United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2223A)
EPA 305-B-00-001
August 2000
4>EPA
Environmental
Screening Checklist
and Workbook for
Terminal Operations
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Disclaimer
The environmental screening checklist and workbook are
tools to be used to help you evaluate compliance at your
facility. They do not contain an exhaustive list or
description of all federal environmental regulations that may
apply to your facility. In addition, your facility is responsible
for knowing and complying with all applicable state, local,
and tribal requirements.
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
W-i
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Table of Contents
TABLE OF CONTENTS
INTRODUCTION W -iii
How Can I Use the Checklist and Workbook? . . . W -iii
How Are the Checklist and Workbook Organized? W -v
Where Can I Get Help? W-vi
CHECKLIST
SECTION 1.0 PERMIT REQUIREMENTS W-1
1.1 National Pollutant Discharge Elimination System (NPDES)
Permit Program W-1
1.2 Pretreatment Requirements W-5
1.3 Underground Injection Control (UIC) W-6
1.4 Air Emissions W-7
1.5 Wetlands W-8
1.6 Resource Conservation and Recovery Act (RCRA) W-9
SECTION 2.0 PLANNING AND REPORTING REQUIREMENTS W-13
2.1 EPCRA Planning Requirements W-13
2.2 EPCRA Emergency Notification W-14
2.3 EPCRA Hazardous Chemical Reporting W-17
2.4 RCRA Contingency Plan W-18
2.5 Underground Storage Tanks (USTs) W-21
2.6 Spill Prevention, Control, and Countermeasures (SPCC) Plan W-22
2.7 Facility Response Plan (FRP) W-24
2.8 Risk Management Plan (RMP) W-26
SECTION 3.0 TRAINING REQUIREMENTS W-28
3.1 RCRA Emergency Response Training W-28
3.2 Air Conditioning Repair Training . W-28
3.3 Pesticide Applicator Certification W-29
3.4 FRP Training Program W-30
SECTION 4.0 RECORDS MAINTENANCE . W-31
4.1 NPDES Recordkeeping W-31
4.2 Air Emissions Recordkeeping W-32
4.3 RCRA Recordkeeping W-33
4.4 Underground Storage Tanks Recordkeeping W-34
4.5 Records of Pesticide Application W-37
SECTION 5.0 RECYCLERS AND RECLAIMING SERVICES W-38
5.1 Hiring Recyclers and Reclaiming Services W-38
GLOSSARY OF TERMS G -1
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
W-ii
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Introduction
INTRODUCTION
The United States Environmental Protection Agency (EPA) is providing the Environmental
Screening Checklist and Workbook for Terminal Operations as a public service to the truck
terminal industry with warehouses, loading docks or freight handling. EPA's Office of
Compliance, through various meetings with industry representatives, facility owners, and
technicians, determined there is a lack of information available to facilities to help them attain
or remain in compliance with applicable federal environmental regulations. The checklist and
workbook highlight important or key environmental requirements as they apply to the various
federal environmental programs.
How CAN I USE THE CHECKLIST AND WORKBOOK?
You can use the checklist and workbook to evaluate your facility's compliance with the federal
environmental regulations which are applicable to the truck terminal industry. The term facility
refers to, but not limited to, truck terminals with warehouses, loading docks or freight handling.
If problems with compliance are discovered while completing the checklist, you may want to
conduct a more comprehensive self-audit.
You can use the checklist and workbook to evaluate the compliance of either specific activities
or areas of your facility, or your entire facility. Specific areas of your facility that you may want
to review are shown in Exhibit 1. This exhibit, "Index of Activities and Requirements for
Terminal Operations," is a pictorial representation of specific activities that are regulated or
specific environmental requirements at a terminal operations facility. A page reference is
included next to each activity/requirement which takes you to the appropriate section of the
workbook where this topic is discussed. In addition, this exhibit also includes hotlines that you
can contact to obtain more information on applicable environmental requirements. As
indicated on the exhibit, one good source of environmental information for the transportation
sector is the Transportation Environmental Resource Center (TERC). You can reach TERC to
request more information on environmental issues or get answers to your transportation-
related environmental questions by phone or on the world wide web:
TERC Toll-Free Info-Line: 1-888-459-0656
TERC Internet Address: http://www.transource.org
Please remember that all of these materials are a beginning, not the final word, on
environmental compliance requirements. While federal environmental requirements are
highlighted in the checklist and workbook, a comprehensive discussion of all requirements is
NOT included. In addition to federal requirements, you may be subject to state, tribal, and/or
local requirements. You can use these materials to build a basic understanding or increase
your knowledge of federal environmental requirements, and then seek additional assistance
from various federal, state, tribal, and local agencies.
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
W- Hi
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Introduction
How ARE THE CHECKLIST AND WORKBOOK ORGANIZED?
What Is Included? Following this introductory section are the checklist and workbook.
These materials include the following sections:
Section 1.0 Permit Requirements
Section 2.0 Planning and Reporting Requirements
Section 3.0 Training Requirements
Section 4.0 Records Maintenance
Section 5.0 Recyclers and Reclaiming Services
Following these five sections, a glossary is provided for your use.
Where Do I Start? You may first want to become familiar with the workbook because it is more
comprehensive than the checklist in terms of environmental compliance information and
issues. Once you have become familiar with the workbook, you can use the checklist by itself
to conduct a compliance evaluation of your facility.
The two-page checklist, located after this introductory text, is basically a streamlined version of
the workbook and has been included to help make the evaluation of your facility's compliance
as easy and efficient as possible. Because the checklist was designed to evaluate specific
activities and requirements at your operation, it does NOT include all of the questions or
activities found in the workbook.
Each checklist question will ask you about key environmental requirements that are applicable
to a trucking facility. After reading each question, pick the most appropriate response for your
facility. If you are unsure of what is being asked by the question or what a response means
when using the checklist, refer to the same question in the workbook. The workbook includes
some general explanatory text for
each question, as well as
explanations of each response. A
"" next to a response in the
workbook indicates that it is a
preferred response in terms of
environmental compliance (see
box). The use of the workbook is
encouraged as it will help you and
others at your facility conducting
evaluations to respond to the
compliance questions consistently
and accurately.
WHAT DOES THE "" MEAN?
A "" next to a response in the guide indicates
that is the preferred response in terms of
environmental compliance. If you select a
response without a V", you may still be in
compliance. However, you should verify that you
are in compliance by contacting the appropriate
federal or state regulatory agency and discussing
your activity with them.
Can the checklist be personalized? The checklist can be personalized to fit the needs of
your facility. When evaluating environmental compliance, you or the person conducting it
should record certain information on the checklist, including the date, name of the facility,
name of the person conducting the evaluation, and any comments or questions regarding the
compliance evaluation. Such information will help you monitor your facility's continued
progress towards environmental compliance.
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
W-v
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Introduction
WHERE CAN I GET HELP?
During the evaluation and everyday operation of your facility, you may need to obtain
additional information on specific environmental requirements Many resources are available to
you which can provide valuable
information on federal
environmental requirements,
pollution prevention, and other
topics. Some of these resources,
which can be contacted by
telephone or accessed through the
Internet, include publications,
hotlines and information lines, EPA
EMERGENCY RESPONSE & ASSISTANCE
National Response Center (NRC) - U.S. Coast
Guard Oil & Hazardous Material Spills (800-424-
8802)
CHEMTREC operated by Chemical Manufacturers
Association on Health and Safety (800-424-9300)
Environmental Health Effects: (National Institute of
Health) Information on chemicals in ground and
surface water, hazardous wastes (800-643-4794)
Local Emergency Number: 911
Headquarters and regional offices,
financial assistance information,
and pollution prevention websites.
Publications
Sector Notebooks. The
following sector notebooks,
which may be of interest to
the trucking industry, can be downloaded electronically at:
http://es.epa.gov/oeca/sector/index.html Also copies can be ordered from GPO at
(202) 512-1800.
Profile of the Ground Transportation Industry - Railroad, Trucking, and Pipeline
EPA/310-R-97-002 (134 pages)
Profile of the Transportation Equipment Cleaning Industry, EPA/310-R-95-018
(81 pages)
Transportation Equipment Cleaning Industry Effluent Guidelines and Standards -
Proposed Rule. EPA is proposing a regulation that will establish technology-based
effluent limitations guidelines for the discharge of pollutants into waters of the U.S. and
into publicly owned treatment works by existing and new facilities that perform
transportation equipment cleaning operations. For more information, call (202) 260-
4992 or check website: http://www.epa.qov/OST/guide/tecifs22. html
Code of Federal Regulation (CFR) References.
Website: http://www.access.gpo.gov/nara/cfr/index.html
Hotlines and Information Lines
Transportation Environmental Resource Center (TERC) Information Line
Telephone: (888) 459-0656
Website: http://www.transource.org
This resource center is designed to help transportation industries stay on top of
environmental requirements and technologies.
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and Workbook for Terminal Operations
August 2000
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Introduction
American Trucking Associations
Telephone: (703) 838-1700
Website: http://www.greentruck.com
ATA is a trade association representing trucking interests before government on
a wide variety of issues.
Air Risk Information Support Center Hotline
Telephone: (919) 541-0888
Fax: (919) 541-0245
This hotline provides technical assistance and information in areas of health,
risk, and exposure assessment for toxic and air pollutants.
Emergency and Remedial Response Fax-On Demand Service
Telephone: (202) 651-2062
This service offers one-way fax documents about Emergency and Remedial
Response programs.
Emergency and Remedial Response Information
Telephone: (703) 603-8960 or (800) 424-9346 (RCRA/UST, Superfund, and
EPCRA Hotline below)
Environmental Justice Hotline
Telephone: (800) 962-6215
This hotline provides environmental assistance and information relating to
environmental justice issues, including brownfields. See "Brownfields" listing
under Pollution Prevention Websites below for more information.
Hazardous Waste Generator and Recycling
Telephone: (703) 308-8850
This office provides information regarding regulations and guidance concerning
hazardous waste generators, including RCRA manifest and the definitions.
Hazardous Waste - Permits and State Programs
Telephone: (703) 308-8404
This office provides outreach and coordination of RCRA hazardous waste
programs implementation, including permitting, clean up and technical
approach.
Hazardous Waste - Risk Assessment and Economic Analysis
Telephone: (703) 308-8855
This office provides toxicology and exposure data; health and ecological risk
assessment; and sampling, statistical, and analytical methods.
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
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Introduction
Hazardous Waste Information
Telephone: (703) 308-8482
This office provides RCRA Government Performance Results Act (GPRA)
coordination program information collection outreach and guidance.
Hazardous Waste Permits
Telephone: (703) 308-8196
This office provides information regarding regulations and guidance for RCRA
hazardous waste permitting program for waste treatment, storage, and disposal.
National Pesticides Information Line
Telephone: (800) 858-7378
This service provides information relating to pesticide usage, including label
information, incident investigations, emergency human and animal treatment
safety practices, clean-up and disposal, laboratory analyses, and regulations.
National Response Center Hotline/Oil and Hazardous Material Spills
Telephone: (800) 424-8802 or (202) 267-2675
Fax: (202) 267-2165
This hotline can be used to report oil and hazardous material spills that (1)
violate applicable water quality standards, (2) cause a film or "sheen" upon
surface waters or adjoining shorelines, or (3) cause a sludge or emulsion to be
deposited beneath surface waters or upon adjoining shorelines. This hotline is
staffed 24 hours a day, 7 days a week, by U.S. Coast Guard officers and marine
science technicians.
Pollution Prevention Information Clearinghouse (PPIC)
Telephone: (202) 260-1023
Fax: (202) 260-4659
Website: http://www.epa.gov/opptintr/library/libppic.htm
PPIC is a free, non-regulatory service of EPA that provides answers and
referrals in response to questions from the public concerning pollution
prevention.
Resource Conservation and Recovery Act (RCRA) Information
Telephone: (415) 744-2074
This hotline responds to requests for information on hazardous waste
identification; generators; transporters; treatment, storage, and disposal
facilities; recycling sites; and export and import.
RCRA/Underground Storage Tanks (RCRA/UST), Superfund, and Emergency Planning
and Community Right-to-Know (EPCRA) Hotline
Telephone: (800) 424-9346 or (703) 412-9810
This hotline provides information about the RCRA/UST, Superfund, and EPCRA
programs. Specifically, the hotline responds to inquiries about waste
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and Workbook for Terminal Operations
August 2000
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Introduction
minimization programs required under RCRA, source reduction and hazardous
waste combustion, and other components of the waste management regulatory
programs.
Safe Drinking Water Hotline
Telephone: (800) 426-4791 or (703) 285-1093
Fax:(703)285-1101
E-mail: hotline-sdwa@epamail.epa.gov
This hotline provides information about EPA's drinking water regulations and
other related drinking water and groundwater topics. Technicians are available
to get details on legislation and regulations or provide important contacts for
water resources and information on drinking water and groundwater.
Small Business Ombudsman Clearinghouse/Hotline
Telephone: (800) 368-5888 or (703) 305-5938
Fax: (703) 305-6462
This hotline provides regulatory and other environmental information concerning
small business assistance to enhance voluntary regulatory compliance and
pollution abatement and control. It also addresses questions covering all media
programs within EPA.
Stratospheric Ozone Information Hotline
Telephone: (800) 296-1996 or (301) 614-3376
Fax: (301) 614-3395
This information hotline provides in-depth information on ozone protection
regulations and requirements under Title VI of the Clean Air Act Amendments of
1990. In addition, the hotline serves as a distribution center and point of referral
for an array of information pertaining to other general aspects of stratospheric
ozone protection and depletion.
Storm Water Hotline
Telephone: (800) 245-6510
This hotline serves as a clearinghouse for information concerning EPA's storm
water general permits. Information specialists are available to answer technical
questions concerning permit eligibility, specific permit requirements, and provide
guidance materials.
Toxic Substances Control Act (TSCA) Assistance Information Service
Telephone: (202) 554-1404
Fax: (202) 554-5603
The information service provides technical assistance and general information
about programs implemented under TSCA, including inquiries about
import/export of chemicals under the regulatory program.
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Introduction
Underground Storage Tanks
Telephone: (703) 603-9900
Website: http://www.epa.gov/OUST/
This office directs callers on where to obtain information regarding underground
storage tanks.
Used Filter Hotline
Telephone: (800) 99-FILTER (993-4583)
Website: http://www.filtercouncil.org
This hotline, sponsored by the Filter Manufacturers Council, provides
commercial generators of used oil filters with a summary of the state's filter
management regulations, referrals to companies that provide filter management
services, referrals to state agencies, and a brochure entitled "How to Choose a
Filter Management Service."
Wetlands Information Hotline
Telephone: (800) 832-7828 or (703) 748-1304
This information line answers questions concerning the value and function of
wetlands and options for their protection, and accepts requests for certain
wetlands publications.
EPA Headquarters and Regional Office Information
EPA Headquarters
Telephone: (202) 260-1090
Fax: (202) 260-0279
Website: http://www.epa.gov/
Region 1 (CT, MA, ME, NH, Rl, VT)
Telephone: (617) 918-1111
Toll-free: (888) 372-7341
Website: http://www.epa.gov/region1/
Region 2 (NJ, NY, PR, VI)
Telephone: (212) 637-3000
Website: http://www.epa.gov/region2/
Region 3 (DC, DE, MD, PA, VA, WV)
Telephone: (215) 814-5000
Toll-free: (800) 438-2474
Website: http://www.epa.gov/region3/
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Telephone: (404) 562-9900
Toll-free: (800) 241-1754
Website: http://www.epa.gov/region4/
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Introduction
Region 5 (IL, IN, Ml, MN, OH, Wl)
Telephone: (312) 353-2000
Toll-free: (800) 621-8431
Website: http://www.epa.gov/region5/
Region 6 (AR, LA, NM, OK, TX)
Telephone: (214) 665-2200
Toll- free: (800) 887-6063
Website: http://www.epa.gov/region6/
Region 7 (IA, KS, MO, NE)
Telephone: (913) 551-7003
Toll- free: (800) 223-0425
Website: http://www.epa.gov/region7/
Region 8 (CO, MT, ND, SD, UT, WY)
Telephone: (303) 312-6312
Toll-free: (800)227-8917
Website: http://www.epa.gov/region8/
Region 9 (AZ, CA, HI, NV)
Telephone: (415) 744-1305
Website: http://www.epa.gov/region9/
Region 10 (AK, ID, OR, WA)
Telephone: (206) 553-1200
Toll-free: (800) 424-4372
Website: http://www.epa.gov/region10/
EPA's Small Business and Self Assessment Policies
Website: http://es.epa.gov/oeca/finalpolstate.pdf
This website contains information on how a facility might qualify for penalty
reductions through self-disclosure.
Website: http://es.epa.gov/oeca/sbcp2000.pdf
This website contains information on the Small Business Compliance Policy.
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Pollution Prevention Websites
EPA's Home Page
Website: http://www.epa.gov
This site provides information about EPA offices, programs and initiatives, and
regulations.
EPA's Compliance Assistance Centers
Website: http://es.epa.gov/oeca/mfcac.html
This site provides links to EPA's Compliance Assistance Centers.
EPA's Pollution Prevention
Website: http://www.epa.gov/opptintr/p2home/
EPA's pollution prevention (P2) site includes general P2 information and
publications, information on P2 in the regulations, the definition of P2 as defined
under the Pollution Prevention Act of 1990, and information about voluntary P2
programs. There are also links to EPA and non-EPA P2 sites.
EPA's Office of Pollution Prevention and Toxics (OPPT)
Website: http://www.epa.gov/opptintr/index.html
This site provides access to federal publications, OPPT programs and initiatives,
and other information sources related to pollution prevention.
ERA'S Office of Underground Storage Tanks
Website: http://www.epa.gov/OUST/
This site provides access to federal publications and links to other resources
about preventing pollution from underground storage tanks containing
petroleum or hazardous substances.
EPA's Oil Program
Website: http://www.epa.gov/oilspill
This site contains comprehensive information on oil spill prevention,
preparedness, and response.
EPA's Brownfields
Website: http://www.epa.gov/swerosps/bf/index.htmltfinfo
EPA's Office of Solid Waste and Emergency Response's Brownfields site
provides information about projects and initiatives, tools, contacts, publications,
and other information regarding Brownfields.
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Chemical Emergency Preparedness and Prevention Office
Website: http://www.epa.gov/ceppo/
This site provides information regarding hazardous and extremely hazardous
substances, including planning and reporting requirements.
EPA's Enviro$en$e
Website: http://es.epa.gov
This site provides P2 information, as well as a link to the National P2
Roundtable described below.
National Fire Protection Association
Website: http://www.nfpa.org
This site contains information on the National Fire Protection Association codes
and standards.
National Pollution Prevention Roundtable Home Page
Website: http://www.p2.org/
This site provides access to the latest information on legislative and regulatory
P2 developments, National Roundtable publications, state P2 program
websites, and a directory of industrial P2 publications.
Pollution Prevention Information Clearinghouse
Website: http://www.epa.gov/opptintr/library/libppic.htm
Operated by EPA's Office of Pollution Prevention and Toxics, this clearinghouse
is a free, non-regulatory service that provides telephone reference and referral,
document distribution for selected EPA documents, and a special collection
available for interlibrary loan.
Pollution Prevention Cooperatives
Coordinated with EPA's Enviro$en$e program, these cooperatives provide easy
access to pollution prevention and cleaner production resources around the
Internet.
(1) U.S. Federal Agency Pollution Prevention Cooperative
Website: http://es.epa.gov/cooperative/federal/
(2) State and Local Government/Business Assistance Cooperative
Website: http://es.epa.gov/cooperative/stateandlocal/
Solvents Alternative Guide (SAGE)
Website: http://clean.rti.org/
This on-line guide provides pollution prevention information on solvent and
process alternatives for parts cleaning and degreasing. It also provides access
to EPA's Air Pollution Prevention and Control Division website.
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ENVIRONMENTAL COMPLIANCE CHECKLIST FOR TERMINAL OPERATIONS
Facility Name:
Facility Location:
Site Reviewer:
Date:
J.8 PERMIT REQUEREIMENTS
NPDES Permit
Program
Pretreatment
Requirements
UIC
Air Emissions
Wetlands
RCRA
Has the facility obtained a National Pollutant Discharge Elimination System (NPDES) permit?
(p. W-2)
Has the facility complied with all reporting requirements specified by its NPDES permit? (p. W-3)
Does the facility have a storm water permit?
If Yes, does the facility have a storm water pollution prevention plan (SWPPP)?
(p.W-4)
Does the facility's SWPPP include all of the required elements? (p. W-4)
Is a certification included in the SWPPP? (p. W-5)
If discharging to a municipal sanitary sewer, has the facility notified the Publicly-Owned Treatment
Work (POTW) and received approval for discharges? (p. W-6)
If discharging to an underground injection control (UIC) well, does the facility comply with UIC
program requirements? (p. W-6)
Does the facility have air permit(s)? (p. W-8)
Has the facility obtained a CWA Section 404 permit for any projects that may impact wetlands?
(p. W-9)
Does the facility generate hazardous waste? (p. W-l 1 )
How much hazardous waste does the facility generate per month? (p. W-l 1 )
Does the facility have an EPA hazardous waste generator ED number? (p. W-12)
How does the facility manage/dispose of its hazardous waste? (p. W-12)
YD No NA a
YD N D NA D
YD No NA D
YD N a NA D
YD N o NA D
YD N D NA a
YD N n NA D
YD N D NA D
YD N D NA D
YD N a NA D
YD N D NA D
a Up to 220 Ibs
D >220 and < 2,200 Ibs
D 2,200 Ibs or more
YD No NA D
Ships hazardous waste
off site / Disposes of
hazardous waste on site
/ Other / NA
2.0 PLANNING AND REPORTING REQUIREMENTS
EPCRA Planning
Requirements
EPCRA Emergency
Notification
EPCRA Hazardous
Chemical Reporting
RCRA Contingency
Plan
Did the facility participate in emergency planning activities when it has extremely hazardous
substances (EHSs) in excess of their threshold planning quantities (TPQs)? (p. W-14)
Did the facility immediately notify the proper authorities after the facility experienced an accidental
release of a hazardous or extremely hazardous substance ? (p. W-l 5)
When reporting a spill, did the facility include the required information for initial notification?
(p. W-l 5)
After initial notification of any spills and releases, has the facility provided a written follow-up
emergency notice(s) to-the proper emergency agencies? (p. W-16)
Has the facility submitted the MSDSs or list of EPCRA extremely hazardous substances to the local
authorities? (p. W-l 7)
Does the facility meet its reporting requirement annually under Section 312 of EPCRA? (p. W-l 8)
For a large quantity generator (LQG), does the facility have a written contingency plan for
responding to spills and releases of hazardous wastes? (p. W-19)
Did the facility submit its written contingency plan to the appropriate authorities? (p. W-19)
For a small quantity generator (SQG), does the facility have the basic contingency procedures in
place? (p. W-20)
YD
YD
YD
YD
YD
YD
YD
YD
YD
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA-
NA'
NA
NA:
NAD
NAD
NAD
NAD
NAD
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E>
USTs
SPCC Plan
FRP
RMP
RCRA Emergency
Response Training
Air Conditioning
Repair Training
Pesticide Applicator
Certification
FRP Training
Program
NPDES
Rccordkeeping
Air Emissions
RCRA
USTs
Records of Pesticide
Application
Hiring Recyclers/
Reclaiming Services |
I VIRONMENTAL COMPLIANCE CHECKLIST FOR TERMINAL OPERAT
2.0 PIAN3N1NG AND REPORTED REQIHREMENTS (CONTINUED)
Has the State/Tribal underground storage tank (UST) program been notified of any USTs located on
site? (p. W-21)
Does the facility have a spill prevention, control, and countermeasures (SPCC) plan? (p. W-22)
Does the facility's SPCC plan include all of the required elements? (p. W-23)
Has the facility's SPCC plan been reviewed and certified by a professional engineer? (p. W-24)
Does the facility have a Facility Response Plan (FRP)? (p. W-24)
Does the FRP include all of the required elements? (p. W-25)
Does the facility have a Risk Management Plan (RMP)? (p. W-26)
3.G m4INMG REQUIREMENTS
Has the facility trained its employees on how to handle hazardous waste and emergencies?
(p. W-28)
Are refrigerant-containing appliances maintained and serviced by certified technicians? (p. W-29)
When applying restricted use pesticides (RUPs) on property, does the facility ensure that the
pesticide applicator is currently certified in the appropriate category? (p. W-29)
If an FRP is required, does the facility provide a facility response training program and oil spill
drill/exercise program for its employees? (p. W-30)
4.0 RECORDS MAINTENANCE
Does the facility keep records of monitoring information for the 3 year minimum requirement?
(p.W-31)
As part of the SWPPP, does the facility maintain records of incidents (e.g., spills or other
discharges) and other information describing the quality and quantity of storm water discharges?
(p. W-32)
As part of the SWPPP, does the facility maintain records documenting inspections and maintenance
activities? (p. W-32)
Does the facility meet the recordkeeping requirements of its air permit(s)? (p. W-32)
Does the facility keep copies of its manifests for the 3 year minimum requirement? (p. W-33)
Does the facility maintain records of its hazardous waste management training program? (p. W-33)
Does the facility maintain leak detection records? (p. W-35)
Does the facility maintain corrosion protection records? (p. W-35)
Does the facility maintain records showing that a system was repaired or upgraded? (p. W-35)
Does the facility maintain records of the site assessment results required for permanent closure for at
least 3 years after closing a UST? (p. W-36)
Does the facility maintain records that document its financial responsibility? (p. W-36)
Does the facility maintain accurate records of use and storage of pesticides? (p. W-37)
:::;'u:5^0 RECYCLERS AND RECLAIMING SERVICES
If selling used refrigerant, does the facility ensure that the reclaimer is certified? (p. W-38)
IONS
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
-
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
YD
-
ND
ND
ND
ND
ND
ND
No
-
ND
ND
ND
No
ND
ND
ND
ND
ND
No
ND
No
ND
ND
No
ND
ND
-
-
NA
NA
NA
NA
NA
; NA
NA
_
NA
NA
NA
NA
-ftv^-
NA
NA
NA
NAJ
NAJ
NA
NA|
NA|
NA
NA
NA
NA]
_
NA]
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Permit Requirements
SECTION 1.0 PERMIT REQUIREMENTS
I. I National Pollutant Discharge Elimination System
(NPDES) Permit Program
NOTE: The following questions, all of which are included in the accompanying checklist,
will help the facility examine its operations relating to NPDES permit program for
compliance with environmental requirements:
a. Has the facility obtained a National Pollutant Discharge Elimination
System (NPDES) permit? (p. W-2)
b. Has the facility submitted monitoring results on a discharge monitoring report
(DMR) form to its permitting agency? (p. W-3)
c. Has the facility complied with all reporting requirements specified by its
NPDES permit? (p. W-3)
d. Does the facility have a storm water pollution prevention plan (SWPPP)?
(p. W-4)
e. Does the facility's SWPPP include all of the required elements? (p. W-4)
1. Is a certification included in the SWPPP? (p. W-5)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Wastewater and Storm Water Management
Truck terminals may discharge wastewater and/or storm water from the following activities:
Vehicle and equipment cleaning
Painting and paint removal
Chemical storage and handling
Fueling
Building and grounds maintenance
Other activities.
Facilities that discharge wastewater and/or storm water directly into surface waters (stream,
river, wetland, etc.) or through any conveyance system, such as any pipe, ditch, tunnel, well,
container, landfill, vessel, etc., through which water flows and then discharges to surface water
must obtain a permit under the Clean Water Act (CWA) NPDES program.
NPDES permits contain industry-specific, technology-based and water quality-based discharge
limits and establish pollutant monitoring and reporting requirements. A facility intending to
discharge into the nation's waters must obtain a permit prior to initiating it. NPDES permits
also contain recordkeeping and possibly site-specific requirements. A facility that intends to
discharge into the waters of the United States must obtain an NPDES permit prior to initiating
it.
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August 2000
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Permit Requirements
Storm Water Discharges
Under the Clean Water Act, it is illegal to discharge any pollutants into navigable waters of the
United States from a point source unless the discharge is authorized by a National Pollutants
Discharge Elimination System (NPDES) permit. Storm water regulations have identified eleven
major categories that are associated with industrial activity (40 CFR ง 122.26 (b) (14) (i - x)).
Those facilities identified under these eleven categories must apply for NPDES permit for
storm water discharge. Transportation facilities are classified as category (viii) which includes
activities such as vehicle maintenance shops, equipment cleaning operations, painting, fueling
operations or airport deicing operations. Contact the state or federal permitting agency for
more information regarding NPDES discharge permitting requirements.
The following discharges do NOT require NPDES permits:
Introduction of sewage, industrial wastes or other pollutants into a publicly owned
treatment works (POTW) by indirect discharges. (Although not federally required, a
POTW may require a permit. A facility should contact the local sewer authority to find
out more about these requirements).
Discharges of dredged or fill material into waters of the United States. (These
discharges are regulated under CWA Section 404 permits.)
Discharges of storm water/wastewater into an underground injection well. [These
discharges are regulated under the Safe Drinking Water Act (SDWA) Underground
Injection Control (UIC)] program. For more information, contact the Safe Drinking
Water Hotline at 1-800-426-4791].
1.1 a Has the facility obtained a National Pollutant Discharge Elimination
System (NPDES) permit?
A facility must have an NPDES permits in order to discharge industrial wastewater
through a storm sewer or directly into surface waters. Persons responsible for
wastewater discharges requiring an NPDES permit must apply for an individual permit
or seek coverage under a general permit (if available) at least 180 days before
discharge of wastewater/storm water is scheduled to begin.
The wastewater may need treatment on site to reduce pollutant concentrations prior to
discharge to be in compliance with NPDES permit limits. Note: Some NPDES permits
may include both wastewater and storm water discharge requirements. Other facilities
have a separate permit for each type of discharge.
The EPA or an authorized state or territory can issue an NPDES permits. As of
September 1999, EPA has authorized 43 states and one territory to administer the
NPDES program. Of the authorized states and territory, only the Virgin Islands does
not have delegated authority for the storm water general permits program as well. EPA
has not delegated authority to the following states and territories: Alaska, Arizona,
District of Columbia, Idaho, Maine, Massachusetts, New Hampshire, New Mexico,
Pacific Territories, Puerto Rico, and Federal Tribal Lands. The facility should contact
EPA or the appropriate state regulatory agency to find out how to obtain a permit
application.
Q Yes
Facility has obtained an NPDES permit.
.
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August 2000
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Permit Requirements
Q Ato
Q NA
Facility has not obtained an NPDES permit, but requires one.
Facility does not discharge wastewater directly to a body of water.
1. 1b Has the facility submitted monitoring results on a discharge
monitoring report (DMR) form to its permitting agency?
NPDES permits may require a facility to routinely conduct monitoring of its wastewater
discharges and submit its monitoring results to the permitting authority (state or EPA).
You must submit monitoring results for wastewater and/or sludge analysis on a DMR
form. Your permit will specify the monitoring schedule.
Q yes Facility has submitted its monitoring results on a DMR form to its permitting
agency.
Q No Facility has not submitted its monitoring results on a DMR form to its
permitting agency.
Q NA Facility does not have applicable monitoring and reporting requirements.
1. 1c Has the facility complied with all reporting requirements specified by
its NPDES permit?
There are some reporting requirements that apply to all facilities. These requirements
are summarized below:
Event
Any noncompliance with your permit that may
endanger health or the environment
Other noncompliance
Any planned physical alterations or additions to
your facility
Any planned changes in your discharge that
may result in noncompliance
Notify the permitting authority of the transfer of
the facility to a new owner
Reporting Time Frame
Within 24 hours of becoming aware of violation;
written submission within 5 days
At the time the facility's monitoring reports are
submitted
As soon as possible
In advance of changes
As soon as possible
Q Yes Facility met the above reporting requirements within the required time
frame.
Q No Facility has not met the above reporting requirements within the required
time frame.
Q NA None of the above requirements has applied to the facility.
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
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Permit Requirements
1.1d Does the facility have a storm water pollution prevention plan
(SWPPP)?
If a facility must obtain an NPDES storm water permit, it will need to prepare and
implement an SWPPP. Facilities must SWPPPs to prevent storm water from coming in
contact with potential contaminants. An SWPPP is a step by step process for ensuring
that pollutants from the industrial activities are not making their way into storm water
discharges from the site.
Q Yes Facility has an SWPPP.
Q No Facility does not have an SWPPP.
Q NA Facility is not required to have an SWPPP.
1.1e Does the facility's SWPPP include all of the required elements?
SWPPPs are facility specific, because every facility is unique in its source, type, and
volume of contaminated storm water discharges. Therefore, SWPPPs will vary.
Regardless of the variations, all plans must include several elements, such as a map
and site specific considerations. The elements include:
Facility size and location
Climate
Hydrogeology: the environmental setting of each facility (e.g., water quality of
receiving stream)
Predicted flow of storm water discharges
Volume and type of storm water and pollutants that could potentially be
discharged.
SWPPPs must also address how the facility will complete the following activities:
Develop a pollution prevention team
Develop general and specific measures and controls to prevent or minimize
pollution of storm water (articulated as Best Management Practices in your plan)
Test outfalls
Train employees
Conduct inspections and evaluations
Conduct recordkeeping and reporting.
Q Yes Facility's SWPPP includes all of the required elements listed above.
Q No Facility's SWPPP does not include all of the required elements listed above.
Q NA Facility is not required to prepare an SWPPP.
Environmental Screening Checklist
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August 2000
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Permit Requirements
1.1f Is a certification included in the SWPPP?
Each SWPPP must include a certification, signed by an authorized individual, stating
that the facility must test the discharges from the site for the presence of non-storm
water discharges. The certification must include the following:
Description of possible significant sources of non-storm water,
Results of any test and/or evaluation conducted to detect such discharges,
The test method or evaluation criteria used, the dates on which
tests/evaluations were performed, and the on-site drainage points directly
observed during the test or evaluation.
If certification is not feasible, the SWPPP must describe why (e.g., no access to
discharge sites).
Q Yes Facility's SWPPP includes a certification.
Q No Facility's SWPPP does not include a certification, or certification is not
feasible and facility has included an explanation in the SWPPP.
Q NA Facility is not required to have an SWPPP.
See Section 4.1 for a list ofNPDES recordkeeping requirements.
1.2 Pretreatment Requirements
NOTE:
The following question, included in the accompanying checklist, will help the facility
examine its operations relating to the pretreatment program for compliance with
environmental requirements:
a.
If discharging to a municipal sanitary sewer, has the facility notified the
POTWand received approval for discharges? (p. W-6)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a " ) for environmental compliance.
Discharges to Local Publicly-Owned Treatment Works (POTWs)
POTWs are treatment plants that receive and treat wastewater through municipal sanitary
sewers prior to discharge to receiving waters (e.g., streams, lakes, rivers). One may also
referred to these as municipal wastewater treatment plants (WWTPs). POTWs may
implement a pretreatment program and regulate discharges to the sanitary sewer through
prohibitions on certain discharges, discharge limits, and discharge permits.
Facilities should contact their local POTW to see if any pretreatment requirements or limits
apply to them. To meet discharge limits and requirements, the owner or operator of the facility
that generates wastewater (e.g., from vehicle and equipment washing) may have to pretreat
the wastewater. Although contacting the POTW is not a federal requirements, the facility could
be liable if it discharges a significant amount of oil, or other fluid, and those discharges cause
the POTW to violate its own NPDES permit.
Environmental Screening Checklist
and Workbook for Terminal Operations
August 2000
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Permit Requirements
1.2a If discharging to a municipal sanitary sewer, has the facility notified
the POTWand received approval for discharges?
Q Yes Facility has contacted POTW and if necessary, received approval for
discharges.
Q No Facility has not contacted POTW or has not received approval for
discharges.
Q NA Facility does not discharge to a municipal sanitary sewer.
1.3 Underground Injection Control (UIC)
NOTE:
The following question, which is included in the accompanying checklist, will help
the facility examine its operations relating to UIC permits for compliance with
environmental requirements:
a.
If discharging to an underground injection control (UIC) well, does the
facility comply with UIC program requirements? (p. W-6)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
1.3a If discharging to an underground injection control (UIC) well, does the
facility comply with UIC program requirements?
Note: As a general rule, the
discharge of industrial wastewater
to UIC wells is NOT appropriate.
Facilities that discharge industrial wastewater
to underground injection control (UIC) wells
must comply with the rules established under
the UIC program. Truck terminal facilities may
typically use Class V UIC wells. Generally,
Class V wells include shallow non-hazardous
industrial waste injection wells, septic systems and storm water drainage wells. Class V
UIC wells (e.g., septic systems, storm water drainage wells) are authorized by rule
provided they do not endanger underground sources of drinking water and meet
certain minimum requirements.
UIC program requirements stipulate that the facility must submit basic inventory
information about a Class V well to the EPA or the primacy state agency. In addition,
many UIC primacy state programs have additional prohibitions or permitting
requirements. However, certain types of Class V wells release fluids that are very likely
to contain elevated concentrations of contaminants that may endanger drinking water.
Therefore, New requirements went into effect December 7, 1999, which further regulate
two (2) types of Class V wells, Large Capacity Cesspools and Motor Vehicle Waste
Disposal Wells. Note: See below for information relating to EPA's New rule regarding
Class V wells.
Q Yes Facility complies with UIC program requirements.
Q No Facility does not comply with UIC program requirements.
Q NA Facility does not discharge industrial wastewater to UIC wells.
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and Workbook for Terminal Operations
August 2000
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Permit Requirements
New Rule for Regulating Class V Wells
EPA is further regulating two (2) types of UIC Class V wells in Source Water Protection
Areas for community and non-transient non-community water systems that use groundwater
as follows:
Large-Capacity Cesspools. New cesspools are prohibited nationwide as of April 5, 2000,
and existing cesspools will be phased out nationwide by April 5, 2005.
Motor Vehicle Waste Disposal Wells. New wells are prohibited nationwide as of April 5,
2000. Existing wells in regulated areas will be phased out, but owners and operators can
seek a waiver and obtain a permit. For more information about this New rule, contact the
SDWA Hotline at 1-800-426-4791.
1.4 Air Emissions
NOTE: The following question, which is included in the accompanying checklist, will
help the facility examine its operations relating to air permits for compliance with
environmental requirements:
a. Does the facility have air permitfs)? (p. W-8)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Air Emissions
The federal Clean Air Act (CAA) and the Clean Air Act Amendments (CAAA) of 1990 regulate
air pollution in the United States. Although the CAA is a federal law, state and local air
pollution control agencies do much of the work in carrying out the act. It is important for you to
know all applicable federal, state, and local regulations, because in many instances, state and
local regulations may be more stringent than the federal regulations and/or include additional
requirements.
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August 2000
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Permit Requirements
l.4a Does the facility ha ve air permit(s) ?
States typically issue air pollution permits for certain operations such as painting and
surface preparation if operations meet certain state regulatory criteria are met.
Generally a permit is required if air pollution control equipment is used, such as a
baghouse or scrubber. Check with the state for specific criteria and requirements.
For more information on air emissions relating to truck terminal operations, refer to
http://www.trucking.org/greentruck/air_emissions/.
Q Yes Facility has air permits and they are current.
Permit No(s).:
Q No Facility has not obtained air permits.
Q NA Permits are not required.
See Section 4.2 for recordkeeping requirements for air emissions.
1.5 Wetlands
NOTE:
The following question, which is included in the accompanying checklist, will
help the facility examine its operations relating to wetlands for compliance with
environmental requirements:
a. Has the facility obtained a CWA Section 404 permit for any projects that
may impact wetlands? (p. W-9)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
CWA Section 404 Permits for Wetlands
Under Section 404 of the Clean Water Act (CWA), a facility must have a permit before
discharging dredged or fill material into U.S. waters, including most wetlands. Swamps,
marshes, bogs, vernal pools, playas, and prairie potholes are common names for wetlands.
Under the Section 404 Permit Program, the U.S. Army Corps of Engineers (Corps) reviews
permit applications to determine whether the project represents the least environmentally
damaging, practicable alternative, and to ensure that the project will not be contrary to the
public interest. Additionally, EPA typically provides the Corps with comments on permit
applications and has veto authority under Section 404.
The Corps issues permits as either individual or general permits. Individual permits are issued
on a case-by-case basis and are commonly required for larger projects. General permits may
be issued on a state, regional, or nationwide basis, and under certain conditions eliminate the
need for an individual permit. To determine whether your project will require an individual or
general permit, check with your local Corps office.
Environmental Screening Checklist
and Workbook for Terminal Operations
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Permit Requirements
i.Sa Has the facility obtained a CWA Section 4O4 permit for any projects
that may impact wetlands?
Q Yes Facility has obtained a permit for all projects impacting wetlands.
Q No Facility has not obtained a permit.
Q NA Facility is not planning any new projects at this time.
1.6 Resource Conservation and Recovery Act
(RCRA)
NOTE: The following questions, all of which are included in the accompanying checklist,
will help the facility examine its operations relating to RCRA hazardous waste
management for compliance with environmental requirements:
a. Does the facility generate hazardous waste? (p. W-11)
b. How much hazardous waste does the facility generate per month?
(p. W-11)
c. Does the facility have an EPA hazardous waste generator ID number?
(p. W-12)
d. How does the facility manage/dispose of its hazardous waste? (p. W-12)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
Identifying Hazardous Waste
If a facility thinks its waste is hazardous,
but is unsure, the facility should call the
RCRA/UST, Superfund, EPCRA Hotline
at 1-800-424-9346, or the Chemical
Referral Service Hotline at 1-800-262-
8200, which is maintained by the National
Chemical Manufacturer's Association.
Facilities with service and maintenance activities
may produce hazardous waste (e.g., certain
spent chemical solvents, spilled or unused fuels,
spilled or unusable paints and thinners, or rags
and absorbents used to clean up spills of
hazardous wastes). Therefore, it is important
that the facility identify and manage hazardous
wastes properly to protect the facility,
coworkers, and others in the community, as well
as the environment. As a waste generator, the
facility is responsible for all steps in hazardous waste management, from generation to final
disposal. A facility can be held liable for any mismanagement of its wastes, even after the
wastes leave the facility. Therefore, it is important for every facility to know the facts.
What is Hazardous Waste?
To be considered "hazardous waste," materials must first meet EPA's definition of "solid
waste." Solid waste is discarded material, such as garbage, refuse, and sludge, and can be
solids, semisoiids, liquids, or contained gaseous materials. Solid wastes that meet the
following criteria are hazardous and subject to regulations under the Resource Conservation
and Recovery Act (RCRA) (40 CFR Part 261):
Environmental Screening Checklist
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August 2000
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Waste Management
Listed waste. Waste is considered hazardous if it appears on one of four lists of
hazardous wastes published in 40 CFR Part 261 Subpart D. Currently, more than 400
wastes are listed. Wastes are listed hazardous because they are harmful to human health
and the environment when not properly managed. Even when properly managed, some
listed wastes are so dangerous that they are called "acutely hazardous wastes." Examples
of acutely hazardous wastes include wastes generated from some pesticides that can be
fatal to humans even in low doses.
Characteristic waste. If waste does not appear on one of the hazardous waste lists, it still
might be considered hazardous if it demonstrates one or more of the following
characteristics:
- Ignitable: Ignitable wastes can create fire under certain conditions (e.g., temperature,
pressure) or are spontaneously combustible (40 CFR 261.21). Examples include certain
used paints, degreasers, oils and solvents.
Corrosive: Corrosive wastes are acids or bases that are capable of corroding metal,
such as storage tanks, containers, drums, and barrels (40 CFR 261.22). Examples
include rust removers, acid or alkaline cleaning fluids, and battery acid.
- Reactive: Reactive wastes are unstable and explode or produce toxic fumes, gases,
and vapors when mixed with water (40 CFR 261.23). Examples include lithium-sulfide
batteries and explosives.
Toxic: Toxic wastes are harmful or fatal when ingested or absorbed, or leach toxic
chemicals into the soil or groundwater when disposed of on land (40 CFR 261.24).
Examples include wastes that contain high concentrations of heavy metals, such as
cadmium, lead, or mercury.
A facility can determine if its waste is toxic by having it tested using the Toxicity Characteristic
Leaching Procedure (TCLP), or by process knowledge. Result of the TCLP analysis is
available at a laboratory. It is designed to replicate the leaching process and other effects that
occur when wastes are buried in a typical municipal landfill. If the leachate from the waste
contains any of the regulated contaminants at concentrations equal to or greater than the
regulatory levels, then the waste exhibits the toxicity characteristic. Process knowledge is
detailed information on wastes obtained from existing published or documented waste analysis
data or studies conducted on hazardous wastes generated by similar processes. For example,
facilities can used EPA's lists of hazardous wastes in 40 CFR Part 261 (as discussed above)
as process knowledge.
Universal Waste Rule
In 1995, EPA issued the Universal
Waste Rule as an amendment to
RCRA to reduce the regulatory
burden on businesses by providing
an alternative and less stringent set
of management standards for three
types of waste that potentially would
be regulated as hazardous: (1) spent
batteries (e.g., nickel cadmium, small
sealed lead acid batteries that will not be reclaimed or regenerated at a battery
recycling/reclamation facility); (2) pesticides that have been suspended or canceled, including
Universal Waste Rule
On July 6, 1999, EPA issued a final rule called the
universal waste rule. This rule provides alternative, less
stringent procedures for several types of wastes such as
batteries, pesticides, mercury thermostats and lamps
including fluorescent. Copies of the rule and
corresponding fact sheet can be found at the
RCRA/UST, Superfund, EPCRA Hotline at
1-800-424-9346.
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August 2000
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Waste Management
those that are part of a voluntary or mandatory recall under the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) or by the registrant; and (3) mercury thermostats including
temperature control devices containing metallic mercury. Check with the state regulatory
agency to see if it has adopted the Universal Waste Rule. For additional information check
website: http://www.epa.gov/epaoswer/hazwaste/id/univwast.htm
1.6a Does the facility generate hazardous waste?
Q Yes Facility has gone through the waste determination process or used
process knowledge and determined that it does generate hazardous
waste.
Q No Facility has determined that it does not generate hazardous waste.
Q Not Facility has not gone through this process. Note: Facility must
determined immediately conduct this process to determine if it is generating a
hazardous waste.
1.6b How much hazardous waste does the facility generate per month?
When determining the volumes of waste generated, only waste in a container or other
unit waiting to be disposed of is "generated." Thus, solvent stored in a drum waiting
for disposal or recycling is "generated," while solvent in a parts cleaner that is currently
in use is not yet a waste and is not yet been generated.
The facility generates: (Pick one)
Q No more than 220 Ibs C700 kg) of hazardous waste per month. This is
approximately % of a 55-gallon drum or less of hazardous waste in any month. In
this case, the facility is considered a conditionally exempt small quantity
generator (CESQG) and an EPA identification (ID) number is not required.
Between 220 Ibs (100 kg) and 2,200 Ibs
(1,000 kg) of hazardous waste per month.
In this case, the facility generates 1/4 of a
55 gallon drum of hazardous waste, but
less than five 55 gallon drums of
hazardous waste in any month. In this
case, the facility is a small quantity
generator (SQG) and must have an EPA
ID number.
Over 2,200 Ibs (7,000 kg) of hazardous
waste per month. In this case, the facility
generates approximately five 55 gallon
drums or more of hazardous waste in any
month. In this case, the facility is a large
quantity generator (LQG) and must have
Note: If the facility is a CESQG and
generates no more than 2.2 Ibs
(1 kg) of acutely hazardous waste
(or 220 Ibs [700 kg] of hazardous
waste spill residues) in a calendar
month, and never stores more than
that amount for any period of time,
the facility may manage the acutely
hazardous waste according to the
CESQG requirements. If the facility
generates more than 2.2 Ibs (7 kg)
of acutely hazardous waste, it must
be managed according to the LQG
requirements.
an EPA ID number.
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Waste Management
' WK 9coฐAf haza,rdous waste generated includes only waste (1) defined as
nnt n Y A re8ulatlon8' & determined to be hazardous by the facility, and (3)
not otherw.se exempt from counting. For example, used oil that has not been mixed
with anything and is destined for recycling does not have to be counted.
cndarrnoth ff ed fa" ^ ^^ generation limits in any
calendar month are called episodic generators. If the amount of waste
generated m a given calendar month places the generator in a different category the
a^nT ฐTPly Wlth a" aPP|icable requirements of that category for all Jaste
h^rHo T h M undar m0nth' Fฐr examP|e' if a generator produces 300 kg of
hazardous waste ,n March, that waste is subject to SQG requirements; if the same
dUCeS 1'5ฐฐ k9 ฐf hazardous waste in April, that waste is subject to LQG
1.6c Does the facility have an EPA hazardous waste generator ID number?
If the facility is an SQG or LQG (as discussed in Question 1.6b), it must have an EPA
hazardous waste generator ID number. This requirement applies even for episodic
nnmh?r ^ฐ T ^ lnto the SQG or LQG categories for one month only. This
number must be entered on all hazardous waste manifests. It is usually near the top of
ins Torm undsr tns h^?3fi[nn "f^onar^frtr ir^ & ** if ซ ปAซซXซ. ^i .
iv , iu-<_4wu iy vjci id OLwl ILJ TT. na SI3TS ISsI Iฃ*Q Trlff* ni irviri^r fh^ r^i irv^l^^v
. -II xt -AL XL_ , *jiaL^ loouco LIic iiufiiDsr, ins numDฉr
wm start with the state abbreviation followed by the number (e.g., NY-12345678)
UESQGs do not need an identification number under federal law. Contact the state or
EPA regulatory agency to obtain a copy of EPA form 8700-12 "Notification of
PD?oAฐuS^aSte Activity-" For additional help, call the RCRA/UST, Superfund
EPCRA Hotline at 1-800-424-9346 or 703-412-9810. Mซ"u.,u,
Q Yes Facility has obtained an EPA ID permit as described above.
Q No Facility has not obtained an EPA ID number.
Q NA Facility is a CESQG and is not required to obtain an EPA ID number.
1.6d How does the facility manage/dispose of its hazardous waste?
Q Ships hazardous waste off site to:
A RCRA-permitted TSDF
A recycling facility
An interim status facility or
An exempt facility.
Q Disposes of hazardous waste on site and is a RCRA-permitted TSDF.
Q Other Note: If not managing hazardous waste by one of the above options facility
is out of compliance and must rectify the situation immediately.
Q NA Facility does not generate hazardous waste.
See Section 4.3 forRCRA recordkeeprng requirements.
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August 2000
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Planning and Reporting Requirements
SECTION 2.0 PLANNING AND
REPORTING REQUIREMENTS
2.1 Emergency Planning and Community Right-to-
Know Act (EPCRA) Planning Requirements
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its pperations relating to EPCRA planning for compliance with
environmental requirements:
a. Did the facility participate in emergency planning activities when it has
extremely hazardous substances (EHSs) in excess of their threshold
planning quantities (TPQs)? (p. W-14)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
EPCRA Planning Requirements
Title III of the Superfund Amendments and Reauthorization Act (SARA), also known as the
Emergency Planning and Community Right-to-Know Act (EPCRA) establishes requirements for
federal, state, and local governments, and industry regarding emergency planning and
"community right-to-know" reporting of hazardous and toxic chemicals. It requires industry to
report detailed information concerning the use, generation, and release of hazardous and toxic
materials.
The purpose of EPCRA is to: (1) encourage and support industry's emergency planning for
response to chemical accidents (in coordination with state and local governments) through
emergency planning and emergency notification; and (2) provide local governments and the
public with information about possible chemical hazards in their communities by requiring
facilities to report to federal, state and local authorities their hazardous chemical inventory and
toxic chemical releases.
The emergency planning sections (Sections 301-303) of EPCRA help state and local
government develop emergency response and preparedness capabilities through better
coordination and planning, especially with the local community.
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2.1 a
Did the facility participate in emergency planning activities when it
has extremely hazardous substances (EHSs) in excess of their
threshold planning quantities (TPQs)?
Under Section 302 of EPCRA, if a facility has any of the
400 extremely hazardous substances (EHSs) (e.g.,
ammonia, chlorine, nitric acid, sulfuric acid) listed in 40
CFR Part 355 in excess of their threshold planning
quantities (TPQs), the facility must notify its state
emergency response commission (SERC) within 60 days
that the facility is subject to emergency planning
requirements.
A threshold planning
quantity (TPQ) is the
amount of an extremely
hazardous substance (in
pounds) at a facility that
triggers a reporting
requirement. EHSs and
their TPQs are listed in
40 CFR Part 355.
In addition, the facility must participate in the local
emergency process and must provide any information to
the local emergency planning committee (LEPC) deemed necessary for development or
implementation of a local emergency plan.
a Yes The facility did participate in emergency planning activities.
Q No The facility did not participate in emergency planning activities.
Q NA The facility does not have any EHSs in excess of their TPQs, and so does not
required to participate in emergency planning activities.
2.2 EPCRA Emergency Notification
NOTE: The following questions, all of which are included in the accompanying checklist, will
help the facility examine its operations relating to EPCRA emergency notification for
compliance with environmental requirements:
a. Did the facility immediately notify the proper authorities after the facility
experienced an accidental release of a hazardous or extremely hazardous
substance, (p. W-15)
b. When reporting a spill, did the facility include the required information for
initial notification? (p. W-15)
c. After initial notification of any spills and releases, has the facility provided
a written follow-up emergency notice(s) to the proper emergency
agencies? (p. W-16)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
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2.2a Did the facility immediately notify the proper authorities after the
facility experienced an accidental release of a hazardous or extremely
hazardous substance?
Under Section 304 of EPCRA, you must immediately notify the Local Emergency
Planning Committees (LEPCs) and the State Emergency Response Commissions
(SERCs) likely to be affected, if there is a release into the environment of a hazardous
substance that exceeds the reportable quantity for that substance (40 CFR Part 355).
The substances (some are common to both lists) which are under these requirements
include:
"Extremely Hazardous Substances" listed in Appendices A and B of 40
CFR Part 355.
"Hazardous Substances" subject to emergency notification requirements
under CERCLA Section 103(a). These substances and reportable
quantities are in 40 CFR Section 302.4. Note: There are federally
permitted release exemptions of these substances that may be
applicable to your facility. Refer to your regulatory agency for more
information about these exemptions.
The LEPCs and SERCs will coordinate response activity to your spill or accident, and
prevent harmful effects to the public and community at large. In addition, if your
facility releases a CERCLA hazardous substance, you also must notify the National
Response Center (NRC) at 1-800-424-8802.
Q Yes The facility immediately notified the proper authorities.
Q No The facility did not immediately notify the proper authorities.
Q NA The facility did not experience any accidental releases of hazardous or
extremely hazardous substances.
2.26 When reporting a spill, did the facility include the required
information for initial notification?
Under EPCRA, you must notify the emergency authorities immediately upon
discovering a reportable spill. (The term immediately is not further defined.) Thus the
person making the report must use good judgement in determining how much time to
spend in collecting information prior to making the notification. One can notify by
telephone, radio, or in person. To the extent possible, provide the following information
(40 CFR 355.40):
Chemical name/identity of material(s) released
Whether the material(s) is an extremely hazardous or a hazardous
substance
Estimate of the quantity of any material that was released
Time and duration of the release
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Whether the release was to the air, water, and/or land
Any known or anticipated acute or chronic health risks associated with the
emergency
Proper precautions to take as a result of the release, including evacuation
Name and telephone number of the person(s) to be contacted for further
information.
Q Yes The facility included the information listed above to the extent practicable.
Q No The facility did not include the information listed above to the extent
practicable.
Q NA The facility has not experienced a spill of a hazardous or extremely
hazardous substance.
2.2c After initial notification of any spills and releases, has the facility
provided a written follow-up emergency notice(s) to the proper
emergency agencies?
After initial notification of spills and releases to the appropriate agencies, your facility
must provide a written follow-up emergency notice(s), as soon as practical after the
release. The follow-up notice(s) must update information provided in the initial notice
and provide information on actual response actions taken and advice regarding medical
attention for exposed individuals.
Q Yes Facility submitted a written follow-up emergency notice(s) that included all of
the information described here to proper emergency agencies.
Q No Facility did not submit a written follow-up emergency notice(s) or did not
submit one that included all of the information described above to the proper
emergency facilities.
Q NA The facility has not experienced a spill of a hazardous or extremely
hazardous substance.
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2.3 EPCRA Hazardous Chemical Reporting
NOTE: The following questions, all of which are included in the accompanying checklist,
will help the facility examine its operations relating to EPCRA hazardous chemical
reporting for compliance with environmental requirements:
a. Has the facility submitted the MSDSs or list of EPCRA extremely
hazardous substances to the local authorities? (p. W-17)
b. Does the facility meet its reporting requirement annually under Section
312 of EPCRA? (p. W-18)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
EPCRA Hazardous Chemical Reporting
Section 311 of EPCRA requires you to report to the SERC, LEPC, and local fire department
the presence of hazardous chemicals in excess of reporting thresholds at your facility (40 CFR
Part 370). This reporting is a one-time requirement unless new information becomes available
that reveals a chemical has an additional hazard. Additionally, this reporting requirement must
occur within 90 days for any new chemical in excess of the reporting threshold handled on site.
The chemicals subject to this requirement include:
EPCRA extremely hazardous substances (EHS) listed at 40 CFR Part 355
Appendix A in excess of 500 Ibs or the threshold planning quantity (TPQ),
whichever is lower (40 CFR 370.20); and
The Occupational Safety and Health Administration (OSHA) considers any chemical
in excess of 10,000 Ibs (40 CFR 370.20) hazardous.
2.3a Has the facility submitted the MSDSs or list of EPCRA extremely
hazardous substances to the local authorities?
To meet the Section 311 reporting requirement, the facility must submit to the LEPC,
the SERC, and the fire department either (1) the MSDSs (or copies), or (2) a list of the
EPCRA extremely hazardous substances and OSHA hazardous chemicals above
threshold quantities on site at the facility (40 CFR 370.21). (The list must include the
chemical or common name of each substance and must identify the applicable hazard
categories.)
Q Yes The facility has met the Section 311 reporting requirement.
Q No The facility has not met the Section 311 reporting requirement
Q NA The facility has none of the regulated chemicals above the threshold
quantities.
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2.3b Does the facility meet its reporting requirement annually under
Section 312 ofEPCRA?
Under Section 312 of EPCRA, your facility must meet an annual reporting requirement
if it has OSHA hazardous chemicals and EPCRA's EHSs in excess of reporting
thresholds. The reporting thresholds are 500 Ibs or the TPQ, whichever is lower for
EPCRA EHSs and 10,000 Ibs for an OSHA hazardous chemical. If exceeding the
reporting thresholds at any time in the preceding year, you must submit to the LEPC,
SERC, and the fire department an "Emergency and Hazardous Chemical Inventory
Form" by March 1 of the following year for those substances.
States may choose one of two formats for the chemical inventory forms: Tier I and Tier
II. The Tier I form provides aggregate information on hazardous chemicals and
includes estimates of the maximum and average daily amounts present and the
location of the chemicals. Tier II information is similar to Tier I information, except that it
must be chemical-specific, not aggregate information. Most states use Tier II reporting
forms.
Q Yes The facility met its annual reporting requirement under Section 312.
Q No The facility did not meet its annual reporting requirement under Section 312.
Q NA Facility has none of the regulated chemicals in excess of reporting
thresholds.
2.4 RCRA Contingency Plan
NOTE: TheJฐIIฐwing questions, all of which are included in the accompanying checklist
will help the facility examine its operations relating to RCRA contingency plans for
compliance with environmental requirements:
a. For a large quantity generator (LQG), does the facility have a written
contingency plan that includes all of the required elements? (p. W-19)
b. Did the facility submit its written contingency plan to the appropriate
authorities? (p. W-19)
c. For a small quantity generator (SQG), does the facility have basic
contingency procedures in place? (p. W-20)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
RCRA Contingency Plan
A contingency plan usually answers a set of "what if" questions such as "what if one of the
vapor degreasers leaks," or "what if there is an explosion and/or fire at a hazardous waste
storage area?" If you are a small or large quantity generator of hazardous waste, the
emergency preparedness requirements under the Resource Conservation and Recovery Act
(RCRA) require that you develop a contingency plan for responding to spills or releases of
hazardous wastes.
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What is hazardous waste?
Your waste is hazardous if (1) it appears on
one of four lists published in the hazardous
waste regulations (40 CFR Part 261); (2)
demonstrates one of the four hazardous waste
characteristics of ignitability, corrosivity,
reactivity, or toxicity; or (3) is a mixture of a
listed hazardous waste and other wastes. See
Section 1.5 for more information.
If you are a large quantity generator (LQG),
you must have a written contingency plan. If
you are a small quantity generator (SQG),
you must have basic contingency procedures
in place. A written contingency plan is not
federally required for SQGs or conditionally
exempt small quantity generators
(CESQGs), however, EPA strongly
recommends it. It is also important to check
with your state and local authorities for any -^^^^^^^^^^^^^^^^^^^^^^
additional contingency plan or emergency
preparedness requirements.
2.4a For a large quantity generator (LQG), does the facility have a written
contingency plan that includes all of the required elements?
The written contingency plan for an LQG must contain the following:
Instructions on what to do in the event of a fire, explosion, or release;
The arrangements agreed to by local police and fire departments, hospitals, and
state and local emergency response teams to provide emergency services;
An emergency coordinator (employee) responsible for assessing emergency
situations and making decisions to respond;
The names, addresses, and phone numbers of all person qualified to act as
emergency coordinators;
The location of all emergency equipment at the facility; and
An evacuation plan.
Q Yes Facility has a written contingency plan that addresses all of the requirements
listed above.
Q No Facility does not have a written contingency plan, or has one that does not
include all of the requirements listed above.
Q NA Facility is not an LQG and is not required to have a written contingency plan.
2.4b Did the facility submit its written contingency plan to the appropriate
authorities?
The facility must submit copies of the written contingency plan to the local police and
fire departments, hospitals, and state and local emergency response teams that may
be called upon to provide emergency services. The facility should maintain
documentation showing that local authorities have been notified.
Q Yes Facility submitted copies of the contingency plan to the appropriate
authorities.
Q No Facility has not submitted copies of the contingency plan to the appropriate
authorities.
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Q NA Facility is not required to have a written contingency plan.
2.4c For a small quantity generator (SQG), does the facility have basic
contingency procedures in place?
SQGs must have basic contingency procedures to follow in the event of an emergency.
These procedures include the following:
An emergency coordinator (employee) either at the facility or on call who is
responsible for coordinating all emergency response measures.
Information posted next to the telephone, including: (1) the name and number of the
emergency coordinator; (2) the locations of the fire extinguishers and spill control
material; and (3) the telephone number of the fire department.
Ensure that all employees are thoroughly familiar with proper waste handling and
emergency procedures.
Q Vies Facility has the basic contingency procedures.
Q No Facility does not have the basic contingency procedures.
Q NA Facility is not an SQG, and so is not required to follow basic contingency
procedures.
See Section 4.3 fora list ofRCRA recordkeeping requirements.
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2.5 Underground Storage Tanks (USTs)
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its operations relating to USTs for compliance with environmental
requirements:
a. Has the state/tribal underground storage tank (UST) program been notified
of any USTs located on site? (p. W-21)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
Underground Storage Tanks
A facility may have underground storage tanks
(USTs) to supply fuel for trucks or other vehicles.
USTs are also used to store used oil or fuel to run
emergency power generators. A UST is a tank
and any underground piping connected to the tank
that has at least ten percent of its combined
volume underground.
Note: USTs that store flammable
and combustible liquids must meet
provisions under the National Fire
Protection Association (NFPA) 30
Flammable and Combustible Liquids
Code. Requirements under NFPA
30 include provisions for tank
storage and piping systems.
To protect human health and the environment
from dangerous releases, USTs must have leak
detection and spill, overfill, and corrosion
protection. Other UST requirements address notification, installation, corrective action,
financial responsibility, and recordkeeping. Tanks installed after 1988 heed to comply with all
UST requirements upon installation. Tanks installed before 1988 had until December 1998 to
comply with spill, overfill, and corrosion protection requirements, so these USTs should be in
compliance with all requirements now. For more information on USTs, visit EPA's Office of
Underground Storage Tanks website at http://www.epa.gov/OUST/.
Some USTs are not covered by federal regulations (e.g., tanks storing heating oil used on
premises where it is stored, tanks on or above the floor of underground areas, such as
basements or tunnels, emergency spill and overflow fill tanks); however, the state, tribal, or
local regulatory agency may regulate such USTs. Be sure to ask these agencies if additional
or more stringent requirements apply to the facility.
2.5a Has the State/Tribal UST program been notified of any USTs located
on site?
Facilities with on-site regulated UST systems must to submit a notification form to the
responsible state/tribal Underground Storage Tank (UST) program. The form includes
certification of compliance with federal requirements for installation, cathodic protection,
release detection, and financial responsibility for UST systems installed after December
22, 1988. For more information on how to obtain and complete the form, call EPA's
UST Hotline at 1-800-424-9346.
Q Yes Facility has submitted a notification form to the responsible state/tribal UST
program office.
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Q No Facility has not submitted a notification form to the responsible state/tribal
UST program office.
Q NA Facility has no USTs.
2.6 Spill Prevention, Control, and Counter-measures
(SPCC) Plan
NOTE: The following questions, which are included in the accompanying checklist, will help
the facility examine its operations relating to SPCC plans for compliance with
environmental requirements:
a. Does the facility have a spill prevention, control, and countermeasures
(SPCC) plan? (p. W-22)
b. Does the facility's SPCC plan include all of the required elements?
(p. W-23)
c. Has the facility's SPCC plan been reviewed and certified by a professional
engineer? (p. W-24)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
SPCC Plan
In 1973, EPA issued the Oil
Pollution regulation (40 CFR Part
112) to address the oil spill
prevention provisions contained in
the Clean Water Act (CWA) of
1972. The regulation forms the
basis of EPA's oil spill prevention,
control, and countermeasures
(SPCC) program, which seeks to
prevent oil spills from certain
aboveground and underground
storage tanks.
On December 2, 1997, EPA proposed a rule called the
Oil Pollution Prevention and Response; Non-
Transportation Related Onshore and Offshore
Facilities - Proposed Rule. It eliminates the
requirement of preparing an SPCC plan for those non-
transportation related facilities having an aboveground
capacity in excess of 660 gallons, as long as the facility
stores 1,320 gallons or less of oil. This rule is expected
to become final in October 2000. For more information,
call EPA's RCRA/UST, Superfund, and EPCRA
Hotline at 1-800-424-9346.
2.6a Does the facility have a spill prevention, control, and
countermeasures (SPCC) plan?
A facility must have an SPCC plan if it:
Has an aboveground storage capacity of more than 660 gallons in a single AST or
more than 1,320 gallons in multiple ASTs, or a total underground storage capacity
of 42,000 gallons; and
Could reasonably be expected to discharge oil in harmful quantities into navigable
waters of the United States.
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Note that the limits are different for above and below ground tanks. When adding
totals, the capacity:
Includes amount of oil that could be held (e.g., 1,500-gallon tank with 350 gallons of
oil would still count as 1,500 gallons toward the total).
Includes oil stored in drums, buckets, etc. (e.g., 1,600-gallon aboveground tank,
plus a 1,500-gallon aboveground tank, plus five 55-gallon drums would equal 3,375
gallons total storage).
The SPCC plan must be maintained on site if the facility is normally manned for at least
8 hours per day. Otherwise, it must be kept at the nearest field office.
Q yes Facility meets the criteria listed above, and has an SPCC plan.
Q No Facility meets the criteria listed above, but does not have an SPCC plan.
Q NA Facility does not meet the criteria listed above, and does not have an SPCC
plan.
2.6b Does the facility's SPCC plan include all of the required elements?
The facility must maintain the SPCC plan on site if the facility is normally manned for at
least eight hours per day. Otherwise, it must be at the nearest field office. An SPCC
plan is a written description of how a facility's operations comply with the prevention
guidelines under the Oil Pollution Prevention regulation. Each SPCC plan, while
unique to the facility it covers, must include certain elements to ensure compliance with
the regulations. These elements include:
Written descriptions of any spills occurring within the past year, corrective actions
taken, and plans for preventing their recurrence.
A prediction of the direction, rate of flow, and total quantity of oil that could be
discharged where experience indicates a potential equipment failure.
A description of secondary containment
and/or diversionary structures or equipment
to prevent discharged oil from reaching
navigable waters.
If containment and/or diversionary
equipment or structures are not practical,
a strong oil spill contingency plan and a
written commitment of manpower,
equipment, and materials to quickly
control and remove spilled oil.
Secondary Containment
Under SPCC guidelines, all storage tank
installations should be constructed so
that secondary containment is provided
for the entire contents of the largest
single tank plus sufficient freeboard to
allow for precipitation. Diked areas
should be sufficiently impervious to
contain spilled oil. If dikes are not
appropriate, a facility may use an
alternative system.
A complete discussion of the spill
prevention and control measures applicable to the facility and/or its operations.
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An SPCC plan is not the same as a "hazardous materials plan," or an "emergency
response plan." However, some facilities may combine the SPCC plan with another
plan. If this is done, the plan should include wording such as "spill control and
emergency response plan." For more information refer to EPA's website at
http://www.epa.gov/oerrpage/oilspill/spccplan.htm.
Q Yes The SPCC plan includes all of the elements listed above.
Q No The SPCC plan does not include all of the elements listed above.
Q NA Facility is not required to have an SPCC plan.
2.6c Has the facility's SPCC plan been reviewed and certified by a
professional engineer?
A professional engineer must review the facility's SPCC plan and certifies it. After initial
certification, a registered professional engineer must review the SPCC plan and
approves it once every 3 years. Furthermore, the plan must be modified within six
months if a "significant change" occurs at your facility. Review and appropriate
modification must occur when new field-proven technology has been developed that
will significantly reduce the likelihood of a spill at the facility.
Q Yes The facility's SPCC plan is certified by a professional engineer.
Q No The facility's SPCC plan is not certified by a professional engineer, or has
not been reviewed once every 3 years by a professional engineer.
Q NA Facility is not required to have an SPCC plan.
2.7 Facility Response Plan (FRP)
NOTE: The following questions, which are included in the accompanying checklist, will help
the facility examine its operations relating to facility response plans for compliance
with environmental requirements:
a. Does the facility have a Facility Response Plan (FRP)? (p. W-24)
b. Does the FRP include all of the required elements? (p. W-25)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
2.7a Does the facility have a Facility Response Plan (FRP)?
The Oil Pollution Act (OPA) amends the Clean Water Act (CWA) to include
requirements for facility response plans (FRPs). An FRP is required if your facility
could cause "substantial harm" to the environment. A facility has the potential to cause
substantial harm if [40 CFR 112.20(f)(1)]:
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(1) The facility transfers oil over water to or from vessels and has a total oil storage
capacity, including both aboveground storage tanks (ASTs) and USTs greater than
or equal to 42,000 gallons; or
(2) The facility's total oil storage capacity, including both ASTs and USTs, is greater
than or equal to one million gallons and one of the following is true:
The facility does not have secondary containment for each aboveground storage
area sufficient to contain the capacity of the largest AST within each storage area
plus freeboard to allow for precipitation;
The facility is located at a distance such that a discharge could cause injury to an
environmentally sensitive area;
The facility is located at a distance such that a discharge would shut down a
public drinking-water intake; or
The facility has had a reportable spill greater than or equal to 10 000 gallons
within the last five years.
A facility may make the determination whether the could cause substantial harm to the
environment through two methods:
(1) Through a self-selection process (EPA has established criteria located in 40 CFR
Part 112, Appendix C, to assist facilities in making that determination).
(2) By determination of the EPA Regional Administrator (which is based on factors
similar to the self-selection factors, and also type of transfer operations at the
facility, the facility's oil storage capacity, lack of secondary containment, proximity to
environmentally sensitive areas, or drinking-water intakes, and/or the facility's spill
history). K
Q VGS Facility has an FRP.
Q A/o Facility does not have an FRP.
Q NA Facility is not required to have an FRP.
2.7b Does the FRP include all of the required elements?
FRPs must address certain critical items, including the following:
Be consistent with the National Contingency Plan (NCP) and the Area Contingency
Plan covering your location;
Identify a qualified individual having full authority to implement removal actions and
require immediate communication between that person and the appropriate federal
authorities and responders;
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Identify and ensure availability of resources to remove, to the maximum extent
practicable, a worst-case discharge;
Describe training, testing, unannounced drills, and response actions of persons at
the facility;
Be updated periodically; and
Be submitted for approval with each significant change.
Q Vies Facility's FRP includes all of the elements listed above.
Q No Facility's FRP does not include all of the elements listed above.
Q NA Facility is not required to have an FRP.
2.8 Risk Management Plan (RMP)
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its operations relating to risk management plan for compliance with
environmental requirements:
a. Does the facility have a Risk Management Plan (RMP)? (p. W-26)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
Risk Management Plans
Under Section 112(r) of the Clean Air Act (CAA), EPA must establish a program to prevent
accidental chemical releases (Chemical Accidental Release Rule). The main goal of this
regulation is to communicate potential risks to the public and to ensure that facilities have
implemented a baseline safety management program to reduce the possibility of a release.
The primary tool to accomplish this goal is the Risk Management Plan (RMP).
The plan the facility submits to EPA will summarize the program and must be made available
to the public. The facility submits the plan for EPA review for accuracy and completeness.
The EPA, state, or local agency conducts a site visit at the facility to determine whether the
plan accurately reflects its risk management program in operation. For more information
about risk management planning requirements, see EPA's Office of Chemical Emergency
Preparedness and Prevention's website at http://www.epa.gov/ceppo/.
2.8a Does the facility have a Risk Management Plan (RMP)?
The facility must develop an RMP if it facility stores any of the 140 regulated
substances (e.g., propane) identified under the CAA's Section 112(r) at, or above,
specific threshold quantities for those chemicals. Sources should have complied with
the rule by June 20, 1999. If the facility does not already have an RMP, it must develop
one as soon as possible.
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Under Section 112(r) of the CAA, an RMP must include the following:
Documentation of process safety information
Process hazard analysis of the off-site impact of an accident
Documentation of operating procedures
Training program
Pre-startup reviews
Maintenance program
Management of Change Program
Accident investigation
Emergency response program
Safety audits
Registration with the Chemical Safety and Hazard Investigation Board
Hazard assessment of worst-case scenario
Submittal of RMP to EPA, SERC, LEPC, and available for public review.
Q Yes Facility has an RMP.
Q No Facility does not have an RMP.
rj NA Facility is not required to have an RMP.
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Training Requirements
SECTION 3.0 TRAINING REQUIREMENTS
3.1 RCRA Emergency Response Training
3.1 a
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its operations relating to RCRA emergency response training for
compliance with environmental requirements:
a. Has the facility trained its employees on how to handle hazardous waste
and emergencies? (p. W-28)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
Has the facility trained its employees on how to handle hazardous
waste and emergencies?
Under the Resource Conservation and Recovery Act (RCRA), small quantity generators
(SQGs) and large quantity generators (LQGs) must train employees on procedures for
properly handling hazardous waste and emergency procedures. The LQGs must
formalize and have employees complete the training within six months of accepting a
job involving the handling of hazardous waste. In addition, facility personnel must take
part in an annual review of the initial training. Furthermore, employees who are
responding to releases of hazardous substances and hazardous wastes must be
trained under OSHA's Hazardous Waste1 Operations and Emergency Response
(HAZWOPER) requirements. (See discussion under Question 1.5b for definitions of
LQGs and SQGs.)
Q Yes The facility has trained its employees as described above.
Q No Facility has not trained its employees as described above.
Q NA Facility is not an LOG or an SQG and, therefore, not required to provide
hazardous waste management training.
3.2 Air Conditioning Repair Training
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its operations relating to air conditioning repair training for compliance
with environmental requirements:
a. Are refrigerant-containing appliances maintained and serviced by certified
technician? (p. W-29)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
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Training Requirements
3.2a Are refrigerant-containing appliances maintained and serviced by
certified technician?
If the facility uses or employs technicians to service and maintain refrigerant-containing
appliances, they must be certified by an EPA-approved technician certification program.
(Contact the Stratospheric Information Hotline at 1-800-296-1996 for a list of
certifying organizations.)
Q Yes The facility ensures that all technicians are certified.
Q No The facility does not ensure that all technicians are certified.
Q NA The facility does not service or maintain refrigerant-containing appliances.
3.3 Pesticide Applicator Certification
NOTE: The following question, which is included in the accompanying checklist, will help
the facility examine its operations relating to pesticide applicator certification for
compliance with environmental requirements:
a. When applying restricted use pesticides (RUPs) on property, does the
facility ensure that the pesticide applicator is currently certified in the
appropriate category? (p. W-29)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
3.3a When applying restricted use pesticides (RUPs) on property, does the
facility ensure that the pesticide applicator is currently certified in the
appropriate category?
EPA classifies certain pesticides as restricted use pesticides (RUPs) based on toxicity or
environmental hazard as opposed to non-restricted use pesticides which do not require
certified RUP applicators. The facility will know if the pesticide is classified as a restricted
use pesticide (RUP) by reading the label. These pesticides may be applied only by a
certified applicator or under the direct supervision of a certified applicator. States oversee
the program for the certification of applicators of restricted use pesticides. Facilities that
are interested in having their personnel become certified applicators should contact their
State. For a list of state FIFRA/Pesticides contacts, see the Transportation
Environmental Resource Center's website at
http://www.transource.org/greentruck/state/fifrah.htm.
Q Ves The RUP pesticide applicators are currently certified and trained.
Q No The RUP pesticide applicators are not certified and trained.
Q NA The facility does not apply restricted use pesticides on its property.
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Training Requirements
3.4 FRP Training Program
NOTE: The following question, which is included in the accompanying checklist, will help
the facility examine its operations relating to facility response plan training for
compliance with environmental requirements:
3.4a
a. If an FRP is required, does the facility provide a facility response training
program and oil spill drill/exercise program for its employees? (p. W-30)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
If an FRP is required, does the facility provide a facility response
training program and oil spill drill/exercise program for its
employees?
If the facility must have a facility response plan (FRP), it also must develop and
implement a facility response training program. Training must be specific in nature and
scope to the responsibilities of facility personnel identified in the facility response plan.
In addition, the facility must develop and implement an oil spill drill/exercise program.
The drill/exercise program is comprised of tabletop and deployment exercises that are
both announced and unannounced, as well as participation in larger area drills and
exercises. To satisfy the drill/exercise program, the facility may participate in the
federal government's Preparedness for Response Exercise Program.
Q Yes
a NO
Facility has a facility response training program and oil spill drill/exercise
program for its employees.
Facility did not develop and implement a facility response training program
and/or an oil spill drill/exercise program for its employees.
Q NA Facility is not required to have an FRP.
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Records Maintenance
SECTION 4.0 RECORDS MAINTENANCE
4.1 NPDES Recordkeeping
NOTE: The following questions, which are included in the accompanying checklist, will help
the facility examine its operations relating to NPDES recordkeeping for compliance
with environmental requirements:
a. Does the facility keep records of monitoring information for the 3 year
minimum requirement? (p. W-31)
b. As part of the SWPPP, does the facility maintain records of incidents (e.g.,
spills or other discharges) and other information describing the quality
and quantity of storm water discharges? (p. W-32)
c. As part of the SWPPP, does the facility maintain records documenting
inspections and maintenance activities? (p. W-32)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
4.1 a Does the facility keep records of monitoring information for the 3 year
minimum requirement?
It is extremely important to keep accurate records of monitoring information. The
facility must report monitoring results for wastewater discharges on a Discharge
Monitoring Report (DMR) form to the NPDES permitting agency. The permit will specify
the monitoring and reporting schedule. Permit writers determine such requirements on
a facility-specific basis. Records of monitoring information under the NPDES program
must include:
The date, exact place, method, and time of sampling and the names of the person
or persons taking the samples;
The dates analyses were performed;
Who performed the analyses;
The analytical techniques or methods used;
The results of such analyses.
NPDES permits require that all records related to monitoring be maintained at the
facility for at least 3 years. Note: Many states require these records to be maintained
for at least 5 years.
Q Yes Facility maintains monitoring records as described above.
Q No Facility does not maintain monitoring records listed above and/or for a
minimum of 3 years.
Q NA Facility does not have wastewater discharges.
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4.1b As part of the SWPPP, does the facility maintain records of incidents
(e.g., spills or other discharges) and other information describing the
quality and quantity of storm water discharges?
Q Yes Facility maintains records as described above.
Q No Facility does not maintain records as described above.
Q NA Facility is not required to have an SWPPP.
4.1c As part of the SWPPP, does the facility maintain records documenting
inspections and maintenance activities?
Q Yes Facility maintains records as described above.
Q No Facility does not maintain records as described above.
Q NA Facility is not required to have an SWPPP.
4.2 Air Emissions Recordkeeping
NOTE: The following question, which is included in the accompanying checklist, will help
the facility examine its operations relating to air emissions recordkeeping for
compliance with environmental requirements:
a. Does the facility meet the recordkeeping requirements of its air permit(s)?
(p. W-32)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
4.2a Does the facility meet the recordkeeping requirements of its air
permit(s)?
States may require facilities that conduct certain operations (e.g., parts cleaning,
painting/paint removal, construction) obtain an air permit. Air permits often require
recordkeeping to verify permit compliance. Contact the state or local air pollution
control agency for more information.
Q Yes Facility meets the recordkeeping requirements of its air permit(s).
Q No Facility does not meet the recordkeeping requirements of its air permit(s).
Q NA Facility is not required to have an air permit.
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Records Maintenance
4.3 RCRA Recordkeepmg
NOTE: The following questions, which are included in the accompanying checklist, will help
the facility examine its operations relating to RCRA recordkeeping for compliance
with environmental requirements:
a. Does the facility keep copies of its manifests for the 3 year minimum
requirement? (p. W-33)
b. Does the facility maintain records of its hazardous waste management
training program? (p. W-33)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
4.3a Does the facility keep copies of its manifests for the 3 year minimum
requirement?
The facility must meet various recordkeeping requirements as part of its hazardous
waste management obligations. The Uniform Hazardous Waste Manifest Form is a
multi-copy shipping document that reports the contents of the shipment, the transport
company used, and the treatment/disposal facility receiving the wastes. The hazardous
waste generator, the transporter, and the treatment/disposal facility must each sign this
document and keep a copy. The waste disposal/treatment facility also must send a
copy back to the generating facility, so it can be sure that its shipment was received. A
copy of the manifest must be at the generating facility for 3 years or until a signed copy
of the manifest is received from the waste disposal/treatment facility. The signed copy
of the manifest must be kept on file for 3 years.
Q Vies Facility maintains a copy of its manifest for a minimum of 3 years.
Q No Facility has not maintained a copy of its manifest for a minimum of 3 years.
Q NA Facility does not generate hazardous waste.
4.3b Does the facility maintain records of its hazardous waste
management training program?
As discussed in Section 3.1, large quantity generators (LQGs) must provide its
employees a hazardous waste management training program within 6 months after the
date of employment or assignment to a facility, or to a new position at the facility,
whichever is later. The owner or operator of an LQG facility must maintain records of
its training program, including:
(1) The job title and name of employee for each position at the facility related to
hazardous waste management.
(2) A written job description for each position which must include the requisite skill,
education, or other qualifications, and duties assigned for each position.
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(3) A written description of the type and amount of both introductory and continuing
training given to each person filling a position.
(4) Records that document the training or job experience required has been given to
and completed by facility personnel.
Q Yes Facility maintains all documentation listed above.
Q No Facility does not maintain all required documentation.
Q NA Facility is not an LQG and therefore not required to provide a hazardous
waste training program.
4.4 Underground Storage Tanks Recordkeeping
NOTE: The following questions, which are included in the accompanying checklist, will help
the facility examine its operations relating to recordkeeping for USTs for compliance
with environmental requirements:
a. Does the facility maintain leak detection records? (p. W-35)
b. Does the facility maintain corrosion protection records? (p. W-35)
c. Does the facility maintain records showing that a repaired or upgraded
system was properly repaired or upgraded? (p. W-35)
d. Does the facility maintain records of the site assessment results required
for permanent closure for at least 3 years after closing a UST? (p. W-36)
e. Does the facility maintain records that document its financial
responsibility? (p. W-36)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
UST Recordkeeping Requirements
A facility can use underground storage tanks (USTs) to store product or waste. Facilities with
USTs are responsible for assuring that there are not leaks or spills from USTs. For example, a
facility must assure that USTs maintain their integrity and are protected from spills, overfills,
and corrosion. A facility should regularly review areas around the tanks to observe any signs
of tank spills, overflows, and leaks. In addition, facilities must maintain all records including
permits, registrations, and installation or closure records, and submit appropriate notification
information to EPA or the state implementing agency. A facility will have to keep records that
are available to an inspector during an on site visit to prove the facility meets certain
requirements. The facility must keep these records long enough to show the facility's recent
compliance status in five major areas: (1) leak detection; (2) overflow, spill, and corrosion
protection; (3) corrective actions; (4) closure; and (5) financial responsibility.
Facilities should check their regulatory authority about specific recordkeeping requirements.
Generally, a facility should follow this useful rule of thumb for recordkeeping: When in doubt,
keep it.
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4.4a Does the facility maintain leak detection records?
The facility will have to keep records of leak detection performance and maintenance
information including the following:
The last year's monitoring results and the most recent tightness test;
Copies of performance claims provided by leak detection manufacturers; and
Records of recent maintenance, repair, and calibration of on-site leak detection
equipment.
O Yes Facility maintains records listed above on site.
Q No Facility does not maintain all records listed above on site.
Q NA Facility does not have a LIST.
4.4b Does the facility maintain corrosion protection records?
Corrosion protection records include results of last two tests proving the cathodic
protection system is working and the last three inspections proving that impressed
current systems are operating properly.
Q Yes Facility maintains corrosion protection records on site.
Q No Facility does not maintain corrosion protection records on site.
Q NA Facility does not have a UST.
4.4c Does the facility maintain records showing that a repaired or
upgraded system was properly repaired or upgraded?
Q Vies Facility maintains records as described above.
Q No Facility does not maintain records as described above.
Q NA Facility does not have a UST.
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Records Maintenance
4.4d Does the facility maintain records of the site assessment results
required for permanent closure for at least 3 years after closing a
UST?
These results are important because they show the impact of a facility's UST on the
surrounding area.
Q Yes Facility maintains records for at least 3 years after closing a UST
as required.
Q Wo Facility does not maintain records for at least 3 years after closing a UST
as required.
Q NA Facility has not closed any USTs.
4.4e Does the facility maintain records that document its financial
responsibility?
Financial responsibility documentation shows one of the following. The facility:
Participates in a state financial assurance fund;
Has insurance coverage;
Has a guarantee from another firm;
Has a surety bond;
Has a letter of credit;
Has passed a financial test;
Has set up a trust fund; or
Uses another financial method(s) of coverage approved by the state.
Q Yes Facility maintains records that document financial responsibility.
Q No Facility does not maintain records that document financial responsibility.
Q NA Facility does not have a UST.
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Records Maintenance
4.5 Records of Pesticide Application
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its operations relating to records of pesticide application for
compliance with environmental requirements:
a. Does the facility maintain accurate records of use and storage of
pesticides? (p. W-37)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
4.5a Does the facility maintain accurate records of use and storage of
pesticides?
Best management practices (BMPs) for pesticides include keeping accurate records of
use and storage. Records of use are useful to track when the next application should
occur to control weed or pest problems. Label directions can determine the frequency
of application. Records of stored pesticides allow for inventory management so that
oldest pesticides can be used first. Then a facility avoids purchasing excess pesticides.
In addition, accurate recordkeeping for pesticide storage can be crucial in the event of
an accidental spill or fire so that emergency responders can know exactly the hazards
posed.
Q Yes Facility maintains accurate records of use and storage of pesticides.
Q No Facility does not maintain accurate records.
Q NA Facility does not use pesticides.
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Recyclers and Reclaiming Services
SECTION 5.0 RECYCLERS AND
RECLAIMING SERVICES
5.1 Hiring Recyclers and Reclaiming Services
NOTE: The following question, which is included in the accompanying checklist, will help the
facility examine its operations relating to hiring recyclers and reclaiming services for
compliance with environmental requirements:
a. If selling used refrigerant, does the facility ensure that the reclaimer is
certified? (p. W-38)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a "*O for environmental compliance.
5.1 a If selling used refrigerant, does the facility ensure that the reclaimer
is certified?
Under Section 608 of the Refrigerant Recycling Rule, if a facility wants to sell used
refrigerant, an EPA-certified reclaimer must process it. To reclaim refrigerant means to
reprocess the refrigerant to at least the purity specified in the ARI Standard 700-1993,
Specifications for Fluorocarbon Refrigerants and to verify this purity using tests
prescribed in Standard 700-1993.
Q Vies Facility ensured that the reclaimer was certified.
Q No Facility did not ensure that the reclaimer was certified.
Q NA Facility does not sell used refrigerant.
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Glossary of Terms
GLOSSARY OF TERMS
Aboveground storage tank: Any tank or other container that is aboveground, partially buried,
bunkered, or in a subterranean vault. This includes floating fuel system.
Acute Hazardous Waste: Commercial chemical products and manufacturing intermediates
having the generic names listed in 40 CFR 261.33; off-specification commercial chemical
products and manufacturing chemical intermediates which, if they met specification, would
have the generic names listed; any residue or contaminated soil, water, or other debris
resulting from the cleanup of a spill of any of these substances; any residue remaining in
containers that are not empty by RCRA standards (40 CFR 261.7)
Aquifer: A saturated water bearing formation of permeable rock, sand, or gravel.
Ambient Standards: Standards for the quality of outdoor air.
Asbestos: A naturally occurring fibrous mineral used in buildings for its heat retarding
properties that may cause serious respiratory problems if inhaled. CAA regulates removal and
disposal.
Caustic: Any substance which can burn, dissolve, corrode, or eat away by chemical reaction.
CERCLA Hazardous Substances: CERCLA Section 101(14), as amended, defines
"hazardous substance" by referencing other environmental statutes, including: CWA Sections
311 and 307(a); CAA section 112; RCRA Section 3001; and TSCA Section 7. A list of over
600 CERCLA hazardous substances is provided in 40 CFR 302.4. EPA has the authority to
designate additional hazardous substances not listed under the statutory provisions cited
above.
CFR: Code of Federal Regulations. A codification of the regulations published by federal
government agencies.
Chlorofluorocarbons (CFCs): The chemical group found in refrigerants such as freon and in
propellants for aerosol containers. These chemicals have been determined to be partially
responsible for depletion of ozone levels in the upper atmosphere.
Civil Penalties: Monetary penalties which can be imposed on companies and individuals for
violations of civil laws and regulations.
Clean Air Act (CAA): The federal law designed to improve air quality by regulating air pollution
emission from stationary and non-stationary sources. The Act includes National Ambient Air
Quality Standards (NAAQS) for specific pollutants.
Cleanup: Actions taken to deal with a release or threat of a hazardous substances release
that could affect people or the environment. The term "cleanup" is sometimes used
interchangeably with the terms "remedial action," "removal action," "response action," "remedy,"
"remediation," or "correction action."
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Glossaiy of Terms
Cleanup Operation: An operation in which hazardous substances are removed, contained,
incinerated, neutralized, stabilized, cleaned up, or in any other manner processed or handled
with the ultimate goal of making the site safer for people or the environment.
Clean Water Act (CWA): The purpose of this federal law is to restore and maintain the water
quality of lakes, streams and rivers. This goal is being pursued by controlling both point
sources and non-point sources of discharge into surface water.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
The federal law established in 1980 to identify, investigate, and clean up sites that might
release hazardous substances into the environment. It also established funding for these
cleanup projects (commonly called Superfund) and procedures for recovering any fund money
expended. CERCLA also requires the reporting of spills and releases of hazardous
substances.
Conditionally Exempt Small Quantity Generators: Hazardous waste generators who are
basically exempt from the majority of RCRA regulations due to the small amounts generated
and the low frequency of production. One must generate less than 100 kilograms of hazardous
waste per month, or less than 1 kg of acute hazardous waste to qualify as a conditionally
exempt small quantity generator.
Container: Any portable device in which a material is stored, transported, treated, disposed of,
or otherwise handled, including drums, pails, buckets, and inner liners.
Corrosive: Material with a pH of less than 2.0 or greater than 12.5 or a material capable of
dissolving or wearing away steel at a rate greater than 0.25 inch per year.
Cradle-to-Grave: The Resource Conservation and Recovery Act requirement for management
and tracking of hazardous waste is documented from the source of the waste (i.e., generator)
through its transportation, to treatment, storage and eventually acceptance by a disposal
facility.
Criminal Penalties: Penalties imposed for a willful and/or knowing violation of a criminal law.
They include monetary fines for companies and individuals and jail time for individuals.
Department of Transportation (DOT): The federal agency that regulates the transport of
hazardous materials under the Hazardous Materials Transportation Act. These materials
include CERCLA hazardous substances and RCRA hazardous wastes.
Direct Discharge: Clean Water Act defines direct discharge as any addition of any pollutant or
combination of pollutants to (a) U.S. waters from any "point source", or (b) waters of the
"contiguous zone" or the ocean from any point source other than a vessel or other floating craft
which is being used as a means of transportation. This definition includes additions of
pollutants into waters of the U.S. from: surface runoff which is collected or channeled by man;
discharges through pipes, sewers, or other conveyances owned by a State, municipality, or
other person which do not lead to a treatment works; and discharges through pipes, sewers, or
other conveyances, leading into privately owned treatment works.
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Glossary of Terms
Discharge: The accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying,
or dumping of waste into or on any land or water.
Disposal: The discharge deposit, injection, dumping, spilling, leaking, or placing of any solid
waste or hazardous waste into any land or water so that such solid waste or hazardous waste,
or any constituent thereof, enters the environment, is emitted into the air, or is discharged into
any waters, including groundwater.
Disposal Facility: A facility or part of facility at which solid or hazardous waste is intentionally
placed into or on any land or water, and at which waste will remain after closure.
Effluent: Any gaseous, liquid, or solid waste material that is released into the environment.
Emergency Response: A response effort by employees from outside the immediate release
area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to
an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous
substance. Responses to incidental releases of hazardous substances which can be absorbed,
neutralized, or otherwise controlled at the time of release by employees in the immediate
release area, or by maintenance personnel, are not considered to be emergency responses
within the scope of the OSHA HAZWOPER standard. Responses to releases of hazardous
substances involving no potential safety or health hazard (i.e., fire, explosion, or chemical
exposure) are not considered to be emergency responses.
Emergency Planning and Community Right-to-Know Act (EPCRA): The federal law
requiring corporate disclosure to local communities about the chemicals used by the company.
It also requires the notification of certain spills and releases.
EPA Hazardous Waste Code: The code assigned by EPA to each hazardous waste listed in
RCRA regulations and to each hazardous waste characteristic identified in RCRA regulations.
EPA ID Number: The identification number assigned by EPA to each hazardous waste
generator, transporter and treatment, storage, and disposal facility.
EPA Region: The states and territories found in any one of ten EPA regions, such as Region
4Tennessee, Kentucky, North Carolina, South Carolina, Georgia, Florida, Alabama, and
Mississippi.
Erosion: The process of being worn away or deteriorated by wind or water:
Evacuation: A personnel or population protection strategy that provides for the orderly
movement of people away from an actual or potential hazard.
Facility: All buildings, structures, equipment, and other stationary items that are located on a
single site or on continuous or adjacent sites and that are owned or operated by the same
person (or by any person which controls, is controlled by, or under common control with such
person). Under certain circumstances, a facility can include rolling stock and other transport
vehicles.
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Glossary of Terms
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): The federal law which
regulates the sale, distribution, and use of pesticides and establishes requirements for
registration, labeling, use, and disposal of these products.
Fire Hazards: Hazardous chemicals, including flammable chemicals, that are liable to cause
fire through friction, absorption, spontaneous chemical changes, retained heat, or which can
be ignited readily and burn vigorously and persistently; combustible liquids having flashpoints
at or above 90ฐF but below 100ฐF; flammable liquids with flash points below 100ฐF; pyrophoric
chemicals that ignite spontaneously in air at temperatures of 130ฐ F or below; and oxidizers
that can promote combustion in other materials, causing fire either by themselves or through
the release of oxygen or other gases.
Freeboard: The vertical distance from the normal water surface to the top of the confining
wall.
Friable Asbestos Material: Any material that contains more than one percent asbestos by
weight, and can be crumbled, pulverized, or reduced to powder by hand pressure.
Fugitive Emissions: Air emissions not normally vented through a stack, chimney, vent, or
equivalent opening. Fugitive emissions includes emissions from ponds, lagoons, landfills, and
piles of stored materials.
Generator of Hazardous Waste: Entity that produces hazardous waste. Generators are
classified by how much hazardous waste they produce in a given time period. In general,
there are three classes of waste generators: conditionally exempt small quantity generators,
small quantity generators, and large quantity generators. The generator is required to
determine if a waste is hazardous. If the waste is hazardous, the generator must apply for and
obtain an EPA ID number before transporting the waste to an approved treatment, storage,
and disposal facility. The generator must also use a hazardous waste manifest to track the
hazardous waste, must package and label the hazardous waste, and must keep records of its
shipments for 3 years.
Groundwater: Water below the land surface in a zone of saturation.
Hazard: A circumstance or condition that can do harm. Hazards are categorized into four
groups: biological, chemical, radiation, and physical.
Hazard Classes: These are descriptive terms prescribed by the Department of Transportation
to categorize the nature of DOT regulated materials. There are nine numeric classes and two
word classes as follows: Class 1 (explosives), Class 2 (gases), Class 3 (flammable liquids),
Class 4 (flammable solids and substances), Class 5 (oxidizing substances), Class 6
(poisonous and infectious substances), Class 7 (radioactive), Class 8 (corrosive), and Class 9
[miscellaneous substances, and Combustible Liquids, ORM-D (consumer commodities)].
Hazardous Material: A substance designated by the Department of Transportation as posing
a potential hazard when transported. See 49 CFR 171.101 for a list of DOT hazardous
materials. Hazardous wastes requiring a manifest are considered hazardous materials.
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Glossary of Terms
Hazardous Substance: CERCLA Section 101(14), as amended, defines "hazardous
substance" by referencing other environmental statutes, including: CWA Sections 311 and
307(a); CAA section 112; RCRA Section 3001; and TSCA Section 7. A list of over 600
CERCLA hazardous substances is provided in 40 CFR 302.4. EPA has the authority to
designate additional hazardous substances not listed under the statutory provisions cited
above.
Hazardous Waste: A solid waste material that may cause or significantly contribute to serious
illness or death or that may pose a substantial threat to human health or the environment if not
managed properly, and which includes liquids, semisolids, and contained gases. Hazardous
wastes are subject to manifest reporting requirements. A material is considered a hazardous
waste under RCRA if it meets one of the following conditions:
The material has been listed as a hazardous waste by regulations.
It is ignitable, corrosive, reactive, or toxic.
It is a mixture of a listed hazardous waste and a non-hazardous waste.
Hazmat: A contraction of Hazardous Materials.
Ignitable: Material that has a flashpoint less than 140ฐF, is combustible through friction, is
combustible through absorption of moisture, or can spontaneously combust.
Incident: A release or potential release of a hazardous material, substance, or waste into the
environment.
Indirect Discharge: A discharge which goes to a publicly-owned treatment works (POTW).
Indirect discharges do not need a National Pollutant Discharge Elimination System (NPDES)
permit but must comply with the POTW pretreatment standards.
Influent: Wastewater or other raw or partially treated liquid flowing into a basin, treatment
process, or treatment plant.
Land Disposal: Includes, but is not limited to placement of hazardous waste in a landfill,
surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt
bed formation, underground mine or cave, or concrete vault or bunker intended for disposal
purposes. Land disposal facilities are a subset of treatment, storage, and disposal facilities
(TSDFs). Groundwater monitoring is required at all land disposal facilities. Waste material can
only be disposed of at a permitted facility.
Land Disposal Restrictions: Regulations prohibiting the disposal of hazardous waste on land
without prior treatment of the waste. Land disposal restriction notifications ensure proper
treatment of the waste prior to disposal.
Landfill: A disposal facility or part of a facility where waste is placed in or on land and which is
not a land treatment facility, a surface impoundment, or an injection well.
Large Quantity Generators: One of three classes of hazardous waste generators under
RCRA producing 1,000 kilograms or more of hazardous waste in one calendar month at a given
location.
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Listed Waste: Waste listed as hazardous under 40 CFR Part 261. A waste is listed as a
hazardous waste based on the process from which the waste was generated and/or the
constituents found in the waste.
Local Emergency Planning Committee (LEPC): A local community group, including police
and fire departments, which must be notified in the event of an accidental release that exceeds
the reportable quantity of the following substances (1) EHSs (listed in 40 CFR Part 355,
Appendices A and B); or (2) hazardous substances subject to emergency notification
requirements under CERCLA Section 103(a) (listed in 40 CFR 302.4).
Major Stationary Source: Any stationary source that emits or has the potential to emit 100
tons per year or more of any air pollutant.
Manifest: The "cradle-to-grave" paperwork recording hazardous waste movement from its
generation through final storage or disposal. All parties must keep records for 3 years.
Material Safety Data Sheets (MSDS): Information sheets which provide workers with details
on the health and physical hazards of chemicals to which they may be exposed in the
workplace.
Maximum Achievable Control Technology (MACT): Generally, the best available control
technology, taking into account cost and technical feasibility.
Milligrams per Kilogram (mg/kg): Weight of a substance, measured in milligrams, contained
in a weight of the total material, measured in kilograms. A concentration used to measure
solid materials such as contamination in soil.
Milligrams per Liter (mg/l): Weight of a substance, measured in milligrams, contained in a
volume of solution measured in liters. A concentration used for liquid substances.
Monitoring: The process of measuring certain environmental parameters on a real-time basis
for spatial and time variations. For example, air monitoring may be conducted with direct
reading instruments to indicate relative changes in air contaminant concentration at various
times.
National Ambient Air Quality Standards (NAAQS): Standards established by the Clean Air
Act for air quality of an area in terms of allowable levels of specific pollutants.
National Emission Standards for Hazardous Air Pollutants (NESHAP): The EPA regulations
which govern specific processes which could possibly emit certain hazardous pollutants such
as asbestos into the air.
National Pollutant Discharge Elimination System (NPDES): A permitting system under the
CWA established for regulating direct discharges of wastewater from industries and
municipalities into surface waters of the United States.
National Priority List (NPL): The prioritized list required by CERCLA of abandoned or
uncontrolled hazardous waste sites.
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National Response Center: The center (1-800-424-8802) which must be notified immediately
of releases of hazardous substances in excess of their reportable quantities and hazardous
materials (under certain circumstances).
New Source Performance Standards (NSPS): Standards established by the EPA under the
CAA for new, modified, or reconstructed operations which emit air pollutants.
Nonattainment: The status of an area that is determined to exceed any national ambient air
quality standard for a particular pollutant.
Oil: Oil of any kind or in any form, including but not limited to petroleum, fuel oil, oil sludge, oil
refuse, and oil mixed with wastes.
On site: The same or geographically contiguous property which may be divided by public or
private right-of-way, provided the entrance and exit between the properties are at a crossroads
intersection and access is by crossing, as opposed to going along, the right-of-way. However,
non-contiguous properties owned by the same person but connected by a right-of-way which he
or she controls and to which the public does not have access are also considered on-site
properties.
Operator: The person responsible for the overall operation of a facility or process.
Occupational Safety and Health Administration (OSHA): A federal agency which protects
worker health and safety under the Occupational Safety and Health Act and plays an important
role in environmental issues such as chemical exposure in the workplace.
Outfall: The mouth of a drain or sewer which flows directly into surface water.
Owner: The person who owns a facility or part of a facility.
Parts per Million (ppm): A standard or measurement for concentrations of pollutants. A ratio
(volume/volume or weight/weight) usually used for airborne concentration of gases or vapors,
for concentrations of chemicals in water, or concentrations of chemicals in soil.
Permit: A written document issued by the government that establishes standards and/or
pollutant limits for water discharges, air emissions, or for the handling, treating, storing, or
disposing of hazardous waste.
Pesticide: Any substance or mixture of substances intended for preventing, destroying,
repelling or mitigating any pest; any substance/mixture of substances intended as a plant
regulator, defoliant or desiccant.
pH: A measure of alkalinity or acidity on a scale whose values range from 0 to 14 with 7
representing neutral. Numbers less than 7 correspond to increasing acidity. Numbers greater
than 7 correspond to increasing alkalinity.
Point Source Discharges: Any discernible, confined, and discrete conveyance, including but
not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling
stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other
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floating craft from which pollutants are or may be discharged. This term does not include return
flows from irrigated agriculture or agricultural storm water runoff.
Pollutant or Contaminant: Any element, substance, compound, or mixture which after release
into the environment and upon exposure, ingestion, inhalation, or assimilation into any
organism, either directly from the environment or indirectly by ingesting through food chains, will
or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer,
genetic mutation, physiological malfunctions, or physical deformation in such organisms or their
offspring. It presents an imminent and substantial danger to public health or welfare.
Pollution Prevention: Any source reduction activity that results in the reduction of total volume
of waste, reduction of toxicity of waste, or both, as long as the reduction is consistent with the
goal of minimizing present and future risks to public health and the environment. Transfer of
hazardous constituents from one environmental medium to another does not constitute waste
minimization (see waste minimization).
Polychlorinated biphenyls (PCBs): A hazardous chemical once widely used in electrical
transformer oil and now subject to a manufacturing ban and use restrictions under TSCA.
Potentially Responsible Party: See PRP.
Preliminary Assessment/Site Investigation (PA/SI): The first phase of a site investigation for
possible chemical contamination. It consists of a record search, investigation of prior site uses,
on-site inspections, and possible site sampling to determine if a potential threat exists.
Publicly-Owned Treatment Works (POTW): Any device or system used in the treatment
(including recycling and reclamation) of municipal sewage or industrial wastes of a liquid nature
which is owned by a "State" or "municipality." This definition includes sewers, pipes, or other
conveyances only if they convey wastewater to a POTW providing treatment.
Reasonably Available Control Technology (RACT): Control technology that is reasonably
available and both technologically and economically feasible. Usually applied to existing
sources in nonattainment areas; in most cases is less stringent than new source performance
standards.
Regulated Material: A substance or material that is subject to regulations set forth by the EPA,
Department of Transportation, or any other federal and/or state agency.
Releases: Defined by federal and most state laws as any spilling, leaking, pouring, dumping,
emitting, discharging, injecting, escaping, leaching, or disposing of hazardous wastes or
hazardous substances into the environment. This includes the abandonment of barrels,
containers, and other closed receptacles containing any hazardous substance or pollutant.
Under environmental laws, the term "release" does not include releases which result in
exposure to persons solely within a workplace, with respect to a claim which such persons may
assert against the employer of such persons.
Reportable Quantity (RQ): The minimum quantity of a CERCLA hazardous substance or
EPCRA extremely hazardous substance which is reportable. A release equal to or greater than
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than the RQ within a 24-hour period must be reported to the appropriate authorities (i.e.,
National Response Center).
Resource Conservation and Recovery Act (RCRA): The federal act which regulates the
management of hazardous waste from the point of generation through transport, storage, and
disposal. It also regulates underground storage tanks and nonhazardous waste disposal
under separate subtitles.
SARA Title III: The part of SARA, now known as EPCRA (Emergency Planning and
Community Right-to-Know Act) which regulates emergency response plans, community right-
to-know issues, and chemical release reporting.
Safe Drinking Water Act (SDWA): The federal act which deals with the quality of treated
drinking water. Regulations developed by EPA under authority of this act include drinking
water standards.
Sedimentation: The act or process of depositing sediment.
Site Inspection: The collection of information from a Superfund site to determine the extent
and severity of hazards posed by the site. It follows and is more extensive than a preliminary
assessment.
Sludge: A solid, semi-solid, or liquid material produced by the process of settling or sinking
caused by gravity. Sludges are generally waste products and are commonly generated by
municipal and industrial water treatment processes and air pollution control processes.
Sludges also occur in process tanks where liquids are stored. Sludges must be tested to
determine if they are hazardous wastes.
Small Quantity Generators (SQGs): One of the three classes of hazardous waste generators
under RCRA. SQGs produce between 100 and 1,000 kilograms of hazardous waste at a
given location.
Soil and Groundwater Analysis: Tests used to determine the presence of substance
contamination and concentration levels. The analysis may involve soil borings and the
installation of test pits and/or monitoring wells.
Solid Waste: Any garbage, refuse, sludge, or other waste materials not excluded by definition.
Exclusions include domestic sewage and any mixture of other wastes that pass through a
sewer system to a publicly-owned treatment works (POTW); industrial wastewater discharges
that are point source discharges subject to regulation under the Clean Water Act; irrigation
return flows; nuclear materials defined by the Atomic Energy Act; and "in situ" or "in position"
mining materials. Note that wastewaters being collected, stored, or treated before discharge
and sludges generated by wastewater treatment are not excluded. EPA defines hazardous
waste as a subset of solid waste.
Solvent: Any substance that can dissolve another substance. The term is most often used to
mean petroleum-based solvents, capable of dissolving greases, oils, tars, and asphalts. Many
petroleum-based solvents are volatile, flammable, may be hazardous, and may be regulated
as an air pollutant. Used solvents being disposed of (even if recycled) must be manifested as
hazardous waste unless exempted.
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Source Standards: Standards for emission levels at the source or point of emission.
Special Waste: A type of waste which is not a hazardous waste but requires more care than a
regular solid waste and may require special disposal procedures. Examples include: certain
sludges, asbestos containing waste materials, and oil waste.
Spill Prevention, Control, and Countermeasure (SPCC) Plan: Plan designed to ensure that
a facility puts in place containment and other control measures that will prevent oil spills from
reaching navigable U.S. waters.
State Emergency Response Commission (SERC): The state agency which must be notified
in the event of an accidental release of an extremely hazardous substance, a CERCLA
hazardous substance, or a chemical with an MSDS above the chemical's threshold planning
quantity (TPQ) or its reportable quantity (RQ).
Stationary Source: Any building, structure, facility, or installation that emits or may emit any air
pollutant.
Storage: The holding of hazardous waste for a temporary period, at the end of which the
hazardous waste is treated, disposed of, or stored elsewhere. Generators are required to have
a RCRA permit for storage of hazardous waste for more than 90 days or 180 days, depending
on the generator's status. Treatment or disposal facilities must be permitted.
Super-fund Amendments and Reauthorization Act (SARA): The amendments to CERCLA
which increased available funds for site cleanups, added cleanup standards, and required
hazardous waste operations training for site workers and emergency response personnel.
Superfund: The common name for CERCLA. It also refers to the fund that is to be used for
cleaning up hazardous substance sites.
Toxic Substances Control Act (TSCA): The federal law designed to evaluate the human
health and environmental effects of all chemical substances entering the U.S. market, to
establish an inventory of existing chemicals, and to regulate the use and disposal of toxic
substances. PCBs are regulated under TSCA.
Toxicity Characteristic Leaching Procedure (TCLP): A physical/chemical analytical
procedure used to determine if a substance is classified as a toxic hazardous waste. If the test
results show that a solid waste exceeds any of the limits prescribed for 39 specific
contaminants, the waste is deemed to be a characteristically toxic hazardous waste. (The other
three characteristics are corrosivity, ignitability and reactivity.)
Transporter of Hazardous Waste: Entity that moves or transports hazardous waste by truck,
rail, boat, or plane and has received an EPA hazardous waste transporter ID number. Some
states also require proper permits. (On-site movement of hazardous waste does not apply.)
Transporters of hazardous waste must properly manifest and record movement as part of
"cradle-to-grave" tracking required by RCRA. In addition, transporters must follow Department
of Transportation (DOT) Hazardous Materials regulations and must immediately notify the
appropriate officials if a release or incident occurs. Transporters are responsible for
undertaking emergency response to any accident that occurs during transportation.
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Treatment: Any method, technique, or process, including neutralization, designed to change
the physical, chemical, or biological character or composition of any hazardous waste to
neutralize such waste, to recover energy or material resources from the waste, or to render
such waste non-hazardous, safer to transport, store or dispose of, or amenable to recovery,
storage, or reduction in volume.
Treatment, Storage, and Disposal Facilities (TSDFs): Usually refers to off-site facilities
where untreated hazardous waste can be taken for treatment, storage, and/or disposal.
TSDFs are subject to RCRA requirements and permits. TSDFs complete the "cradle-to-grave"
cycle by continuing record keeping requirements. There are many complex rules for facility
operations and training of employees.
Underground Injection Control (UIC): The program under the Safe Drinking Water Act that
regulates the use of wells to pump fluids into the ground.
Underground Storage Tank (UST): USTs are regulated under RCRA, Subtitle I by the federal
government and by individual states under state programs. A UST is a tank, including any
underground pipes, which contains or used to contain regulated hazardous substances or
petroleum and has at least 10% of its volume beneath the surface of the ground.
United States Environmental Protection Agency (EPA): The federal regulatory agency in
charge of administering and enforcing various federal environmental laws.
Used Oil: Any oil that has been refined from crude oil or any synthetic oil that has been used
and as a result of that use is contaminated by physical or chemical impurities.
Waste Minimization: This is the reduction in volume ortoxicity of wastes generated by source
reduction or recycling. Generators and TSDFs operating under RCRA permits are required to
certify annually that they have waste minimization plans in place and that the plans are being
implemented at their facilities. Generators must also sign a waste minimization statement
when signing the manifest.
Waste Pile: Any non-containerized accumulation of solid, non-flowing hazardous waste that is
used for treatment or storage.
Waters of the United States: (1) Navigable waters, waters subject to tidal action shoreward to
the mean high water mark and currently used or may be used to transport goods moving in
interstate or foreign commerce, including oceans, coastal and inland waters, lakes, rivers and
streams that are navigable; (2) Tributaries of navigable waters; (3) Wetlands, including those
adjacent to waters of the United States as defined above; and (4) Surface waters.
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