A_
O&M Practices Good Average Poor_
Housekeeping Good Average Poor_
B. Specific Conclusions
Compliance questionable due to:
Changes in raw materials and/or fuels
Production rate increases
Operational changes in process
Deterioration of process equipment.
-------
Table D-4
EXAMPLE OF INSPECTION CHECKLIST*
GENERAL INFORMATION
A. Plant Location (mail address)
B. Chief Corporate Officer (name/phone).
C. Plant Manager (name/phone)
D. Environmental Contact (name/phone)
E. Sources Inspected Production Status
F. Reasons for Inspection (check appropriate items)
Routine Inspection Compliance Progress
Complaint Investigation Permit Review/Renewal.
Stack Testing Observed Tax Certification
Special Studies Emergency Episode.
Other Equipment Malfunction.
G. Plant Representative Contacted (name and title)
H. Inspection Procedures and Conditions
Prior Notice (check one) Yes No.
Time/Date Duration Onsite
Type Inspection (check one) Counterflow Followup.
Other
Weather__ Wind Direction
PRE-INSPECTION INTERVIEW
A. Production Status: Normal Abnormal
B. Control Equipment: Normal Abnormal
C. - Permit/Compliance Schedule Changes Needed: Yes No.
D. Comments
Revised from Enforcement Workshop on Plant Inspection and Evaluation, Volume II
Draft, EPA, OE, SSE, February 1979
(03/89)
-------
D-3
Table D-3 (cent.)
SOURCES SUBJECT TO TITLE 40 CFR PART 61
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS
Pollutant Subpart Source
Inorganic arsenic P Arsenic trioxide and metallic arsenic
production facilities
Volatile hazardous air V Equipment leaks (fugitive emission
pollutants (VHAP)* sources)
Radon-222 W Licensed uranium mill tailings
Volatile hazardous air pollutant (VHAP) means a substance regulated under this part for which a
standard for equipment teaks has been proposed and promulgated.
As of February 1, 1989, benzene and vinyl chloride are VHAPs.
-------
Table D-3
SOURCES SUBJECT TO TITLE 40 CFR PART 61
NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS
Pollutant
Subpart
Source
Radon-222
Beryllium
B
C
Underground uranium mines
Extraction plants
Ceramic plants
Foundries
Incinerators
Machine shops
Beryllium
Mercury
Vinyl chloride
Radionuclides
Radionuclides
Benzene (leaks)
Radionuclides
Asbestos
Inorganic arsenic
Inorganic arsenic
D
E
H
K
M
N
0
Rocket motor firing
Ore processing plants
Chlor-alkali plants
Sludge incinerators
Sludge drying plants
Ethylene dichloride plants
Vinyl chloride plants
Polyvinyl chloride plants
DOE facilities
Facilities'licensefty the Nuclear
Regulatory Commission and Federal
facilities not covered by Subpart H
Equipment in benzene service (plants
designed to produce more than
1,000 megagrams of benzene per year)
Elemental phosphorus plants
Asbestos mills
Manufacturing
Demolition and renovation
Spraying
Fabrication
Waste disposal
Glass manufacturing plants
Primary copper smelters
(03/89)
-------
D-6
NATIONAL EMISSIONS STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP)'
Sources Covered
NESHAP includes new and existing stationary sources that emit or have
the potential to emit any one of six hazardous air pollutants. The pollutants and
sources covered are listed in Table D-3.
Existing sources must comply within 90 days but can obtain waivers for
up to 2 years for installation of controls. New sources or modified sources
coming online after the publication of standards must achieve immediate
compliance.
Requirements
• Compliance Status
Submit to Agency within 90 days of publication
of standard adequate information on design,
method of operation, weight/month of
hazardous material and control devices Yes No
• Agency Notification
Proper notice before startup and before
emissions testing l_Yes No
• Emissions Testing
Emission testing conducted using prescribed
reference methods Yes No
Written results sent to Agency Yes No
• Monitoring and Reporting
Required monitoring being performed Yes No
Reporting to Agency Yes No
40 CFR, Part 61. 1980
(03/89)
-------
Table D-2
NSPS SOURCES REQUIRING CEM
Source
Fossil-fuel-fired steam generator
Fossil-fuel-fired electric utilities
Nitric acid plants
Sulfuric acid plants
Petroleum refineries (FBCCU)
Glaus sulfur recovery unit
Primary copper smelters
Primary zinc smelters
Primary lead smelters
Ferroalloy production facilities
Electric arc furnaces
Kraft pulp mills
Lime manufacturing plants
Phosphate rock plants
Flexible vinyl and urethane
coating and printing
Onshore natural gas processing
plants
Subpart
D
Da
G
H
J
J
P
Q
R
2
AA
BB
HH
NN
FFF
ILL
Effective Date
08/17/71
09/18/78
08/17/71
08/17/71
06/11/73
1 0/04/76
10/16/74
10/16/74
10/16/74
10/21/74
10/21/74
09/24/76
05/03/77
09/21/79
01/18/83
10/01/85
Monitor
opacity, S02,
NOX, 02 orC02
ooacity, SOa,
NOX, 02orC02
NOx
S02
opacity, CO,
S02l H2S
opacity, CO,
SO2, H2S
opacity, SO2
opacity, S02
opacity, SO2
opacity
opacity
opacity, TRS
opacity
opacity
VOC
SO2/T/TRS
(03/89)
-------
Perform Internal
Inspector.
Top section - check:
• Rappers
• Drives
• Insulators
• Heaters
• Blowers
Electrical Field section - check:
• Alignment • Insulators
• Build-up • Erosion
• Rappers • Corrosion
• Drives
Check:
• Hopper section
• Build-up
• Corrosion
• Hopper baffles
Check Gas distribution
devices- ESP
• Inlet • Erosion
• Outlet • Plugging
• Ductwork • Rapping
• Corrosion Systems
End ESP Inspection.
Return for Operations
Inspection
Precipitated
.Operating^
YES
Identify bus section
numbering system
Check for bus sections
which are not operating.
Check electrical character-
istics of each bus section that
is operating
• Primary voltage
• Primary current
• Secondary current
• Secondary voltage (if
measured)
• Spark rate
Check rapper sequence &
timing
Check insulators purge &
heating system.
Check operational status
Hopper heaters & vibrators
Solids removal system
'Are
"there anj
indications of
^non-compliance^
opera-
.tion?,
IYES
NO
END
ESP
INSPECTION
Reschedule operatonal
inspection. Recommend
maintenance work.
END ESP INSPECTION
Figure D-3
Electrostatic Precipitator Inspection Flowsheet
(03/39)
-------
APPENDIX E
WATER POLLUTION CHECKLISTS
-------
ie t-
NPDES Compliance Inspection Rep
ort (Form 3560-3) r_i
Umtsd Stales Environmental ^'"•et'on Agencv Form Approved
A f~ f\ JL Washington 0 C 20460
<*EPA NPDES Compliance Inspection Report ŁŁ ŁŁŁ,.„
Section A: National Data System Coding
Transaction Code NPDES yr/mo/day
ii a| 8| 3| i ' ^ 1 | | 1 | " d Ml
Remarks
1 ! 1 i 1 1 ' i • M 1 1 M 1 1 I 1
Id!
Reserved Facility Evaluation Sating Bl QA
67J 1 ! 69 7d i 7l| | 72J j
Inspection Type Inspector Fac Type
Jl7 18(_J 19l_j 2<Ł_j
J i I . , i I L ! ; L ! L ! i : ' •
06
73( I I 74 75l i ! ISO
Section 8: Facility Data
Name and Location of Facility Inspected
Namefs; of On-Site Representative^) Title(s)
Entry Time Q AM D PM p«rm" Effective Date
Exit Time/Date Permit Expiration Date
Phone No
-------
INSTRUCTIONS
Section A: National Data System Coding (i.e., PCS)
Column 1: Transaction Code: Use N, C, or D for New, Change, or Delete. All inspections will be new
unless there is an error in the data entered.
Columns 3-11: NPDES Permit No. Enter the facility's NPDES permit number. (Use the Remarks
columns to record the State permit number, if necessary.)
Columns 12-17: Inspection Date. Insert the date entry was made into the facility. Use the
year/month/day format (e.g., 82/06/30 = June 30, 1982).
Column 18: Inspection Type. Use one of the codes listed below to describe the type of inspection:
A — Performance Audit E — Corps of Engrs Inspection S — Compliance Sampling
B — Biomonitormg L — Enforcement Case Support X — Toxic Sampling
C — Compliance Evaluation P — Pretreatment
D — Diagnostic R — Reconnaissance Inspection
Column 19: Inspector Code. Use one of the codes listed below to describe the lead agency in the
inspection.
C — Contractor or Other Inspectors (Specify in N — NEIC Inspectors
Remarks columns) R — EPA Regional Inspector
E — Corps of Engineers S — State Inspector
J — Joint EPA/State Inspectors—EPA lead T —Joint State/EPA Inspectors—State lead
Column 20: Facility Type. Use one of the codes below to describe the facility.
1 — Municipal. Publicly Owned Treatment Works (POTWs) with 1972 Standard Industrial Code
(SIC) 4952.
2 — Industrial. Other than municipal, agricultural, and Federal facilities.
3 — Agricultural. Facilities classified with 1972 SIC 0111 to 0971.
4 — Federal. Facilities identified as Federal by the EPA Regional Office.
Columns 21 -66: Remarks. These columns are reserved for remarks at the discretion of the Region.
Column 70: Facility Evaluation Rating. Use information gathered during the inspection (regardless
of inspection type) to evaluate the quality of the facility self-monitoring program. Grade the program
using a scale of 1 to 5 with a score of 5 being used for very reliable self-monitoring programs, 3 being
satisfactory, and 1 being used for very unreliable programs.
Column 71: Biomonitoring Information. Enter D for static testing. Enter F for flow through testing.
Enter N for no biomonitoring.
Column 72: Quality Assurance Data Inspection. Enter Q if the inspection was conducted as
followup on quality assurance sample results. Enter N otherwise.
Columns 73-80: These columns are reserved for regionally defined information.
Section B: Facility Data
This section is self-explanatory.
7 Section C: Areas Evaluated During Inspection
Indicate findings (S, M, U, or N) in the appropriate box. Use Section D and additional sheets as
necessary. Support the findings, as necessary, in a brief narrative report. Use the headings given on
the report form (e.g., Permit, Records/Reports) when discussing the areas evaluated during the
inspection. The heading marked "Other" may include activities such as SPCC, BMP's, and multime-
dia concerns.
Section D: Summary of Findings/Comments
Briefly summarize the inspection findings. This summary should abstract the pertinent inspection
findings, not replace the narrative report. Reference a list of attachments, such as completed
checklists taken from the NPDES Compliance Inspection Manuals and pretreatment guidance
documents, including effluent data when sampling has been done. Use extra sheets as necessary.
EPA Form 3560-3 (Rev. 3-8S) Reverse
-------
E-3
Appendix E (cont.)
SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN
(SPCC) CHECKLIST
1. Does this facility have:
a. More than 1,320 gallons of above-ground
oil storage capacity or a single container
with a capacity of more than 660 gallons? Yes No_
b. More than 42,000 gallons of underground
oil storage capacity?
2. Does this facility have a Spill Prevention Control
and Countermeasure (SPCC) plan? Yes No_
a. Has the SPCC plan been certified by a
registered professional engineer? Yes No_
b. Date the SPCC plan was last certified:
c. Original date SPCC plan was prepared:
3. Are there other State or local requirements for
hazardous materials spill prevention and control
plan? Yes No_
a. Is this hazardous materials SPCC plan
available? Yes No_
4. Have any reportable spills of petroleum products
or hazardous materials occurred at this facility within
the last review period? Yes No_
List:
a. Were these spills reported to the proper
authorities? Yes No_
b. Were these spills cleaned up properly? Yes No_
c. Were measures taken to prevent future spills? Yes No_
-------
E-4
Appendix E (cont.)
d. Is there evidence of these reported spills or
other spills at the facility? Yes No_
5. Does the SPCC plan include:
a. Notification procedures? Yes No_
b. Inspection procedures? Yes No_
c. A facility drawing which includes storage
tanks and containment areas? Yes No_
d. Oil spill prevention designee? Yes No_
6. Does the facility have:
a. Secondary containment or diversionary
structures at oil storage areas? Yes No_
b. Spill cleanup materials available or informa-
tion on where these materials are available? Yes No_
c. Security? Yes No.
COMMENTS:
-------
APPENDIX F
RCRA CHECKLISTS
-------
F-1
RCRA INSPECTION CHECKLISTS"
Table F-1
RCRA COMPLIANCE INSPECTION REPORT
GENERATORS CHECKLIST
Note: State laws, in many cases are more stringent than Federal law for many
of the generator requirements, but particularly in the area of accumulation time.
Be aware of these differences and modify this protocol as needed!
• Does the State in which the generator is
located have RCRA State authorization? Yes No
Has the generator identified the differences
between the State program and the Federal
program? Yes No
SECTION A - EPA ID NUMBER
1. Does generator have EPA ID Number?
2.
a. If yes, EPA ID Number.
Yes
No
Are there other EPA ID Numbers used at this
location? (If yes, list the other numbers and
identify where they are used and for what they
were issued.) Yes
No
SECTION B - HAZARDOUS WASTE DETERMINATION
1. Has the generator determined whether hazard-
ous waste(s) (§261 Sub-part D) are generated
at this facility? Yes.
a. Are records of the determinations kept by
the generator (262.40)? Yes.
b. List hazardous waste and quantities
•i- - on an attachment (Include EPA Hazard-
ous Waste Number. Provide waste name
and description.)
No.
No
These checklists are to be used only as guides and references should be made to both
RCRA and the regulations (40 CFR Parts 260 through 270 except for Part 268, which is
covered in Appendix G) for recent changes.
(03/89)
-------
F-2
Table F-1 (cont.)
2. Are solid wastes that exhibit hazardous
characteristics generated (§261 Subpart C)? Yes No.
a. If yes, list wastes and quantities on an attachment. Include
EPA Hazardous Waste Number. Provide waste name and
description.)
b. How are waste characteristics determined (testing,
knowledge of process)?
. (1) If determined by testing, did
generator use test methods in
Part 261, Subpart C (or
equivalent)? Yes No
(2) If equivalent test methods used,
attach copy of methods.
3. Identify total quantities of hazardous waste generated per month, for
the last 12 months, for both acutely hazardous waste and other
hazardous waste.
(kg/mo) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Acutely toxic
Other hazardous
waste
4. Does the generator qualify as a Small
Quantity Generator (SQG) for the entire last
12-month period (§261.5)? Yes No
(If no, list the months that the generator was a full generator.)
5. Is generator exempted or conditionally exempted from regulation
*- because of:
a. Small quantity generator (§261.5) Yes No
b. Produces nonhazardous waste at this
time (§261.4) Yes No
6. Are any nonhazardous wastes generated? Yes No
-------
F-3
Table F-1 (cont.)
a. If yes, did generator identify them as
nonhazardous by testing or by knowl-
edge of process? Yes No
(1) If determined by testing, did
generator use test methods in
Part 261 Subpart C (or
equivalent)? Yes No
(2) If equivalent test methods used, attach copy of
methods.
b. List wastes and quantities deemed nonhazardous or
processes from which nonhazardous wastes were produced.
Use narrative explanation sheets.
SECTION C - UNIFORM HAZARDOUS WASTE MANIFEST SYSTEM
1. Has generator shipped hazardous waste
offsite since November 19, 1980 (§262
Subpart B)? Yes No
a. If no skip to Section D, Question #8.
b. If yes, identify the name, EPA ID Number and site address(es)
of the offsite facilities. (Use back of page for additional
facilities if needed.)
Name
Name
Name
Name
Address
Address
Address
Address
2. If not exempt, is the waste manifested on the
Uniform Hazardous Waste Manifest (§262,
^ Appendix) Yes No_
If so, do the manifests contain:
a. Name and mailing address of
generator? Yes No_
b. The name and EPA ID Number of
each transporter? Yes No_
-------
F-4
Table F-1 (cont.)
c. DOT waste description, including
proper shipping name, hazardous class
and DOT identification number? Yes No
d. Number and type of containers (if
applicable)? Yes No
e. Quantity of each waste transported? Yes No
f. Name, EPA ID Number and site
address of facility designated to receive
the waste? Yes No
g. The following certification: effective
September 1, 1985? Yes No
"I hereby declare that the contents of this consignment are fully and
accurately described above by proper shipping name and are classified, packed,
marked and labeled, and are in all respects in proper condition for transport by
highway according to applicable international and national government
regulations.
Unless I am a small quantity generator who has been exempted by statute
or regulation from the duty to make a waste minimization certification under
Section 3002(b) of RCRA, I also certify that I have a program in place to reduce
the volume and toxicity of waste generated to the degree I have determined to be
economically practicable and I have selected the method of treatment, storage or
disposal currently available to me which minimizes the present and future threat
to human health and the environment."
3. Does the facility designated to receive the waste have:
a. A RCRA permit? Yes No
b. Interim status? Yes No
c. A permit, license or registration from a
state to manage municipal or industrial
solid waste? Yes No.
-------
F-5
Table F-1 (cont.)
Does the generator retain copies of the
manifests? Yes No
If yes, complete 6a through 6e (§262.23).
(Inspect completed manifests at random and indicate how many
manifests were inspected. Obtain copies of all manifests with
violations and describe violations.)
Did the generator sign and date all manifests? Yes No
Who signed the manifests for the generator?
Name Title.
Name Title
b. Did the generator obtain the handwritten
signature and date of acceptance from
the initial transporter? Yes No_
c. Does generator retain one copy of the
manifest signed by the generator and
transporter? Yes No_
d. Do return copies of manifest include
facility owner/operator signature and
date of acceptance? Yes No_
e. If the copy of the manifest from the
facility was not returned within 45 days,
did generator file an Exception Report
(§262.42)? Yes No_
If yes, did it contain:
(1) A legible copy of the manifest Yes No_
(2) A cover letter explaining
generator's efforts to locate waste
and the results of those efforts? Yes No_
Has generator retained copies for
3 years? Yes No_
-------
F-6
Table F-1 (cont.)
SECTION D - PRFTRANSPQRT REQUIREMENTS
1. Does the generator package waste? Yes No_
If not, why not? (Skip the rest of Section D)
If yes, complete the following questions.
2. Does generator package waste in accordance with
DOT requirements 49 CFR 173, 178 and 179
(§262.30)? Yes No
3. Inspect containers to be shipped. (Use narrative explanation sheet
to describe containers and condition.)
a. Are containers leaking, corroding or
bulging? Yes No
b. Is there evidence of heat generation
from incompatible wastes in containers? Yes No
c. Are containers labeled according to
DOT (49 CFR 172 Subpart E)? Yes No
d. Are containers marked according to
DOT requirements (49 CFR 172
Subpart D)? Yes No
e. Is each container of 110 gallons or less
marked with the following words? Yes No
"HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal.
If found, contact the nearest police or public safety authority or the
U.S. Environmental Protection Agency."
Generator's name and address .—
Manifest Document Number.
(Note: During accumulation times, see below, only the words "Hazardous
Waste" must appear on containers of 110 gallons or less.)
-------
F-7
Table F-1 (cont.)
4. If there are any vehicles present onsite loading or unloading
hazardous waste, inspect for presence of placards (49 CFR 172
Subpart F). Note this instance on narrative explanation sheet.
5. Accumulation time (§262.34)
a. Is facility a permitted storage facility? Yes No
b. Has all hazardous waste, generated in
excess of the SQG limits, been shipped
offsite or sent to onsite treatment,
storage or disposal within 90 days. Yes No
(1) Is the waste placed in containers
and managed in accordance
with the container management
requirements for facility owners
or operators (§265 Subpart I)? Yes No
(Generators who qualify for the SQG provided they
comply with the 50-foot buffer requirement for ignitable
waste.)
(2) Is the date upon which each
period of accumulation began
clearly marked on each
container? Yes No
(3) What system does the generator use to determine
when the SQG rate is exceeded? Explain
(4) Are the words "Hazardous
Waste" clearly marked on each
container of 110 gallons or less
and visible for inspection? Yes No_
(03/89)
-------
F-8
Table F-1 (cont.)
(5) For quantities in excess of the
respective SQG rates, is the
generator complying with the
facility standards for Prepared-
ness and Prevention (Part 265
Subpart C) and Contingency
Plan/Emergency Procedures
(Part 265 Subpart D)? Yes No_
(6) For hazardous waste generated
below the respective SQG rates,
is the generator complying with
the modified requirements for
SQGs (§261.5) Yes No_
(7) Do the facility hazardous waste
management personnel have the
requisite training documented in
their personnel file (§265.16) Yes No_
c. Have hazardous wastes, generated at
a rate between 100 kg/mo and
1,000 kg/mo, been accumulated less
than 180 days, or 270 days if the facility
is over 200 miles away (effective
September 22, 1986)? Yes No_
d. Is the total amount of all hazardous
waste accumulated onsite and
generated below 100 kg/mo, less than
1,000 kg? Yes No_
e. Is the total amount of hazardous waste,
accumulated onsite, generated at a rate
between 100 kg/mo and 1,000 kg/mo,
less than 6,000 kg? Yes No_
f. Does the generator inspect containers
for leakage or corrosion (§265.174)? Yes No_
(1) If yes, how often?
(Review inspection records.)
g. Does the generator handle ignitable or
reactive waste? Yes No
-------
F-9
Table F-1 (cont.)
(1) If yes, does the generator locate
ignitable or reactive wastes at
least 15 meters (50 feet) inside
facility's property line (§265.176)? Yes No.
(2) Does the generator separate and
protect ignitable or reactive
wastes from sources of ignition
(§265.17)? Yes No_
Note: If generator accumulates waste onsite for more than 90 days, fill out
facilities checklist, Section A-9, Personnel Training; Section B -
Preparedness and Prevention; and Section C - Contingency Plan and
Emergency Procedures.
9. Describe storage/accumulation area(s). Use photographs and
narrative explanation sheet.
SECTION E - RECORDKEEPING AND RECORDS
1. Is generator keeping the following records (§262.40)?
(Note: The following must be kept for a minimum of 3 years.)
a. Manifests or signed copies from
designated facilities? Yes No
b. Biennial reports (does not apply to
SQGs)? Yes No_
c. Exception reports (does not apply to
SQGs)? Yes No.
d. Test results or other means of
determination, as required? Yes No_
2. ~ Where are facility records kept (at the facility, offsite, etc.)
3. Who is responsible for keeping the records?.
Title:
-------
F-10
Table F-1 (cont.)
F. SPECIAL CONDITIONS
1. Have hazardous wastes been received from
or transported to a foreign source (§262.50)? Yes No_
If yes,
a. For imports, has generator filed a notice
with the Regional Administrator? Yes No_
b. For exports, has generator filed a notice
with the Administrator, Office of Interna-
tional Activities, A-106, 4 weeks before
the initial shipment to each country? Yes No_
c. For exports, are waste manifests signed
by the foreign consignee? Yes No_
d. If the generator transported wastes out
of the country, has he received confirma-
tion of delivery of the shipment? Yes No_
(1) Identify those shipments for which
confirmation of delivery have not
been received within 90 days of
shipment by manifest number.
(2) Has generator filed an Exception
Report for all those shipments
identified in 1d(1) above? Yes No_
e. Has the exporter filed, with the Admini-
strator, an export summary report for the
previous year by March 1 ? Yes No_
-------
F-11
Table F-2
RCRA COMPLIANCE INSPECTION REPORT
TRANSPORTER(S) AND VEHICLE CHECKLIST
SECTION A - GENERAL TRANSPORTER INFORMATION
1. Does transporter have EPA Identification
Number? Yes No_
EPA ID Number
2. Does more than one transporter or address
use this identification number? How many? Yes No
3. Identify the mode(s) of transportation used by transporter.
Air Rail Highway Water Other
(specify)
Specification:
4. Does transporter have all necessary permits? Yes No
State permit number:
Federal permit number:.
5. Does transporter ship hazardous waste out of
the U.S.? Yes No_
6. Does transporter ship hazardous waste into
the U.S.? • Yes No
If yes, complete "Generator Checklist" for these hazardous wastes.
7. Does transporter mix hazardous wastes of
different DOT shipping descriptions by placing
them into a single container? Yes No
If yes, complete "Generator Checklist" for these mixtures.
SECTION-B - TRANSFER FACILITIES
1. Does the transporter store manifested ship-
ments of hazardous waste in containers
meeting the requirements of §262.30 at a
transfer facility? Yes No
(03/89)
-------
F-12
Table F-2 (cont.)
2. Is all manifested hazardous waste, tempo-
rarily stored by the transporter, shipped offsite
within 10 days? Yes No_
If not, complete "TSDF Checklist".
SECTION C - Manifest and Recordkeepinq Requirements
1. Are all shipments of hazardous wastes accom-
panied by an approved manifest (EPA
Form 8700-22 or EPA Form 8700-22A)? Yes No_
2. Does all required information appear on the
manifest (49 CFR 172.205)? Yes No.
3. Inspect completed manifests at random and indicate number
inspected. Obtain copies of all manifests with deficiencies and
provide narrative explanation.
4. If transporter has shipped hazardous waste(s)
out of the United States, is the date of exit and
the name and address of receiving facility
indicated on manifest? Yes No
5. Special Conditions
a. If transportation occurs by water (bulk
shipment), does the transporter:
(1) Ship to the designated facility? Yes No_
(2) Maintain shipping papers with
information contained on
manifest? Yes No_
(3) Obtain designated facility
signature and date of receipt? Yes No_
^ (4) Retain a copy of manifest or
7 shipping papers? Yes No_
b. If transportation occurs by rail, does the
transporter:
(1) Sign and date manifest acknowl-
edging acceptance? Yes No.
-------
F-13
Table F-2 (cont.)
(2) Return signed copy to nonrail
transporter? Yes No_
(3) Forward at least three copies of
the manifest to the next appro-
priate destination? Yes No_
(4) Retain one copy of manifest and
rail shipping papers? Yes No_
(5) Ensure shipping papers accom-
pany the waste(s)? Yes No_
(6) On delivery, obtain name, date
and signature of designated
facility or transporter? Yes No_
6. Does transporter retain copies of manifests
and shipping papers for the required 3-year
period? Yes No
SECTION D - MANIFEST COMPLIANCE
1. Does the transporter ship all waste to either
the designated facility listed on the manifest or
the alternate facility (when applicable) or the
next designated transporter? Yes No
2. Does the transporter assure delivery to the
designated facility outside the U.S.? Yes No
3. What procedures does the transporter follow when delivery of
hazardous wastes to designated facility is prevented? (Use
narrative explanation sheets.)
SECTION E - PRETRANSPORT REVIEW
1. ~- Do«s the transporter check to assure that the generator has
compiled with the following requirements?
a. Has the generator packaged wastes in
accordance with DOT requirements
(49 CFR 173)? Yes No
b. Has the generator packaged wastes in
repacks? Yes No
-------
F-14
Table F-2 (cont.)
c. Has the generator labeled wastes in
accordance with DOT requirements
(49 CFR 172, Subpart E)? Yes No_
d. Has the generator marked wastes in
accordance with DOT requirements
(49 CFR 172, Subpart D)? Yes No_
e. Has generator marked each container
of 110 gallons or less used in such
transportation with the following words
and information displayed in accord-
ance with the requirements of
49 CFR 172.304? Yes No.
HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal.
If found, contact the nearest police or public safety authority or the U.S.
Environmental Protection Agency.
Generator's Name and Address:
Manifest Document Number:
Did generator placard or offer the initial
transporter the appropriate placards
according to DOT (49 CFR 172,
Subpart F)? Yes No.
SECTION F - EMERGENCY ACTION
1. Has transporter ever been involved in a dis-
charge of hazardous wastes? Yes No.
a. If yes, was the National Response
Center (800-424-8802 or
202-426-2675), U.S. Coast Guard,
the State and the principal office of
transporter notified? Yes No_
b. Was a written report submitted to DOT
within 10 days following the discharge Yes No.
Attach copy of report (if available).
-------
F-15
Table F-2 (cont.)
2. Has the transporter obtained an Emergency
Identification Number from EPA for the
cleanup operation? Yes No_
a. If yes, identify the number(s):
SECTION G • TRANSPORT VEHICLE INSPECTION
1. Company/name/designation of vehicle: _
2. Truck drive r"s name:
3. What hazardous wastes are listed on manifest? List in narrative
explanation.
4. Form of containerization of hazardous wastes:
drums, size: gallons (ea), amount (i.e., 30 drums)
portable tanks - number volume (ea)
gondola
tanker-type volume (ea)
5. Narrative explanation of condition of containerization (leaking,
corroded, funning, damaged, improperly sealed, poor condition,
improper lining, etc.)
6. Is truck properly placarded and marked
(49 CFR, Subpart F)? Yes No
7. Did generator have to repackage wastes by
truck driver's request? Yes No_
8. Is truck driver aware of any special handling
of materials? Yes No_
7 If yes, describe.
9. Does truck driver have the National
Response Center phone number accessible? Yes No_
-------
F-16
Table F-2 (cont.)
COMMENTS:
-------
F-17
Table F-3
RCRA COMPLIANCE INSPECTION REPORT
TREATMENT, STORAGE AND DISPOSAL FACILITIES (TSDFs)
CHECKLIST FOR INTERIM STATUS FACILITIES (PART 265)
SECTION A - GENERAL FACILITY STANDARDS
1. Does facility have EPA Identification Number
(§265.11)? Yes No.
If yes, EPA Identification Number:
If no, explain:
2. Has facility received hazardous waste from a
foreign source (§265.12)? Yes No_
If yes, has he filed a notice with the Regional
Administrator 4 weeks in advance of the initial
shipment? Yes No
Waste Analysis
3. Does the facility have a written waste analysis
plan (§265.13)? Yes No.
If yes, is a copy maintained at the facility? Yes No_
If no, proceed to question 5.
4. Does the plan include:
a. Parameters for which each waste will be
analyzed? Yes No.
b. Rationale for the selection of these
.*_ parameters? Yes No_
c. Test methods used to test for these
parameters? Yes No_
d. Sampling method used to obtain
sample? Yes No_
(03/89)
-------
F-18
Table F-3 (cont.)
e. Frequency with which the initial analysis
will be reviewed or repeated? Yes No_
(1) If yes, does it include require-
ments to retest when the process
or operation generating the
waste has changed? Yes No_
f. (For offsite facilities) Waste analyses
that generators have agreed to supply? Yes No_
g. (For offsite facilities) Procedures which
are used to inspect and analyze each
movement of hazardous waste including:
(1) Procedures to be used to deter-
mine the identity of each
movement of waste? Yes No.
(2) Sampling method to be used to
obtain representative sample of
the waste to be identified? Yes No.
Security
5. Does the facility provide adequate security to
minimize the possibility for the unauthorized
entry of persons or livestock onto the active
portions of the facility (§265.14)? Yes No.
If no, describe inadequacies. (Use narrative explanation sheet and
include a drawing indicating any inadequacies in the facility's
security system.)
If yes, is security provided through:
a. 24-hour surveillance system (e.g.,
television monitoring or guards)? Yes No
ffi
b. (1) Artificial or natural barrier
around facility (e.g., fence or
fence and cliff)? Yes No
-------
F-19
Table F-3 (cont.)
Describe type of security:
AND
(2) Means to control entry through
entrances (e.g., attendant, tele-
vision monitors, locked entrance,
controlled roadway access)? Yes No_
Describe type of security:
6. Is a sign with the legend, "Danger-Unauthorized
Personnel Keep Out," posted at the entrance to
the active portion of the facility? Yes No_
Is it written in English and legible from at least
25 feet? Yes No
Note: The sign must also be written in any other language predominant in
the area surrounding the facility (e.g., in New Mexico and Texas areas
bordering Mexico, the sign must be in Spanish).
If a sign exists with a legend other than "Danger-Unauthorized
Personnel Keep Out," what does that legend say?
General Inspection Requirements
7. a. Does the owner/operator maintain a
written schedule for inspecting
(§265.15)? Yes No.
(1) Monitoring equipment, if
applicable? Yes No_
(2) Safety and emergency
equipment? Yes No_
(3) Security devices? Yes No_
(4) Operating and structural
equipment, if applicable? Yes No_
-------
F-20
Table F-3 (cont.)
(5) Does the schedule or plan
identify the types of problems to
be looked for during inspection? Yes No_
(a) Malfunction or deteriora-
tion (e.g., inoperative sump
pump, leaking fitting, erod-
ing dike, corroded pipes or
tanks, (etc.)? Yes No_
(b) Operator error? Yes No_
(c) Discharges (e.g., leaks
from valves or pipes, joint
breaks, etc.)? Yes No_
b. Is a written schedule for these inspec-
tions maintained at the facility? Yes No_
(1) Are records of these inspections
maintained in an inspection log
(§265.15)? Yes No_
(2) If yes, does it include:
(a) Date and time of
inspection? Yes No_
(b) Name of inspector? Yes No_
(c) Notation of observations? Yes No_
(d) Date and nature of repairs
or remedial action? Yes No_
(3) Are there any malfunctions or
other deficiencies noted in the
inspection log that remain
unconnected? Use narrative
explanation sheet. Yes No_
(4) Are records of the inspection log
maintained at the facility for at
least 3 years? (Obtain copies of Yes No_
incomplete or inadequate
inspection records.)
-------
F-21
Table F-3 (cont.)
Personnel Training
8. Does the owner/operator maintain a person-
nel training program (§265.16)? Yes No.
a. If yes,
(1) Is the program directed by a per-
son trained in hazardous waste
management procedures?
(2) Is the program designed to pre-
pare employees to respond
effectively to hazardous waste
emergencies? Yes No_
(3) Is a training review given
annually? Yes No_
b. Does the owner/operator keep the following
records:
(1) Job title and written job descrip-
tion of each position? Yes No_
(2) Description of the type and
amount of introductory and
continuing training Yes No_
(3) Documentation that training has
been given to employees? Yes No_
c. Are these records maintained at the
facility? Yes No_
Requirements for lanitable. Reactive or Incompatible Waste
9. Does facility handle ignitable or reactive
waste (§265.17)? Yes No_
- a. If yes, is waste separated and confined
from sources of ignition or reaction? Yes No_
b. Are "No Smoking" signs posted in
hazardous areas where ignitable or
reactive wastes are handled? Yes No
-------
F-22
Table F-3 (cont.)
10. Observe containers (§265.17)
a. Are containers leaking, corroding or
bulging? Yes No_
Use narrative explanation sheet to describe containers in
this condition.
b. Has the facility ever placed incompat-
ible wastes together? Yes No
If yes, what were the results? Use narrative explanation
sheet. Look for signs of mixing of incompatible wastes (e.g.,
fire, toxic mist, heat generation, bulging containers, etc.).
SECTION B - PREPAREDNESS AND PREVENTION
1. Is there evidence of fire, explosion or
contamination of the environment (§265.31)? Yes No
If yes, use narrative explanation sheet to explain.
2. Is the facility equipped with (§265.32)?
a. Easily accessible internal communica-
tions or alarm system? Yes No
b. Telephone or two-way radio to call.
emergency response personnel? Yes No
c. Portable fire extinguishers, fire control
equipment, spill control equipment and
decontamination equipment? Yes No
(1) Is this equipment tested and
maintained as necessary to
assure its proper operation?
(Note last inspection/test date.) Yes No
d. Water of adequate volume for hoses,
sprinklers or water spray system? Yes No
(1) Describe source of water
-------
F-23
Table F-3 (cont.)
(2) Indicate flow rate and/or pressure and storage
capacity, if applicable.
3. Is there sufficient aisle space to allow
unobstructed movement of personnel and
equipment (§265.35)? Yes No
4. Has the owner/operator made arrangements
with the local authorities to familiarize them
with characteristics of the facility (§265.37)? Yes No_
If no, has the owner/operator attempted to
make such arrangements? Yes No
5. In the case that more than one police or fire
department might respond, is there a
designated primary authority (§265.37)? Yes No_
If yes, indicate primary authority:
a. Is the fire department a city, volunteer or onsite fire
department?
6. Does the owner/operator have phone num-
bers of and agreements with State emergency
response teams, emergency response contrac-
tors and equipment suppliers? Yes No
Are they readily available to the emergency
coordinator (§265.37)? Yes No_
7. Has the owner/operator arranged to familiar
ize local hospitals with the properties of
hazardous waste handled and typed of
injuries that could result from fires, explosions
or releases at the facility? Yes No_
. If no, has the owner/operator attempted to do
"- this (§265.37)? Yes No_
8. If the State or local authorities decline to enter
into the above-referenced agreements, is there
documentation of this (§265.37)? Yes No
-------
F-24
Table F-3 (cont.)
SECTION C - CONTINGENCY PLAN AND EMERGENCY PROCEDURES
1. Does the facility have a contingency plan
(§265.52)? Yes No.
If yes, does it contain:
(1) Actions to be taken in response
to emergencies? Yes No_
(2) Description of arrangements with
police, fire and hospital officials? Yes No_
(3) List of names, addresses, phone
numbers of personnel qualified to
act as emergency coordinator? Yes No_
(4) List of all emergency equipment
at the facility? Yes No_
(5) Evacuation plan for facility
personnel? Yes No_
2. Is a copy of the contingency plan maintained
at the facility (§265.53)? Yes No.
3. Has a copy been supplied to local police and
fire departments (§265.53)? Yes No_
4. Is the plan a revised SPCC plan (§265.52)? Yes No_
5. Is there an emergency coordinator onsite or
within short driving distance of the plant at all
times? Yes No_
If yes, list primary emergency coordinator:
SECTIONS - MANIFEST SYSTEM. RECORDKEEPING AND REPORTING
1. Has facility received hazardous waste from
offsite since November 19, 1980 (§265.71)? Yes No_
If no, proceed to question 5.
-------
F-25
Table F-3 (cont.)
If yes, does the facility retain copies of all mani-
fests? Inspect manifest at random, indicate
number inspected, describe deficiencies and
obtain copies of all deficient manifests.) Yes No
2. Has the facility received any hazardous waste
from a rail or water (bulk shipment) transporter
since November 19, 1980 (§265.71)? Yes No_
If yes, is it accompanied by a shipping paper? Yes No_
(1) Has the owner/operator signed
and dated the shipping paper
and returned a copy to the
generator? Yes No_
(2) Is a signed copy given to the
transporter? Yes No_
3. Has the facility received any shipments of hazardous waste since
November 19, 1980, which were inconsistent with the manifest
(§265.72)?
a. If yes, has he resolved the discrepancy
with the generator and transporter? Yes No
b. If no, has Regional Administrator been
notified? Yes No
4. Has the facility received any waste (that does
not come under the small generator exclusion)
not accompanied by a manifest (§265.76)? Yes No_
If yes, has facility submitted an unmanifested
waste report to the Regional Administrator? Yes No_
5. Does the facility have a written operating
_. record (§265.73)? Yes No_
"a. Is a copy maintained at the facility? Yes No_
b. Does the record include:
-------
F-26
Table F-3 (cont.)
(1) Description and quantity of each
hazardous waste and the
methods and dates of its treat-
ment, storage or disposal at the
facility? Yes No_
(2) Location and quantity of each
hazardous waste? Yes No_
(a) Is this information cross-
referenced with specific
manifest document num-
bers, if applicable? Yes No_
(3) Location and quantity of each
hazardous waste recorded on a
map or diagram of each cell or
disposal area (for disposal
facilities only)? Yes No_
(4) Record and results of waste
analyses? Yes No_
(5) Reports of incidents involving
implementation of the contingency
plan (if applicable)? Yes No_
(6) Records and results of required
inspections? Yes No_
(7) Monitoring, testing or analytical
data where required? Yes No_
(8) Closure cost estimates and, for
land disposal facilities, post-
closure cost estimates? Yes No
SECTION^ - PLANS AND REPORTS
1. Have all plans and reports been visually
inspected and/or been made available for
inspection (§265.74)? Yes No_
List plans and/or reports not made available
for inspection. Yes No_
-------
F-27
Table F-3 (cont.)
2. Did operator provide inspector with a drawing
of the facility? Yes No
If yes, identify which are hazardous waste management units on the
drawing.
3. Indicate which of the following apply to wastes managed by this
facility:
Groundwater Monitoring Program (Subpart F) [Table F-4]
Containers (Subpart I) [Table F-5]
Tanks (Subpart J) [Table F-6]
Surface Impoundments (Subpart K) [Table F-7]
Waste Piles (Subpart L) [Table F-8]
Land Treatment (Subpart M) [Table F-9]
Landfill (Subpart N) [Table F-10]
Incinerator (Subpart O) [Table F-11]
Thermal Treatment (Subpart P) [Table F-12]
Chemical, Physical and Biological Treatment (Subpart Q)
[TableF-13]
Underground Injection (Subpart R) [Appendix M]
-------
F-28
Table F-4
GROUNDWATER MONITORING
1. Is the facility operating under
a. Interim status Yes No_
b. RCRA permit (or State equivalent) Yes No_
2. Has the facility implemented a groundwater monitor-
ing program under
a. Interim status Yes No_
b. RCRA permit (or State equivalent) Yes No_
3. Has a waiver demonstration been prepared? Yes No_
a. Does it describe the potential for migration of
waste from the waste management unit to the
uppermost aquifer? Yes No_
b. Does it describe the potential for waste to
enter a water supply or surface water? Yes No_
c. Is it certified by a qualified geologist or geo-
technical engineer? Yes No_
4. Have required monitoring reports been submitted to
EPA and/or the State? . Yes No_
5. Has an adequate hydrogeologic characterization
investigation been conducted at the facility? Yes No_
a. Has the uppermost aquifer been adequately
defined? Yes No_
b. Have flow directions been adequately
defined for the uppermost aquifer? Yes No_
c. "- Have groundwater flow rates been deter-
" mined for hydrologic units within the
uppermost aquifer? Yes No_
6. Has the facility developed and implemented an
operation and maintenance plan for the monitoring
well network and sampling equipment? Yes No.
(03/89)
-------
F-29
Table F-4 (cont.)
SECTION A - INTERIM STATUS PROGRAMS
1. Did the facility initially implement a detection
monitoring program (40 CFR 265.92) or an
assessment monitoring program
(40 CFR 265.93)? Yes No_
2. If a detection monitoring program was
implemented,
a. Was a sampling and analysis plan
prepared? Yes No_
b. Was a sampling and analysis plan in
effect on November 19, 1981? Yes No_
c. Did the program include upgradient
wells not apparently affected by the
facility? Yes No_
d. Did the program include at least four
downgradient wells at the limit of the
waste management area(s)? Yes No_
3. Sampling and Analysis Plan
a. Is the sample collection adequately
described? - Yes No_
b. Is the sample preservation adequately
described? Yes No_
c. Is the sample shipping adequately
described? Yes No_
d. Are the analytical procedures speci-
fically identified? Yes No_
7 e. Is the sample chain-of-custody
adequate? Yes No_
f. Are the quality assurance/quality control
procedures identified? Yes No_
g. Are parameters to be analyzed for those
specified in 40 CFR 265.92(b)? Yes No_
-------
F-30
Table F-4 (cont.)
h. Does the plan contain a sampling
schedule? Yes No_
i. Does the schedule conform to regula-
tory requirements? Yes No_
4. If an assessment monitoring program was implemented,
a. Did the notification of the Regional
Administrator or State Director comply
with 40 CFR 265.93(d)? Yes No.
b. Did submittal of the plan comply with
40 CFR 265.93(d)?
c. Was it certified by a qualified geologist
or a geotechnical engineer?
d. Was it approved by EPA or the State?
e. Does it determine the rate and extent of
waste migration?
f. Does it determine the concentrations of
waste constituents in groundwater?
g. Has a groundwater quality assessment
report been submitted?
h. Does the facility keep records on the
results of analyses and evaluations?
SECTION B - RCRA PERMIT PROGRAMS
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
1. Which of the following programs are required
by the permit? Yes No_
a. Detection monitoring (40 CFR 264.98) Yes No_
- b. Compliance monitoring (40 CFR 264.99) Yes No_
c. Corrective action (40 CFR 264.100) Yes No_
2. Have sampling and analysis plans been
developed for the required groundwater
monitoring program(s)? Yes No_
-------
F-31
Table F-4 (cont.)
a. Has the required plan(s) been approved by
b.
c.
d.
e.
f.
g.
EPA or the State? Yes
Has the program been implemented? Yes
Are the selected monitoring parameters
adequate? Yes
Is the point of compliance properly located?Yes
Is the delineation of waste management
areas appropriate? Yes
Is leakage from non-regulated units expected
to affect groundwater quality at the point of
compliance? Yes
Have any groundwater samples been
analyzed for Appendix VIII parameters
(40CFR261)? Yes
No
No
No
No
No
No
No
SECTION C - MONITORING WELLS
1. Are
a.
b.
c.
d.
e.
f.
g-
h.
i.
j.
wells
Adequately designed Yes
Properly constructed Yes
Appropriate materials used Yes
Located as indicated on map in
sampling plan Yes
Marked with proper identifying
designation Yes
Installed in appropriate hydrologic
zones Yes
Secured from unauthorized entry Yes
Protected from damage by vehicular
traffic Yes
Surveyed for elevation Yes
Marked for surveyed point Yes
No
No
No
No
No
No
No
No
No
No
-------
F-32
Table F-4 (cont.)
2. Are the locations and numbers of wells
adequate to satisfy the requirements of
40 CFR 265.91 for interim status facilities or
40 CFR 264.97 for permitted facilities? Yes No_
3. Are the wells being adequately maintained? Yes No_
4. Are the wells accessible year round? Yes No_
SECTION D - MONITORING PROCEDURES
1. Are adequate field procedures being used for
a. Measuring depth to water Yes No_
b. Purging the well befc sampling Yes No_
c. Measuring pH, conductivity and
temperature Yes No_
d. Other field parameters Yes No_
e. Collecting samples Yes No_
f. Preserving samples Yes No_
g. Cleaning reused equipment between
wells • Yes No_
h. Storing samples after collection Yes No_
i. Disposal of purge water Yes No_
j. Monitoring for vapors and radiation Yes No_
2. Is the field crew adequately trained for
sampling? Yes No_
3. 7 Are the records kept during sampling
adequate? Yes No_
4. Are sampling and analysis plan procedures
being followed for:
a. Approaching the well Yes No_
b. Opening the well Yes No.
-------
F-33
Table F-4 (cont.)
c. Measuring the water level Yes No
d. Purging the well Yes No
e. Collecting samples Yes No
f. Preserving samples Yes No
g. Chain-of-custody Yes No
h. Documenting sampling Yes No
i. Shipping samples Yes No
-------
F-34
Table F-5
CONTAINER STORAGE CHECKLIST
(Subpart I)
1. Does the facility store hazardous waste in containers? Yes No_
2. Are the containers marked "Hazardous Waste" or
equivalent to identify the contents? Yes No_
3. Are the containers in good condition (check for leaks,
corrosion, bulges, etc.)? Yes No_
If no, explain in narrative and document with photograph.
4. If a container is found to be leaking, does the operator
transfer the hazardous waste from the leaking
container? Yes No_
5. Is the waste compatible with the containers and/or
its liner? Yes No_
If no, explain in narrative.
6. Are the stored containers closed? Yes No_
If no, explain in narrative.
7. Are containers holding hazardous waste opened,
handled or stored in such a manner as to cause the
container to rupture or leak? Yes No_
8. Does facility conduct weekly inspection records? Yes No_
If no, explain in the narrative the frequency of inspection.
9. Does facility maintain weekly inspection records? Yes No_
10. Are containers holding ignitible or reactive wastes
located at least 15 meters (50 feet) from the facility
property line? Yes No_
If no, explain in narrative and document with photograph.
11. Are incompatible wastes stored in the same
containers? Yes No_
12. Are containers holding incompatible wastes kept
apart by physical barrier or sufficient distance? Yes No_
(03/89)
-------
F-35
Table F-5 (cont.)
If no, explain in narrative and document with photograph(s).
13. Does the facility have satellite storage at the point of
hazardous waste generation §262.34(C)(1)? Yes No
Are containers in the satellite storage area clearly
marked with the date accumulation began? Yes No.
14. Do the containers at any one generation point exceed
55 gallons of hazardous waste or 1 quart of acutely
hazardous wastes? Yes No
15. If yes, in the previous question:
(a) Is the container holding the excess wastes
marked with the date the material began
accumulating? Yes No
(b) Has this waste been accumulating for
more than 3 days? Yes No.
16. Are these points at or near the process generating
the waste? Yes No
-------
F-36
Table F-6
TANKS CHECKLISTS
TANK SYSTEM INSPECTION GUIDANCE
NOTE: List each tank and specify compliance status. [Collective checklist(s)
may be used for all similar tanks in compliance.) This checklist does not apply to
covered underground tanks that cannot be entered for inspection.
Has the facility completed the form, "Notification of Underground Storage
Tanks", as required by 40 CFR Part 280 (FR/vol. 53, no. 185/September 23,
1988, page 37208, 37209, and 37210) including:
I. Ownership of Tank(s)
II. Location of Tank(s)
III. Contact Person at Tank Location
IV. Type of Notification
V. Certification of Description of Tanks
VI. Description of Underground Storage Tanks
(completed for each tank at facility)
VII. Certification of Compliance
(completed for all new tanks at facility)
Yes No
A.3
I. Small Quantity Generators - Compliance with 40CFR § 265.201 and
Parts 280 and 281, as applicable
A.1 A.2
Tank volume (gallons) Tank description
(e.g., aboveground, steel, lined)
Tank location (e.g., inside on cement floor, outside on asphalt pad)
B.1 Material Stored: Be as specific as possible (e.g., 20% Methylene chloride,
30% 1,1,-trichloroethane, 50% mineral spirits)
B.2 Does this tank ever contain waste other than the above? Yes No
If so, list other waste:
EPA Hazardous Waste Number Waste Description
B.3 Are hazardous wastes placed in tanks that are compatible
with the waste so that the tank or inner liner may not
fail prematurely? Yes No_
(03/89)
-------
F-37
Table F-6 (cont.)
C.1 Are wastes being stored in tanks for greater than
180 days? Yes No_
C.2 Is the disposal site greater than 200 miles away? Yes No_
C.3 Are wastes being stored in tanks for greater than
270 days? Yes No_
C.4 SQGs, who store waste greater than 180 days (270
days if shipped over 200 miles) or who exceed the
6,000 kg limit. Has the owner/operator applied for
an operating permit? Yes No_
C.5 Does the owner/operator inspect the tank system routinely for the
following?
Discharge control equipment each operating day Yes No_
Data from monitoring equipment (e.g., gauges) each
operating day Yes No
Level of waste in tank each operating day Yes No
Materials for signs of corrosion weekly Yes No
Area around tank for spills or leaks weekly Yes No
D. Special wastes
D.1 Is the owner/operator storing ignitable or reactive wastes so that it does not
generate heat, fire, violent reactions, gases that are flammable, toxic dusts,
or other means to threaten human health?
yes no NA
D.2 Does the owner/operator follow appropriate procedures for reactive or
ignitable wastes? (See Special Wastes, Checklist VI)
yes no NA
E.1 Is the tank labeled "Hazardous waste"? Yes No_
E.2 Tank condition - Indicate presence of any of the following.
-------
F-38
Table F-6 (cont.)
Discolored paint or rust anywhere on tank system Yes No_
Blister, cracks, bulges, or other signs of potential
failure Yes No
Worn hoses, rips in liners Yes No
E.3 Does the area around the tank show any evidence
of spills (e.g., discoloration, dead vegetation)? Yes No_
E.4 Are uncovered tanks operating with a minimum of
2 feet (60 cm) freeboard or are they equipped with
containment structure? Yes No_
E.5 In tanks with a continuous feed system, is the system
equipped with a cut-off or by-pass system? Yes No_
F. Preparedness and Prevention Plan Compliance
F.1 Is there an emergency/response plan? Yes No_
F.2 Internal communication or alarm system available? Yes No_
F.3 Is telephone or other device capable of summoning
emergency assistance from local police, fire or
other emergency response teams available? . Yes No_
F.4 Are portable fire extinguishers and spill control
equipment available and in operational condition? Yes No_
F.5 Water available to supply water hose streams? Yes No_
II. Documentation of General Inspection Requirements under § 264.195.
265.195 and Parts 280 and 281 as aoolicable
A.1 Inspection plan/procedures adequately thorough
in order to identify problem areas and small leaks Yes No_
A.2 Documented inspection as scheduled in permit ( ) for overfill
controls
yes no NA
-------
F-39
Table F-6 (cont.)
A.2a Interim status and 90-day accumulation tank systems must have the overfill
controls inspected (and documented) each operating day
yes no NA
A.3 Documented daily inspection of aboveground
portions of tank system Yes No_
A.3a Use of inspection devices
yes no Provide name of device used
A.4 Documented daily inspection of monitoring and
leak inspection data Yes No_
A.5 Documented daily inspection of construction mate-
rials of both tank system and secondary contain-
ment, and inspection of tank location and secondary
containment for signs of erosion or releases Yes No_
A.6 Confirmation of proper operation of the cathodic protection system within 6
months of initial installation
yes no date of inspection
A.6a Annual inspection of cathodic protection after installation
yes no NA
A.7 Bimonthly inspection of all sources of impressed current
yes no NA
A.7a Method used to inspect impressed-current system
Existing Tank Systems - Compliance with § 264.191, 265.191 and
Parts 280 and 281, as applicable
A.1
Tank volume (gallons) Tank type (above-, on-, in-, below ground
-------
F-40
Table F-6 (cont.)
B.1 Material Stored: Be as specific as possible (e.g., 20% Methylene chloride,
30% 1,1,-trichloroethane, 50% mineral spirits)
EPA Hazardous Waste Number Waste Description
C. Secondary containment
C.1 Does this tank system have secondary containment? Yes No_
If yes, see Checklist IV, if no continue below
C.2 Has facility been granted a variance from
secondary containment? Yes No_
C.3 Is a written assessment of tank system integrity
on file? Yes No_
C.4 If assessment is provided, has it been reviewed and
certified by a registered, professional engineer? Yes No_
C.5 C.5a Documented Yes No_
Tank Age
C.6 C.6a Documented Yes No_
Facility Age
C.7
Date when secondary containment is required
D. Design Standards
D.1 Thi4ank4s constructed with: [be as specific as possible (e.g., fiberglass-
reinforced plastic, mild steel, nickel based alloy)].
D.2 Document evaluates tank system in accordance with
the most recent applicable design standards Yes No_
D.3 Is tank material generally compatible with waste? Yes No_
-------
F-41
Table F-6 (cont.)
E. Corrosion protection measures (applicable to tank
systems with metal components in contact with soil
or water)
E.1 Document describes existing corrosion protection
measures? Yes No
E.2 Type of system employed (coatings, wraps, electrical isolation devices,
sacrificial-anode, impressed-current)
F. Non-enterable. underground tanks
F. 1 Method of leak testing used
F.1a Verification of annual testing Yes No
F.1 b Tank found to be tight Yes No
F.1c Leak testing device accounts for the following changes:
Temperature Yes No
High water table Yes No_
Tank end deflection Yes No
Vapor pockets Yes No
G. Other tank types
G.1 Method of leak testing used
G.1a Verification of annual testing Yes No
G.1 b Tank found to be tight Yes No
G.2 Internal Inspections
G.2a Certification by registered, professional engineer Yes No_
G.2b Has the engineer checked and documented
inspection of all appropriate factors? Yes No
-------
F-42
Table F-6 (cont.)
H. Tank ancillary equipment
H.1 Feed systems, safety cutoff and/or bypass systems,
pressure controls are described in written
assessment
Yes
H.2 Has ancillary equipment been leak tested or under-
gone other approved integrity assessment annually? Yes.
H.3 Method of leak testing used
H.4 Have any of the leak tested tank system components
been found to be leaking or unfit? Yes
No
No
No
If any of the tanks system components have failed the examinations or leak tests,
Release Response Checklist VI should be included for this tank system.
IV. New Tank Systems - Compliance with § 264.192 and Parts 280 and 281,
as applicable
A.
A.1
A.3
A.5
New Tank Design
A.2
Tank volume (gallons) Tank type (above-, on-, in-, below ground
A.4
Tank Dimensions
Tank shape (spherical, cylindrical, etc.)
The tank is constructed with: [be as specific as possible (e.g., fiberglass-
reinforced plastic, mild steel, nickel-based alloy)]
B. Material Stored: Be as specific as possible (e.g., 20% Methylene chloride,
30% 1,1,-trichloroethane, 50% mineral spirits)
EPA Hazardous Waste Number
Waste Description
C. Tank System Installation
-------
F-43
Table F-6 (cont.)
C.1 Certification of inspection and supervision of instal-
lation and design by independent installation expert
or qualified engineer Yes No
C.2 Did the inspection include the following:
Weld breaks Yes No
Punctures Yes No"
Scrapes on protective coating Yes No"
Cracks Yes No"
Corrosion Yes No"
Other damage or inadequate construction Yes No~
C.3 Has a detailed description of the installation
been provided? Yes No_
C.4 Has the tank passed a test for tightness prior to
being covered or placed in use? Yes No_
C.5 Has the ancillary equipment (e.g., piping) passed a
test for tightness? Yes No_
C.6 Has a detailed description of the tightness testing
been provided? Yes No_
D. Secondary containment - Compliance with § 264.193
D1 Has the facility been granted a variance? Yes No_
If yes, go to Section F. on this checklist
D.2 Is secondary containment for new tanks and
ancillary equipment installed? Yes No_
D.3 Secondary containment is: (circle one) liner,
vault, double-walled component
D.4 Secondary containment materials are
D.5 Type of leak detection equipment employed
D.6 Record of leak detection operation available Yes No_
D.7 Have any leaks from the primary section into
secondary containment been detected? Yes No_
-------
F-44
Table F-6 (cont.)
D.8 Was leaked waste removed from the secondary
containment system within 24 hours? Yes No_
D.9 Was the repair to the primary system documented
prior to returning tank into service? Yes No_
E. Exemption of secondary containment for tank systems or component
§264.193(f)
E.1 Is all aboveground, straight piping that is not covered
by secondary containment inspected daily? Yes No_
E.2 Are all welded flanges, welded joints, and welded
connections inspected for leaks daily? Yes No_
E.3 Are all sealless or magnetic coupling pumps
visually inspected for leaks daily? Yes No_
E.4 Are all pressurized, aboveground piping systems
with automatic shutoff devices visually inspected
for leaks daily? Yes No
F. External Corrosion Protection for metal components or equipment
§264.192
F.1 Has a corrosion potential assessment been pre-
pared by a corrosion expert? Yes No
F.2 Type of corrosion protection installed (coatings, wraps, electrical isolation
devices, sacrificial-anode, impressed-current)
F.3 Has a corrosion expert supervised the installa-
tion of any field fabricated corrosion protection
(e.g., cathodic-protection devices)? Yes No
If any of the tank system components have failed tightness testing or have
resulted mjeaks that had releases outside the secondary containment, Release
Response Checklist VI should be included for this tank system.
V. Jank Systems that Store or Treat Ignitable or Reactive Wastes
Compliance with § 264.198 and Parts 280 and 281, as applicable
-------
F-45
Table F-6 (cont.)
A. Special Requirements for ignitable or reactive wastes
A.1 Has waste been treated, mixed or otherwise ren-
dered nonreactive or not ignitable (except in
emergency conditions) so that the mixture is no
longer ignitable or reactive? Yes No
A.2 Has complete chemical identification of waste
compatability been determined prior to mixing
of wastes? Yes No
A.3 Is the tank protected from conditions that may
cause it to ignite (e.g., use of spark proof tools)
or protected from contact with materials that may
cause it to react? Yes No_
A.4 Is the required National Fire Protection Associa-
tion distance between waste management area
(ignitable wastes) and public ways and adjoining
properties maintained? Yes No_
A.5 Has an appropriate method of tank system decon-
tamination been selected based on the type of
waste residues remaining in a receiving vessel? Yes No_
VI. Release Response - Compliance with § 264.196 and Parts 280 and 281,
as applicable
A.1 Notification of releases to Regional Administrator (from file review)
date: description:
A.1 a Did the 0/0 report to the Regional Administrator within 30 days of each
release with the following information
- likely route of migration of release
- characteristics of surrounding soil
- results of sampling
- proximity to downgradient drinking water, surface water and population
- description of response actions planned or taken
yes no N/A
-------
F-46
Table F-6 (cont.)
A.2 Did the 0/0 immediately remove the tank component from service after
spill/leak?
A.3
A.4
A.5
A.6
yes
no not able to verify
N/A
Was waste removed from leaking component of the tank system and from
secondary containment?
yes no N/A
Were visible releases to the environment contained?
yes no N/A
Has secondary containment, repair, or closure of the tank system been
provided?
yes
no
N/A
Was the repair certified by an independent, qualified, registered, profes-
sional engineer?
yes
no
N/A
Indicate Presence
VII. Visual Tank System Inspection General Operating Requirements
§ 264.194 and Parts 280 and 281, as applicable
A. Aboveground Portions § 264,265.194(a)
A.1 Metal Tanks -
Look for:
Gross leakage
Major corroded areas
Deterioration (e.g, blisters)
Discolored paint
Cracks
(nozzle connections, in welded seams, under rivets)
-------
F-47
Table F-6 (cont.)
Buckles and bulges
Defective manhead gaskets
Corrosion of tank tops or roofs
Corrosion around nozzles and valves
Erosion around foundation, pads and
secondary containment
Cracks in concrete curbing and ringwalls
Rotting of wooden supports
Welds and anchor bolts between tank bottoms
and ringwalls
Deterioration of protective coatings such as
discoloration and film lifting
A.2 Fiberglass-Reinforced Plastic Tanks -
Look for:
Gross leakage
Bending, curving or flexing
Longitudinal cracks in horizontal tanks
Vertical cracks in vertical tanks
A.3 Concrete Tanks - Above Ground Portion?
Look for:
Gross leakage
Cracks
Porous areas permeable to liquid (wet spots)
Deterioration of protective coatings such as
discoloration and film lifting
B. Underground tanks § 264.192 and Parts 280 and 281, as applicable
-------
F-48
Table F-6 (cont.)
B.1 Is the (new) tank protected from vehicular traffic (paving over tanks should
extend at least 1 foot beyond perimeter in all directions)
yes no N/A
B.2 If the backfill is not covered, is it porous and homogenous?
yes no N/A
B.3 Is there water pooling or depressions in thk area of the tank
yes no N/A
C. Spill and Overfill Prevention Measures § 264.194
C.1 Are spill prevention controls (e.g., check valves,
dry disconnect couplings) in use? Yes No_
C.1 a Is there any evidence of spillage from discon-
nect or uncoupling operations? Yes No_
C.2 Are overfill prevention controls (e.g., level sensing
devices, high level alarms) present and operational? Yes No_
C.3 Is sufficient freeboard maintained in uncovered
tanks to prevent overtopping due to wave or wind
action or by precipitation? • Yes No_
C.4 Is there any evidence of overtopping or major
spills? Yes No
D. Inspection of Ancillary Systems § 264.194 and Parts 280 and 281, as
applicable
D.1 Inspect piping for the following: Indicate Presence
Pipe7bends, elbows, tees, and other restrictions
for leaks, external corrosion and rust spots
Deterioration (e.g., blisters) and discolored paint
Orifice plates deteriorated
Throttle valves w/broken stems, missing handles
-------
F-49
Table F-6 (cont.)
Wear and tear in flexible hoses
Traffic passing over hoses
Vibration or swaying of pipe systems while pumping
D.2 Inspect pumps and compressors for the following: Indicate Presence
Foundation cracks
Excessive vibration or cavitation of pumps
Leaky pump seals
Missing anchor bolts
Excessive dirt, burning odors, or smoke
Depleted lubrication oil reservoir in compressor
D.3 Inspect heat exchangers and vapor control systems
for:
Rust spots or blisters
E. Auxiliary systems for permitted tanks § 270.16
Is the following equipment the same as specified on
permit and is it operational?
E.1 Level Sensor
E.2 Alarm System
Indicate Presence
Yes
No
Identification
Identification
E.3 Spill proof couplings, entry points
Identification
E.4 Safety Cutoff or Bypass System
E.5 Pressure controls (vents)
Yes No.
Yes No.
Yes No_
Yes No
F. Secondary Containment § 264.193 and Parts 280 and 281, as applicable
-------
-------
F-50
Table F-6 (cont.)
F.1 Will the secondary containment (liners and vaults)
contain 100% of the design capacity of the largest
tank in its boundary plus a 25-year, 24-hour rainfall? Yes No_
F.2 Is water collected in secondary containment system? Yes No_
F.3 Does any water in secondary containment system
appear discolored or otherwise contaminated or is
there evidence of waste within the containment
system? Yes No_
F.4 Double-walled tanks: §264.193(e)(3) Yes No_
F.4a If metal, is there appropriate corrosion protection for
the outer shell? Yes No_
F.4b Does it have an operational, built-in continuous
leak-detection system? Yes No_
F.5 Vaults: § 264.193(e)(2)
F.5a Does all concrete, including sumps, have liners
or coatings? Yes No_
F.5b Is a vault constructed with chemically resistant
water stops at all joints? Yes No_
F.5c Is there deterioration of protective coatings such
as discoloration and film lifting? Yes No_
F.5d Are there any cracks visable in the concrete? Yes No_
F.6 Liners: § 264.193(e)(1)
F.6a Does the liner cover all the surrounding earth
likely to come into contact with wastes, including
berms and dikes? Yes No_
F.6b If c% liners, do liners show signs of drying and
cracking? Yes No_
F.6c If polymeric liners, do liners show signs of punc-
tures, deterioration due to sunlight, chemical spills,
rips, tears, gaps, or cracks? Yes No_
F.6d If a concrete liner, is there any deterioration of its
protective coating? Yes No
-------
F-51
Table F-6 (cont.)
G. Corrosion Control (metal tank and metal components in, on, or under-
ground)
G.1 Presence of trapped water near tank system (if
underground tank system, is water pooling in area
above tank location?) Yes No_
G.2 The use of dry, crushed rock or gravel as backfill
material Yes No_
G.3 Existence of nearby visible metal structures Yes No_
G.4 Coatings or wraps
G.4a Is the coverage complete? Yes No_
G.4b Has the cover or wrap dried, cracked or dissolved? Yes No_
G.4c Has the coating or wrap been damaged by spills? Yes No_
G.5 Electrical isolation devices
G.5a Are they adequate depending upon the number of
nearby, underground metal structures? Yes No_
G.5b Are the devices damaged in any way? Yes No_
G.6 Sacrificial-anode system
G.6a How long has it been in place? Yes No_
G.6b Have the anodes decreased significantly in size? Yes No_
G.6c Is the sacrificial-anode system damaged? Yes No_
G.7 Impressed-current system
G.7a How long has it been in place? Yes No_
G.7b Have the current requirements changed over time? Yes No_
G.7c Is the impressed-current system damaged? Yes No_
G.7d Is the impressed-current system properly
maintained? Yes No
-------
F-52
Table F-6 (cont.)
VIII. Closure. Post-closure Care - Compliance with
§ 264.197 and Parts 280 and 281, as applicable
A. Tank Systems with Secondary Containment - § 264.1 97(a) (clean closure)
A.1 Visual verification of clean closure
yes no N/A
Indicate if done
Tank system materials removed _
Verification of proper disposal of contaminated equipment _
Contaminated soils and residues disposed or treated properly _
B. Tank systems that cannot be practicably decontaminated - § 264.1 97l(b)
B.1 Has the owner/operator demonstrated satisfactorily that all contaminated
soils cannot be removed? _ _ _
yes no N/A
B.2 Closure of tank site meeting § 264.310 landfill requirements
B.2a Does contaminated area have appropriate final
cover? Yes _ No _
B.2b Is owner/operator maintaining cover integrity? Yes _ No _
B.2c Is 0/0 monitoring ground water according to
Subpart F? Yes _ No _
C. Tank Systems without Secondary Containment - § 264.1 97(c)
C.1 Has 0/0 prepared a closure plan for § 264.1 97(a)
and a contingency plan for § 264.197(b) which
submitted to EPA? Yes _ No
C.2 If the closure plans have not been submitted, are
they on file at the facility? Yes _ No
C.3 Is or has the facility closed this tank system at the
present time? Yes _ No
If yes, evaluate closure with appropriate evaluation in A or B above.
-------
STATE USE ONLY
Date Received
GENERAL INFORMATION
\otification is required by Federal law for ill underground tanks that have been
S* 1° S™" r'*ull"d substances since January 1. 1974. that ire in the pound as of
Mav S, 19g«, or that are brought into use after May 8.1986. The information requested
is required by Section 9002 of the Resource Conservation and Recovery Act.lRCRAl.
as amended.
The pnmar\ purpose of this notification program LS to locate and evaluate under-
ground tanks that store or ha\e stored netrofeum or hazardous substances li is
evwcted .hat the information \ou provide will be hdsed on reasonably available
records or in the absence ol such rctords \our knowledge, belie), or recollection
Who Must Notify? Section 3002 ot RCRA. js amended, requires that, unless
exempted, owners ol underground tanks that store regulated substances must notify
designated State or local agencies ol the existence of their tanks Owner means —
Ul in the case ot an underground storage tank in use on November 8. 1984 or
brought into use after that date, any person who owns an underground storage tank
used lor the storage, use. or dispensing ol regulated substances, and
(u) in the case of anv underground storage tank in use before November 8. 1984.
but no longer in use on that date, anv person who owned such tank immediately before
the discontinuation of us use.
What Tanks Are Included? Underground storage tank is defined as any one or
combination ot tanks that (11 is used to contain an accumulation of "regulated sub-
stances, "and (2) whose volume (including connected underground piping) is \W( or
more beneath the ground Some examples a re underground taru- storing: I. gasoline.
used oil. or diesel fuel, and 1. industrial - ..vents, pesticides, herbicides or fumigants!
Vkhat Tanks Are Excluded? Tanks .•-.^..-d from the ground are not subject to
notification Other tanks excluded from - -'ivauonare:
I. farm or residential tanks of 1.100 gallor ir ;e> own^fjrho km>*in|ly faib to notify or submits false information
stanbesubject to • civil nenalty not to exceed SIO.OM for each tank for which
notification a not 0ven or for which false information • submitted.
aaaiaaaaaai
INSTRUCTION
•^^^^^^^^^^aBB«BBBB«BBBBBJ«J«BBBB«i
Please type or print in ink all items except "signature" in Section V. Thh form mutt by completed for
each location containing underground storage tanks. If more than 5 tanks are owned at this location
photocopy the reverse side, and staple continuation sheets to this form.
Indicate number of
continuation sheets
attached
I OWNERSHIP OF TANK(S)
Owner Name (Corporation. Individual, Public Agency, or Other Entity)
Street Address
County
City
State
ZIP Code
Area Code Phone Number
Type of Owner r4f«r*«//tfwfappfx(2j
G Current Q State or Local Gov't
I~l Former f~l F«d«f»IGoVt
LJ Former l_| (GSA^(jty, D no
D Private or
Corporate
D Ownership
iirtrartam
___
(If same as Section 1 , marH box here CD
Facility Name or Company Site Identifier, as applicable
Street Address or State Road, as applicable
County
City (nearest)
state
ZIP Code
Indicate
number of
tanks at this
location
Mark box here if tank(s)
are located on land within r—i
an Indian reservation or LJ
on other Indian trust lands
Name (If same as Section I, mark box here Q)
III CONTACT PERSON AT TANK LOCATION
Job Title
Area Code
Phone Number
IV TYPE OF NOTIFICATION
LJ Mark box here only if this ts an amended or subsequent notification for this location.
V. CERTIFICATION (Read and sign after completing Section VI.)
W that • have P6^"8"/ examined and am familiar with the information submitted in this and all attached
'mmediately reSP°n8ible f°r °btainin9 *» info™*i0"-' *•"•"•
-------
F-54
Own«r Nam« (from S«ctlon I).
Table 5--n
Location (from Section II).
VI DESCRIPTION OF UNDERGROUND STORAGE TANKS (Comptete ,w ~ch ran* a, «*« focatton I
Tank Identification No. (e.g., A8C-123), or
I Arbitrarily Aligned Sequential Number (e.g., 1,2,3...
1. Status of Tank
Currently in Use
Temooranly Out of Use
Permanently Out of Use
Brought into Use after 5/8/86
2. Estimated Age (Years)
3. Estimated Total Capacity (Gallons)
4. Material of Construction
(Mark one m)
Steel
Concrete
Fiberglass Reinforced Plastic
Unknown
Other, Please Specify
5. Internal Protection
(Mar* all that apply fflj
Cathodic Protection
"n'tenor Lining (e.g., epoxy resins)
None
Unknown
Other, Please Specify
6. External Protection
(Mark all that apply x)
Cathodic Protection
Painted (e.g., asphaltic)
Fiberglass Reinforced Plastic Coated
None
Unknown
Other, Please Specify
7. Piping
(Mark all that apply g )
Bare Steel
Galvanized Steel
Fiberglass Reinforced Plastic
Cathodically Protected
Unknown
Other, Please Specify
8. Substance Currently or Last Stored
In Greatest Quantity by Volume
(Mark all that apply x)
a. Empty
b. Petroleum
Diesel
Kerosene
Gasoline (including alcohol blends)
Used Oil
.4 Other, Please Specify
~ a Hazardous Substance
Please Indicate Name of Principal CERCLA Substance
_ OR
Chemical Abstract Service (CAS) No.
Mark box 3 if tank stores a mixture of substances
d. Unknown
9. Additional Information (tor tanks permanently
taken out of service)
a. Estimated date last used (mo/yr)
b. Estimated quantity of substance remaining (gal.)
c. Mark box a if tank was filled with inert material
(e.g., sand, concrete)
EPA Form 7530-1 (11-85) Reverse
Tank No. Tank No.
Tank No. Tank No.
in
czn
* U.*. G«*ram*m mntMt Ofltati >•••—tM-711
Page 2
-------
Table 5-A
Owner Name 'from See',.or
Location (from Section il)
Page No
VH. CERTIFICATION OF COMPLIANCE (COMPLETE FOR ALL NEW TANKS AT THIS LOCATION)
10 Installation marx ail >Hat acoly)
I—i The mstailer ras teen certified by the tank and piping manufacturers
j—i
i—i The installer "as been certified or licensed by the implementing agency
i—, The installation *as been inspected and certified by a registered professional engineer
I—I The installation has been inspected and approved by the implementing agency
Lj All work listed on the manufacturer's installation checklists has been completed
I—I Another method was used as allowed by the implementing agency Please specify
11 Release Detection (mark all that apply)-
I—I Manual tank gauging.
I—I Tank tightness testing with inventory controls.
i—I Automatic tank gauging.
I—I Vapor monitoring.
I—I Ground-water monitoring.
I—I Interstitial monitoring within a secondary barrier.
I—I Interstitial monitoring within secondary containment.
I—I Automatic line leak detectors.
I—I Line tightness testing.
I—I Another method allowed by the implementing agency. Please specify:
12. Corrosion Protection (if applicable)
I—I As specified for coated steel tanks with cathodic protection.
I—I As specified for coated steel piping with cathodic protection.
I—I Another method allowed by the implementing agency. Please specify:
13. I have financial responsibility in accordance with Subpart I. Please specify:
Method: T '
Insurer:
Policy Number:
14. OATH: I certify that the information concerning installation provided in Item 10 is true to the best of my belief and knowledge.
Installer: __
Name
Date
Position
Company
EPA Form 7530-1 (9-88)
-------
F-56
Table F-7
SURFACE IMPOUNDMENTS CHECKLIST
(Subpart K)
NOTE: List each surface impoundment and specify compliance status.
Complete an individual checklist for each impoundment. [Collective checklist(s)
may be used for all similar impoundments.]
1. Are there any surface impoundments which are not
being used which the facility does not plan to use in
the future? Yes No
If yes, has all hazardous waste and hazardous waste
residue been removed from the impoundment? Yes No_
2. Are impoundments presently used to treat or store
waste? Yes No_
3. Has any new unit, replacement of an existing unit
or lateral expansion of an existing unit that is within
the area identified in the Part A, received waste
beginning 05/08/85? Yes No_
a. If no, go to question 4.
b. If yes,
(1) Did the facility notify the Regional
Administrator (RA) 60 days prior to.
receiving waste? Yes No_
(2) Did the facility file a Part B within
6 months of receipt of such notice? Yes No_
c. Does the impoundment have at least two
liners and a leachate collection system, as
required by 40 CFR 265.271 ? Yes No
^ If no, use narrative explanation to describe alternate system or, if
^ waiver was granted, demonstration to RA (§265.221).
4. Does the impoundment have at least 2 feet (60 cm)
of freeboard? Yes No
If no, what is the freeboard?
(03/89)
-------
F-57
Table F-7 (cont.)
5. Is there evidence of overtopping of the dike? Yes No.
If yes, describe.
6. What type of dike (e.g., earthen, concrete, steel) does the impoundment
have?
a. If the dike is earthen, does it have adequate
protective cover (e.g., grass, shale, rock) to
minimize wind and water erosion? Use
narrative explanation sheet to explain
deficiencies. Yes No
b. Describe dike and its condition.
7. What wastes are treated or stored in the impoundment? Use narrative
explanation sheets.
8. Are hazardous waste chemically treated in the
impoundment? Yes No
a. If yes:
(1 ) Are waste analyses and trial tests
conducted on these wastes? Yes _ No_
(2) Does the owner/operator have written
documented information on similar
treatment of similar wastes under
similar operating conditions? Yes _ No_
b. Is this information retained in the operating
record? . Yes _ No_
9. Do records indicate that freeboard level is inspected
. Yes _ No_
1 0. Do records indicate the impoundment, dike and sur-
rounding vegetation are inspected to detect leaks,
deterioration or failures at least once a week? Yes _ No_
1 1 . Does the facility maintain a record of the closure
plan on site? Yes _ No_
-------
F-58
Table F-7 (cont.)
12. Are ignitabie or reactive wastes placed in the
impoundment? Yes No_
a. If no, proceed to question 13.
b. If yes, are they treated, rendered or mixed
before or immediately after placement in the
impoundment so they no longer meet the
definition of ignitabie or reactive? Yes No_
OR
c. Are the wastes protected from possible
ignition or reaction sources and certified as
such by a qualified chemist? Use narrative
explanation sheet to describe situation. Yes No_
OR
d. Is the impoundment used solely for
emergencies? Yes No_
(1) If yes, has treatment, storage or dis-
posal been conducted on these
wastes? Describe this situation. Yes No
13. Has the facility ever placed incompatible wastes'in
the impoundment? Yes No.
a. If yes, what were the results. Use narrative
explanation sheet. Look for signs of mixing
of incompatible wastes (e.g., fire, toxic mist,
heat generation, bulging containers, etc.)
14. What is the impoundment lined with?
15. Does the impoundment solely neutralize corrosive
waste or waste listed in Subpart I solely because
of corrosivity? Yes No
-------
F-59
T^ble F-8
WASTE F :S CHECKLIST
(.' art L)
NOTE: Waste piles may also be ma,.aged as a landfill.
1. Is the pile containing hazardous waste protected
from wind? Yes No_
2. For offsite facilities, is a representative sample of
waste from each incoming shipment analyzed
before the waste is added to the pile to determine
the compatibility of the wastes? Yes No_
a. For offsite facilities, does the analysis include
a visual comparison of color and texture? Yes No_
3. Is the leachate or runoff from the pile considered a
hazardous waste? Yes No_
a. If yes, is the pile managed with the following?
(1) An impermeable base compatible with
the waste? Yes No_
(2) Runon diversion? Yes No_
(3) Leachate ana runoff collection? Yes No_
OR
b. Is the pile protected from precipitation and
runon by some other means? Yes No_
Describe on narrative explanation sheet.
4. Are liquids or wastes containing free liquids placed
in the pile? Yes No_
5. Are ignitable or reactive wastes placed in the pile? Yes No_
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
pile so it no longer meets the definition of
-^ ig/iitable or reactive? Use narrative sheet
to describe procedure. Yes No_
OR
b. Is the waste protected from sources of igni-
tion or reaction? Yes No_
(03/89)
-------
F-60
Table F-8 (cont.)
(1) If yes, use narrative explanation sheet
to describe separation and confine-
ment procedures.
(2) If no, use narrative explanation sheet
to describe source of ignition or
reaction.
6. Is there evidence of fire, explosion, gaseous
emissions, leaching or other discharge from the
hazardous waste pile? Use narrative explanation
sheet. Yes No_
a. Does the waste pile have a leachate detec-
tion, collection and removal system? Yes No_
b. If no, does the inspection plan include a
schedule of inspection of the devices for
controlling precipitation and runon and
runoff? Yes No_
c. Is the waste pile periodically removed for
inspection of the base? Yes No_
7. Have incompatible wastes ever been placed
together in the waste pile? Yes No
If yes, what was the result?
8. Have there been other wastes previously stored at
the site of the present waste pile? Yes No_
a. Have hazardous wastes been piled in the
same area where incompatible wastes or
materials were previously piled? Yes No_
b. If yes, was the area decontaminated? Use
narrative explanation sheet. Yes No_
9. Is a closure plan available? Yes No
a. Will all waste residues, system components,
subsoils, etc., be decontaminated and/or
removed? Yes No_
b. If the above cannot be decontaminated, will
the facility be closed as a landfill? Yes No_
-------
F-61
Table F-9
LAND TREATMENT CHECKLIST
(Subpart M)
Note: Hazardous waste must not be placed in or on a land treatment facility
unless the waste can be made less hazardous or nonhazardous by degradation,
transformation, or immobilization processes occurring in or on the soil.
1. Is runon diverted away from the land treatment
facility? Describe using narrative explanation
sheet. Yes No
2. Is runoff from the land treatment facility collected? Yes No
3. Is the runoff analyzed to see if it is a hazardous
waste? Yes No_
a. If the runoff is considered hazardous, how is
it handled? Use narrative explanation sheet. Yes No.
b. If it is not a hazardous waste, is it discharged
through a point source to surface waters? Yes No_
If yes, list NPDES Permit No.
4. Is wind dispersal controlled? Yes No
Describe using narrative explanation sheet.
5. What hazardous wastes are treated at the land treatment facility? Use
narrative explanation sheet.
Part 261, Subpart D Listed Wastes Characteristic Wastes
a. For those listed wastes, were analyses
done to determine the concentrations of
those constituents which caused the
waste to be listed? Yes No
If yes, what are these concentrations? Use narrative explanation
sheet.
b. " For those characteristic wastes designated EP toxic because of the
extraction procedure, what are the concentrations of the following?
(03/89)
-------
F-62
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Table F-9 (cont.)
Concentration Waste
Concentration
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4 D
2,4,5-TP Silvex
6. Obtain a copy of the land treatment process and
include it with the report.
7. Are food chain crops grown? Yes No
a. If no, go to question 9.
b. If yes, can the owner/operator demonstrate from field testing that
arsenic, lead, mercury or other toxic waste constituents:
(1) Will not be transferred to the food
portion of the crop or ingested by
food chain animals. Yes No
OR
(2) Will not occur in greater concentrations
in the crops on the facility than in the
same crops on untreated soils in the
same region? Yes No
c. ^ Is the following information used for making the above demonstra-
. tion and is it kept at the facility?
(1) Tests for specific wastes and applica-
tion rates being used at the facility Yes No
(2) Crop characteristics Yes No
(3) Soil characteristics Yes No
-------
F-63
Table F-9 (cont.)
(4) Sample selection criteria Yes No_
(5) Sample size determination Yes No_
(6) Analytical methods used Yes No_
(7) °tgtistical procedures Yes No_
d. Was -gional Administrator notified by
Janua , 1981 that food chain crops had
been o; ~uld be grown at the facility? Yes No_
e. Does the facility treat wastes that contain
cadmium? Yes No_
(1) If no, go to question 9.
(2) If yes, list these wastes. Use narrative
explanation sheet.
(3) Was the pH of the soil and waste mix-
ture 6.5 or greater at the time of each
waste application? Yes No_
If the pH was less than 6.5, did the waste
contain cadmium concentrations of
2 mg/kg (dry weight) or less? Yes No_
(4) Is the annual application rate of cad-
mium less than 0.5 kg/ha (kilograms
per hectare) for the following:
tobacco, leafy vegetables, or root
crops grown for human consumption? Yes No_
For all other food chain crops, is the
annual cadmium application rate:
^ (i) Less than or equal to
^ 2.0 kg/ha (through
June 30, 1984) Yes No_
(ii) Less than or equal to
1.25 kg/ha (July 1,1984
through December 31,
1986) Yes No_
-------
F-64
Table F-9 (cont.)
Less than or equal to
0.5 kg/ha (January 1,
1987 to present) Yes No
Table F-9 (cont.)
8. Does the facility have an unsaturated zone monitor-
ing plan? Yes No_
a. If no, explain circumstances on narrative explanation sheet.
b. If yes, does the plan include:
(1) Soil monitoring Yes No
(2) Soil pore water monitoring (water
above the saturated zone) Yes No_
(3) Sample depths below waste
incorporation Yes No
(4) Number of samples to be taken Yes No_
(5) Frequency and time of sampling Yes No_
(6) Analysis of soil samples Yes No_
9. Does implementation of the plan yield:
a. Background soil-pore liquid quality and
chemical makeup of soil not affected by
treatment zone leakage Yes No_
b. The quality of soil-pore liquid and chemical
makeup of soil below the treatment zone Yes No
10. Have background levels of soil quality been
established? Yes No
11. Is monitoring occurring in the soil-pore zone
immediately below the treatment zone? Yes No
12. Has a sampling and analysis plan been prepared and does it include:
a. Sample collection techniques Yes No_
b. Sample preservation and shipment Yes No_
-------
F-65
Table F-9 (cont.)
c. Analytical procedures Yes No_
d. Chain-of-custody control Yes No_
13. Has a statistically significant change over back-
ground been found in the soil quality? Yes No_
a. If yes, has the RA or State been notified? Yes No_
b. Have operating practices been modified? Yes No_
14. Is the following information (for each hazardous waste) kept at the facility?
a. Application dates Yes No
b. Application rates Yes No
c. Quantities Yes No
d. Waste location Yes No
15. Does the facility have a closure/post-closure plan? Yes No
If yes, where is it kept?
16. Are ignitable or reactive wastes treated at the
facility? (Circle appropriate waste.) Yes No
a. If yes, are the wastes immediately incor-
porated into the soil so that they are no
longer reactive or ignitable? Yes No
b. Describe or attach a copy of treatment.
17. Are incompatible wastes placed in the facility? Yes No
18. If so, are the incompatible wastes placed in
different locations in the facility? Yes No
If no, look for signs of fire, heat generation, toxic mists, etc. (Use narrative
explanation sheet.)
-------
F-66
Table F-10
LANDFILLS CHECKLIST
(Subpart N)
Has any new unit, replacement of an existing unit
or lateral expansion of an existing unit that is within
the area identified in the Part A, received waste
after 05/08/85? Yes No
a. If no, proceed to question 4,
b. If yes,
(1) Did the facility notify the Regional
Administrator 60 days prior to receiving
waste? Yes No_
(2) Did the facility file a Part B within
6 months of receipt of such notice? Yes No_
c. Does the landfill have at least two liners and
a leachate collection system? Yes No
If no, use narrative explanation sheet to describe alternate system,
or, if waiver was granted, to describe demonstration to Regional
Administrator (§265.301).
2. Is there a runon control system? Yes No
Describe on narrative explanation sheet.
3. Is runoff from the landfill collected? Yes No
a. Is runoff analyzed to determine if it is a
hazardous waste? ' Yes No
b. If it is a hazardous waste, how is it managed? (Use narrative
explanation sheet.)
c. Is the collected runoff discharged through a
point source to surface waters? Yes No
If yes, list NPDES permit number
4. Is trre landfill managed so that wind dispersal is
controlled? (Note blowing debris.) Yes No.
5. Is the following information maintained in the
operating record? Yes No
(03/89)
-------
F-67
Table F-10 (cont.)
a. On a map, the exact location and dimensions,
including depth of each cell with respect to
permanently surveyed benchmarks? Yes No
AND
b. Contents of each cell and the approximate
location of each hazardous waste type within
each cell? Yes No
6. Are reactive or ignitable wastes placed in the
landfill? Yes No
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
landfill so they are no longer reactive or
ignitable? Yes No
b. Describe treatment, etc. or attach a copy of treatment.
7. Are incompatible wastes placed in the same landfill
cell? Yes No
If yes, what are the results? Use narrative explanation sheet. (Look for
signs of mixing of incompatible wastes, e.g., fire, toxic mist, heat
generation, etc.)
Describe how it is possible for incompatible wastes to be placed in the
same landfill cell. (Use narrative explanation sheet.)
8. Have bulk or non-containerized, hazardous liquid
wastes or wastes containing free liquids been
placed in the landfill since May 8, 1985? Yes No
9. Is the liquid waste treated chemically or physically
so that free liquids are no longer present? (Use
narrative explanation sheet.) Yes No_
10. Are containers holding liquid wastes placed in the
landfill? Yes No.
If yes,
a. Has all free-standing liquid been removed? Yes No_
OR
-------
F-68
Table F-10 (cont.)
b. Has waste been mixed with absorbent or
solidified so that free-standing liquid is no
longer observed? Yes No_
OR
c. Is the container very small, such as an
ampule? Yes No_
OR
d. Is the container designed to hold free liquids
for use other than storage, such as a battery
or capacitor? Yes No_
OR
e. Is the container a lab pack? Yes No_
11. Are empty containers placed in the landfill? Yes No_
a. If yes, are they reduced in volume (e.g.,
shredded, crushed)? Yes No_
12. Does the landfill or cell(s) have a cover? Yes No_
a. If no, go to question 13.
b. If yes, answer the following:
(1) Is there evidence of site instability
(e.g., erosion, settling)? (Use
narrative explanation sheet.) Yes No_
(2) Is there evidence of ponding of water
onsite? (Use narrative explanation
sheet.) Yes No_
(3) Is there any indication of improper or
inadequate drainage? (Use narrative
explanation sheet.) Yes No_
13. Do«s the.facility have closure/post-closure plans? Yes No_
a. " If yes, where are they maintained?
b. Do the plans address the following items?
(1) Control of pollutant migration? Yes No_
(2) Control of surface water infiltration? Yes No_
(3) Prevention of erosion? Yes No
-------
F-69
Table F-11
INCINERATORS CHECKLIST
(Subpart O)
1. Is the incinerator operating at steady state
conditions (temperature and air flow) before
adding hazardous waste? Yes No_
If no, explain in narrative.
2. Is a waste analysis performed on hazardous waste
not previously incinerated at facility? Yes No_
3. Does it include analysis for the following?
a. Heating value Yes No_
b. Halogen content Yes No_
c. Sulfur content Yes No~
d. Concentration of lead Yes No"
e. Concentration of mercury Yes No_
f. Is the above information documented in the
operating record? Yes No_
(NOTE: d and e are not required if the facility has written documented data
that show the elements are not present.)
4. Are any of the following instruments existing on the incinerator? Does the
owner/operator monitor them at least every 15 minutes when incinerating
hazardous waste? Check under applicable column.
Existing Monitored
Waste feed Yes No Yes No
Auxiliary fuel food Yes No Yes No
Air flow Yes No Yes No
Incinerator temperature Yes No Yes No
Scrubber flow Yes No Yes No
Scrubber pH Yes No Yes No
Relevant level controls Yes No Yes No
(NOTE: Afterburner and temperature, Oz, and CO meters are examples of
relevant level controls.)
a. Does the owner/operator monitor the stack plume (emissions) at
least hourly for:
(1) Color (normal) Yes No
(03/89)
-------
F-70
Table F-11 (cont.)
(2) Opacity Yes No_
b. Does the owner/operator monitor the incir
equipment at least daily including: (circle the
(1 ) Pumps, valves, conveyors, pipes for
leaks, spills and fugitive emissions.
(Use narrative explanation sheet.)
(2) Emergency shutdown controls
(3) System alarms
c. Are these inspections referenced in the
inspection log? Review inspection plan,
note deficiencies in narrative.
5. Is a closure plan maintained for the incinerator?
If yes, is it kept at the facility?
6. What wastes are incinerated onsite?
lerator and associate
ise not in compliance)
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Weight or Volume
EPA Hazardous Waste No. Description Incinerated Daily
-------
F-71
Table F-12
THERMAL TREATMENT CHECKLIST
(Subpart P)
NOTE: Applies to thermal treatment of hazardous waste in devices other than
incinerators.
1. Is the process a non-continuous (batch) process? Yes No.
If no, is the process operating at steady S
temperature) before
adding hazardous waste?
2. Does the operating record document weak
analysis, for all wastes burned?
a. Does it inclur-? analyses for the following
(1) Heat value
(2) Hale content
(3) Sulf :ontent
(4) Cor antration of lead
(5) Concentration of mercury
b. Is this information documented in the
operating record?
(NOTE: 4 and 5 are not required if the facility ha:
that show the elements are not present.)
3. Are the existing instruments which relate to
control monitored at least every 1 5 minutes?
Existing
a. Waste feed Yes No
b. Auxiliary fuel feed Yes No
c. Treatment process temp. Yes No
d. Relevant process flow Yes No
e. . Relevant controls (e.g.,
late conditions (including
Yes No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
s written documented data
combustion and emission
Monitored
Yes No
Yes
Yes
Yes
No
No
No
afterburner and tempera-
ture controls, Oa and CO
meters) Yes No Yes No.
(03/89)
-------
F-72
Table F-12 (cont.)
4. Are stack plume (emissions) monitored at least
hourly? Yes No_
5.
6.
7.
a. Color (normal) Yes
b. Opacity Yes
Is thermal treatment process equipment monitored
at least daily including: (NOTE: circle those not in
compliance). Yes
a. Pumps, valves, conveyors, pipes, etc., (for
leaks, spills and fugitive emissions) Yes
b. Emergency shutdown controls Yes
c. System alarms Yes
Is a closure plan maintained at the facility? Yes
Is open burning or detonation of waste explosives
conducted? Yes
If yes, is the detonation performed in accordance
with the following table? Yes
Pounds of Waste Minimum Distance From Open
Explosives or Burning or Detonation to
Propellants the Property of Others
0-100 204m (670 ft.)
101-1,000 380m (1,250 ft.)
1 ,001 -1 0,000 530m (1 ,730 ft.)
1 0,001-30,000 690m (2,260 ft.)
No
No
No
No
No
No
No
No
No
8. Is there evidence of open burning of
hazardous wastes except for waste explosives? Yes No_
Use-narrative explanations sheet to describe details.
-------
F-73
TableF-13
CHEMICAL, PHYSICAL AND BIOLOGICAL TREATMENT CHECKLIST
(Subpart Q)
NOTE: Applies to treatment in other than tanks, surface impoundments and
land treatment facilities.
1. Describe treatment process (include information on wastes treated).
2. Inspect treatment process and equipment:
Are there any leaks, corrosion or other failures
evident? Yes No
If yes, describe.
3. Is the process a continuous feed system? Yes No_
If yes, is it equipped with a means to stop waste
inflow (e.g., waste feed cutoff system or bypass). Yes No
4. If hazardous waste is to be treated which is substantially different from any
hazardous waste previously treated at the facility or if a substantially
different process than any previously used at the facility is to be used to
chemically treat hazardous wastes, are the following obtained:
a. Waste analyses and trial treatment tests (e.g.,
bench scale)? Yes No
OR
b. Written, documented information on similar
treatment or similar wastes? Yes No.
5. Does the owner/operator inspect the following, where present (indicate
which items are present)?
a. At least daily
Discharge control and safety equip-
ment (e.g., waste feed cutoff, bypass,
drainage or pressure relief systems)? Yes No
(2) Data gathered from monitoring equip-
ment (e.g., pressure and temperature
gauges)? Yes No_
(03/89)
-------
F-74
Table F-13 (cont.)
b. At least weekly
(1) Construction materials of treatment
process or equipment to detect erosion
or obvious signs of leakage? Yes No_
(2) Construction materials of an area
immediately surrounding discharge
confinement structures? Yes No_
6. Does the facility have a closure plan? Yes No_
7. Where is the plan maintained?
8. Are ignitable or reactive wastes placed in the
treatment process (circle appropriate waste). Yes No
If yes, is the waste treated, rendered or mixed before
or immediately after being placed in the treatment
process so it no longer meets the definition of
ignitable or reactive? Describe or attach a copy of
the treatment. Yes No
9. Has the facility treated incompatible wastes? Yes No
If yes, what were the results. Use narrative explanation sheet. Look for
signs of mixing of incompatible wastes (e.g., fire, toxic mist, heat
generation, etc.)
10. If a waste is to be placed in treatment equipment
that previously held an incompatible waste, was
that equipment washed? Yes No
If yes, describe washing procedures. Use narrative explanation sheet.
Describe how it is possible for incompatible wastes to be placed in the
same treating equipment. Use narrative explanation sheet.
-------
F-75
Table F-14
RCRA CHECKLIST FOR RECYCLABLE WASTES
AND WASTES BURNED FOR ENERGY RECOVERY
(40 CFR Part 266)
Name of Facility:
Address:
EPA I.D. Number
Facility Inspection Representative:
Title:
Telephone Number:
SECTION A - RECYCLABLE MATERIALS USED IN A MANNER
CONSTITUTING DISPOSAL
The following questions are to assist in evaluating compliance with
40 CFR Part 266, Subpart C.
1. Is the waste applied to the land? Yes No
If no. the regulations do not apply.
If yes, is it mixed with other substances? Yes No
If it is mixed with other substances, do they react
with waste? Yes No
2. If mixed, is the combined material produced for
public use in a manner which constitutes disposal? Yes No_
If yes, have the recyclable materials undergone a
chemical reaction when producing the product such
that the material is not separable from the product by
physical.means? Yes No_
If yes to both of the above, the material is not regulated.
3. If waste oil or other material is being used for dust
suppression or road treatments, has it been tested
for dioxin? Yes No_
4. Is the waste subject to Subpart D of 40 CFR
Part 268 (Land Disposal Restrictions)? Yes No_
(03/89)
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F-76
TableF-14(cont.)
If yes, does it meet the applicable treatment
standard? Yes No
5. Are the requirements of 40 CFR Part 262 appli-
cable to the transporter of the material? Yes No
6. Are the requirements of 40 CFR Part 263 appli-
cable to the transporter of the material? Yes No
7. Is the use of the recyclable materials such that
the owner/operator is subject to any requirements
of 40 CFR Parts 264/265, Subparts A through
N, Parts 270 and 124? Yes No
SECTION B - ENERGY RECOVERY
These are questions pertaining to facilities that recycle wastes to be
burned for energy recovery (Marketers and Burners) that are regulated by
40 CFR Part 266, Subparts D and E.
NOTE: Regarding generators and waste as fuel standards. Generators of used
oil or hazardous waste are subject to the waste as fuel marketer standards if
they sell waste fuels directly to burners for energy recovery. Generators are
subject to the burner standards if they burn used oil or hazardous waste for
energy recovery.
1. Does the facility receive used oils or hazardous
waste for the purpose of marketing waste as fuel
for energy recovery? Yes No
If yes, complete the marketer checklist of Section B.1.
2. Does the facility burn its waste as fuel for energy
recovery? Yes No
If yes, complete the burner checklist of Section B.2.
SECTIONS. T - MARKETERS/PROCESSORS OF WASTE FUELS
Site Characterization
1. Does the facility accept waste oil? Yes No_
Specify types and source:
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F-77
Table F-14 (cont.)
2. Does the facility blend hazardous waste with
waste oil to be marketed as fuel? Yes No_
3. Does the facility accept hazardous waste fuel
(i.e., used oil previously blended with hazard-
ous waste)? Yes No.
4. Does the facility accept hazardous waste? Yes No_
Specify waste and generator type:
5. Does the facility accept only used oil? Yes No_
6. Does the facility have Interim Status or a
permit (RCRA §3005)? Yes No_
Specify:
7. Does the facility generate hazardous waste? Yes No
If yes, refer to the generator checklist, also.
8. Inspect the following general operating practices:
Storage Treatment Disposal
Drum Settling Landfill
Above-ground tank(s) Heat addition Land
Treatment
Under-ground tank(s) In-Line Filtering Surface
Impoundment
Other Certrifugation
Tank sizes Screen Filtration Other
Dehydration
Emulsion Breaking
'^ Blending
Descriptions and Observations:
9. Specify other material recycled as fuel.
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F-78
Table F-14 (cont.)
10. Has the facility notified the Agency of their
waste fuel activity [§266.34{b), or
§266.43(b)(3)]? Yes No_
If no, explain:
11. Does the facility have manifests for all ship-
ments of hazardous waste and blended
hazardous waste fuel (received or sent)
(§265.70)? Yes No
Review manifests and obtain copies of deficient documents.
12. Does the facility have a copy of the required
notice burners or marketers to whom waste
fuel is marketed [§266.34(e) or §266.43(b)(5)]? Yes No.
13. Does the facility have invoice information for
shipments of used oil claimed to be specifica-
tion used oil fuel [§266.43(b)(6)]7 Yes No_
14. Does the above invoice information for speci-
fication used oil fuel have a cross-reference to
analysis or other information? Yes No_
15. Does the facility analyze for metals and
halogens? • Yes No_
Specify methods:
16. Does the facility have records of analysis or
other information documenting that the used
oil meets the specification? Yes No_
17. Does the facility have the records required
* under §266.34(f) or §266.43(b)(6)? Yes No_
Comments:
NOTE: If a facility markets hazardous waste fuel, the facility is
subject to storage requirements of Parts 262, 264 or 265 and 270,
Subparts A through L Complete the TSDF checklist.
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F-79
Table F-14(cont.)
SECTION B.2 - BURNERS OF USED OIL FUEL AND HAZARDOUS WASTE
Comments:
The following questions pertain to facilities regulated under Part 266 who
burn waste fuel for energy recovery. These do not necessarily apply to
incineration under Subpart O of Part 265.
1. Does the facility burn used oil fuel? Yes No
Specify: Off-specification Specification
2. Does the facility burn hazardous waste fuel? Yes No
If yes, was the facility in existence before
May 26, 1986?* Yes No
3. Does the facility's burning unit(s) classify as
industrial boiler(s) or industrial furnace(s)? Yes No
If no, does the facility have records of analysis
or other information documenting that the used
oil meets the required specifications
[§266.44(b)]? Yes No
4. Has the owner/operator notified EPA of their
waste fuel activity [§266.35(b) or §266.44(b)]? Yes No
5. Does the facility have records of the required
notices sent to the fuel suppliers (marketers)
for hazardous waste fuel or off-specification
used oil [§266.35(d) or §266.44(c)]? Yes No
6. Does the facility have Interim Status or a
permit (§3005)? Yes No
Storage requirements for hazardous waste fuel under Subparts A through L, Parts 262,
264 or 265 and 270 apply to these facilities as of May 29, 1986. Therefore, refer to the
checklist for inspection of TSDF.
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F-80
Table F-14(cont.)
SECTION C - RECYCLABLE MATERIALS USED FOR PRECIOUS METAL
RECOVERY
The following questions are to assist in evaluating compliance with
40 CFR Part 266, Subpart F.
1. Is the recyclable material being kept for speculative
purposes, as defined in Part 261.1 (c)(8)? Yes No
If yes, owner/operator is subject to all applicable provisions of 40 CFR Parts 262
through 265, 270, and 124.
2. Are any of the following metals reclaimed or expected
to be reclaimed from the material: gold, silver,
platinum, paladium, irridium, osmium, rhodium,
ruthenium, or any combination of these? Yes No
If yes, has the person notified EPA pursuant to
section 3010 of RCRA? Yes No_
3. Do storage records show:
a. The volume of materials stored at the begin-
ning of the calendar year? Yes No_
b. The amount of these materials generated or
received during the calendar year? Yes No_
c. The amount of materials remaining at the
end of the calendar year? Yes No_
4. If the wastes are shipped offsite for recycling, are
the shipments accompanied by a hazardous waste
manifest [266.70(b)(2)]? Yes No_
If they are manifested as hazardous wastes, do
lanehban notifications accompany the shipments? Yes No_
Are copies of the manifest and land ban notifica-
cations kept by the generator for at least 3 years? Yes No_
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F-81
Table F-14 (cont.)
SECTION D - SPENT LEAD-ACID BATTERIES BEING RECLAIMED
The following questions are to assist in evaluating compliance with
40 CFR Part 266, Subpart G.
1. Does the facility reclaim lead-acid batteries? Yes No
If yes, the regulations apply.
2. Has the facility complied with the notification
requirements of section 3010 of RCRA? Yes No_
3. Has the facility complied with applicable provisions of Part 264, as
identified in 40 CFR Part 266.80(b)(2)? Yes No
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APPENDIX G
LAND DISPOSAL RESTRICTIONS CHECKLIST
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G-1
Appendix G
LAND DISPOSAL RESTRICTIONS PROGRAM CHECKLIST
Does the facility use one or more of the following methods for disposal of
hazardous waste:
Landfill Yes No
Surface impoundment Yes No
Waste pile Yes No
Injection well* Yes No
Land treatment Yes No
Salt dome Yes No
Salt beds Yes No
Underground mines or caves Yes No
Concrete vaults or bunkers Yes No
Other land disposal including
unlined ditches Yes No
If the answer is yes to one or more of the above, then the facility uses a
method of land disposal regulated by the Land Disposal Restrictions Program.
Proceed with the checklist.
Directions: Review process descriptions and determine what wastes are
handled at the facility. Use Part A of the checklist, Sections I through VI to
determine if the waste stream is restricted under the Land Disposal Restrictions
Program, and if applicable, to determine the effective dates of the restriction.
Proceed to Part B of the checklist to see general requirements applicable to all
facilities. Refer to Part B Section II to determine the other applicable
requirements depending on the operating status (i.e., generator, transporter,
TSD), then refer to the referenced Parts of the checklist [e.g., generator (Part C),
transporter (Part D), etc.].
Refer to 40 CFR Part 148 for specific dates applicable to disposal of restricted wastes in
injection wells.
(03/89)
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G-2
PART A- Determination of Restricted Constituents
Section A-l- Solvent Wastes(268.3Cn (effective November 8,1986, except for
disposal into injection wells, which was effective August 8,1988)
Does the facility generate any of the following F001 through F005
constituents as the result of being used in the process either in pure form or
commercial grade?
F001
Tetrachloroethylene Yes No
Trichloroethylene Yes No
Methylene chloride Yes No
1,1,1-trichloroethane Yes No
Carbon tetrachloride Yes No
F002
Tetrachloroethylene Yes No
Trichloroethylene Yes No
Methylene chloride Yes No
1,1,1-trichloroethane Yes No
Chlorobenzene Yes No
Trichlorofluoromethane Yes No
1,1,2-trichloro-1,2,2-
trifluoroethane Yes No
1,2-dichlorobenzene (same as ortho) Yes No
FOQ3
Xylene Yes No
Acetone Yes No
Ethyl acetate Yes No
Ethyl benzene Yes No
Ethyl ether Yes No
Methyl isobutyl ketone Yes No
n-butyl alcohol Yes No
Cyclohexanone Yes No
Methanor- Yes No
If the F003 waste stream has been
mixed with a non-restricted solid
or nonlisted hazardous waste, does
the resultant mixture exhibit the
ignitability characteristic? Yes No
If the answer is no, then land ban does not apply to this waste stream.
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G-3
F004
Cresols and cresylic acid Yes No
Nitrobenzene Yes No
F005
Toluene Yes No
Methyl ethyl ketone Yes No
Carbon disulfide Yes No
Isobutanol Yes No
Pyridine Yes No
a. If any of the above constituents are used as a solvent (i.e., as a
cleaning agent, wetting agent, paint remover, degreaser, or
dilutant, etc.,), where the substance is not chemically altered, then
the substance when spent, is restricted under the Land Disposal
Restrictions Program. Solvents are restricted both above and
below the treatment standards listed in Table G-1. If the substance
is chemically altered during the process or it has not been used as
a solvent it is not restricted under land ban.
b. If the waste is a mixture of constituents, answer this to determine
whether it is a "solvent mixture" covered under Part 268.30 (a)(3).
1. If the waste stream is mixed and contains two or more of the
F001 through F005 constituents determine the concentra-
tion, before use, of all the constituents in the mixture. If the
waste stream is a mixture containing a total of 10% or more
(by volume) of one or more of the F001, F002, F004 or F005
constituents then it is a restricted waste. For example:
Solvent mixture before use
5% methylene chloride
2% trichloroethylene
25% 1,1,1-trichloroethane
68% mineral spirits
100%
With respect to the F003 solvent wastes, if, before use, the waste stream
is mixed and contains only F003 constituents, it is a restricted waste. For
example:^
33% acetone
16% methanol
51% ethyl ether
100%
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G-4
Table G-1
TREATMENT STANDARDS* FOR F-SOLVENTS AND DIOXINS
IN WASTE EXTRACT
Concentration (in ma/L)
F001-F005 Spent Solvents
Acetone
N-butyl alcohol
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Cresols (and cresylic acid)
Cyclohexanone
1,2-dichlorobezene
Ethyl acetate
Ethyl benzene
Ethyl ether
Isobutanol
Methanol
Methylene chloride
Methyl ethyl ketone
Methyl isobutyl ketone
Nitrobenzene
Pyridine
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1 ,1 ,2-Trichloro-1 ,2,2-trifluoroethane
Trichloroethylene
Trichlorofluoromethane
Xylene
F020-F023 and F026-F028
Dioxin Containing Wastes
HxCDD-all hexachlorodibenzo-p-dioxins
HxCDF-all hexachlorodibenzofurans
PeCDD-all pentachlorodibenzo-p-dioxins
PeCDF-all pentachlorodibenzofurans
TCCD-all tetrachlorodibenzo-p-dioxins
TCDF^all tetrachlorodibenzofurans
2,4,5-trlchlorophenol
2,4,6-trichlorophenol
2,3,4,6-tetrachlorophenol
Pentachlorophenol
Wastewaters
0.05
5.0
1.05
0.05
0.15
2.82
0.125
0.65
0.05
0.05
0.05
5.0
0.25
0.20
0.05
0.05
0.66
1.12
0.079
1.12
1.05
1.05
0.062
0.05
0.05
Other Wastes
0.59
5.0
4.81
0.59
0.05
0.75
0.75
0.125
0.75
0.053
0.75
5.0
0.75
0.96
0.75
0.33
0.125
0.33
0.05
0.33
0.41
0.96
0.091
0.96
0.15
Concentration
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppb
< 1 ppb
< 0.05 ppm
< 0.05 ppm
<0.10 ppm
< 0.01 ppm
Table CCWE from 268.41
(03/89)
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G-5
If the waste stream is a mixture containing F003 constituents and a total
of 10% or more of one or more of the F001, F002, F004 and F005 listed
constituents before use, it is a restricted waste. For example:
50% xylene (F003)
12% TCE (F001)
38% mineral spirits
100%
If (a) or (b) above indicate that the F001 through F005 constituents are
restricted, refer to Part B of this checklist for applicable requirements.
Section A-ll- Dioxin Wastes (268.31^ (effective date November 8,1986)
Does the facility generate wastes with the codes F020 through F023 or
F026 through F028? Yes No
These wastes are restricted and can not be land disposed between
November 1986 and November 1988 unless the disposal facility meets the
requirements of 268.5(h)(2). Refer to 40 CFR Part 268.31 (d) for exemptions,
extensions and variances to this rule.
If the facility generates the above wastes, refer to Part B of this checklist
for applicable requirements.
Section A-lll-California List Wastes /26S.32) (effective July 8,1987)
Does the facility generate any of the following hazardous wastes (the
wastes must be RCRA hazardous wastes as defined in Part 261)?
a. Liquid wastes with a pH less than or equal to 2
b. Liquid wastes containing polychlorinated biphenyls (PCBs) at
concentrations greater than or equal to 50 ppm
c. Liquid wastes that are primarily water and contain halogenated
organic compounds (HOCs) in total concentration greater than or
equal to 1,000 mg/L and less than 10,000 mg/L [See Table G-2]
d. Liquid wastes including free liquids associated with any solid or
j_ sludge, containing free cyanides at concentrations greater than or
*7 equal to 1,000 mg/L
e. Liquid wastes, including free liquids associated with any solid or
sludge, containing the following metals (or elements) or
compounds of these metals (or elements) at concentrations
greater than or equal to those specified
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G-6
Table G-2
list of Halogenaced Organic Compounds
in to Part 2»— Lst of
Haiog0a«t«d Organic Compound*
Regulated Uadar 4 28U3
In determining th« concentration of HCCs
m a hazardous west* for purposes of the
! 206.22 land disposal prohibition. EPA has
defined the- HOC* thai mint be included in
the calculation as any compounds having a
carbon-halogen bond which are listed m this
Appendix (se« I 288.2). Appendix III to Part
-S* consists of the following compounds:
3romodichloramethane
3romomethane
Carbon Tetrachloride
Chlorobenzen*
2-Chloro-l,3-but*diene
Chiorodibromomethane
Chloroethene
2-Chloroethyi vinyl ether
Chloroform
Chloromethane
3-Chioropropene
1.2-Dibromo-3-chloropropane
l.2-Dibroraomethane
Oibramomtthant
Trans-1.4-Dichloro-2-butene
Dichlorodifluoremethane
l.l-Dichloroethane
i.2-Dichloroethane
l.l-Dichloroethylene
Tran»-l.2-Dichioroethene
i.2-0ichloroprapant
Tnn»-l.3-0ichloropropene
c:s-1.3-Dichioropropene
lodomethane
Methylene chloride
l.l.l.2-Tetrachloroethane
1.1.2,2-Tetrachloroethane
Tetrachlorocthene
Trtbromomethane
l.l.l-Tnchioroethene
1.1.2-Trichloreethane
Tnchioroethene
Tnchloromonofluoromethajie
M3-Trichloraprap«n«
Vinyl chlond* 4
Semivo/ati/8*
Bisf2-chloroethoxy)ethane
Bis(2-chioro«thyi!ether
Bn(2-chloroisopropyl) ether
?-Chloroamiine
Chlorobenzilatt
p-Chloro-fn-dioxms
TetracnlcTOdibenzo-p-d;ox;.-:j
TetracJiioroaibenzofuran
13.7.9.Tetracnlorodibenzo-o-
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G-7
1. Arsenic and or compounds (as As) 500 mg/L
2. Cadmium and/or compounds (as Cd) 100 mg/L
3. Chromium (VI) and/or compounds (as Cr VI) 500 mg/L
4. Lead and/or compounds (as Pb) 500 mg/L
5. Mercury and/or compounds (as Hg) 20 mg/L
6. Nickel and/or compounds (as Ni) 134 mg/L
7. Selenium and/or compounds (as Se) 100 mg/L
8. Thallium and/or compounds (as T1) 130 mg/L
f. Nonliquid and liquid hazardous wastes containing HOCs in total
concentrations greater than or equal to 1,000 mg/kg are prohibited
from land disposal on July 8,1989 [refer to 268.32(g)(2) for
exemptions)]
If any of (a) through (f) above constituents are generated at or above (or
less than for pH) the concentrations specified, then the waste stream is
restricted. Refer to Part B of this checklist for applicable requirements.
Section A-IV- First-Third wastes (268.10 and 268.33) (effective date
August 8,1988)
Determine if the facility generates any of the wastes listed in 268.10 (also
listed in Table G-3 ). If the wastes are listed both in Table F-3 and 40 CFR Part
268.33, then applicable treatment standards have been established for the
waste stream.
If the waste stream is listed in Table G-3 but not listed in 268.33 (i.e.,
listed for wastewaters but not for nonwastewaters, or vice versa, or the waste is
not listed at all), then the waste is a "soft hammer" waste.
A soft hammer waste can not be land disposed in a surface
impoundment or landfill unless the unit meets minimum technology
requirements outlined in 268.5(h)(2)* (double liner, leachate detection system,
groundwater monitoring system, etc.), and prior to disposal the generator must
certify to the Administrator that they have investigated the availability of
treatment capacity and have determined that disposal in the landfill or surface
impoundment is the only practical alternative available to the generator (RCRA
Section 3004(g)(6)(a) and 268.8) [Refer to Part C of this checklist for further
information about generator requirements].
Soft hammer wastes are not prohibited from other forms of land disposal
until Ma^-8,1990, when a "hard hammer" falls as stipulated in Section
3004(g)(6Xc) of RCRA. If the Administrator fails to publish treatment standards
for any listed waste by May 8,1990, then the waste is prohibited from land
disposal.
Before November 8,1988, the facMy had to meet minimum technology requirements, but
after November 8,1988 the disposal unit receiving the waste must meet minimum
technology standards.
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G-8
Table G-3
First-Third Listed Wastes
§24*10
g)i
ol
f«r lond
CstejMithment e*
on*
Standards
SOURCE 51 PR 1930S. May 28. 1986. unless
otherwise noted.
§268.10 Identification of wutM to be
evaluated by August 8. 1988.
EPA will take action under sections
3004(gX9) and 3004
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G-9
Table G~3 Cone.
menu, dners. soap*. »nd stabilizer* cow-
•.lining cnronuum and lead.
Kort— Decanter tan* car sludfw from
coking operation*.
K09*— Untreated waatewater from the pro-
duction of 2.4- D.
K101— Distillation tar residua* from the dis-
tillation of aniline-based compound* in
the production of veterinary pharmaceuti-
cal* from arsenic or orono- arsenic com*
pound*.
Kl02-Reatdue from the use of activated
carbon for decolortzatlon in the produc-
tion of veterinary pharmaceutical* from
arsenic or organo-arsenic compound*.
K103— Proce** residue* from aniline extrac-
tion from the production of aniline.
KID*— Combined wastewater stream* gener-
ited from nitrobenzene/ aniline produc-
tion.
K104— Warte water treatment sludffi from
the mercury cell procew in chlorine pro-
duction.
i2«J.JJ(«> Watttt
POOl— Warfarin, when present at eoncentra-
tion greater than 0.3%
P004— AJdrtn
POOS— Ally! alcohol
PO 10— Arsenic acid
PfUl- Arsenic (VI oxide
PO 1 2- Arsenic (III) oxide
P01S— Beryllium dust
P019— BU-(chloromethyl) ether
P018— Brucine
P030— Soluble cyanide salu not eUewhere
specified
P039— Olchloropnenyianine
P037-Dleldnn
P039— Otsulfoton
P041— Olethyl-D-rutrophenyl phosphate
P048— 2.4-Dinitrophenol
P050— GndMUlJut
P05«— Fluoracetie acid, sodium salt
POS»— Heptachlor
P063— Hydrocen cyanide
P06«— Methyl HydraHne
P069— MethytUetonitnie
P070— Aldlcart
POTl-Methyl parathlon
POCl-Nltroclyeerin*
POM-N-Nltro*odtmethylamiae>
P0«4— M-Nltroeomethylvlnylamine
POTT— O«mium tetraoxld*
POtt-Phenytmereurtc acetau
P0»« PHoruo
POVT-Ptmphur
P101-PTop*r»arl alcohol
P10S— Sodium aside
P10»— Strychnine and salu
PUO-Tetrmethyi lead
Pll5-ThalUum (I) sulfate
PJ20— Vanadium pentoxio*
Pin-Zinc pboeohidiv when preaent at coo-
centmioa* neater than 10%
P123— Toxaphene
J 2S1.3VJ)
U007— Aery I amide
UOOt— Acryiomtnle
UOIO— Mltoraydn C
U012-Anlllne
U01S— aenatoaerldin*
U01>— Bens< a>*jnthrmcen«
UOlft- Benzene
UOSa— Benzo* aniyrene
U039-Methyl bromide
U031— a-Butanot
U03«— Chiortane, teenniea*
U037— Chiorobeniene
U041— n-Chloro-2,3-epoxypropan«
0043— Vinyl cnioride
U044— Chloroform
U04«— Chlororaethyt methyl ether
U050— Chrysene
UOSl-Cr«o*ou
UOS3— Crbtonaldehydc
UO«t-DDT
U0«3— Oibens o (a. h) anthracene)
U0«4— 1.2:7.1 Dlbewopyrene
UOfl«-Dtbromo-J-
U 159— Methyl ethyl ketona
UlTt-Nttropropane. 2-
um-N-Nitroec-N-methylurea
UlSO—N-NltroaopyrroUdlne
U 1 85— Pentacftloronl tro benzene
Ul8*-Phenoi
U192— Pronamid*
ITTOO ffeeerplne
UZOtv-Tetracnloroetban*. 1.1.3,2-
U210— Tttraaftloroethylene
U211- Carbon tetneblortd*
U319— Thiouna
U220-Toluene
U231-Toluenediamin»
U233— Toluene dllaocyanau
U23»-»i*taylchlorofonB
U2TT-Trtehlaroethiael 1.1A
U33«—TTlehloroethylen«
U237-Uradl mustard
U23«-Ctnyl carbamat*
U34«— Warfarin, when preeent at concentra-
tion* of 0.3% or les*
C249— Zinc phosphide, when present at con-
centration* o( 10% or tea*
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G-10
Exceptions to the general rules of applicability:
a. For wastes that are both first-third and California list wastes the
following hierarchy applies
1. First-third treatment standards (268.41 and 43), when
effective, supersede the California list prohibitions, because
they are more specific and more stringent.
2. If the first third waste is a "soft hammer" waste and
California list waste it may be subject to the California list
prohibitions and the soft hammer requirements. If treatment
standards are listed in 40 CFR Parts 268.42 [e.g., PCBs
greater than or equal to 50 ppm and HOCs greater than or
equal to 1000 ppm (as of April 1988)],the California list
treatment standards apply, otherwise the soft hammer
prohibitions apply. Whichever is the most stringent applies.
The effect of this distinction is that treatment residues from
the California list treatment (PCBs and HOCs) can be
disposed in non-minimum technology landfills and surface
impoundments. For those without treatment standards in
268.41 or 268.43 the treatment residues must meet the
California list prohibition levels [Section III of this Part] at a
minimum and the soft hammer prohibition [i.e., the
generator must notify that the waste is both first third and
California list waste and certify that the waste meets the
treatment standards for California list, but the treatment
residues still have to go into a facility meeting minimum
technology standards of 268.5(h)(2)].
b. Several treatment residues derived from the treatment of first-third
wastes have been reclassified as third-third wastes and are not
currently regulated under the "soft hammer; refer to 268.12(b) for
these wastes.
c. Some types of surface impoundments and landfills are permitted
to receive soft hammer wastes as described in 268.5(h)(2) or
3004(o)(2), because they have demonstrated equivalency to
minimum technology standards.
If the waste stream generated is restricted as listed in this Section, refer
to Part B j>f this checklist for applicable requirements.
Section A-V- Second-third wastes (268.11^ (proposed effective date June
8,1989)
Refer to 40 CFR Part 268.11 (also Table G-4) for a list of the wastes
proposed to be listed in the second-third restrictions. Further requirements
have not been developed to date.
-------
Table G-4
Second-Third Listed Wastes
G-ll
92M.1I IdMKtflcMiM of *a*te» U» to
evaluate* by JUM 8. 199ft.
EPA will take action under section*
3004 of the Re-
source Conservation and Recovery
Act. by June 8, 1989. for the following
*astes (for ease of understanding the
xastes have been listed by the section
of 40 CFR Part 281 under which they
were listed):
§ 28i.il Wastt*
FO10—Quenching bath sludge from oil
bath* from metal heat treating operation*
where cyanide* are used in the process.
roil—Spent cyanide solution* from salt
oath oot cleaning from metal heat treat-
mi operation*.
FO12—Quenching wastewater treatment
sludge* from metal heat operation* where
cyanide* are used In the process.
F02«— Wait** including but not limited to.
distillation residues; heavy end*, tan and
reactor clean-out waste* from the produc-
tion of chlorinated aliphatic hydrocar-
bon*, having carbon content from one co
five, utilizing free radical catalyzed proc-
ess**. [Thia listing doe* not include light
end*, spent filters and filter aid*, spend
desiccams. wastewater. wastewater treat-
ment sludge*, spent catalyst*, and waste*
listed in I 261.32.1.
§ 291.32 Wastes
K00«— Distillation bottom* from the pro-
duction of acetaldehyde from ethylene.
KOIO— Distillation side cut* from the pro-
duction* of acetaldehyd* from ethylene.
K019— Heavy end* from the distillation of
ethylene dlchlortde In ethylene dlchlortde
production.
K025-DI*tlllatlon bottom* from the pro-
duction of nitrobenzene by the nitration
of benzene.
K027—Centrifuge and distillation residue*
from toluene diiaocyanate production.
K028 Spent catalyst from the hydroehlor-
inator reactor in the production of 1.1.1-
trictiloroethane.
K039—Waste from the product steam strip-
per in the production of 1.1,1-tnchloroeth-
ane.
KOM—Wastewster from the washing and
stripping of phorate production.
K03»-FUtar cake from the filtration of
diethylphoepnoro-dfthio** acid In the pro*
duction of phoratet.
KMO-Wastewater-treatmem sludge from
the production ofphomtti
K 041-Wastewster treatment sludge from
the production of toxaphene.
K042— Heavy end* or distillation residue*
from the distillation of tetrachloroben-
zene in the production of 2.4.5-T.
K04J— 2.9-Dtehiorophenol wane from the
production of 3.4-D.
KW8—Distillation bottom* from the pro-
duction of 1.1.1-trichloroethane.
K0»4—Heavy end* from the heavy end*
column from the production of U.l-trich-
loroethane.
K09T-Vacuum stripper discharge from the
chlordane ehlortnator in the production of
chlordan*.
K0#«—Untreated proce** wastewater from
the production of toxaphene.
KlQft Separated, aqueous stream from the
reactor product washing step in the pro*
duction of chlorooensenea.
pool— i • Acetyl.2-Uuoure»
POOS— Acroletn
POOT— 5-< AminoethyD-3-isoxazolol
POOB— *-Aminopyrtdlne
POM— Thiopftenol
P02S— 1 •< o-Chlorophenyl tthlourem
P027— Propanemtnle. 3s:hloro
P029— Copper cyanide*
P040— O.O-Dletnyl o-pyraanyl pho*phor-
othioate
P043— Dlisopropyl fluorophoephate
P044— Dlmethoate
P040— 2.4-DlthioOiuret
POS4— Aziridlne
POS7— Pluoracetamide
P0«0— Isodrln
PO«J— Hexaethyltetraphoaphate
P0««— Methomyt
POeT-2-Methylaziridine
P073-Alpha.naphthylthiourea (A1TTU)
POT4— Nickel cyanide
P088— Octamethylpyropho*phoramide
P098— Potassium cyanide
PI 04— Silver cyanide
PI 09— Sodium cyanide
P107— Strontium jul/Jde
PH 1— Tetraethylpyrophoaphate
PU 2-Tetramtromethane
PU3— Thaillc oxide
PU4-Thailluni (I) seiemte
U002— Acetone
U003— Acetomtrtle
U005— o- Acety laminofluorene
U00«— Acrylic add
UOU-Amitrole
U014— Auramine
U015— A*a*«nne
U020-aenMn«*ulfonyl chloride
U021-3enadlne
L'n23-Srnzotru niondp
C02S— Dichloro»'(lnl
L'032-Calcuiri riiromate
L'03S-Chloramoucil
L'04"-8f(a-cnioruiiaphthalenv
C'049— 4-Chloro-o-ioluidme. lu arochlondc
COST-Cvclohcxanone
C058--C\ riophospnamidi-
C059— D»unom\ cm
U060-DDO
U062— Diallatp
L'0'0— o-Dichiorobfnzene
COT3 — DicliloroOfnzidene 3.3-
t'080-Mrtri\ irne cniorid*
L'083— Dichloropropane. 1.2-
L'092— Dimfttu lamme
U093— Oim*tn\iaminoa»o benzene
C094— DimftnyiBen»*)amnraoene.7.l2-
L'098— Dimnh>lbenzidine.3.3'-
U097-Dim«hylcarbamoyl chloride
U09«— Dimeth>lhydraane. l.l-
U099— Dimetnylhydrazine. 1.2-
UlOl-Dtmeihylphenol. 2.4-
U108— Oinitrotoluene. 2.9-
U107— Di-n-octyl phthaiate
U109— 1.2. Diphenyihydrazine
UltO— Oipropylamine
U 11 1 — Dt- N- Propylniirosamme
UlM-Ethylenebis-tdithiocarbamicacid)
U116— Ethylene thiourea
U 1 19— Ethyl metnanesulfonate
U 1 27- Hexachioro benzene
U12S— Hexachlorobutadiene
rJ131-Hexachloro*lh*ne
U133-Hydrogen suifide
U138—Methyl iodide
'JUO— Isooutyl ncodol
L.'142 —Keoone
C143—L*>iocaroine
U144—L#sd iceute
L.'H«— Lf\A suoace'.aie
U147 —Maleic ann>dnde
U149— Malononurue
UlSO-Meipnaian
U181—Meth>l isooutyl netone
U18J-Metnyl metnacr>:ne
U183—N-Methsi N-nuro-N-nurosoguinKUne
0'184—Methyltfiiouracit
U1S5—Naphlhalene
Uisa— Napthyiamme 2
UIS9—Nurooenrene
UITO—p-Nuropnenol
U172-N-Nuroso-di-n ou
Ul"3-N-Nitroso-dietnanoiimine
U174—N-Nitroso-dieth\ lamme
U178—N-Nltro*o-N-etn> lurfi
U178—N-Nitroso.N-metn> iurrrnane
U179—N-Niirosopipename
U189—Phosphorus ^ulfide
'U193—1.3-Propsne bulione
U196-Pyndmf
U203-S*frole
U205—Selenium disulfide
U206—Streptozotocm
U208—Terachloro^inanf 1112-
L'213—Ti'trah>drofuran
U214-Thallium > I> scnaie
U21S— Thallium < I > carbonate
U2H—Thallium il> cnionde
U217—Thallium d) nitrstf
U21I—Thioacei amide
U235—Tri* 12.3-Dibromoprop> 11 sno
(03/89)
-------
G-12
Section A-VI- Third-third wastes (268.12^ (proposed effective date May 8,1990)
Refer to 40 CFR Part 268.12 (also Table G-5) for a list of the wastes
proposed to be listed in the third-third. Further requirements have not been
developed to date.
Part B- General Requirements and Operation Status
Section B-l- General Requirements Applicable To All Facilities
If the facility generates any restricted wastes; the treatment residues
derived from the treatment of these wastes are also restricted [see
If the answer to any or all of questions 1 through 6 below is yes, then the
waste is np_t restricted under the land disposal restrictions program, except as
number 4 is applicable.
1. Has the facility been granted a case-by-case extension to the
effective date pursuant to 268.5? _ Yes _ No
2. Has the facility been granted an exemption from a prohibition,
pursuant to a petition under 268.6? _ Yes _ No
3. Has the facility applied for a variance from a treatment standard
under 268.44? _ Yes _ No
4. Are the wastes contaminated soil or debris resulting from a
response action taken under CERCLA Sections 104 or 106, or a
corrective action required under RCRA? _ Yes _ No
If the answer is yes, the following effective dates for prohibitions apply:
Solvent wastes, except soil and debris are prohibited from
land disposal effective November 8,1988
Solvent contaminated soil or debris is prohibited from land
disposal effective November 8,1990. The unit receiving the
waste must meet minimum technology standards in
268.5(h)(2).
Wastes listed in 268.31 and 268.32, where the wastes are
^ contaminated soil or debris are prohibited effective
- November 8,1990 as long as the disposal unit meets the
minimum technology requirements of 268.5(h)(2).
5. Is the facility a small quantity generator of less than 100 kilograms
of non-acute hazardous waste per month or less than one
kilogram of acute hazardous waste per month as defined in
261.5? _ Yes _ No
6. Is the generator a farmer disposing of waste pesticides in
accordance with 262.70? Yes No
-------
Table G-5
Third-Third Listed Wastes
G-13
1 JSi» I-' Identification <>t wa»ie« to b*
evaluated by \U» ». ism
(a)EPA vull take action under sections
3004 and 3004(m> of the Re-
source Conservation and Recovery
Act. by May 8. 1990. for the following
Bastes i for eaae of understanding, the
*asies have been listed by the section
of 40 CFR Part 281 under *hich they
were listed):
$ ?S1 J2 Waste*
K002— Wa.itewtier treatment Ourtge from
the production of chrome scilo* and
orange pigments
K003— Wastewater treatment sludge from
the production of moi>bdate oranite pig-
ments.
KOOS— Wutevtater treatment itudce from
tne production of chrome green pigments.
K006— Wutewater treatment sludge from
the production of chrome oxide green pig-
ments (anhydrous and n yarned)
KOOT— Wastewater treatment Mudge from
the production of iron blue pigments.
KO 23— Distillation iignt ends from tne pro-
duction of phtnalic anhydride from naph-
' halene.
K02S— Stripping still tails from the produc-
tion of methyl ethyl pyndine*.
Kn32~Wastewater treatment sludge from
the production of i-nlordane.
K033— Wastewater and scrub water from
the rhionnation of cyclooemadiene m the
production of rhlordane
K034-Prlter solids from the rtexachlorocy-
eloprntadiene m the production of chior
dine.
K093-Dislillanon lixht ends from the pro-
duction of pmnalic anhydride from ortlio-
K094-0istillation bottoms from tin- pro-
duction o( phtnalic anhydride from ortho-
KlOO-Waste Ifacning solution from »cid
leaching of emission rontrol dust-siudue
from secondary load *n drng.
POOS— Aluminum phosphide
P009— Ammonium picrate
PO 13— Barium cvanide
POlT-Bromoacetonr
P021-C.ilnum rvanide
P'l'JJ t .irUon diMiilidi-
PO'j.t C) i In M i. it i-i:iUlcli*tl«'
HUJ-t- n fhluronniiinrX-^ .
PO^S • a«-n/\l chloride
P033 - Cv anoiii-n ( hloridi-
PU34-4.6-Diniiro-o-rM-loln-N\ i
P018- Qirtml.VMiic
PtH'.'-Epincplirinr
nol
PQ-t8-Alphn.
nnhf
P04T-4 8-Ditiitro-o-rrc.-ifrole
L'091— 3.3 Dinni(!iox\b«inxKiiiif
L'u98-.e
•-eatment standards aooticaoie to
wastes prohibited u,. :• 5 5;5a3»-
263.33 of thj» Part still j;;;y
(d) Hazardous wastes .s:eu .n
{ ^fia.io which are rr.i\eu -..IJ'J^M?,
radjoective was'e*. The 'reaiment
standards applicable to •.»asies
prohibited under 55 268 3O-:sfl 3: ofik 3
part still apply.
(03/89)
-------
G-14
7. Is the facility (generator, TSD, transporter, etc) diluting a restricted
waste or the residual from treatment of a restricted waste as a
substitute for adequate treatment? Yes No
If yes, this is prohibited, refer to 268.3.
8. Is the facility treating a restricted waste in a surface impoundment?
Yes No
If yes, refer to 268.4 to determine if the operation is exempted.
9. If the generator, treatment, storage or disposal facility is managing
a waste covered by site specific variance from a treatment
standard in accordance with 268.44, has the facility complied with
the waste analysis requirements under 268.7?
Yes No
If no, refer to 268.44(k)
Section B-ll- Operation Status
Generators- Refer to Part C for additional requirements
Transporters-Refer to Part D for additional requirements
Treatment, Storage or Disposal facilities- Refer to Part E for additional
requirements
If more than one of the above apply refer to each section as noted.
Part C- Generator Requirements
If the answer to any of the following questions is "no", refer to the
referenced section of the regulations to document nonqompliance.
1 Has the generator tested the waste or an extract developed using
the TCLP method [Appendix I of 268] or used knowledge to
determine if the wastes produced are restricted [268.7(a)]7
Yes No
2 Has each shipment of restricted waste, which does not comply
with applicable treatment standards [268.32 or RCRA 3004(d)J,
been accompanied with a notification [268.7(a)(1)]?
Yes No
3.^7 Does each notification include all of the following items?
a. EPA hazardous waste number Yes No
b. Treatment standards and all applicable prohibitions in
268.32 or RCRA Section 3004(d) Yes No
c. The manifest number associated with the shipment of waste
Yes No
d. Waste analysis data where available Yes No
-------
G-15
4. If the generator has determined that he is managing a restricted
waste, but the waste meets treatment standards and can be land
disposed, is each shipment accompanied with both a notification
(as above) and certification as required in 268.7(a)(2)?
Yes No
5. If the waste is subject to a case-by-case extension (268.5),
exemption (268.6), an extension under 268.1(c)(3), or a nation-
wide variance under Subpart C, has the generator forwarded a
notice with the waste to the TSD receiving the waste as required in
268.7(a)(3)? Yes No
6. If the generator is managing wastes subject to 268.33 (f) but not
268.3, has the generator submitted a notification with each
shipment of waste [268.7(a)(4)]? Yes No
7. If the generator determines that the waste is restricted based
solely on knowledge of the waste, is all of the supporting data
used to make that determination kept onsite in the files (starting
August 8, 1988) [268.7(a)(5)J? Yes No
8. Has the generator retained onsite a copy of all notices,
certifications, determinations, waste analysis data, etc., required
by Part 268, for the last 5 years (starting August 8,1988)
[268.7(a)(6)]? Yes No
9. Has the generator prepared and submitted demonstrations and
certifications required by 268.8 to the Regional Administrator
and/or TSD facility as applicable? Yes No
10. If the generator is storing wastes for the purpose of accumulation,
does the storage comply with the requirements in 262.34 (Storage
< 90 days) [268.50(a)(1)]? Yes No
Part D Transporter Requirements
Has the transporter stored manifested shipments of restricted wastes for
more than 10 days? Yes No
If yes, refer to 268.50(a)(3).
Part E Treatment, Storage and Disposal Facilities
Section Erl General Requirements Applicable to all Treatment. Storage and
Disposal Facilities
If the answer to any of the following questions is "no" refer to the
referenced section of the regulations to document noncompliance.
-------
G-16
1. Before a facility treats, stores or disposes of a hazardous waste
have they obtained a detailed chemical and physical analysis
which contains all of the information necessary to treat, store or
dispose of the waste in accordance with Part 268, as required in
264.13(a)(1) or 265.13(3)0)? Yes_ No
2. Has the waste analysis plan been updated with the methods
which will be used to meet the additional requirements for specific
waste management methods specified in 268.7 [264.13(b)(6) or
265.13(b)(6)]? Yes No
3. Does the waste analysis plan include the procedures and
schedule required in 264.13(b)(7) or 265.13(b)(7) for surface
impoundments exempted from land disposal restrictions
(treatment impoundments) under 268.4(a)? Yes No
4. Do hazardous waste treatment, storage or disposal facilities store
wastes in tanks or containers for the purpose of accumulation to
facilitate proper recovery, treatment or disposal?
a. If so, is each container marked to identify the contents and
the date each period of accumulation begins [268.50
(a)(2)(i)] Yes No
b. If so, is each tank clearly marked with a description of the
contents, the quantity of each hazardous waste received
and the date each period of accumulation begins (or the
required information can be in the operating record)
285.50(a)(2)(ii)?
Yes No
5. Does the facility have copies of the notice and/or certification
required by generators and treatment facilities for each restricted
waste received [268.7(c) and 264.73(b)(11-16) or 265.73(b)(9-
14)]? Yes No
6. Has the facility stored restricted wastes onsite for in excess of one
year? Yes No
Refer to 268.50(d-f) for exemptions to storage requirements for restricted
wastes.
Section E-TTTreatment Facility Specific Requirements
If the answer to any of the following questions is "no" refer to the
referenced section of the regulations to document noncompliance.
1. Has the treatment facility tested their wastes according to the
frequency in the waste analysis plan required by 264.13 or 265.13
[268.7(b)]7 Yes No
-------
G-17
2. For wastes with treatment standards expressed as concentrations
in the waste extract (268.41), has the treatment facility tested
treatment residues or an extract of the residues (using the TCLP
method in 268 Appendix I) to assure that the residues meet
applicable treatment standards [268.7(b)(1)]? Yes No
3. For wastes prohibited under 268.32 or RCRA 3004(d) but without
treatment standards, has the treatment facility tested the treatment
residues according to generator testing requirements specified in
268.32 [268.7(b)(2)J? Yes No
4. For wastes with treatment standards expressed as concentrations
in the waste (268.43), has the facility tested the treatment residues
to assure that the residues meet applicable treatment standards
[268.7(b)(3)]7 Yes No
5. Has a notification complying with the requirements of 268.7(b)(4)
been sent with each waste shipment to the land disposal facility?
Yes No
6. Has a certification complying with the requirements of 268.7(b)(5)
been sent with each shipment of waste or treatment residue of a
restricted waste to the land disposal facility when the waste or
treatment residue has been treated in compliance with applicable
treatment standards? Yes No
7. If the waste or treatment residues do not comply with applicable
treatment standards or prohibitions, has the treatment facility sent
applicable notice and/or certification with the wastes which are to
be stored or treated at a different facility as required in 268.7(b)(6
and 7)? Yes No
8. If the wastes are recyclable materials used in a manner
constituting disposal subject to provisions of 266.20(b), has the
owner/operator submitted with each shipment a notification and
certification in accordance with 268.7(b)(8)? Yes No
9 Has the treatment, recovery or storage facility kept copies of the
generator demonstrations (if applicable) and certification in the
operating record [268.8(c)]? Yes No
10. Has the treatment or recovery facility certified that wastes have
been treated in accordance with the generators demonstration
^ [268.8)(c)(1)]7
Yes No
11. Has the treatment, recovery, or storage facility sent a copy of the
generators demonstration (if applicable) and certification under
268.8(a)(2) and certification under 268.8(c)(1) (if applicable) to the
facility receiving the waste or treatment residues [268.8(c)(2)]?
Yes No
-------
G-18
Section E-lll Disposal Facility Specific Requirements
If the answer to any of the following questions is "no" refer to the
referenced section of the regulations to document noncompliance.
1. Does the facility have a record of the quantities (and date of
placement) for the wastes disposed as required in 264.73(b)(10)
or 265.73(b)(8)? Yes No
2. Has the disposal facility tested the waste or extract of the waste
according to the requirements in 268.7(c) to assure that the wastes
or treatment residues are in compliance with applicable treatment
standards in 268 Subpart D, 268.32 or RCRA Section 3004(d)?
Yes No
3. Has the disposal facility tested incoming restricted wastes at the
frequency specified in the waste analysis plan required by 264.13
or 265.13 [268.7(c)(2)J? Yes No
4. Does the land disposal unit meet the requirements of 268.5(h)(2),
if it is a surface impoundment or landfill? Yes No
5. Has the facility complied with the certification requirements for
wastes specified in 268.7(c)(3) and 268.8(d)? Yes No
-------
APPENDIX H
CERCLA CHECKLIST
-------
H-1
Appendix H
CERCLA CHECKLIST
1. Notification
a. Has the facility notified the proper regula-
tory authorities concerning sites of past
hazardous substance releases and former
hazardous substance storage, treatment
and disposal areas [CERCLA 103(a) and
(c)]? Yes No_
b. What sites have been listed in any notification?
2. Unreported Sites
a. Are there indications of other sites at the
facility which may be appropriate for notifi-
cation (from records review, interviews,
evidence of spills, aerial photographs, etc.)? Yes No
b. List any potentially contaminated sites which have not been
reported.
3. CERCLA Response Actions
a. (1) Has the preliminary assessment
(40 CFR 300.64) been completed? Yes No.
<2) Was the preliminary assessment
adequate? Yes No_
(03/89)
-------
H-2
Appendix H (cont.)
(3) Findings and status:
0)
(2)
(3)
(1)
(2)
(3)
^ (1)
Were immediate removals (40 CFR
300.65) conducted at any of the sites?
Was the removal adequate (verifica-
tion data)?
Findings and status:
Has there been a site evaluation phase
and National Priorities List (NPL) deter-
mination to assist with any planned
removals and/or remedial actions
(40 CFR 300.66)?
Was this evaluation and determination
adequate?
Status:
Yes
Yes
No_
No
Has a Hazardous Ranking System (HRS)
score been determined for these sites
[40 CFR 300.66(b)]? Yes_
(2) Was this ranking adequate?
Yes
No_
No
-------
H-3
Appendix H (cont.)
(3) Status:
e. (1) Was a planned removal or remedial
action (40 CFR 300.67 and 68) taken? Yes No_
(2) Was this planned removal or remedial
action successful? Yes No_
(3) Status:
4. Comments:
-------
APPENDIX I
TSCA FORMS
-------
-------
Appendix I
CONFIDENTIALITY NOTES AND DISCUSSIONS
The TSCA Notice of Inspection [Figure 1-1] and Inspection Confidentiality
Notice [Figure I-2] are presented to the facility owner or agent in charge during
the opening conference. These notices inform facility officials of their right to
claim as contidential business information any information (documents, physical
samples or other material) collected by the inspector.
Authority to Make Confidentiality Claims
The inspector must ascertain whether the facility official, to whom the
notices were given, has the authority to make business confidentiality claims for
the company. The facility official's signature must be obtained at the
appropriate places on the notices certifying that he does or does not have such
authority.
The facility owner is assumed to always have the authority to make
business confidentiality claims. In most cases, it is expected that
the agent in charge will also have such authority. It is possible that
the officials will want to consult with their attorneys (or superiors in
the case of agents in charge) regarding this issue.
If no one at the site has the authority to make business
confidentiality claims, a copy of the TSCA Inspection
Confidentiality Notice and Notice and Declaration of Confidential
Business Information form [Figure 1-3] are to be sent to the chief
executive officer of the firm within 2 days of the inspection. He will
then have 7 calendar days in which to make confidentiality claims.
The facility official may designate a company official, in addition to
the chief executive officer, who should also receive a copy of the
notices and any accompanying forms.
(03/89)
-------
vvEPA
TOXIC SUBSTANCES CONTROL ACT
MOTICE OF INSPECTION
_Y SSQ \0,
3 - i R M \ A V E
5 ?iPV1AD2RESS
REASON FOR INSPECTION
Under the authority of Section 11 of the Tox.c Substances Control Act.
For the purpose of inspecting (including taking samples, photographs, statements, and other inspection act.vit as1 a,- estao ;-,
ment, facility, or other premises in wrrcn chemical substances or mixtures or articles containing same are manufacture 3roc
essed or stored, or held before or after their distribution m commerce (including records, files, papers, orocesses, contro s, a~c
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same n connect or
with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on whether -.:*,-
requirements of the Act applicable to the chemical substances, mixtures, or articles within or associated with such orerp'ses or
conveyance have been complied with.
In addition, this inspection extends to ICheck appropriate blocks}:
C A. Financial data CD D. Personnel data
D 8. Sales data O E. Research data
CH C. Pricing data
The nature and extent of inspection of such data specified in A through E above is as follows;
NSPECTOR SIGNATURE
RECIPIENT SIGNATURE
NAME
NAME
DATE SIGNED'
fltLE
DATE SIGNED
EPA Form 7740-3 (12-821
INSPECTION FILE
-------
FIGURE 1-2
»EPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
TSCA INSPECTION CONFIDENTIALITY NOTICE
OMB Vo 2070 y
E,p,res 3 3! 38
1 INVESTIGATION IDENTIFICATION
DATE
INSPECTOR NO.
DAILY SEQ. NO.
2. FIRM NAME
3. INSPECTOR NAME
4. FIRM ADDRESS
5. INSPECTOR ADDRESS
6. CHIEF EXECUTIVE OFFICER NAME
7. TITLE
TO ASSERT A CONFIDENTIAL BUSINESS INFORMATION CLAIM
It is possible that EPA will receive public requests for release of the
information obtained during inspection of the facility above. Such
requests will be handled by EPA in accordance with provisions of the
Freedom of Information Act (FOIA), 5 (JSC 552; EPA regulations
issued thereunder, 40 CFR Part 2; and the Toxic Substances Control
Act (TSCA), Section 14. EPA is required to make inspection data
available in response to FOIA requests unless the Administrator of the
Agency determines that the data contain information entitled to confi-
dential treatment or may be withheld from release under other excep-
tions of FOIA.
Any or all the information collected by EPA during the inspection may
be claimed confidential if it relates to trade secrets or commercial or
financial matters that you consider to be confidential business infor-
mation. If you assert a CBI claim, EPA will disclose the information
only to the extent, and by means of the procedures set forth in the
regulations (cited above) governing EPA's treatment of confidential
business information. Among other things, the regulations require that
EPA notify you in advance of publicly disclosing any information
you have claimed as confidential business information.
A confidential business information (CBI) claim may be asserted at any
time. You may assert a CBI claim prior to, during, or after the infor-
mation is collected. The declaration form was developed by the Agency
to assist you in asserting a CBI claim. If it is more convenient for you to
assert a CBI claim on your own stationery or by marking the individual
documents or samples "TSCA confidential busines* information," it is
not necessary for you to use this form. The inspector will be glad to
answer any questions you may have regarding the Agency's CBI
procedures.
While you may claim any collected information or sample as confiden-
tial business information, such claims are unlikely to be upheld if they
are challenged unless the information meets the following criteria:
1. Your company has taken measures to protect the confi-
dentiality of the infowiation, and it intends to continue
to take such measures.
2. The information is not, and has not been, reasonably obtainable
without your company's consent by other persons (other than
governmental bodies) by use of legitimate means (other than
discovery based on showing of special need in a judicial or
quasi-judicial proceeding).
3. The information is not publicly available elsewhere.
4. Disclosure of the information would cause substantial
harm to your company's competitive position.
At the completion of the inspection, you will be given a receipt for all
documents, samples, and other materials collected. At that time, you
may make claims that some or all of the information is confidential
business information.
If you are not authorized by your company to assert a CBI claim, this
notice will be sent by certified mail, along with the receipt for docu-
ments, samples, and other materials to the Chief Executive Officer of
your firm within 2 days of this date. The Chief Executive Officer must
return a statement specifying any information which should receive
confidential treatment.
The statement from the Chief Executive Officer should be addressed
to:
and mailed by registered, return-receipt requested mail within 7 calen-
dar days of receipt of this Notice. Claims may be made any time
after the inspection, but inspection data will not be entered into the
special security system for TSCA confidential business information
until an official confidentiality claim is made. The data will be handled
under the agency's routine security system unless and until a claim is
made.
TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE:
I have received and read the notice
If there is no one on the premises of the facility who is authorized to make
business confidentiality claims for the firm, a copy of this Notice and other
inspection materials will be sent to the company's chief executive officer. If
there it another company official who should also receive this information,
please designate below.
SIGNATURE
NAME
NAME
TITLE
TITLE
DATE SIGNED
ADDRESS
EPA Form 7740-4 (12-82)
-------
1-4
FIGURE 1-3
US ENVIRONMENTALVROTECtlON AGENCY
^•^ ^H*ffM\Jl WASHINGTON, DC 20460 Fora- Accn,»a
^"^•""HtX TOXIC SUBSTANCES CONTROL ACT E^fr^i ' -'' 5: •'"'"'
* m DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
1. INVESTIGATION IDENTIFICATION
DATE
INSPECTOR NO.
3. INSPECTOR ADDRESS
DAILY SEQ. NO.
2. FIRM NAME
4. FIRM ADDRESS
INFORMATION DESIGNATED AS CONFIDENTIAL BUSINESS INFORMATION
NO.
DESCRIPTION
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above is designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the infor-
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intends to
continue to take such measures; (2) The information is not, and has not been reasonably anainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would cause substantial
harm to the company's competitive position.
INSPECTOR SIGNATURE
NAME
TITLE
PPA F~ 77—L1 <17-0'>1
DATE SIGNED
CLAIMANT SIGNATURE
NAME
TITLE DATE SIGNED
i--
-------
&EPA
TOXIC SUBSTANCES CONTROL ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
INVEST1 3
N IDENTIFICATION
DATE
MO
'DAILY SEQ NO
2. FIRM NAME
ADDRESS
4 FIRM ADDRESS
Nl-ORMATION DESIGNATED AS CONF'DENTIAL BUSINESS INFORMATION
DESCRIPTION
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledges that the information described above is designated as Confidential Business Information under Section 14(c) of the
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unless the mfor
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intends to
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by other
persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would cause substantial
harm to the company's competitive position.
MSPECTOR SIGNATURE
CLAIMANT SIGNATURE
AME
NAME
DATE SIGNED
TITLE
DATE SIGNED
EPA Form 7740-2 (12-82)
I-'C ~/»Tin»> "'I E
-------
* • ^_S^J^\ ° - ' -^ . - _. ^,
fc?*W •* «^^^V TOXIC SUBSTANCES CONTROL ACT - "._ _ "
^^••l * % TSCA INSPECTION CONFIDENTIALITY NOTICE
i .\.EJ- ;-7 ;,\ IDE>JTI::ICA"ION
DA~H ' \5F = :*-iR \0 'DAILY SEQ. NO
1
3 '\SPEC c OR \A\1c
5 INSPECTOR ADDRESS
4 FIRM ADDRESS ~~1
6. CHIEF EXECUTIVE OFFICER NAM?
1 TITLE
TO ASSERT A CONFIDENTIAL BUSINESS INFORMATION CLAIM
It is possible that EPA will receive public requests for release of the
irformatipn obtained during inspection of the facility above. Such
requests will be handled by EPA in accordance with provisions of the
Freedom of Information Act (FOIA), 5 USC 552, EPA regulations
issued thereunder, 40 CFR Part 2; and the Toxic Substances Control
Act (TSCA), Section 14. EPA is required to make inspection data
available in response to FOIA requests unless the Administrator of the
Agency determines that the data contain information entitled to confi-
dential treatment or may be withheld from release under other excep-
tions of FOIA.
Any or all the information collected by EPA during the inspection may
be claimed confidential if it relates to trade secrets or commercial or
financial matters that you consider to be confidential business infor-
mation. If you assert a CBI claim, EPA will disclose the information
only to the extent, and by means of tha procedures set forth in the
regulations (cited above) governing EPA's treatment of confidential
business information. Among other things, the regulations require that
EPA notify you in advance of publicly disclosing any information
you have claimed as confidential business, information.
A confidential business information (CBI) claim may be asserted at any
tine. You may assert a CBI claim prior to, during, or after the infor-
mation is collected. The declaration form was developed by the Agency
to assist you in asserting a CBI claim. If it is more convenient for you to
assert a CBI claim on your own stationery or by marking the individual
documents or samples "TSCA confidential business information," it is
not necessary for you to use this form. The inspector will be glad to
anwer any questions you may have regarding the Agency's CBI
procedures.
While you may claim any collected information or sample as confiden-
tial business information, such claims are unlikely to be upheld if they
are challenged unless the information meets tha following criteria:
1. Your company has taken measures to protect the confi-
dentiality of the information, and it intends to continue
to take such measuretr-
2.
3.
4.
The information is not, and has not been, reasonably octamab e
without your company's consent Dy other persons
governmental bodies) by use of legitimate -neaps
discovery based on showing of special need m a
quasi-judicial proceeding).
otrer '-an
ot~er '"an
juQiC a' or
The information is not publicly available elsewhere.
Disclosure of the information would cause substantial
harm to your company's competitive position.
At the completion of the inspection, you will be given a receipt for ail
documents, samples, and other materials collected. At that time, you
may make claims that some or all of the information is confidential
business information.
If you are not authorized by your company to assert a CBI claim, this
notice will be sent by certified mail, along with the receipt for docu-
ments, samples, and other materials to the Chief Executive Officer of
your firm within 2 days of this date. The Chief Executive Officer must
return a statement specifying any information which should receive
confidential treatment.
The statement from the Chief Executive Officer should be addressed
to:
and mailed by registered, return-receipt requested mail within 7 calen-
dar days of receipt of this Notice. Claims may be made any time
after the inspection, but inspection data will not be entered into the
special security system for TSCA confidential business information
until an official confidentiality claim is made. The data will be handled
under the agency's routine security system unless and until a claim is
mad*.
TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE
I have received and read the notice
If there is no one on the premises of the facility who is authorized to make
busmen confidentiality claims for the firm, a copy of this Notice and other
inspection materials will be sent to the company's chief executive officer. If
there is another company official who should also receive this information,
please designate below.
SIGNATURE
NAME
NAME
TITLE
TITLE
DATE SIGNED
ADDRESS
EPA Form 7740-4 (12-82)
INSPECTION FILE
-------
1-6
Appendix I (cont.)
Four copies are made of the Declaration of Confidential Information form and
distributed to:
Facility owner or agent in charge
Other company official (if designated)
Document Control Officer
Inspection report
-------
Appendix I (cont.)
Confidentiality Discussion
Officials should be informed of the procedures and requirements that
EPA must follow in handling TSCA confidential business information. The
inspector should explain that these procedures were established to protect the
companies subject to TSCA and cover the following points during the
discussion.
Data may be claimed confidential business information during the
closing conference if a person authorized to make such claims is
onsite at the facility.
• It is suggested that a company official accompany the inspector
during the inspection to facilitate designation (or avoidance, if
possible) of confidential business data.
A detailed receipt for all documents, photographs, physical
samples, and other materials [Figure 1-4] collected during the
inspection will be issued at the closing conference.
An authorized person may make immediate declarations that
some or all of the information is confidential business information.
This is done by completing the Declaration of Confidential
Business Information form. Each item claimed must meet all four
of the criteria shown on the TSCA Inspection Confidentiality
Notice.
• - If no authorized person is available onsite, a copy of the notices,
along with the Receipt for Samples and Documents, will be sent
by certified, return-receipt-requested mail to the Chief Executive
Officer of the firm and to another company official, if one has been
designated.
-------
FIGURE 1-4
r-7
vvEPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
TOXIC SUBSTANCES CONTROL ACT
RECEIPT FOR SAMPLES AND DOCUMENTS
IDATE
_1. INVESTIGATION IDENTIFICATION
INSPECTOR NO.
371
RECTOR ADDRE
DAILY SEQ. NO.
2. FIRM NAME
Form Approved
CMS No 2070-CC07
Approval expires 3-3i -33
lADOflESS
The documents and samples of chemical substances and/or mixtures described below were collected in connection with the
administration and enforcement of the Toxic Substances Control Act.
NO.
RECEIPT OF THE DOCUMENT(S) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
DESCRIPTION
OPTIONAL:
DUPLICATE OR SPLIT SAMPLES: REQUESTED AND PROVIDED CH NOT REQUESTED D
INSPECTOR SIGNATURE
NAME
RECIPIENT SIGNATURE
NAME
DATE SIGNED"
DATE SIGNED
EPA Form 7740-1 (12-82)
INSPECTOR'S RLE
-------
APPENDIX J
TSCA PCB CHECKLIST
-------
•J '
-------
--f
Appendix J
PCB COMPLIANCE INSPECTION REPORT
(40 CFR PART 761)
A. FACILITY SUMMARY
Name and address of facility (include county, state and zip code)
(Responsible Official)
(Facility Representative)
(Title)
(Title)
(Phone)
(Phone)
Type of facility (utility, salvage yard, etc.)
B. INSPECTION/REVIEW
Inspected by:
Reviewed by:
COMMENTS:
(Signature)
(Signature)
(Agency and Date)
(Agency and Date)
(06/87)
-------
X-N
Appendix J (cont.)
'NVETORY
I. As of July 2, 1978, did facility contain in-service, stored for future
use, or disposal:
a. 50 or more large high- or
low-voltage PCB
capacitors? Yes No N/A C/A_
b. One or more PCB
transformers? Yes No N/A C/A_
c. 45 kgs (99.4 Ibs.) or more
PCB chemicals, substances
or mixtures? Yes No N/A C/A.
2. Disposition of PCB items at time of inspection:
Identify source of the above information (company records,
manufacturer's labels, etc.)
N/A • Not appicable
C/ A • Comments attached
-------
Appendix J (cent.)
If any PCB items are not properly marked, describe deficiencies
below. Description must include information on amount of PCBs
involved.
3. If company has PCB-contaminated transformers, explain how
company determined the transformers contained 50 to 500 ppm
PCB.
4. Does the facility have any other
PCB items (electromagnets,
hydraulic systems, etc.)? Yes No N/A C/A
If yes, list number and type of item; whether it is in-service, storage
or sent to disposal; and if it is properly marked.
5. a. Were there observations of
leaks or spills or any sign of
improper disposal of PCB
substances or mixtures. Yes No N/A C/A
b. If yes, document, sample and describe below. Description
must include information on amount of PCBs involved.
6. a. Was there any indication
that waterways in the vicinity
have been contaminated by
spills, leaks or improper
disposal? Yes No N/A C/A
-------
Appendix J (cont.)
b. If yes, document, sample and describe below. Descrioticn
must include information on the amount of PCBs involved
and the name of the waterway.
7. a. Were samples collected for
analysis of PCB residual
concentration? Yes No N/A C/A.
b. If yes, describe below.
D. STORAGE AND HANDLING
1. Location:
a. Does the facility have its
own storage site for PCBs? Yes No N/A C/A
b. If the storage site is not within the boundary of the facility,
give the site's name and address.
2. Does storage site meet physical
requirements [761.42(a) - Physical
Requirements] Yes No N/A C/A
a. Provide protection from
rainfall? Yes No N/A C/A
b. Meet floor requirements
with 6-inch continuous
curbing? Yes No N/A C/A_
c. Meet containment volume
requirements? Yes No N/A C/A_
-------
Appendix J (cont.)
(1) What is total containment volume of storage site?
(Length x Width x Height)
(2) What is the internal volume of the largest PCB article
or container stored within the storage site?
(3) What is the total internal volume of all PCB articles
and containers within the storage site?
Is item 1 greater than
two times item 2?
Yes No N/A C/A
or '
25% of item 2.7 Yes No N/A C/A.
d. (1) Is the area within the
curbed area void of
drains, valves, expan-
sion joints or other
openings? Yes No N/A C/A
(2) If no, document location of opening, drainage patch
and ultimate disposal location in logbook and
describe below.
e. Is storage site located above
the 100-year flood water
elevation level? Yes No N/A C/A
JL f. Are storage areas ade-
quately marked? Yes No N/A C/A
g. Any deficiencies in permanent storage facility must be
documented with photographs and described below.
Description must include amount of PCBs involved.
-------
Appendix J (cont.)
3. Containers:
a. Are ail PCB items which are
located within storage areas
dated [761.65(c)(8)j? Yes No N/A C/A
b. Do PCB containers comply
with DOT specifications
except as noted in 3c and
3d below [761.65(c)(6)J? Yes No N/A C/A
c. Are any non-liquid PCBs
being stored in containers
larger than those specified
in DOT regulations
[761.65(c)(6)]7 Yes No N/A C/A
(1) Do these containers
provide as much
protection and have
the same strength as
DOT containers? Yes No N/A C/A
d. Are any liquid PCBs being
stored in containers larger
than those specified in DOT
regulations [761.42(c)(7)]7 Yes: No N/A C/A
(1) Do containers comply
with OSHA
specifications? Yes No N/A C/A
(2) Has SPCC plan been
prepared and
implemented? Yes No N/A C/A
^_ Storage Site Operations:
a. Are all PCB items arranged
so they can be located by
date? [761.65(c)(8)] Yes No N/A C/A
b. Do observations indicate
good housekeeping
procedures? Yes No N/A C/A
-------
Appendix J (cont.)
c. Is moveable equipment
decontaminated by
approved procedures? Yes No N/A C/A
d. Are PCB items stored and
handled in a manner that
protects them from acci-
dental breakage or damage? Yes No N/A C/A
5. Other Storage Areas:
a. Are any of the following temporarily being stored outside the
prescribed area: [761.65(c)(1)J
(1) Nonleaking PCB
articles and PCB
equipment? Yes No N/A C/A
Is date removed from
service noted on the
article or equipment? Yes No N/A C/A
Have they been there
fewer than 30 days? Yes No N/A C/A
(2) Leaking PCB articles
and PCB equipment
placed in a non-
leaking PCB
container? Yes No N/A C/A
Is the date removed
from service noted on
the container? Yes No N/A C/A
Have they been there
fewer than 30 days? Yes No N/A C/A
(3) Containers of liquid
PCBs at concentra-
tions of 50 to
500 ppm? Yes No N/A C/A
Is SPCC plan avail-
able pertaining to
temporary storage
area? Yes No N/A C/A
-------
Appendix J (cont.)
Are containers marked
to indicate the liquid
does not exceed
500 ppm? Yes No N/A C/A
Is the date removed
from service noted on
the containers? Yes No N/A C/A
Have containers been
there fewer than
30 days? Yes No N/A C/A
b. Are there any large high
voltage capacitors or PCB
contaminated transformers
next to the storage site
[761.65(c)(2)]7 Yes No N/A C/A
Are they on pallets? Yes No N/A C/A
Is there adequate space
within the storage site to
contain 10% of the volume
of these capacitors and
transformers? Yes No N/A C/A
c. Any deficiencies in temporary storage must be documented
with photographs and described below. Descriptions must
include information on the amount of PCBs involved.
E. DECONTAMINATION
1. ^ Does the facility drain or cleanse
~~- PCB transformers or other equip-
ment containing PCB substances
or mixtures prior to disposal or
decontaminate movable
equipment? Yes No N/A C/A
2. Does the facility claim to have an
exemption from incineration
[761.60(e)] or exemptions under
761.80? Yes No N/A C/A
-------
Appendix J (cont.)
3. Is the drainage and solvent filling
site adequate to protect against
spills and leaks and consequent
contamination of surrounding
areas and waterways? Yes No N/A C/A
4. Do solvents to be used for remov-
ing PCBs contain less than 50 ppm
RGBs [761.79]? Yes No N/A C/A_
5. Was a sample of the solvent which
was used for PCB removal
obtained? Yes No N/A C/A
6. Was the rinse volume of the
dilutant approximately equal to
10% of the container's total volume
[761.79(a)]? Yes No N/A C/A
7. Are PCB transformers completely
filled with solvent and allowed to
stand for at least 18 hours before
being drained [761.60(b)(1)J? Yes No N/A C/A
8. Are the drained PCB chemical
substances or PCB solvent mix-
tures properly disposed of or
stored? Yes, No N/A C/A
9. Are solvents or materials which
have been used for decontamina-
tion of PCB equipment disposed of
or stored in the same manner as
PCB mixtures? Yes No N/A C/A
10. If decontamination procedures
_i were not observed during inspec-
~7 tion, did facility representative
demonstrate knowledge of proper
decontamination procedures? Yes No N/A C/A
11. Does facility have written decon-
tamination procedures? Yes No N/A C/A
-------
F.
Appendix J (cont.)
Any deficiencies in the decontamination procedures must be
described below.
RECORDKEEPING
1 . Do records indicate the date PCBs
were:
a.
b.
c.
2. Do
a.
b.
c.
d.
e.
Removed from service?
Placed in storage for
disposal?
Placed in transport for
disposal?
records indicate the quantity of
Yes
Yes_
Yes
No
_No
No
the above items
The weights of PCBs and
PCB items in PCB
containers? Yes_
The identification of contents
of PCB containers? Yes
The number of PCB
transformers?
The weight of PCBs in PCB
transformers?
The number of PCB large,
Yes
Yes_
_No
No
No
_No
N/A
N/A
N/A
C/A
C/A
C/A
as follows:
N/A
N/A
N/A
N/A
C/A
C/A
C/A
C/A
4_ high- and low-voltage
capacitors? Yes No N/A C/A
3. Do records indicate the quantities of PCBs remaining in service
broken down as follows:
a. The weight of PCBs and
PCB items in PCB
containers? Yes No N/A C/A
-------
Appendix J (cont.)
b. The identification of contents
of PCB containers? Yes No N/A C/A
c. The number of PCB
transformers? Yes No N/A C/A_
d. The weight of PCBs in PCB
transformers? Yes No N/A C/A.
e. The number of PCB large,
high- and low-voltage
capacitors? Yes No N/A C/A_
4. a. Is the information requested
in paragraphs 1, 2 and 3
above compiled in an annual
document? (This document
must be prepared by July 1
and cover the previous
calendar year.) Yes No N/A C/A_
b. List years for which annual documents are available.
5. Any deficiencies in recordkeeping must be described below
including information on amount of PCBs involved.
6. If owners or operators maintain
more than one facility that contains
PCBs in the quantities prescribed in
paragraph C 1, are records and
documents kept at a single
location? Yes No N/A C/A
If yes, list location.
7. Do records provide information on
a PCB disposal facility? Yes No N/A C/A
-------
Appendix J (cont.)
If yes, list name, location and type of facility (i.e., incinerator, bo;!
landfill, etc.)
G. DISPOSAL
1. Are PCB articles or containers, which were
stored for disposal after January 1, 1983,
disposed of within 1 year? Yes No.
2. Were items stored for disposal before
January 1, 1983? Yes No_
a. Were they disposed of by
January 1, 1984? Yes No_
3. What items are disposed and state the disposal methods?
-------
APPENDIX K
TSCA SECTIONS 5 AND 8 CHECKLIST
-------
Table K-1
GLOSSARY QF TERMS AND ACRONYMS-
TOXIC SUBSTANCES CONTROL ACT SECTIONS 5 AND 8
SECTION 5.
PMS
SNURs
NOC
TME
R&D
SECTION 5(e)
Order
"Bona fide"
Inquiry
SECTION 5(f)
Order/Rule
"New Chemicals"
(Note: TSCA Chemicals do not include pesticides, drugs,
cosmetics, firearms, etc., by definition)
Premanufacture Notification to EPA is required for ail "new"
TSCA chemicals, i.e., those not listed on the §8(b) existing
chemical inventory.
Significant New Use Rule^ require subsequent notification to
EPA when usage/exposure changes (i.e., in addition to
PMN).
Notice of Commencement to Agency is required before
manufacture begins (after PMN review period has expired).
Test Marketing Exemption to PMN requirement can be
obtained on application to and approval by EPA - usually
subject to specific restrictions.
Research and Development Exemption - automatic exemp-
tion, does not require Agency review or approval.
An administrative order prohibiting or limiting the manufacture,
processing, distribution, use and/or disposal of a chemical for
which a PMN is required because there is insufficient informa-
lion to permit evaluation.
Inquiry by manufacturer that intends to manufacture a specific
chemical to determine whether that chemical is on the confi-
dential portion of the Section 8(b) inventory. (Manufacturer
must establish intent to manufacture to get reply from EPA.) If
the chemical in question is not on the inventory and no PMN
is filed subsequently, the manufacturer may be targeted for
an inspection.
An administrative order or rule prohibiting/limiting the manu-
facture, etc., of a chemical for which a PMN is required
because there is a reasonable basis to conclude that such
activities present an unreasonable risk to health/environment.
(06/87)
-------
*
r\-
SECTION 8
PAIR
ITC
SECTION 8(a)
Level A
Inspection
SECTION 8(b)
Inventory
SECTION 8(c)
Inspection
SECTION 8(d)
Inspection
SECTION 8(e)
Inspection
Table K-1 (com.)
istina Chemicals'1
Preliminary Assessment Information Reporting Rules
Promulgated under Section 8(a) Level A - require reporting to
Agency of production, uses and exposure of specific
chemicals or classes of chemicals.
Interagency Testing Committee - designates chemicals listed
in PAIR rules as well as some of the chemicals in section 8(d)
rules. ITC is established under section 4(e) of TSCA. It also
recommends chemicals for inclusion in testing rules under
section 4(a).
An inspection to determine compliance with PAIR rules.
Inventory compiled by EPA of all chemicals
manufactured/processed in U.S. that were manufactured,
imported or processed in the period 1975-77. Chemicals for
which PMN is submitted are added to inventory when
manufacturing/processing cpmmences (i.e., upon receipt of
NOC). A major updating of the inventory will be undertaken
in 1986.
An inspection to determine whether the manufacturer, proces-
sor, etc., has kept required records concerning allegations of
previously unknown significant adverse reactions to health or
environment.
An inspection to determine compliance with rules requiring
submission of health and safety studies for chemicals or
classes of chemicals designated by the Agency or the ITC.
An inspection to determine whether the manufacturer, proces-
sor, etc., has properly notified EPA (within 15 days of
knowledge) regarding chemicals that present a substantial
risk to health or environment.
-------
Tabie K-2
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
TSCA SECTIONS 5 AND 8 CHECKLIST
Complete^
I. Inspection Management
II. Nature of Facility
III. §5 General Information
IV. Bona fitfq Review
V. Specific PMN Review
VI. 5(e) and 5(f) Order
VII. TME Review
VIII. TSCA §5 Research & Development (R&D)
IX Low Volume Exemption (LVE)
X. Polymer Exemption
XI. Significant New Use Rule (SNUR)
XII. TSCA §8(a) Level A and 8(d) Compliance Review
XIII. TSCA §8(c) and 8(e) Compliance Review
(06/87)
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
TSCA SECTION 5/8 CHECKLIST
INSPECTION MANAGEMENT (Attach additional information as necessary)
1. Name and Address of Facility:
2.
3.
4.
5.
6.
7.
8.
9.
Telephone No.:
DUNS No.:
Telephone Contact (Name, Title and Date):
Written Notification (Date): _
Date and Time of Inspection:
Inspection Team:
[Exhibit 1]
(lead)
TSCA Notice of Inspection Issued to (Name, Title):
TSCA ICN Notice Issued to (Name, Title):-
Other Company Inspection Participants (Names, Titles):
1.
[Exhibit 2]
_ [Exhibit 3]
2.
3.
4.
5.
10. Type of Inspection:
.Routine
.Followup
.Special Request
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
INSPECTION MANAGEMENT (cont.)
11. Scope of Inspection (List by Federal Register, CAS No. or other
designation):
Gen. Inv.:
Spec. PMN:
TMEs:
LVEs:
PEs:
5(e)/5(f):
BFs:
8(a)L(A):
8(b):
8(c):
8(d):
8(e):
Sect. 4:
Other:
Other:
12. Walk-through:
Areas:
Yes
No
13. TSCA Receipt for Samples and Documents Issued to-
(Name and Title).
TSCA Declaration of CBI Issued to:
, [Exhibit 4]
(Name and Title).
[Exhibit 5]
14. Followup Information Requested: Yes No
Date Received:
15. Remarks:
-------
K-6
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
NATURE OF THE FACILITY (Attach additional information as necessary):
1. Facility History, Organization and Corporate Relationship:
2. Scope, Size and Functions of the Facility:
3. Facility Description and Layout:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
TSCA 65 GENERAL CHEMICAL INVENTORY COMPLIANCE REVIFW
A. Intervieweefs): 1.
2.
B. Chemicals: Manufactured Imported Processed Other
1. Prepared list of chemicals available by
CASR No. Yes No
2. List verified against company business
records: Yes No
What records:
3. Records reviewed in lieu of prepared list (type and dates):
Chemicals reviewed on open inventory by
via
Date search completed:
No. unlisted chemicals:
Date unlisted chemicals sent to OCM:
Date reply:
No. chemicals unlisted in conf. inventory:
Date followup with facility:
Date reply: Status:
(attach list)
(attach copy)
5. Additional Notes and Remarks:
-------
K-3
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
IV. TSCA S5 BONA FIDE REVIEW:
A.
B.
C.
Interviewee(s): (1)
(2)
1.
2.
3.
4.
5.
6.
7.
1.
2.
3.
4.
5.
EPA Accession No.
Name of chemical:
CAS Registry No. if known:
Date of submission:
Date of response by Agency: '
Was chemical found on confidential inventory?
If yes, did company commercialize product?
What records were reviewed during inspection?
8. Remarks:
Was PMN filed for chemical?
Date of submission:
Was NOC submitted:
PMN No.
Was PMN reviewed during this inspection?
Remarks: ^____
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
v- SPECIFIC PREMANUFACTURE NOTIFICATION fPMN) COMPLIANCE
REVIEW- (One PMN per form)
A. Interviewees: (1)
(2).
B. General Information;
1. PMN No.: 90-day Date: NOG Date:
2. Advance copy available: Yes No
Copy at site: Yes No_
3. Chemical Name:
4. Other Names:
5. Use at site: Manufacture Import Process
R&D Other
C. Production Compliance;
1. Date of first commercial manufacture or import (circle):
How verified (records reviewed and dates):
2. Dates and amounts of R & D Production: (1).
Use.
(2).
Use.
(Attach if more than 2 R&D batches)
How verified (records reviewed and dates):
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
V. SPECIFIC PREMANUFACTURE NOTIFICATION (PMN) COMPLIANCE
REVIEW (cont.l
Mass balance and disposition of R&D material:
3. PMN and R&D records complete as per 40 CFR Part 720.78:
Yes No.
Description of PMN records:
Description of R&D records:
4. Additional remarks:
-------
<-•
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
V- SPECIFIC PREMANUFACTURE NOTIFICATION fPMW CQMPl
REVIEW (cont.)
D. Technical Content
1. Chemical identity:
2. Monomer verifications (for polymers only):
3. Impurities:
4. By-products:
5. Use(s):
6. Operation:
7. Exposure:
8. Env. Release:
9. Processing:
10. Test data:
11. Additional Information:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VI. SPECIFIC PMN-§5(e) and 5W ORDER
A. Interviewee(s): (1)
(2)
B. Compliance Restrictive Elements:
Was PMN chemical in commercial production at time of inspection?
Yes No
1. Testing Trigger
Specified Testing Production Volume Trigger
Was a Trigger volume reached? Yes No_
If yes, when
If yes, has prescribed testing been
initiated? Yes No_
If yes, was commercial production
stopped? Yes No_
Remarks:
2. Gloves
Was glove testing a requirement? Yes No
If yes, was imperviosity testing
conducted? Yes No
Was testing conducted by PMN Submitter/Contractor (circle
one)?
Did testing protocol meet Agency
guidelines? Yes No
Were gloves demonstrated to be
impervious? Yes No
Was glove usage observed? Yes No
Remarks:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VI. SPECIFIC PMN-S5fe) and Sffl ORDER teont.)
3. Protective Devices and Hazard Communication
What were protective clothing requirements?
Were employees observed to be wear-
ing protective clothing as described in
consent order? Yes No
Were other protective measures and
equipment in use by employees as
described in consent order? Yes No_
Describe:
Were employees instructed and trained
in the proper use of protective equip-
ment and measures? Yes No
How was this documented? ^^_^^_
Were affected employees notified in
training sessions with respect to the
hazards, dangers and concerns of
the PMN chemical? Yes No.
Were signed attendance sheets avail-
able for review by the inspector? Yes No.
Had all operators received appropriate
training? Yes No.
How verified: _
4. Waste Disposal
What was specified disposal requirement?
Was evidence of proper disposal
present? Yes No_
How verified:
-------
K-'-i
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VI. SPECIFIC PMN-S5f^ ^nd 5(fi ORDER (cont.)
5. Label F. sments
What was type size specification?
Actual type size on label:
Remarks:
6. Evidence for Customer Compliance
Was there evidence of customer
compliance with Agency restrictions
on use as described in manufacturer's
letter to final users? Yes No.
Remarks:
7. General (Cleanliness and Housekeeping)
Was the production area of PMN
Chemical clean and well-maintained? Yes No_
Was "9 any evidence of spillage or
envr nental release? Yes No_
Remarks:
-------
X". • -
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VII. TSCA 65 TEST MARKETING EXEMPTION
A. Interviewee^: (1)
(2)
B. General
1.
2.
TME No.: .
Chemical:.
CASR No.:
Date of Receipt:
Verification of Chemical Structure:
C. Restrictions
1. Period of Approved Use:
Verified via:
to,
Production Volume Allowed:
Verified via:
Actual
Number of Customers: Allowed:
Verified via:
Actual
-------
K-15
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VII. TSCA §5 TEST MARKETING EXEMPTION (cont.)
4. Use: Allowed: Actual
Verified via:
5. Worker/Consumer Exposure: Actual:
Allowed: .
Verified via:
6. Additional Remarks:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VIII. TSCA 65 RESEARCH & DEVELOPMENT
A. Interviewees: (1)
(2)
B. Background
1. Does facility conduct TSCA defined
R&D activities? Yes No_
2. If not, where is basic R&D conducted for company?
3. Does facility/company have a written
TSCA R&D policy? Yes No
If yes, does the policy reflect record-
keeping and notification requirements
that became effective 08/04/86? Yes No_
Does the facility/company routinely
submit bona fide inquiries? Yes No
4. Remarks:
-------
K-13
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VIII. TSCA S5 RESEARCH & DEVELOPMENT (R&D1 (cont.)
C. Specific R&D Chemicals (one chemical per page)
1. Were any R&D chemicals specifically
verified for compliance with R&D
exemptions? Yes No
a. Name of chemical:
b. Was chemical produced in a
quantity over 100 kg/year? Yes No_
c. Was recordkeeping complete? Yes No_
What type of records?
d. Were notifications adequate? Yes No_
How verified?
e. Were "technically qualified indi-
viduals" supervising use of the
chemical(s)? Yes No_
f. Were risk reviews adequately
documented? Yes No_
g. Were "prudent Laboratory prac-
tices" documented? Yes No_
How documented?
h. Were disposition records
complete? Yes No_
i. Could a reasonable mass bal-
ance be accomplished for
reviewed chemicals? Yes No_
j. Did amounts produced exceed
R&D requirements? Yes No_
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
VIII. TSCA §5 RESEARCH & DEVELOPMENT (R&D1 (cont.)
k. What was disposition of excess R&D material(s)?
2. Remarks:
-------
K-20
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
IX. LOW VOLUME EXEMPTION (LVE1 (One LVE per form)
A. Interviewee^: (1)
(2)
B. General:
1. LVE No: Date of Receipt:
21 -Day Review Date ..
2. Chemical: CA-, No.:
Other Names:
3. Use(s):
4. Manufacturing Site(s):
C. Restrictions:
D. Compliance:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
IX. LOW VOLUME EXEMPTION (LVE1 fcont.)
E. Production: 1st 12-month period ( to ): kg
2nd 12-month period ( to ): kg
3rd 12-month period ( to ): kg
F. Test Date: Were test data reviewed for
completeness? Yes No
Were data complete? Yes No
Couldn't determine
G. Remarks:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
X. POLYMER EXEMPTION (One PE per form)
A. Interviewees: (1)
(2)
B. General:
1. PE No.: Date of Receipt:
21-Day Review Date:
2. Chemical Name: CAS No.:
Monomer Composition: % Residue %
(Verified? ) % Residue %
% Residue %
Number Average MW: Verified: Yes No
Use(s): Annual Production Vol.: kg
(Actual): kg
Facility/Address of Manufacturer/Importer:
3. Remarks:
-------
K-2:
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XI. SIGNIFICANT NEW USE RULE (SNUR) (One SNUR Chemical per form)
A. Interviewees: (1)
(2)
B. General Information
1.
2.
3.
SNUR No.:
Chemical Name:
Other Names:
Use at site:
90-Day Review Date:
CAS No.:
C. Production Compliance
1. Date of first commercial manufacture, report or progressing
(circle):
How verified (records reviewed and dates):
2. Remarks
Note: The PMN"Technical Content (Part V) and 5(e)/5(f) Order (Part VII)
forms are to be used as appropriate for any SNUR review.
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XII. TSCA §8te) LEVEL A AND
A. Interviewees:
COMPLIANCE REVIEW
B.
(1)
(2)
68(a) Level A
1.
2.
3.
4.
5.
Name of Chemical:
CAS Registry Number:
Published Reporting Date for PAIR/CAIR:
Corporate fiscal year:
Was PAIR/CAIR report submitted:
Date of Submission:
Yes
No
6. What information on PAIR/CAIR report was verified?
7. What records were reviewed?
8.
9.
Did records agree with submitted report?
Remarks: _
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XII. TSCA §8fa) LEVEL A AND 8fd) COMPLIANCE REVIEW (cont.)
C.
1. Published reporting date for 8(d):
2. Was 8(d) report submitted? Yes No.
Date of Submission:
3. Studies submitted (by title):
4. Remarks:
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XIII. TSCA §8(c) and 8tel COMPLIANCE REVIEW
A. Interviewees: (1)
(2)
B.
Did facility have a §8(c) file ? Yes No.
Location of file:
Contents: (1) Allegations: Yes No.
If yes, how many?
(Attach list of chemical(s), processes and effects)
(2) Copy of the 8(c) regu-
lations? Yes No_
(3) Copy of company or
facility 8(c) policy? Yes No.
2. If allegations were on file, did they
appear to represent unknown effects? Yes No_
Remarks:
3. Were recorded allegations filed correctly
and completely? Yes No_
Remarks:
4. Other records (OSHA, incident files, lawsuits) reviewed for
allegations and findings?
-------
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XIII. TSCA §8te) and 8(e) COMPLIANCE REVIEW (cont.)
5. Were company officials generally knowl-
edgeable of 8(c) requirements? Yes No.
Remarks:
C.
6. Had there been any apparent attempts
at employee outreach? Yes No.
Remarks:
7. Were fact sheets and other information
left with plant officials? Yes No
1. Did the facility or company have a §8(e)
policy? Yes No.
Did the facility have an 8(e) file? Yes No.
Location of file:
Has the facility or company made any
TSCA §8(e) submittals to the Agency? Yes No_
List:
Were all 8(e) submissions filed within
15 days? Yes No.
How verified:
-------
K-23
INSPECTION NO.
FACILITY/CITY
INSPECTION DATE
XIII. TSCA 68(c) and 8fel COMPLIANCE REVIEW teont.)
2. Were company officials generally knowl-
edgeable of 8(e) requirements? Yes No.
Remarks:
3. Were other spills or releases reported
to EPA State authority or the Coast
Guard in a timely manner? Yes No_
Remarks:
4. Have any civil lawsuits been filed
against the facility with respect to health
or environmental effects? Yes No_
Remarks:
-------
APPENDIX L
PESTICIDE (FIFRA) CHECKLIST
-------
Appendix L
PESTICIDE (FIFRA) INSPECTION CHECKLIST
INTERVIEW/RECORDS
1. Are pesticides used at the facility? Yes No
a. Circle general types used:
Algacides Insecticides Fungicides Herbicides Rodenticides
Other
2. Are any restricted use pesticides used at
this facility? Yes No
3. Are pesticides applied by facility personnel? Yes No
4. Are pesticides handlers certified? Yes No
a. Circle type of certification:
EPA State DOD Other
b. Are pesticide handlers authorized for
restricted use pesticides? Yes No,
c. Are licenses/certificates current (not expired)? Yes No_
5. Has the facility pesticide program been inspected
before? Yes No,
a. Circle by whom:
EPA State DOD Other
b. General results _____
6. Does the facility have application records? Yes No_
7. Has the facility filed restricted use pesticide reports? Yes No_
8. Does the facility have inventory records? Yes No_
9. Are target pests indicated on application records? Yes No_
a. Are the pesticides used registered for use
against the target pest? Yes No.
(03/89)
-------
Appendix L (cont.)
10. Are pesticide handlers' training records current? Yes No
a. Types of trainina
STORAGE
1.
2.
3.
4.
5.
6.
7.
8.
9.
Is the storage area located on a flood plain?
Is the storage area fenced?
Is the storage area kept locked?
*
Are pesticides stored under cover?
Is the area well ventilated?
Is the area posted with pesticide or chemical
warning signs (i.e., DANGER - POISON)?
Are pesticides separated by type?
Are the pesticides properly labeled?
Are pesticides stored in other than original
containers?
a. Explain, if yes.
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
_ No
No
_ No
_ No
No
No
MIXING/LOADING
1.
2.
3.
4.
5.
6.
7.
Is there a mixing/loading area?
Is the mixing/loading equipment functional?
Does the equipment help reduce the handlers
exposure to pesticide?
Are label directions followed?
Is protective clothing worn by handlers?
Does protective clothing look used?
Is there a mechanism for rinsing containers?
Yes
Yes
Yes_
Yes
Yes
Yes
Yes
_ No
No
_No
_ No
_No
_No
_ No
-------
Appendix L (cont.)
8. How is rinse liquid disposed of?
9.
Is spray equipment cleaned between applications?
a. How is rinse liquid disposed of?
Yes
No
CONTAINER DISPOSAL
1.
2.
3.
4.
5.
6.
7.
Are label directions followed?
Are empty containers triple rinsed?
Are containers offered for scrap or recycle?
Are containers punctured or crushed to help
prevent improper reuse?
Are drums given away for burn barrels, etc.?
Is there a container disposal site at the facility?
Is the site fenced and locked?
8. Are there pesticide or chemical warning signs
posted?
WORKER PROTECTION STANDARDS
1.
2.
3.
4.
5.
6.
Does responsible party keep application records?
Does responsible party know when workers re-enter
fields?
Does responsible party warn workers and/or post
fields?
Is responsible party informed by applicator when
re-entry restrictions apply?
Does responsible party understand current worker
protection standards?
Does applicator notify responsible party when using
RUPs?
Yes_
Yes_
Yes_
Yes_
Yes_
Yes
Yes_
Yes
Yes
Yes
Yes
Yes
Yes
Yes
_ No
_ No
__ No
_No
_ No
_No
__No
__ No
_ No
_No
_No
_ No
_No
No
-------
L-4
7. Dees applicator post fields when using RUPs? Yes No_
APPLICATION OBSERVATION
1. Is spray turned on/off outside of the target field? Yes No_
2. Is drift of pesticide mist visible off of the target field? Yes No_
3. Is the application pattern recorded? Yes No_
4. Are weather measurements taken? Recorded? Yes No_
5. Are measures taken to ensure safety of field
workers? Yes No.
6. Is the application planned to minimize drift to
houses, schools, cars, etc.? Yes No.
-------
APPENDIX M
WATER SUPPLY CHECKLIST
-------
M--
Appendix M
WATER SUPPLY CHECKLIST
Date of Inspection
Community Noncommunity
1. Basic Information
Supply Name I.D. Number
County Phone ',
Establishment p0p. Served
No. of Service Connections
Period of Operation: 12 month Seasonal
If Seasonal: From Jo
2. Surface - Other community system Wells Spring Surface
3. Other community system name _____
4. Wells (source of information) Well log (attached)
Year installed Casing Diameter in. Depth ft
Distance to potential contamination ft. Source '
Controlled access to well? Yes No
If yes, distance
Comments: --—ZIZIIZZIZIIZZIZZZIZZZIIZZZZZI^^
Well Details:
Well house Yes No Well seal Yes No_
Heated, lighted Yes No Water level
_ . device Yes No
Casing above grade Yes No Grouted Yes NO
Subject to flooding Yes No Casing vent Yes NO
Pump Details:
Brand and Model __ Horsepower _
Capacity gpm at ft nead
Type: (Circle)
Su5-me,rf JU!? PumP removal provision
Vertical turbine Pump to waste piping
Deep well jet Capacity adequate
Shallow well jet Sample tap
Shallow well centrifugal
Comments
-------
M-2
5.
6.
Other Source
Appendix M (cent.)
Spring
Surface source
Security (signs, fences, etc.)
Minimum available flow
Sources of contamination
Source area ownership
Springs
Fencina Yes No
Surface run-
off ditch Yes x ' o
Springbox Yes
Comments:
qpm Measured
Screened Overflow Yes
Hatch and curbing Yes
Bottom drain Yes
Estimate
No
No
No
Surface Source^
Impoundment Yes No_
Diversion dam Yes No_
Infiltration gallery Yes No~
Source name:
Spillway Yes
Intake screens Yes
Drain Yes
No
No
No
Comments:
Storage
General: Volume gallons Type:
Separate inlet/
outlet
Hatch
Water level
indicator
Reservoir: Material
Overflow
Screened vent
Covered
.Reservoir Hydro-pneumatic
Yes
Yes_
Yes
No
__No
__No
Drain to
daylight
Flap valve
Booster pump
Yes
Yes
Yes_
Yes
Yes
Yes
No
No
_ No
No
No
No
ank: Operating ranae
-------
Appendix M (cont.)
7.
Distribution System
Types of piping
Adequate pressure (20)
Flushing program
Chlorination: Continuous chlorination?
Sodium Proportional
hypochlorite Yes No to flow
Calcium DPD chlorine
hypochlorite Yes No test kit
Gas Chlorine Yes No Booster pump
Typeofchlorinator:
Contact time provided by:
Volume of contact chamber:
Estimated maximum system flow:
Contact time - A/B -:
Yes
Yes_
Yes
Yes_
Yes
Yes
No
No
No
No
No
No
gallons (A)
(Bl
minutes
Comments:
9. Monitoring: Type of system (check)
Ground water
Surface water
Purchase from other water system
Parameter
Coliform bacteria
Turbidity
Inorganics (nitrate)
Radiologic
contaminants
Organics
Other
Required
Frequency
Sampling
Current?
Yes No
Met MCLs?
Yes No
Comments:
-------
APPENDIX N
UNDERGROUND INJECTION CONTROL (UIC) CHECKLIST
-------
Table N-1
UIC INSPECTION CHECKLIST
Regulate"/ Authority to Conduct inspections
Safe Drinking Water Act §1445
40 CFR §144.1 (c)
40 CFR §144.51(i)
RCRA §3007(a) (Class I wells only)
I. Type of UIC Program
EPA Administered (40 CFR Parts 146 & 147 applicable)
State Administered (Applicable State Regulations)
II. Type of Well (40 CFR 146.5)
Class I (see Parts IV, VA)
Class II (see Parts IV, VB)
Class III (see Parts IV, VC)
Class IV (see Parts IV, VD)
Class V (see Parts IV, VE)
Operation Authority
Rule
Permit
IV. General Requirements [must comply with 146.65 (as of July 26, 1988)]
Construction
(1) Depth to base of USDW
(2) Depth to injection zone ___
(3) If injecting into USDW, has formation
been exempted? Yes No.
(4) Adequate confining zone between USDW
and injection zone? Yes No_
(5) Surface casing length, type
volume, type of cement
(6) Long string casing length, type.
volume, type of cement
(03/89)
-------
Table N-1 (cont.
(7) Intermediate casing(s) length type: (a)
volume, type of cement.
(b).
(8) Injection tubing length, type.
packer Yes No_
volume, type of cement on packer ~
(9) Injection fluid.
Corrosive Noncorrosive
(10) Injection pressure
(11) Field verification of injection pressure Yes No_
Pressure
(12) Injection pressure limit?
(13) Annular pressure
[Exceeds injection pressure (Class I)] Yes No
(14) Annular fluid
Types of logs run, date and interval tested: (Must comply with
146.66)
(15) Formation data:
Fluid pressure.
Temperature (Class I).
Fracture pressure.
Physical characteristics _
Chemical characteristics.
-------
Table' N-1 (cent.)
.''5) Construction complies with Permit or Rule Yes No
If not, specify ^___
(17) Facility operations match permit/rule
requirements Yes No
If not, specify.
(18) EPA notified of any discrepancies in
operations Yes No
(19) Emergency procedures adequate Yes No
(20) High and low pressure shutoffs on both
pumps and source tanks Yes No
(21) Number and location of injection wells are as
described in inventory and/or permit
conditions Yes No
(22) All information required is available and
current Yes No_
(23) Information is retained for required period Yes No_
(24) Sampling and analysis data are complete Yes No_
(25) EPA notified of any well failures and/or
corrective actions Yes No_
(26) Plugging and abandonment plan on file Yes No_
(27) Financial assurance current and on file Yes No_
V. Operating, Monitoring, Reporting Requirements
A. Class I Requirements:
(1) Injection pressure exceeds maximum Yes No_
(except during stimulation)
(2) Injection between outermost casing
and well bore Yes No
-------
Table N-1 (cont.)
(3) Continuous monitoring of:
a. Injection pressure Yes No
b. Flow rate Yes No"
c. Volume Yes No"
d. Annulus pressure Yes No"
(between tubing and long string)
e. All monitoring equipment
operational [automatic alarms in
accordance with 146.67(f)] Yes No
f. Temperature of injected fluids Yes No]
(4) Sample injected fluid frequently
enough to be representative Yes No
(5) Testing and monitoring require-
ments (146.68)
Waste analysis plan prepared Yes No
Complete in accordance
with 146.68, 148.5, and
268.7 Yes No
Hydrogeologic compatibility Yes No
Compatibility of well materials Yes No
Mechanical integrity
Long string, injection tubing, and annular seal
pressure tested annually (or whenever well
workover completed) Yes No
Long string Pass Fail
Injection tubing Pass Fail
Annular seal Pass Fail
If any were failed, were workovers completed
and the well retested? Yes No
-------
Table N-1 (cont.)
Bottom-hole cement tested with radioactive
tracer survey annually Yes No
Pass Fail
Temperature, noise or other logs every 5 years
to test for fluid movement Yes No
Specify
Pass Fail
Casing inspection logs every 5 years
Yes No
Pass Fail
Other tests, specify.
Ambient Monitoring
Develop monitoring program with, at a.
minimum, monitoring of pressure build-
up in the injection zone and, during shut-
in, pressure fall off tested
Yes No
Other monitoring prescribed by the Director, in
accordance with I4e.69(e)(2) or (f)
Yes No
Specify.
(6) Reporting requirements 146.69
Quarterly reports, including at a minimum:
Maximum injection pressure
Description of events
Exceeding operating parameters
Triggering alarms, required by 146.67(f)
Total volume of fluid injected
-------
Table N-1 (cont.)
Changes in annular volume
Physical, chemical and other characteristics of
injected fluid
Results of monitoring under 146.68
Reporting within 30 days, or with the next quarterly
report, whichever is later, the results of:
Mechanical integrity tests
Any other test prescribed by the Director
Any well workover
Closure plan
Facility must prepare, maintain, and comply with
a closure plan, in accordance with 146.71
Post closure
Prepare, maintain, and comply with a plan for
post closure care, in compliance with 146.72
Financial responsibility
Demonstrate and maintain financial
responsibility, in accordance with 146.73
Restrictions on injection of wastes
Injection must comply with restrictions in
Parts 148 and 268
Restricted from disposal:
Spent solvent wastes in 261.31 numbered
F001-F005, unless waste is a solvent-water
mixture or solvent-containing sludge containing
less than 1% total F001 through F005, listed in
Table A (as of August 8, 1988)
-------
Table N-1 (cont.)
All spent F001 through F005 wastes containing
less than 1% F001 through F005, listed in
Table A (effective August 8, 1990).
Dioxin-containing wastes, specified as F020-
F023, and F026-F028 (effective August 8, 1988)
The above does not apply if the waste is treated to
meet standards of 268.41, an exemption is granted, an
extension of the effective date has been granted, or a
treatability variance has been granted under 268.44.
Extension or exemption petitions in response to
148.20 Yes No
Waste analysis plan in compliance with 148.5 and
268.7 Yes No
Operating record in compliance with 268.7 (i.e., notifi-
cations and certifications for wastes accepted)
B. Class II Requirement?:
(1) Injection pressure exceeds maximum Yes No
(2) Injection pressure exceeds confining zone
maximum adjacent to USDW • Yes No
(3) If operating above fracture pressure:
pressure, location, and number of wells
affected by injection (attach map)
(4) Injection between outermost casing and
well bore Yes No
(5) Representative sample of injection fluid Yes No
(6) Observation of pressure, flow rate and
cumulative volume at the following frequency:
a. Brine disposal (II D) weekly Yes No
-------
N-3
Table N-1 (cont.)
b. Enhanced recovery (II R) monthly Yes No
c. Hydrocarbon (II H) daily Yes No"
d. Cyclic steam daily Yes No"
(7) Recording of one observation of pres-
sure, flow rate, and cummulative volume
at least once every 30 days Yes No
(8) Mechanical integrity test every 5 years Yes No_
(9) Manifold monitoring (for II R or II H)? Yes No_
If - - demonstration approval by
Dire_::r for alternate monitoring Yes No_
(10) Maintain records until next permit
review Yes No
(11) All monitoring equipment operational Yes No_
C. Class. ••'ire..ments:
(1) Fo. i data (Substitute for IV 15)
a. naturally water-bearing:
b. If non water-bearing:
1. Fracture pressure.
1.
2.
3. .
4.
Fluid pressure
Fracture pressure
Physical characteristics
Chemical characteristics
c. If formation is a USDW, monitoring wells must be
located in the injection formation and in any USDW's
above the injection formation to detect migration of
injected fluids, process by-products or formation fluids
outside the injection zone
-------
Table N-1 (cont.)
1. Are appropriate wells
located to monitor injec-
tion operation Yes No
2. If area is subject to sub-
dence or catestrophic
collapse, are wells located
so they will not be phys-
ically affected? Yes No
d. If injection wells penetrate a
USDW and in an area subject to
subsidence or catastrophic
collapse:
1. Are these monitoring
wells completed into the
USDW? Yes No
2. Are the monitoring wells
capable of detecting the
movement of injected
fluids and by-products
into the USDW? Yes No
3. Are the wells located out-
side the physical influence
of subsidence or cata-
strophic collapse? Yes No
e. What is the frequency of monitoring wells under c and
dabove?
f. Were the following points evaluated in the deter-
mination of monitoring frequency?
1. Population relying on
USDW Yes No.
2. Population affected by
injection Yes No
-------
N-'C
Table N-1 (cont.]
3. Proximity of injection to
points of drinking water
withdrawal Yes _ No
4. Operating pressures Yes _ No
5. Nature and volume of
injected fluid Yes _ No
6. Injection well density Yes _ No_
(2) Injection pressure exceeds maximum Yes _ No
(3) Injection between outermost casing
and well bore Yes _ No
(4) Injection fluid sampled frequently
enough to be representative Yes _ No
(5) Monitoring of injection pressure semi-
monthly and either: Yes _ No_
a. Flow rate Yes _ No_
b. Volume Yes _ No
c. Metering and daily recording of: Yes
1 . injected volume . Yes _ No
2. produced fluid Yes _ No
(6) MIT at least once every 5 years for salt
solution mining Yes _ No
(7) Monitoring the fluid volume in the
injection zone semimonthly Yes _ No
(8) Monitoring the appropriate parameters
chosen to measure water quality in the
monitoring wells semimonthly (see
1 2c above) Yes _ No
(9) Quarterly monitoring of wells (see 1 2d
above) Yes _ No
-------
Table N-1 (cont.)
(10) Manifold monitoring? Yes No
(11) Individual well monitoring? Yes No
(12) Facility received approval for manifold
monitoring? Yes No
(13) Quarterly reports to Director? Yes No
including:
a. MIT Yes No
b. Other tests (specify below) Yes No~
c. Reported by project/field Yes No~
d. Individual wells Yes No~
D. Class IV Requirements:
Class IV wells are banned and have no inspection requirements
other than plugging and abandonment or continued monitoring
according to individual State/EPA requirements
(1) Date plugged and abandoned
(2) Other available information
-------
N-'2
Table N-1 (cont.)
E. Clas Requirements:
No monitoring requirements unless permit has been issued by a
delegated State.
If State issued permit, specify requirements and compliance/
noncompliance
-------
Table N-2
ADDITIONAL UIC INSPECTION CHECKLIST*
Date of inspection
Date of last inspection
DESCRIPTION OF CORROSION PREVENTION/MONITORING SYSTEM:
Corrosion loop
Weight loss coupons
Electrical resistance probes
Polarization resistance Probes
Logs-type
Cathodic protection
Soil potential survey
Other (please describe)
DATE OF LAST CORROSION EVALUATION BY OPERATOR:
Type
Visual
Other
(describe briefly)
RESULTS:
OK
Corrosion of:
Casing; depth
Tubing; depth
Packer
From 'Underground Injection Control Inspection Manual," prepared by Engineering
Enterprises, Inc. for EPA, February 1988
(03/89)
-------
N-'-i
Table N-2 (cont.)
Other (indicate component
Injection fluid released Yes No
Contaminated USDW Yes No
CASING MATERIAL:
Steel
Stainless steel
Monel
Titanium
Other; specify
TUBING MATERIAL:
Steel
Stainless steel
Fibercast
Fiberglass
Other
PACKER TYPE AND MATERIAL
Tension
Compression
Material: Steel Other specify
Special protection (please indicate). Note that some packers, especially
tension packers, have rubber pads or special coatings to prevent contact
with injection fluids.
WASTE CHARACTERISTICS:
pH =
Dissolved oxygen (concentration) mg/l
Hydrogen sulfide, HaS (concentration) mg/l
-------
Table N-2 (cont.)
Carbon dioxide, CO2 (concentration) mg/l
Amenable to biological degradation
Acidic
Basic
Most recent sample analysis (attached) indicates no significant changes
EVALUATION OF THE CASING/TUBING/PACKER MATERIALS TO RESIST
CORROSION:
(By consulting the tables in page of the manual, a preliminary evaluation
can be made. The inspector may also use different criteria for evaluation;
however, he/she should indicate the reason for the decision.)
Adequate
Inadequate
Criteria used:
Pressure Gauges
Yes No N/A
1. Is Bourdon tube gauge protected from corrosion and
freezing?
2. Is pressure reading relatively constant? (absence of
rapid pointer movement due to pulsating pressure or
pipeline vibration)
3. Are gauge materials suitable for the media monitored?
4. Is a pressure transducer properly installed?
5. Date gauge last calibrated: __
-------
Table N-2 (cont.)
6. Method of calibration:
Pressure Recorders
1. Are pressure recorders properly installed (e.g., chart protected from
weather, etc.)?
2. Are pressure recorders operational (e.g., ink, charts moving, etc.)?
3. Is back-up gauge provided?
4. Do back-up pressure and recorded pressure agree?
FLOW MEASUREMENT - GENERAL
Yes No N/A (1) (a) Primary flow measuring device is properly
installed and maintained.
Yes No N/A (b) Is there a straight length of pipe before and
after the flowmeter of at least 5 to 20
diameters? This depends on the type of
flowmeter and the ratio of pipe diameter to
throat diameter. Also, the introduction of
straightening vanes may reduce this
requirement.
Yes No N/A (c) If a magnetic flowmeter is used, check for
electric noise in its proximity and that the unit
is properly grounded.
Yes No N/A (d) Is the full-pipe requirement met?
Yes No N/A (2) Flow records are properly kept.
Yes No N/A (a) Records of flow measurement are recorded in
a bound numbered log book.
-------
Table N-2 (cont.)
Yes No N/A (b) All charts are maintained in a file.
Yes No N/A (c) All calibration data is entered in the log book.
Yes No N/A (3) Sharp drops or increases in flow values are
accounted for.
Yes No N/A (4) Actual flow is measured.
Yes No N/A (5) Secondary instruments (totalizers, records, etc.) are
properly operated and maintained.
Yes No N/A (6) Appropriate spare parts are stocked.
Electrical noise can sometimes be detected by erratic operation of the flowmeter's
output. Another indication is the flowmeter location in the proximity of large
motors, power lines, welding machines, and other high electrical field generating
devices.
1. Type of flowmeter used:
2. Note on diagram flowmeter placement in the
system. Observe the direction of flow, the vertical
height relationship of the source, outfall, and
measuring meter. Give all dimensions in pipe
diameters.
3. Is meter installed correctly?
(a) If magnetic flowmeter, it should be installed in
an ascending column, to reduce air bubbles
and assure full pipe flow.
(b) If differential pressure meter such as venturi,
it should be installed in a horizontal plane so
that high pressure tap is on the inlet of flow
and taps are horizontal sloping slightly
downward with facilities for cleaning taps.
-------
Table N-2 (cont.)
4. Flow range to be measured:
No N/A 5. Flow measurement equipment adequate to handle
expected ranges of flow values.
6. What are the most common problems that the
operator has had with the flowmeter?
7. Flowmeter flow rate: mgd; Totalizer flow
rate: mgd; Error %
8. Permit project flow:
Yes No N/A 9. Flow totalizer is properly calibrated.
10. Frequency of routine inspection by trained operator
_/month.
11. Frequency of maintenance inspections by facility
personnel: /year.
12. Frequency of flowmeter calibration:
13. Indicator of correct operation:
redundant flowmeters auxiliary flowmeters
pressure readings other
power usage of pumps
14. Indicators of proper Quality Assurance:
redundant flowmeters frequent calibrations
other.
-------
APPENDIX O
COMMUNITY RIGHT-TO-KNOW CHECKLIST
-------
Table O-1
EPCRTKA CHECKLIST
A. is the facility handling extremely hazardous substances at levels identified
in 40 CFR Part 355 Appendix A or handling mixtures at levels defined in
40 CFR 355.30(e) [40 CFR 355.30(a)]? Yes No
If No, go to C
B. Has the facility owner/operator notified the State emergency response
commission, the local emergency planning agency and the local fire
department that the facility is regulated by EPCRTKA [40 CFR 355.30(b)]?
Yes No
NOTE: In the event no State commission was formed, any report or
notification required by either EPCRTKA or the promulgated regulations
is to be sent to the Governor of the State.
If No, go to C
If Yes:
Obtain copies of all applicable letters or memos of this action.
1. Was the notification submitted by May 17, 1987 or within 60 days
after the facility began handling extremely hazardous substances
[40 CFR 355.30(b)]? Yes No
2. Has the facility owner/operator notified the local emergency
planning committee of the identity of the facility emergency
coordinator and that the person is available to work with the
committee on emergency planning activities [40 CFR 355.30(c)]?
Yes No
3. Was this notification done by September 17, 1987 or within 30 days
of the committee's formation [40 CFR 355.30(c)]?
Yes No
Identify the date the local emergency planning committee was formed.
4. If changes have been made at the facility which are relevant to
emergency planning, has the facility owner/operator notified the
local emergency planning committee of those changes 40 CFR
355.30(d)j? Yes No
(03/89)
-------
Table O-1 (cont.)
C. Has the facility had any release of hazardous substances identified in
40 CFR 302. 4(a), Table 302.4 or 302. 4(b) at levels defined in 40 CFR
302.5? Yes _ No _
If No, go to D
If Yes:
1. Were the persons within the boundary of the facility the only ones
affected? Yes _ No _
2. Is the release a "federally permitted release," as defined in
CERCLA, Section 101(10)? Yes _ No _
3. Is the release continuous, as defined in CERCLA, Section 103(f)?
Yes _ No _
4. Does CERCLA, Section 101(22) exempt reporting of the release?
Yes _ No _
If the answer to all four questions is Yes, the release is not
reportable under EPCRTKA, go to D.
If the answer to any question is No, was the release immediately
reported to the National Response Center [40 CFR 302.6]?
Yes _ No _
Was an immediate report also made -to the local emergency
planning committee [40 CFR 355.40(b)]?
NO _
D. Is the facility owner/operator required by OSHA regulation (Hazard
Communication Rules) to prepare Material Safety Data Sheets (MSDS) for
hazardous chemicals defined by OSHA? (This includes manufacturing
facilities contained within SIC Codes 20 through 39 and non-
manufacturing facilities which were required to comply with the OSHA
regulation by May 23, 1988.) Yes _ No _
If no, go to E
1 . Does the facility have hazardous chemicals in amounts equal to or
greater than 10,000 pounds or extremely hazardous substances
greater than or equal to 500 pounds (or 55 gallons) or the threshold
planning quantity defined in 40 CFR 355, whichever is less?
Yes _ No _
-------
Table O-1 (cont.)
a. If Yes, were MSDSs or a list of materials covered by MSDSs
submitted to the State emergency response commission, the
local emergency planning committee and the local fire
department by October 17, 1987 or within 3 months of the
facility becoming subject to 40 CFR 370 [40 CFR
370.20(b)(1)(i)j? (See 40 CFR 370.21 for information
content reporting requirements.) Yes No
b. If Yes, has the facility owner/operator submitted an
inventory of hazardous chemicals and extremely hazardous
substances to the State emergency response commission,
local emergency planning committee and the local fire
department by March 1, 1988 or by March 1 of the first
year the facility becomes subject to 40 CFR 370 [40 CFR
370.20(b)(2)(i)J? (See 40 CFR 370.25 for inventory
reporting requirements, 370.28 for how to handle mixtures,
and 370.40 for the inventory format.)
2. For hazardous chemicals handled at the facility in an amount less
than 10,000 pounds, were MSDSs or list of chemicals covered by
MSDSs submitted to the above groups by October 17, 1989 or
within 2 years and 3 months of the facility becoming subject to
40 CFR 370 [40 CFR 370.20(b)(1)(ii)]. (See 40 CFR 370.21 for
information content reporting requirements.) Yes No
If Yes, has the facility owner/operator submitted to the State
emergency response commission, the {ocal emergency planning
committee and the local fire department an inventory of hazardous /TV
chemicals by March 1, 1989 or by March 1 of the first year the '
facility becomes subject to 40 CFR 370 [40 CFR 370.20(b)(20(ii)]? ^
(See 40 CFR 370.25 for inventory reporting requirements, 370.28
for how to handle mixtures and 370.40 for the inventory format.)
Yes No
NOTE: On March 1, 1990, the levels for inventory reporting of \
hazardous chemicals becomes any level handled. The levels for /
extremely hazardous substances remain the same.
E. Determine whether the facility is covered by the Toxic Chemical Reporting
requirements in 40 CFR 372.30 for each applicable year by answering the
following for any calendar year since and including 1987:
1. The facility has 10 or more full-time employees. Yes No
2. The facility has an operation found in SIC .codes 20 through 39.
Yes No
-------
Table 0-1 (cont.)
NOTE: See 40 CFR 372.22(b) for further criteria of operation
combinations covered.
3. The facility manufactured, imported, processed, or otherwise
handled toxic chemicals in excess of the threshold quantities
identified in 40 CFR 372.25. (40 CFR 372.65 identifies toxic
chemicals covered by this regulation.) Yes No
Continue only if Yes to all three of the above questions.
If No, go to G.
F. Did the facility owner/operator comply with the following reporting
requirements (40 CFR 372.30).
NOTE: See 40 CFR 372.38 for exemptions:
1. Was an EPA Form R (EPA Form 9350-1) submitted for each toxic
chemical manufactured, imported and/or used in excess of the
applicable threshold quantity? [40 CFR 372.30(a)]
Yes No
2. Was an EPA Form R submitted for each mixture or trade name
product imported, processed, or otherwise used which contains a
toxic chemical(s) in excess of the applicable threshold quantity?
[40 CFR 372.30(b)] Yes No
3. Was i form for calendar year activities submitted before July 1
of the - calendar year? Yes No
G. Determine if tne facility is a supplier of toxic chemicals or mixture [See
40 CFR 372.45(d) through (g) for exemptions.] Yes No
If Yes, continue
If No, end the inspection
1. Did the facility owner/operator provide a written notification that a
shipment contains a toxic chemical or that the shipment contains a
toxic chemical mixture (40 CFR 372.45)? Yes No
2. Did the notification provide the following:
a. The chemical or mixture is subject to reporting requirements
of EPCRTKA and 40 CFR 372? Yes No
-------
Table O-1 (cont.)
b. Each chemical name and Chemical Abstract Service (CAS)
Number? Yes No
c. The weight percent of each chemical in the mixture or trade
name product? Yes No
3. Was the notification sent with the first shipment in each calendar
year beginning January 1, 1987? Yes No
4. If changes were made to the mixture or trade name product, was a
notification provided by the facility owner/operator with the first
shipment after the material changed? Yes No
5. If the facility owner/operator discovers new information about the
mixture or trade name product, was a new notification sent to each
previous recipient within 30 days of the discovery?
Yes No
6. If an MSDS was required to be prepared, was the notification either
attached to or incorporated into the MSDS? Yes No
-------
APPENDIX P
LABORATORY AUDIT CHECKLISTS
-------
p.-
Table P-1
METHOD 1310-EP TOXICITY AND STRUCTURAL INTEGRITY TEST
Checklist
Requirement: 40 CFR 261.24
Reference: SW 846, 2nd ed.
Principle: Sample is pretreated and then continuously extracted with a
weak acid for, typically, 24 hours. The extract is then analyzed
for specified elemental, pesticide and herbicide constituents.*
Essential Equipment:
Does the structural integrity tester conform to specifications?
0.33 kg hammer?
Hammer free fall of 6 inches?
Does the extractor prevent stratification of the sample and extraction
fluid?
Does it ensure that all sample surfaces are continuously brought into
contact with the extraction fluid?
If rotary, does it turn at 29 rpm?
Separate checklists have been prepared for the EP constituents: As, Ba Cd Cr Pb Hg
Se, Ag, Endrin, Lindane, Methoxychlor, Toxaphene, 2,4-D and 2,4,5 TP Silvex.
Element
As
Ba
Cd
Cr
Pb
Hg
Se
Ag
Maximum
Concentration
5 mg/L
100
1
5
5
0.2
1
5
(03/89)
-------
p.9
Reaaepfs.
Is 0 5 molar acetic acid used as the extractant?
is deionized or distilled water which has been monitored for impurities
used?
Is the acetic acid monitored for impurities?
Procedure:
Wastes Containing Free Liquids
Is filter preweighed to the nearest 0.01 g?
Is the filter handled so as to prevent damage and contamination?
Is the sample preweighed to the filter? How much sample
Is the filter prewetted with sample?
Are the filters checked for impurities? How?
If samples do not filter at ambient pressure, is filter pressure properly
incremented up to 75 psig or until gas passes before filtration is
discontinued?
Is filter residue dried at 80 °C in order to determine percent solids?
Is a new portion used for the actual extraction?
Are percent solids correctly calculated?
Is the extract properly preserved, stored and refrigerated?
If the solid comprises less than 0.5% of the waste is it discarded and
the remainder of the sample analyzed directly?
If the solid material in the sample has components larger than 9.5
millimeters or individual surface areas greater than 3.1 square
centimeters is the material subjected to a structural integrity test?
Is the sample for the structural integrity test properly obtained (cut or
cast into a cylinder 3.3 cm diameter x 7.1 cm long)?
Is the structural integrity test properly performed (drop tester, 15 times)
If so tested, are all constituents passed through a 9.5 mm sieve?
-------
If :r.e solid material in the sample has components larger than 9.5
millimeters or individual surface areas greater than 3.1 square
centimeters, is the material subjected to a structural integrity test?
Is the sample for the structural integrity test properly obtained (cut or
cast into a cylinder 3.3 cm diameter x 7.1 cm long)?
Is the structural integrity test properly performed (drop tester, 15 times)
If so tested, are all constituents passed through a 9.5 mm sieve?
If the solid comprises more than 0.5% of the sample, are the
appropriate volumes of liquids and extracting solution determined?
Formula?
Is the amount of distilled water to be added determined correctly?
Are pH adjustments performed in accordance with the procedure?'
Is the temperature maintained between 20 and 40 °C?
At the end of the extraction, is the proper amount of deionized water
added to the mixture.
After filtration, are the resultant liquids from the initial filtration and
extract properly combined?
Are items contacting the sample cleaned to prevent contamination of
the sample?
Analysis:
Elemental Constituents
Is the aqueous liquid portion digested in accordance with SW 846
method 3010?
The pH is adjusted with acetic acid as follows:
1.
Initially, after a brief agitation unless the pH is already
-------
P-4
If an organic phase results, is this digested by methods 3030, 3040, or
3050?
Are the digestion procedures properly performed?
Are atomic absorption methods used to analyze the digests?
Is the method of known additions used in each case?
Pesticides and Herbicides
Are methods 8080 and 8150 used (SW 846, 2nd ed.)?
Are the methods used properly?
Calculation
Are concentrations properly calculated in individual samples?
If more than one phase, is the overall EP concentration properly
calculated from the proportions?
-------
P-5
Table P-2
TOTAL NONFILTERABLE RESIDUE (TSS)
Checklist
Requirements: 40 CFR 136, October 26, 1984, pp. 43234-43442
Reference: Standard Methods, 15th edition and the 1979 EPA Methods
Manual
Principle:
When a solution is filtered using a specified grade of glass fiber
filter, the solids remaining on the filter, after drying at 103 to
105 °C, constitute the amount of total nonfilterable residue or
TSS in that sample aliquot. Differential weighing and
mathematical adjustment for sample volume quantifies the
result in mg/L
Essential Equipment
Drying oven capable of maintaining a temperature between 103 to
105 °C
Drying oven make and model: .
Thermometer graduated in one degree increments at the 100 degree
range
Analytical balance make and model
Analytical balance with adequate capacity and sensitivity of at least
.0001 gram
Vacuum system capable of developing 0.5 atmospheres suction
Air tight desiccator with adequate capacity and sample segregation
Appropriate volumetric sample aliquoting device. Specify
Gooch crucibles or aluminum weighing dishers. Specify
Filtration apparatus. Specify
Flat, nonpointed tweezers
Reagents and Supplies:
Indicating calcium sulfate or silica gel. Specify
(03/89)
-------
P-5
RA 334AH filter media or equivalent? Specify siz"- ind type
Samoiing and Preservation:
If the sample is not analyzed within 2 hours of collection, is it kept at
4 °C?
Are all samples analyzed within 7 days of collection?
Are glass or plastic sample containers used?
Procedure:
Method used?
Is the filter pre-washed with 3- to 20-mL aliquots of distilled or Dl water?
Filters properly dried and desiccated? Time spent
Is the desiccant unspent (blue, not pinkish blue or pink)?
Are filters properly seated, wrinkled side up prior to sample introduction?
Is the sample well mixed before aliquoting?
Is the sample size or filter size selected to yield 2.5 to 200 mg of
deposited residue?
Is volumetric glassware properly sized to ensure accurate aliquoting?
Is the sample residue post-washed with three 10-mL portions of distilled
or deionized water?
In conjunction with post-washing, is sample rinsed from dispensing
glassware if appropriate? (The same rinses should be used for both.)
Are residues dried for a minimum of 1 hour and desiccated until cool?
Are the drying cycles repeated to verify weight constancy?
Are successive weights during this step brought to either less than 4% of
the previous weight or 0.5 mg difference?
Are special forceps used to handle filters?
Are sample volumes and filter weights properly recorded?
Are results calculated correctly?
Are precautions taken during sample handling, drying and desiccation to
keep extraneous material off the filters?
-------
Reau!r9d bv t*^e "979 EPA Methods Manual:
Is the aliquot of sample selected such that at least 0.0576 mg per square
cm of residue is filtered and that total filtration time does not exceed 10
minutes?
If a 4.7 cm diameter filter is not used, is the amount of wash water used
approximately 2 ml per square cm?
The 1979 EPA Manual allows material such as leaves, sticks, fish, and
lumps of fecal matter to be excluded or removed from the sample if their
inclusion would produce results nonrepresentative of the source.
Records:
Are bench records maintained for a period of at least 3 years?
Are the date and time of sampling, as well as the individual performing
the sampling, recorded?
Are the date and time of analysis, the analyst, and the method of analysis
properly documented?
Recommended Quality Control:
Are filter blanks used to check for problems?
Are duplicate samples analyzed? Frequency Range
Is the balance professionally serviced? Last service date
Is the calibration of the balance checked each day of use?
Is a balance calibration log maintained?
Is the balance presently level and in calibration?
Is the balance in an area free from temperature excursions and dust?
Has the calibration of the thermometer been verified? Documented?
Is the oven temperature checked each day of use? Documented?
Note: Place check in left hand column if this item is satisfactory. If
unsatisfactory, additional comments may be included at the end.
------- |