xvEPA
United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2223A)
EPA 305-B-00-002
July 2000
Environmental
Screening Checklist
and Workbook for
Short Line Railroads
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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 tribal, state,
and local requirements.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-i
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Table of Contents
TABLE OF CONTENTS
INTRODUCTION VV - 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 WASTE MANAGEMENT W - 1
1.1 Hazardous Waste Generation, Storage and Transport : W-1
1.2 Used Oil and Used Filters W-10
1.3 Spent solvents W-17
1.4 Used Battery Storage and Disposal W-19
1.5 Used Rags and Shop Towels W-21
1.6 Absorbents/Track Mats W-23
1.7 Fueling W-25
1.8 Recordkeeping Requirements W-28
SECTION 2.0 MECHANICAL OPERATIONS W-30
2.1 Brake Repair W-30
2.2 Equipment Cleaning W-31
2.3 Coolant and Antifreeze Disposal W-33
SECTION 3.0 ENGINEERING OPERATIONS W-37
3.1 Track Ballast Disposal W-37
3.2 Asbestos (Building Renovation/Demolition) W-38
3.3 Construction Activities W-39
3.4 Crossties .- W-41
3.5 Pesticide Use W-43
3.6 On-site Waste Disposal of Nonhazardous Waste W-44
3.7 Trackside Lubricating W-45
3.8 Storage Tanks . W-46
3.9 Wastewater/Storm Water Management W-54
3.10 Yard Dust Control W-63
SECTION 4.0 TRANSPORTATION OPERATIONS W-64
4.1 Hazardous Material Transport W-64
4.2 Locomotive Emissions W-65
4.3 Leaks and Spills W-66
SECTION 5.0 OTHER OPERATIONS W-67
5.1 Metal Machining W-67
5.2 Painting / Paint Removal Operations W-68
5.3 PCB-Containing Equipment W-74
5.4 Air Conditioning Repair W-76
GLOSSARY G -1
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W- il
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Introduction
INTRODUCTION
The United States Environmental Protection Agency (EPA) is providing the Environmental
Screening Checklist and Workbook for Short Line Railroads as a public service to the short line
railroad industry. EPA's Office of Compliance, through various meetings with industry
representatives, facility owners, and technicians, determined there is a need for clear
information for 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?
Use With the Short Line Railroad Handbook: The
checklist and workbook are intended for use with the
Environmental Compliance Handbook for Short Line
Railroads (Handbook). The Handbook provides
information on environmental requirements for short
line railroad operations and contact numbers for
obtaining additional information.
You can use the checklist and workbook
to evaluate your facility's compliance
with the federal environmental
regulations which are applicable to the
short line railroad industry. The term
facility refers to, but is not limited to, a
railroad site overseen by
owners/operators, managers, field ^^^a^^^^^^^^^^^^^^^^^^
personnel, etc. who engage in railroad
operations. 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 Short
Line Railroads," is a pictorial representation of specific activities that are regulated or specific
environmental requirements at a short line railroad 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 ToII-Free Info-Line: 1-888-459-0656
TERC Website 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 Short Line Railroads
July 2000
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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, which are tailored after the Handbook, include the following sections:
Section 1.0 Waste Management
Section 2.0 Mechanical Operations
Section 3.0 Engineering Operations
Section 4.0 Transportation Operations
Section 5.0 Other Operations
Section 5.0 Other Operations includes requirements for several operations, such as metal
machining and painting. While these operations are not as common for most short line
railroads, they may be of interest to some facilities. 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.
WHAT DOES THE "" MEAN?
A V" 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 "",
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.
Each checklist question will ask you
about key environmental requirements
that are applicable to a short line railroad
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
V" 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.
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 the
evaluation 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
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
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Introduction
continued progress towards environmental compliance.
WHERE CAN I GET HELP?
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
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 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
railroad 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.gov/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
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
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This resource center is designed to help transportation industries stay on top of
environmental requirements and technologies.
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.
Hazardous Waste Information
Telephone: (703) 308-8482
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
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This office provides a RCRA coordination program information collection
outreach and guidance. (http://www.epa.gov/wastemin )
National Pesticides Information Line
Telephone: (800) 858-7378
This service provides pesticide information, including information about labels,
incident investigations, emergency human and animal treatment safety practices
and clean-up and disposal.
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.
RCRA/Underground Storage Tanks (RCRAAJST), 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
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.
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July 2000
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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.
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
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
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Introduction
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/
Reg/o/7 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/
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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/region101
Financial Assistance Information
Railroad Rehabilitation and Improvement Financing
Website: http://www.fhwa.dot.gov/tea21/factsheets/r-rrehab.htm
This program is administered by the U.S. Department of Transportation's Federal
Railroad Administration. It is intended to make funding available through non-
federal loans and guarantees for railroad improvements. The purpose of the
funding is to provide direct loans and loan guarantees to:
State and local governments
Government sponsored authorities
Corporations, railroads, and joint ventures that include at least one
railroad.
These loans can be used to acquire, improve, develop or rehabilitate intermodal
or rail equipment of facilities, including track, bridges, yards, and shops;
refinance existing debt incurred for the previous purposes; and develop and
establish new intermodal or railroad facilities.
Small Business Improvement Loans
Website: http://www.GetSmart.com
GetSmart.com is a leading financial search engine allowing consumers to
compare different loan products from multiple lenders in a single location. The
website's search engine matches the borrower's financing preferences with
lenders who are pre-screened and ready to fulfill their requests.
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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.htmlSinfo
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/
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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.
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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ENVIRONMENTAL SCREENING CHECKLIST FOR SHORT LINE RAILROADS
Facility Name: Site Reviewer:
Facility Location: Date:
1.0 WASTE MANAGEMENT - GENERAL
Hazardous Waste
Generation,
Storage, and
Transport*
Used Oil and
Used Filters*
Spent solvents
Used Battery
Storage and
Disposal*
Used Rags and
Shop Towels*
Absorbents/
Track Mats*
Fueling*
Recordkeeping
How much hazardous waste does the facility generate per month? (p. W-6)
Does the facility have an EPA hazardous waste generator ID number? (p. W-7)
Does the facility store hazardous waste in appropriate storage containers? (p. W-7)
How does the facility manage/dispose of its hazardous waste? (p. W-8)
Does the facility have a written contingency plan on site or basic contingency procedures in place for
responding to spills and releases of hazardous wastes? (p. W-9)
Are used oil containers/tanks and associated piping labeled "used oil"? (p. W-ll)
Are used oil containers/tanks and associated piping leak free? (p. W-l 1)
Does the facility prevent the mixing of used oil with hazardous waste ? (p. W-l 1)
How does the facility dispose of its used oil? (p. W-12)
How does the facility manage/dispose of its used oil filters? (p. W-14)
How does the facility manage/dispose of its used fuel filters? (p. W-15)
If halogenated solvents are used in cleaning equipment, has the facility submitted a notification report to
the air permitting agency? (p. W-l 7)
Does the facility store its spent solvents in labeled containers ? (p. W-18)
How does the facility manage/dispose of its spent solvents? (p. W-18)
If storing used batteries, does the facility protect them from storm water contact ? (p. W-20)
How does the facility manage/dispose of used batteries? (p. W-21)
How does the facility manage used rags and shop towels? (p. W-22)
Does the facility determine if used absorbents (e.g., track mats) are hazardous wastes before disposal?
(p. W-24)
How does the facility manage absorbents used for oil spills? (p. W-24)
Are overfill protection measures, spill containment methods, and spill response equipment used during
fueling? (p. W-27)
Does the facility maintain all required environmental compliance records? (p. W-29)
Does the facility keep all service receipts? (p. W -29)
(1) Up to 220 Ifas (CESQG)
(2)220 - 2,200 lbs(SQG)
(3) Over 2,200 Ibs (LQG)
Yn ND NAD
YD No NAD
Ships hazardous waste off site / Disposes
of hazardous waste on site and is RCRA-
permitted TSDF / Other /NA
Yn No NAD
YD N D NA o
YD N D NA D
YD N a NA D
Sent off site for recycling / Burned in an
on-site space heater / Burned off site /
Other /NA
Recycle / Service company / Other / NA
Recycle / Service company / Managed as
hazardous waste / Other / NA
Y n N a NA a
Yn N a NA a
Third party vendor / Permitted discharge to
sanitary sewer /TSDF/ Other / NA
Y n ' N D NA a
Return to supplier / Recycle / Service
company / Universal waste handler / Send
to hazardous waste landfill / Other / NA
Laundry service / Burned for heat / Other
/NA
YD N n NA a
Sent to supplier or service company /
Burned for energy / Disposed of as
hazardous waste / Other / NA
YD N n NA n
YQ ND Don't Know a
YD ND NAD
2.0 MECHANICAL OPERATIONS
Brake Repair
Equipment
Cleaning*
Coolant and
Antifreeze
How does the facility manage used brake shoes and/or other locomotive components? (p. W-30)
Does the facility keep the lids of solvent cleaning equipment closed? (p. W-32)
How does the facility manage/dispose of used locomotive coolants ? (p. W-33)
Recycled off site/Disposed atEPA-
approved disposal site / Other / NA
YD N D NA D
Recycle / Permitted discharge to sanitary
sewer / On-site wastewater treatment / NA
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3.0 ENGINEERING OPERATIONS
Track Ballast
Disposal*
-
Asbestos*
Construction
Activities*
Crossties*
Pesticide Use
On-sitc Disposal
-- '
Trackside
Lubricating
Storage Tanks*
Wastewater/
Storm Water
Management*
Yard Dust
Control*
Hazardous
Material
Transport
Locomotive
Emissions
Leaks and Spills
Painting/Paint
Removal
Operations*
Does the facility manage used track ballast according to the substance (e.g., used oil, hazardous materials)
with which it is contaminated? (p. W-37)
Are all buildings and structures built before 1980?
If Yes, has the facility assessed all buildings and structures built prior to 1980 for their potential for containing
asbestos and treated accordingly? (p. W-38)
How docs the facility manage/dispose of its construction wastes ? (p. W-40)
How does the facility manage/dispose of used crossties? (p. W-42)
Are restricted use pesticides (RUPs) applied only by a certified commercial applicator? (p. W-44)
Docs the facility dispose of nonhazardous waste on site in a permitted landfill or dump? (p. W-44)
Docs the facility place absorbent fabric around rail lubricators to prevent ground contamination with oil?
(p. W-45)
Has the State/Tribal UST program office been notified of any USTs located on site? (p. W-47)
Does the facility conduct leak detection for tanks and piping of all on site USTs? (p. W-47)
Do USTs at the facility meet requirements for spill, overfill, and corrosion protection? (p. W-48)
Does the facility inspect the ASTs daily for leaks and other hazardous conditions? (p. W-51)
Docs the facility have a Spill Prevention, Control, and Countermeasures (SPCC) plan signed by a Professional
Engineer? (p. W-53)
Docs the facility have an NPDES permit for direct discharges? (p. W- 5 8)
Does the facility have a storm water permit?
If Yes, does the facility have a storm water pollution prevention plan (SWPPP)? (p. W-59)
Is a certification included in the SWPPP? (p. W-59)
If the facility discharges wastewater to a municipal sanitary sewer, has facility notified the publicly-owned
treatment works (POTW) and received approval for pretreatment discharges? (p. W-60)
Docs the facility prohibit the use of used oils or other liquid wastes to suppress dust? (p. W-63)
YD No NAD
Ya N a NA D
Y n No NA a
Off site/NA
Recycled / Other
YD N n NA n
YD N n NA D
YD N D NA n
YD ND NAD
YD N D NA D
YD No NA D
YD No NAD
YD ND NAD
YD N D NA a
YD ND NAD
YD N D NA D
YD ND NAD
YD N D NA D
YD Na NAD
4.0 TRANSPORTATION OPERATIONS
Does the facility routinely conduct hazardous material inspections? (p. W-64)
Is the facility familiar with the new emission standards for locomotives? (p. W-66)
which locomotive engines can idle? (p. W-66)
Are faculty crews trained to detect and report all spills and leaks immediately? (p. W-66)
W-64)
(p. W-66)
ng times, or (2) limiting the areas in
iately? (p. W-66)
YD
YD
YD
YD
ND
NO
ND
ND
NAD
NAD
5.0 OTHER OPERATIONS
Air Conditioning*
Repair
Does the facility have air permits? (p. W-69)
How does the facility manage/dispose of paint stripping wastes and baghouse dusts? (p. W-71)
How does the facility manage/dispose of used paints and painting waste products? (p. W-72)
Does the facility employ or hire trained and certified technicians to maintain CFC-containing equipment?
(p. W-77)
YD N D NA n
Recycling / Landfill / Other / N A
Return to supplier / Reuse / Recycle / Other I
/NA
YD N D NA D
* For additional questions regarding these environmental compliance issues refer to the workbook.
Note; Refer to the wotkbookfor environmental compliance information and questions regarding metal machining (p. W-67) andPCB-containing
uipment (p. W-74).
-------
Waste Management
SECTION 1.0 WASTE MANAGEMENT
I. I Hazardous Waste Generation, Storage, and
Transport
(SEE HANDBOOK - PAGES 73-85)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to hazardous
waste generation, storage, and transport for compliance with environmental
requirements:
a. Has the facility determined whether it generates hazardous waste? (p. W-3)
b. How much hazardous waste does the facility generate per month?
(p. W-6)
c. Does the facility have an EPA hazardous waste generator ID number?
(p. W-7)
d. Does the facility store hazardous waste in appropriate storage containers?
(p. W-7)
e. Does the facility meet all hazardous waste storage (quantity and time)
requirements? (p. W-8)
f. How does the facility manage/dispose of its hazardous waste? (p. W-8)
g. Does the facility keep copies of its manifests for the 3 year minimum
requirement? (p. W-9)
h. Does the facility have a written contingency plan or basic contingency
procedures in place for responding to spins and releases of hazardous
wastes? (p. W-9)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Identifying Hazardous Waste
Short line railroads may produce hazardous
wastes. It is important to identify and manage
hazardous wastes properly to protect facility
employees and others in the community, as well
as the environment. If the facility is a hazardous
waste generator, it is responsible for all steps in
hazardous waste management, from generation
to final disposal. The facility can be held liable
for any mismanagement of wastes, even after
they leave the facility. Therefore, it is important
to know the facts. Some of these hazardous
wastes are listed in Exhibit 2.
If the facility is unsure of whether its
wastes are hazardous it can call the
RCRA/UST, Superfund, and 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 Manufacturers
Association.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-1
-------
Waste Management
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,
semisolids, liquids, or contained gaseous materials. Solid wastes that meet the following
criteria are considered hazardous and subject to regulations under the Resource Conservation
and Recovery Act (RCRA) (40 CFR Part 261):
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 as hazardous because they are known to be 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.
The facility can determine if its waste is toxic by having it tested using the Toxicity
Characteristic Leaching Procedure (TCLP), or by process knowledge. TCLP can be
done 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, EPA's lists of hazardous wastes in 40 CFR Part 261 (as discussed above)
can be used as process knowledge.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-2
-------
Waste Management
Universal Waste Rule
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 obtained from the
RCRA/UST, Superfund, EPCRA Hotline at
1-800-424-9346.
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) batteries (e.g., nickel
cadmium, small sealed lead acid) that
are spent (i.e., will not be reclaimed or
regenerated at a battery recycling/reclamation facility); (2) pesticides that have been suspended
or canceled, including those that are part of a voluntary or mandatory recall under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) 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 more information, check website:
http://www.epa.gov/epaoswer/hazwaste/id/univwast.htm)
1.1a Has the facility determined whether it generates hazardous waste?
Q Yes Facility has gone through the waste determination process or used
process knowledge and determined that it does generate hazardous
waste. See Exhibit 2 for common hazardous wastes generated by short
line railroads.
a NO
Facility has determined that it does not generate hazardous waste.
Q NA/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.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-3
-------
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c
-------
Waste Management
1.1b How much hazardous waste does the facility generate per month?
Generation occurs when a substance becomes a waste. When determining the volume
of waste generated, only waste that is in a container or other unit waiting to be
disposed of is considered "generated." Thus, solvent stored in a drum waiting for
disposal or recycling is considered "generated," while solvent in a parts cleaner that is
currently in use is not yet a waste and has not yet been generated.
The facility generates: (Pick one)
No more than 220 Ibs (100 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
(1000 kg) of hazardous waste per month. In
this case, the facility generates more than Y2
of a 55 gallon drum of hazardous waste, but
less than 5 (five) 55-gallon drums of
hazardous waste in any month. In this
case, the facility is considered a small
quantity generator (SQG) and must have
an EPA ID number.
Note: If the facility is a CESQG
and generates no more than 2.2
Ibs (1 kg) of acutely hazardous
waste (or 220 Ibs [100 kg ] of
acutely hazardous waste spill
residues) in a calendar month,
and never store 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
(1 kg) of acutely hazardous
waste, it must manage the
waste according to the LQG
requirements.
Q
Over 2,200 Ibs (1000 kg) of hazardous waste per month. In this case, the
facility generates approximately 5 (five) 55-gallon drums or more of hazardous
waste in any month. In this case, the facility is considered a large quantity
generator (LQG) and must have an EPA ID number.
The total weight of hazardous waste generated includes only waste (1) defined as
hazardous by EPA regulations, (2) determined to be hazardous by the facility, and (3)
not otherwise 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.
Generators who periodically exceed or fall below their normal generation limits in any
given calendar month are called episodic generators. If the amount of waste
generated in a given calendar month places the generator in a different category, the
generator, is responsible for complying with all applicable requirements of that category
for all waste generated during that calendar month. For example, if a generator
produces 300 kg of hazardous waste in March, that waste is subject to SQG
requirements; if the same generator produces 1,500 kg of hazardous waste in April,
that waste is subject to LQG requirements.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-6
-------
Waste Management
1.1c Does the facility have an EPA hazardous waste generator ID number?
If the facility is an SQG or an LOG (as discussed in Question 1.1b), it must have an
EPA hazardous waste generator ID number. This requirement applies even to
episodic generators who may fall into the SQG or LQG categories for one month only.
The facility must enter the number on all hazardous waste manifests. It is usually
placed near the top of the form under the heading, "Generator ID #." If the state issues
the number, it will start with the state abbreviation followed by the number (e.g., NY-
12345678). CESQGs are not required to have an identification number under federal
law. Contact the state or EPA regulatory agency to obtain a copy of EPA form 8700-
12 "Notification of Hazardous Waste Activity." For additional help, call the RCRA/UST,
Superfund, EPCRA Hotline at 1-800-424-9346.
Q Yes Facility has obtained an 8-digit ID number from EPA or the state regulatory
agency that has been granted authority by EPA.
Q No Facility has not obtained an EPA ID number.
Q NA Facility is a CESQG and therefore is not required to obtain an EPA ID
number.
1.1d Does the facility store hazardous waste in appropriate storage
containers?
Containers must meet the following requirements (40 CFR 262.34):
Clearly marked with the words "Hazardous Waste" and the date when waste
accumulation began. Labels for this purpose maybe available from the waste
hauler.
Kept in good condition and stored in a manner that minimizes risks of ruptures,
leaks, or corrosion.
Kept closed except when being filled or emptied, except if volatile explosion is
possible and emergency ventilation is needed.
Inspected at least once per week for leaks or corrosion. Note: Some states may
require facilities to keep a written record of these inspections. Any problems
should be corrected immediately. If any corrections are made, they should be
noted in a permanent record and kept on file for at least 3 years.
Stored in a manner that minimizes the potential for accidental mixing of
incompatible materials.
Q Yes Facility stores waste in containers that meet the above requirements.
Q No Facility stores waste in containers that do not meet the above requirements.
Q NA Facility does not generate hazardous waste.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-7
-------
Waste Management
1.1e Does the facility meet all hazardous waste storage (quantity and time)
requirements?
Hazardous waste generators must store hazardous waste according to the following
requirements:
LQGs may accumulate any amount of hazardous waste for no more than 90 days.
SQGs can accumulate no more than 13,228 Ibs (6,000 kg) of hazardous waste on
site for up to 180 days without permit (or up to 270 days if the facility must transport
the hazardous waste more than 200 miles away for recovery, treatment, or
disposal). If these limits are exceeded, the facility is a treatment, storage, and
disposal facility (TSDF) and must obtain an operating permit.
CESQGs have no maximum on-site time limits for storage but cannot accumulate
more than 2,200 Ibs (1000 kg) of hazardous wastes or 2.2 Ibs (1 kg) of acutely
hazardous waste, or 220 Ibs (100 kg) of acutely hazardous waste spill residues, at
any time.
Q Yes Facility complies with all hazardous waste storage quantity and time
requirements.
Q No
Facility does not comply with all hazardous waste storage quantity and time
requirements.
Q NA Facility does not generate hazardous waste.
1.1f 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.
Environmental Screening Checklist
and Workbook for Short Line Railroads
July 2000
W-8
-------
Waste Management
1.1g Does the facility keep copies of its manifests for the 3 year minimum
requirement?
The facility must meet various recordkeeping requirements as part of hazardous waste
management obligations. The Uniform Hazardous Waste Manifest Form is a multi-copy
shipping document that reports the contents of its 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 hazardous waste generator, so that the generator can be sure that its
shipment was received. A copy of the manifest is required to be kept at the facility for 3
years.
Q Yes Facility maintains a copy of its manifest for a minimum of 3 years.
Q Wo Facility has not maintained a copy of its manifest for a minimum of 3 years.
Q NA Facility does not generate hazardous waste.
1.1h Does the facility have a written contingency plan on site or basic
contingency procedures in place for responding to spills and releases
of hazardous wastes?
If the facility is an LOG, it must have a written contingency plan that includes the
following elements (40 CFR 262.34):
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.
The names, addresses, and phone numbers of all persons qualified to act as
emergency coordinator.
Location of all emergency equipment at the facility and
An evacuation plan.
Although a written contingency plan is not federally required for SQGs or CESQGs, it is
strongly recommended.
SQGs are required to have basic contingency procedures, which include the
following:
An emergency coordinator (employee) who is responsible for coordinating all
emergency response measures.
Information posted next to the telephone, including: (1) name and number of the
emergency coordinator; (2) locations of the fire extinguishers and spill control
material; and (3) telephone number of the fire department.
Ensure that all employees are thoroughly familiar with proper waste handling and
emergency procedures.
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It is also important to check with the state and local authorities for any additional
contingency plan or emergency preparedness requirements.
Q Yes Facility has a written contingency plan or basic contingency procedures in
place.
Q No Facility does not have a written contingency plan or basic contingency
procedures in place.
Q NA Facility is not an SQG or an LQG (i.e., facility is a CESQG) and is not
required to meet RCRA's emergency preparedness requirements.
1.2 Used Oil and Used Filters
(SEE HANDBOOK - PAGES 14,18-20,
33-34, 75-76)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to used oil
and used filters for compliance with environmental requirements.
a. Are used oil containers/tanks and associated piping leak free and labeled
"used oil"? (p. W-11)
b. Does the facility prevent the mixing of used oil with hazardous waste?
(p. W-11)
c. How does the facility manage/dispose of its used oil? (p. W-12)
d. If the facility transports more than 55 gallons of used oil off site at one time, (1)
does it have an EPA ID number, and (2) is it licensed as a used oil transporter?
(p. W-13)
e. Does the facility completely drain used oil filters and/or used fuel filters before
disposal? (p. W-14)
f. How does the facility manage/dispose of its used oil filters? (p. W-14)
g. Has the facility determined if its used fuel filters are hazardous? (p. W-15)
h. How does the facility manage/dispose of its used fuel filters? (p. W-15)
I. Does the facility inspect used oil filter storage areas for oil spills and leaks?
(p. W-15)
j. Does the facility inspect locomotive storage track areas for oil spills and leaks?
(p. W-16)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
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Used Oil
Facilities should consider several environmental issues when performing any oil handling
activities such as oil changes or oil/fuel filter replacement to motor vehicles, maintenance
equipment, and other motors. Most facilities recycle or reclaim used oil. Used oils are
regulated under the Used Oil Standards (40 CFR Part 279), and are typically not in the class
of hazardous wastes at the federal level. However, some states may have stricter disposal
requirements. In addition, used oil generators are also subject to all applicable Spill
Prevention, Control and Countermeasures (SPCC) and underground storage tank (UST)
standards. Contact the state regulatory agency to determine the used oil disposal
requirements. Facilities should maintain all records on their used oil storage and recycling
activities.
1.2a
Are used oil containers/tanks and associated piping leak free and
labeled "used oil"?
The facility must store used oil in leak free
containers labeled with the words "used oil." No
special labels are necessary, provided that the
words "used oil" are visible at all times. Spray
painting, crayon, or handwritten (preferably not in
pencil) labels are okay. One can mix used motor
oil with other used oils (hydraulic oils, transmission
fluids, brake fluids) and store them in the same
tank.
Note: If a facility uses storage
tanks to store waste oil, such
tanks may be regulated under
underground storage tank (UST)
or aboveground storage tank
(AST) regulations.
Some facilities have pipes that connect to the used oil storage tank. Piping runs from
the inside of the building to the outside disposal point (i.e., tank). This way, technicians
can pour their oil in a funnel or small bucket which is attached to the piping, and the oil
goes directly to the tank. In this case, the funnel/bucket or piping should have a label
with the words "used oil."
Q Vies Used oil is in a leak free container(s) labeled with the words "used oil."
Q No Used oil is not in a leak free container(s) and/or is not labeled "used oil."
Q NA Facility does not generate used oil.
1.2b Does the facility prevent the mixing of used oil with hazardous
waste?
A facility should not mix hazardous waste fluids, such as spent solvent, gasoline, or
other hazardous substances, with used oil, or the entire volume may be classified as
hazardous waste. For example, although mixing a listed hazardous waste with used oil
will result in a hazardous waste, mixing a characteristic hazardous waste with used oil
will not result in a hazardous waste, unless it exhibits a hazardous characteristic (see
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Section 1.1). A facility can mix used motor oil with other used oils (e.g., transmission
fluid or brake fluid) and store it in the same container/tank. For questions about which
specific products may be mixed with used oil, call the RCRA/UST, Superfund, and
EPCRA Hotline at 1-800-424-9346.
Q Yes Facility prevents the mixing of used oil with hazardous waste.
Q No Facility does not prevent the mixing of used oil with hazardous waste.
Q NA Facility does not generate used oil.
1.2c How does the facility manage/dispose of its used oil?
Recycling and burning (for energy recovery) of used oil that has not been mixed with
any other waste are the most environmentally protective and often the most
economical approach to handling used oil.
Under Used Oil Management Standards, generators can burn used oil as long as:
The used oil is generated on site.
« Space heaters with maximum heating capacity of 0.5 million BTUs per hour or less
are used to burn the used oil.
» The gases from the space heater are vented outside.
A facility can manage used hydraulic oils and dispose of it as used oil and blende them
with other used oils, such as engine and lube oils. Recycling and reclamation are
preferred over disposal.
Q Sent off site
for recycling
Q Burned in an
on site space heater
Q Burned off site
Other
Q NA
Facility has a regular hauler who takes the used oil to a
recycling facility.
Facility burns its used oil in an on-site heater with maximum
heating capacity of 0.5 million BTUs used to heat the facility
or heat hot water. Note: There maybe Clean Air Act (CAA)
requirements that apply when burning used oil. Contact the
state or local air pollution control agency for more
information.
Facility has a hauler or takes its own oil to a used oil
burner.
Facility does not use any of the methods described above.
Note: Used oil should not be disposed of in sewers, drains,
dumpsters, or on the ground, or used as a dust suppressant
or control.
Facility does not generate used oil.
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1.2d If the facility transports more than 55 gallons of used oil off site at
one time, (1) does it have an EPA ID number, and (2) is it licensed as
a used oil transporter?
If the facility transports more than 55 gallons of used oil off site to an approved used oil
collection center, it must: (1) have an EPA ID number and (2) have a license/permit as
a used oil transporter.
Q Yies Facility has an EPA ID number and is licensed as a used oil transporter.
Q No Facility does not have an EPA ID number, or does not have a license/permit
as a used oil transporter.
Q NA Facility does not transport more than 55 gallons of used oil off site at one
time.
Used Filters
Used Oil Filters: Used oil filters are exempt from federal hazardous waste requirements as
long as the filters:
Are not terne-plated. (Terne is an alloy of tin and lead. The lead in the terne-plating
makes the filters hazardous.)
Are properly drained (i.e., hot-drained) of used oil.
According to federal regulations, a facility can dispose filters as solid waste (in some states)
provided that the filter has been hot-drained to remove residual used oil. This means that no
matter what draining option is used, the facility should remove the filter from a warm engine
and drain it immediately. Four distinct methods of hot-draining can be used:
Gravity Draining: When the filter is removed from the engine, one should place it with
its gasket side down in a drain pan. If the filter has an anti-drain valve, the "dome end"
of the filter should be punctured with a screwdriver (or similar device) so that oil can
flow freely. The filter then should be allowed to drain for 12 to 14 hours.
Crushing: A mechanical, pneumatic, or hydraulic device crushes the filter to squeeze
out the used oil/fuel and compact the remaining filter materials.
Disassembly: A mechanical device separates the filter into its different parts. This
allows most of the used oil/fuel to be removed from the filter, and the metal, rubber,
and paper parts of the filter to be recycled separately.
Air Pressure: One places the filter into a device where air pressure forces the used
oil/fuel out of the filter.
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Protect storage containers designated for used oil filters from storm water with a cover. In
addition, the container should be capable of holding any used oil that seeps from the filters.
Used fuel filters: Drain used fuel filters (using the same procedure as used oil filters) and then
test to determine if they are hazardous. If the fuel filters are hazardous, they count toward the
facility's generator status (see Section 1.1 for more information). Used fuel filters should be in
a separate, marked, fireproof container. If the facility is a CESQG, it can dispose of used fuel
filters in a licensed landfill or give them to a hazardous waste hauler. If the facility is an SQG
or an LQG, then it must use a hazardous waste hauler with an approved EPA ID number.
Manage metal filters as scrap metal if properly drained.
Note: Since disposal requirements of used filters may vary by state, one should consult the
state regulatory agency for proper disposal. For more information regarding state filter
management regulations, and referrals to state agencies and companies that provide filter
management services, refer to the Used Filter Hotline at 1-800-993-4583. This hotline is
sponsored by the Filter Manufacturers Council.
1.2e Does the facility completely drain used oil filters and/or used fuel
filters before disposal?
Q Yes Facility completely drains filters (i.e., no visible signs of free-flowing oil
remains) prior to disposal.
Q No Facility does not completely drain filters prior to disposal.
Q AM Facility does not generate used oil or fuel filters.
1.2f How does the facility manage/dispose of its used oil filters?
Q Recycle Facility recycles filters for scrap metal.
Q Service Facility contracts with a service which takes filters.
Q Trash Facility disposes of filters in the dumpster (e.g., not segregated from
other waste such as paper, plastics, food, etc.).
Q Other Method of disposal is not listed above. Note: The facility may be out of
compliance. Contact the state regulatory agency for assistance.
Q NA Facility does not generate used oil filters.
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1.2g Has the facility determined if its used fuel filters are hazardous?
Q Yes Facility has determined through testing if its used fuel filters are hazardousV
Q No Facility has not determined if its used fuel filters are hazardous.
Q NA Facility does not generate used fuel filters.
1.2h How does the facility manage/dispose of its used fuel filters?
Note: If one determines used fuel filters are hazardous waste, the facility must count
them towards the facility's generator status and manage them accordingly. See
Section 1.1 for more information on hazardous waste management.
Q Recycle
Q Se/v/ce
Q Managed as
hazardous waste
Q Trash
Q Other
UNA
Facility recycles used fuel filters.
Facility contracts with a service which takes used fuel
filters as they are.
Facility manages used fuel filters as hazardous waste.
Filters are discarded in the dumpster (e.g., not segregated
from other waste such as paper, plastics, food, etc.).
Method of disposal is not listed above. Note: The facility
may be out of compliance. Contact the state regulatory
agency for assistance.
Facility does riot generate used fuel filters.
1.21 Does the facility inspect used oil filter storage areas for oil spills and
leaks?
Engine oil can enter the environment when oil filters are changed and stored and when
engines drip crankcase and lube oils. A facility should take measures to minimize oil
dripping by regular maintenance of railroad cars and support vehicles. Take care not to
store used oil and used oil filters near floor drains. Many facilities keep absorbent
materials close to oil drums or oil handling locations in order to protect nearby areas
from contamination.
A facility should inspect all areas where oils are received, stored, used, changed, and
potentially spilled regularly for spills. Use one of the following indicators to identify oil
spills: (1) sheen on water, (2) stained soil, (3) lack of vegetation, or (4) visible leaks.
Contain all spills and clean up immediately after detection. The facility should consult
the Spill Prevention, Control, and Countermeasures (SPCC) plan in the event of a spill
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or leak. The SPCC plan contains detailed information on spill cleanup and remediation.
In addition, if any oil enters surface waterways and produces a sheen, notify the
National Response Center (1-800-424-8802) and state emergency response agency
immediately.
Q Yes Facility inspects storage areas for oil spills.
Q No Facility does not inspect storage areas for oil spills.
Q NA Facility does not have storage areas for used oil and filters.
1.2j Does the facility inspect locomotive track areas for oil spills and
leaks? (SEE HANDBOOK - PAGES 33-34)
Regular cleanup of track areas should be
conducted whenever visible contamination is
detected. Even if no oil contamination is
visible, conduct regular inspections for
locomotive leaking. Whenever leaks are
detected, the facility should take immediate
action to minimize drippings. Actions should
include engine maintenance, the use of
absorbents, and regular emptying of drip pans
installed under the locomotive idle and
storage areas to catch drips of oil, fuel, and
coolant. .
Tip: It is a good idea for a short
line railroad facility to have spill
kits near areas where experience
has shown leaks and spills likely to
occur. Such spill kits may include
kitty litter, organic-based
absorbents and other tools for
containment.
Consult the SPCC plan in the event of a spill or leak. In addition, if any oil enters
surface waterways and produces a sheen, notify the National Response Center (1-
800-424-8802) and state emergency agency immediately.
Q Yes Facility inspects these areas for oil spills.
Q No Facility does not inspect these areas for oil spills.
_
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\ .3 Spent solvents
(SEE HANDBOOK - PAGES 11-13,22)
Note: All of the following questions are included in the accompanying checklist to help the facility
- examine its operations relating to spent solvents for compliance with environmental
requirements.
a. If halogenated solvents are used in cleaning equipment, has the facility submitted
a notification report to the air permitting agency! (p. W-17)
b. Does the facility store its spent solvents in labeled containers? (p. W-18)
c. How does the facility manage/dispose of its spent solvents? (p. W-18)
These questions appear in the following text and may be accompanied with a discussion of
the preferred answers (indicated with a "") for environmental compliance.
Spent solvents
1.3a If halogenated solvents are used in cleaning equipment, has the
facility submitted a notification report to the air permitting agency?
Although most facilities use soap and water
for parts cleaning, some facilities use
halogenated solvents. On December 2,
1994, EPA issued national emission
standards for hazardous air pollutants
(NESHAP) to control toxic air pollutant
emissions from solvent cleaning equipment
(including dip tanks and parts washers) that
use any of six halogenated solvents. These
halogenated solvents include:
Tip: A facility can tell if these chemicals
are contained in the solvent by reading
the label on the container or reading a
Material Safety Data Sheet (MSDS) that
should accompany any hazardous
material the facility has on site. If the
facility does not have an MSDS, one
may be requested from its vendor.
Methylene chloride
1,1,1 -Trichloroethane
Chloroform
- Perchloroethylene
- Trichloroethylene
- Carbon tetrachloride.
All owners and operators of solvent cleaning equipment that use these solvents must
submit an initial notification report to its state/local air permitting agency. This report
must include information on each solvent cleaning machine and control equipment, and
the yearly estimated consumption of each halogenated solvent used. Additional
NESHAP requirements depend on the type of solvent cleaning machine (e.g., batch
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vapor, in-line) that a facility uses. Contact the state/local air pollution control agency for
more information.
Q yes
Q No
Q NA
Facility has submitted a notification report.
Facility has not submitted a notification report.
Facility does not use halogenated solvents to conduct equipment cleaning.
1.3b Does the facility store its spent solvents in labeled containers?
Stored in containers. Containers must be compatible with the substance they are
storing, and have no signs of leaks or significant damage due to major dents or rust.
Containers must also be closed (e.g., lids are on, caps are screwed on tight) except
when actually adding or removing liquid.
Labeled. Containers holding spent solvents that are hazardous and will be transported
for disposal must have labels. Note: Solvents that are being used in a parts washer do
not need labels.
Q yes
Q No
Q NA
Spent solvents are stored in labeled containers.
Spent solvents are not stored in labeled containers.
No solvents are used at the facility.
1.3c How does the facility manage/dispose of its spent solvents?
If a vendor is not used to assure proper handling
and disposal, it is important for the facility to
determine if the spent solvents are hazardous. If
the spent solvents are hazardous, no one should
mix them with nonhazardous wastes such as
used oils. Be sure all hazardous waste is stored,
manifested, transported and disposed of in
compliance with RCRA requirements. Only
treatment, storage, and disposal facilities (TSDFs) should dispose of hazardous waste
Sludges: Facilities must also
determine if sludges, which may
generated during parts cleaning,
are hazardous. If so, they must be
managed in accordance with
RCRA.
Q Third party vendor
Q Storm sewers or
surface waters
Facility uses a third party vendor. Many facilities elect to
use third party vendors providing "turn key" assistance.
These vendors typically provide the solvents and parts
washers, and collect the spent solvents, provide
transportation, and recycle or dispose of the waste.
Facility has obtained an NPDES permit to discharge
nonhazardous waste to storm sewers or to surface
waters.
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Q Sanitary sewer
Q UIC well
Q7SDF
Q Ground
Q Other
UNA
Facility has obtained approval from the POTW to
discharge nonhazardous waste to sanitary sewers.
Discharge may require pretreatment.
Facility discharges nonhazardous waste to an
underground injection control (UIC) well. The facility
complies with UIC program requirements (40 CFR Part
144). For additional questions, contact your State UIC
agency. (A facility cannot discharge hazardous waste to a
UIC well.)
Facility sends hazardous waste to a TSDF for disposal.*/
Facility discards spent solvents on the ground which may
affect groundwater or may flow with storm water into storm
sewers and surface waterways. Caution: All states forbid
the disposal of hazardous spent solvents on the ground.
Method of disposal is not known.
Facility does not generate spent solvents or sludge.
1.4 Used Battery Storage and Disposal (SEE HANDBOOK - PAGES 26 - 30)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to used battery
storage and disposal for compliance with environmental requirements:
a. Has the facility determined whether its batteries are regulated as universal waste or
hazardous waste? (p. W-20)
b. If storing used batteries, does the facility protect them from storm water contact?
(p. W-20)
c. How does the facility manage/dispose of used batteries? (p. W-21)
These requirements appear in the following text and may be accompanied with a discussion
of the preferred answers (indicated with a "") for environmental compliance.
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1.4a Has the facility determined whether its batteries are regulated as
universal waste or hazardous waste?
There are many types of used batteries with different disposal requirements. Some of
these batteries may be classified
as hazardous waste (see Section
1.1) if they are not properly
handled.
For more information on how batteries are covered
under the Universal Waste Rule, contact the
RCRA/UST, Superfund, and EPCRA Hotline at 1-
800-424-9346. Note: Because the Universal Waste
Rule is less stringent than RCRA, some states have
not adopted it. Check with the state regulatory
agency to see if it has adopted the Universal Waste
Rule.
Under the Universal Waste Rule
(40 CFR Part 273), if batteries do
not exhibit hazardous waste
characteristics (see Section 1.1),
they may be regulated as _^
universal wastes and subject to "^^^^^^^^l
less stringent requirements than
other hazardous wastes. For example, many small sealed lead acid batteries (used for
electronic equipment and mobile telephones) and nickel-cadmium batteries are
regulated as universal wastes. Most alkaline batteries are not considered hazardous
waste under RCRA and can be disposed of as general trash. Check with the local
waste authority to see if they have a battery collection program.
Q Yes Facility has gone through the waste determination process (as discussed
in Section 1.1) to determine whether its batteries are universal or
hazardous waste.
D No Facility has not determined whether its batteries should be regulated as
universal or hazardous waste.
Q NA Facility does not generate used batteries.
1.4b If storing used batteries, does the facility protect them from storm
water contact?
When placed out-of-service, the facility should transport batteries to an accumulation
area specifically designed for storage prior to removal from the site. The storage
accumulation area should protect the batteries from weather and storms. It should be
designed (1) with secondary containment to prevent any spillage or leakage from
contaminating the soil or surface waters; and (2) without floor drains that could receive
spills and deliver them to the storm sewer, sanitary sewer, surface water, or injection
well. Battery storage maybe done inside or outside under a tarp or roof. Store
batteries in a containment such as pan or other device so that any leakage cannot
enter floor drains or spill onto the ground. Improperly stored batteries are considered
"abandoned."
Q Yes Used batteries are protected from storm water discharges.
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1.4c How does the facility manage/dispose of used batteries?
Q Return to supplier
Q Recycle
Q Service
Q Universal waste handler
Facility returns used batteries to supplier.
Facility sends batteries to a recycling facility.
Facility pays service company to pick up used
batteries.
Facility sends used batteries classified as universal
waste to a universal waste handler.
Q Hazardous waste landfill Facility sends used batteries to a hazardous waste
landfill. Facility has records of where and how many
batteries were sent.
Q Other
QiNA
Method of disposal is not listed here.
Facility does not generate used batteries.
1.5 Used Rags and Shop Towels
(SEE HANDBOOK - PAGE 76)
NOTE: The following questions, one of which is included in the accompanying checklist (highlighted
in bold), will help the facility examine its operations relating to used rags and shop towels for
compliance with environmental requirements:
a. How does the facility manage used rags and shop towels? (p. W-22)
b. How does the facility store used rags and shop towels on site? (p. W-22)
These questions appear in the following text and may be accompanied with a discussion of
the preferred answers (indicated with a "" for environmental compliance.
Used Shop Rags and Towels
A facility must manage used shop rags and towels as hazardous waste if they are
contaminated with a hazardous waste or display a hazardous characteristic due to the presence
of gasoline or metal-contaminated antifreeze. EPA allows facilities to manage these used rags
and towels by sending them to a laundry service, or disposing of them through an EPA-licensed
hazardous waste transporter and disposal facility.
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Used shop rags and towels contaminated with
used oil only can be recycled; burned for energy
recovery under the same Used Oil Management
Standards existing for burning used oil (see page
W-12, question 1.2c); or disposed of. According to
the used oil regulations, a facility should handle
oil-contaminated rags and towels as used oil until
the oil is removed from them (40 CFR Part 279).
EPA considers used oil satisfactorily removed
when no visible sign of free flowing oil remains in
the rags/towels. /Vote; After used oil has been
removed, the material may still need to be handled
as a hazardous waste if it contains a hazardous
waste or exhibits any property of hazardous waste.
See Section 1.1 for more information regarding
hazardous wastes. Many facilities avoid the
hazardous waste determination process by sending
rather than disposal.
Shop Rag/Towel Laundering
Many states do not consider rags going
for laundering to be hazardous waste
(although a hazardous waste could be
generated by the launderer). This is
because the rag/towel, even if
contaminated with hazardous waste, is
not being discarded and therefore, the
hazardous waste requirements do not
apply. Keep in mind that some states
may consider these rags/towels as solid
wastes, even if they are to be sent for
laundering. Check with the state
regulatory agency on requirements for
managing shop rags/towels.
rags to a laundering facility for washing,
1.5a How does the facility manage used rags and shop towels?
Q Laundry service
Q Burned for heat
Q Hazardous waste
transporter
Q Trash
Facility sends used rags/towels off site to be laundered, often
with technicians' uniforms.
Facility mixes used rags/towels with used oil and burned in a
shop space heater with maximum heating capacity 0.5 million
BTU per hour or sent to a used oil burner. This does not
include burning in a barrel simply for disposal.
Facility mixes used rags/towels with hazardous waste and
disposes through an EPA-licensed hazardous waste
transporter and disposal facility.
Facility disposes of used rags/towels with trash (in a
dumpster) which is not segregated. If rags/towels are
contaminated with hazardous waste, they should not be
disposed of with trash, but managed according to one of the
above options.
Q Other Facility's method of disposal is not listed.
Q NA Facility does not generate used rags or shop towels.
1.5b How does the facility store used rags and shop towels on site?
Q Separate container Facility stores used rags/shop towels In a container (e.g.,
. bucket, can, barrel, on a shelf or bench, etc.).
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Q Stored as
hazardous waste
Q Shop trash can
Q Floor
Q Other
QAM
Facility stores used rags/shop towels contaminated with
hazardous waste according to hazardous waste requirements
(see Section 1.1).
Facility disposes used rags/shop towels in a can/dumpster
that contains all shop waste and not segregated.
Facility places use rags/shop towels on the floor, in a pile, or
they were simply scattered.
Method of storage is not listed.
Facility does not generate used shop rags/shop towels.
1.6 Absorbents/Track Mats
(SEE HANDBOOK - PAGES 33-34,64)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
absorbents and track mats for compliance with environmental requirements.
a. Does the facility use sawdust, soil, or other commercial absorbents for spills and
leaks? (p. W-23)
b. Does the facility determine if used absorbents (e.g., track mats) are
hazardous wastes before disposal? (p. W-24)
c. How does the facility manage absorbents used for oil spills? (p. W-24)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Absorbents
Cleaning up spills and releases of chemicals and petroleum products involves the use of
materials such as kitty litter type substances (known as "quick dry," "speed! dry," or "oil dry"),
clay absorbent, pads, pillows, booms, towels, and other such absorbent materials. Sawdust is
also sometimes used as an absorbent. One must use the proper absorbent for the type of
chemical spilled. Once used in a cleanup, the facility must dispose of these materials properly.
1.6a Does the facility use sawdust, soil, or other commercial absorbents
for spills or leaks?
Q Yes
Facility uses one or more of the above substances.
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Q Wo Facility does not use any of the above substances.
1.6b Does the facility determine if used absorbents (e.g., track mats) are
hazardous wastes before disposal?
Absorbents are hazardous waste if: (1)
they are contaminated with a hazardous
material such as solvent or gasoline, or (2)
they are characterized as hazardous by the
facility. Although used oil is not considered
a hazardous waste if it is recycled, it is a
hazardous waste if it is disposed of in a
landfill and has hazardous characteristics.
Thus, anything that absorbs used oil and is
thrown in the trash could be considered a
hazardous waste, even if it is not mixed
with a hazardous waste. For more
information regarding used oil regulatory
requirements, refer to 40 CFR Part 279.
Track Mats
Some facilities use track mats as
absorbents to protect the track and
ballast area from locomotive leaks. The
facility should test such absorbents to
determine whether they are hazardous or
not and managed accordingly. If the
track mats are hazardous, then the facility
must include them when determining its
generator status. Some service
companies will pick up contaminated
track mats.
Q Yes Facility has determined whether used absorbents are considered hazardous
before disposal.
Q No Facility does not characterize its absorbents.
Q NA Facility does not generate used absorbents.
1.6c How does the facility manage absorbents used for oil spills?
Note: the facility should determine whether used absorbents are hazardous before
disposal.
Q Sent to supplier or
Service company
Q Burned for energy
Q Disposed of as
hazardous waste
Q Nonhazardous and
landfilled
Facility returns used absorbents to its supplier or pays
service company to pick up used absorbents.
Facility burns absorbents used to soak up used oil for
energy recovery in a space heater with maximum heating
capacity of less than 0.5 million BTU per hour.
Facility places hazardous absorbents in drums, labeled as
"Hazardous Waste," and disposes of them through a
hazardous waste hauler.
Facility determined that the absorbents are a
nonhazardous solid waste and disposes of them with
regular trash.
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Q Other
QNA
Facility's method of management is not listed here.
Facility does not use absorbents.
1.7 Fueling
(SEE HANDBOOK - PAGES 63-65)
NOTE: The following questions, one of which is included in the accompanying checklist (highlighted
in bold), will help the facility examine its operations relating to fueling operations for
compliance with environmental requirements:
a. Has (he facility installed Stage I vapor recovery equipment for unloading of gasoline?
(p. W-25)
b. Has the facility installed Stage II vapor recovery equipment at the pumps? (p. W-
26)
c. Do fuel delivery records indicate compliance with appropriate fuel requirements? (p.
W-26)
d. Has the facility clearly labeled the pumps with the product they contain ? (p. W-
e. Do gasoline pump nozzles comply with W gallon per minute flow rate? (p. W-
f. Are overfill protection measures, spill containment methods, and spill response
equipment used during fueling? (p. W-27)
These questions appear in the following text and may be accompanied with a discussion of
the preferred answers (indicated with a "") for environmental compliance.
Fueling
1.7a Has the facility installed Stage I vapor recovery equipment for
unloading of gasoline?
If a facility dispenses gasoline on site for its
vehicles, and is located within an ozone non-
attainment area, the gasoline delivery truck
driver MUST use Stage I vapor recovery
equipment while filling the facility's gasoline
storage tanks.
Tip: Contact the local air pollution
control authority to determine if air
releases from fueling operations
are regulated.
Stage I vapor recovery equipment captures and controls gasoline vapors which would
otherwise go into the atmosphere (1) during the storage of gasoline, or (2) during the
loading and unloading of a gasoline delivery vessel.
a yes
Facility ensures that Stage I vapor recovery equipment is used.
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Q No
Q Don't Know
Q NA
Facility knows that Stage I vapor recovery equipment is not used.
Facility does not know if Stage I vapor recovery equipment is
used.
The facility is either not located in an ozone non-attainment area
or facility does not dispense gasoline.
1.7b Has the facility installed Stage II vapor recovery equipment at the
pumps?
If facility dispenses gasoline and is located in a serious or above ozone non-
attainment area, Stage II vapor recovery equipment must be present and work properly
at each nozzle which dispenses gasoline at the facility. Stage II vapor recovery
captures the vapors from the automobile tank and returns them to the storage tank.
Stage II vapor recovery is the "black boot" on the gasoline nozzle and black hose
extending to the upper fuel pump canopy at dispensing stations.
Q Yes
Q No
Q Don't Know
Q NA
Facility has installed Stage II equipment and it is working.
Facility has not installed Stage II equipment.
Facility does not know if Stage II equipment is installed and/or
working.
The facility is either not located in a serious or above ozone non-
attainment area or does not dispense gasoline.
1.7c Do fuel delivery records indicate compliance with appropriate fuel
requirements?
Fuel delivery tickets (i.e., product transfer documents) are receipts the facility receives
from the fuel deliverer which indicate the type of fuel (e.g., gasoline, diesel, kerosene),
how much was received, when it was received, and whether the delivered fuel complies
with appropriate fuel requirements.
If the facility is located within an ozone
nonattainment area and dispenses gasoline, the fuel
delivery ticket MUST say "RFG, certified for use in
an ozone nonattainment covered area" or "RFG."
RFG stands for reformulated gasoline.
Contact the local air pollution
control authority to determine
if the facility is located in an ,
ozone nonattainment area and
if air releases from fueling
operations are regulated.
If the facility is NOT located within an ozone
nonattainment area, the fuel delivery ticket should
say "CONVENTIONAL GASOLINE. This product does not meet the requirements
for reformulated gasoline, and may not be used in any reformulated gasoline
covered areas" or "CONVENTIONAL."
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If the facility dispenses diesel fuel to on-the-road vehicles, the fuel delivery ticket MUST
say "LOW SULFUR" or "LOW SULFUR DIESEL FUEL."
Q Yes Delivery records indicate compliance with appropriate fuel requirements.
Q No Delivery tickets do not indicate compliance with fuel requirements.
Q NA Facility does not receive fuel.
1.7d Are pumps clearly labeled with the product they contain?
Pumps must have labels to indicate a description of the product (e.g., gasoline, diesel,
kerosene), product grade (e.g., regular, mid-grade, premium), and octane (e.g., 87
octane) that is being dispensed from the nozzle.
Q Yes The facility clearly labels the pumps.
Q No The facility does not label pumps.
Q NA Facility does not have pumps.
1.7e Do gasoline pump nozzles comply with 10 gallon per minute flow
rate?
After January 1, 1996, every retailer handling over 10,000 gallons of fuel per month
must equip each pump, from which gasoline or methanol flows into vehicles, with a
nozzle that dispenses fuel at a flow rate not to exceed 10 gallons per minute. After
January 1,1998, this, requirement applies to every retailer.
Q Yes Facility tested the pump nozzles and they comply with 10 gallon per minute
flow rate.
Q No Facility tested the pump but they do not comply.
Q Don't Facility does not know if pump nozzles have been tested.
Know
Q NA Facility does not dispense gasoline or methanol.
1.71 Are overfill protection measures, spill containment methods, and spill
response equipment used during fueling?
When fueling vehicles, facilities should use overfill protection, spill containment, and
spill response equipment to prevent overflows and spills.
Overfill protection. Facilities can prevent fuel overflows during tank filling by
installing preventive measures, such as self-locking fuel measures and regularly
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Waste Management
monitoring transfers. In addition, a facility can prevent spills that result from
"topping off' tanks by training employees on proper fueling techniques.
Spill containment. Facilities should clean leaks and spills immediately using dry
methods such as absorbent wipes.
Spill response. Portable absorbent booms should be readily available for a quick
response to spills. Use dry absorbent materials such as kitty litter or organic-based
absorbents to absorb oil and grease. Dispose of used absorbent properly in
accordance with federal and state regulations.
Q Yes Facility uses the measures, methods, and equipment described above.
Q No Facility does not use the measures, methods, or equipment described
above.
Q NA Facility does not have fueling operations.
1.8 Recordkeeping Requirements
(SEE HANDBOOK - RECORDKEEPING REQUIREMENTS
UNDER EACH LAW IN CHAPTER III - PAGE 73-109)
NOTE: Both of the following questions are included in the accompanying checklist to
help the facility examine its operations relating to recordkeeping requirements
for compliance with environmental requirements:
a. Does the facility maintain all required environmental compliance records?
(p. W-29)
b. Does the facility keep all service receipts? (p. W-29)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "") for environmental
compliance.
Recordkeeping
Many environmental compliance records must be maintained at the facility including, but not
limited to:
Manifests or shipping papers for all hazardous waste shipments
SPCC facility inspection and maintenance records
Annual employee training records (SPCC and storm water pollution prevention plan)
Biennial reports for large quantity generators
EPCRA Tier II reports
Spill reports.
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1.8a Does facility maintain all required environmental compliance
records?
Q Yes Facility maintains all required records.
Q No Facility does not maintain all required records.
Q Don't Facility is unsure of what records are required to be kept. Note: Contact
Know the state regulatory agency for assistance.
1.8b Does the facility keep all service receipts?
The facility should maintain all of its service receipts, such as those used to pick up
used oil and used batteries.
Q Yes Facility keeps all of its service receipts.
Q No Facility does not keep all of its service receipts.
Q NA Facility does not hire service company(s).
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SECTION 2.0 MECHANICAL
OPERATIONS
2.1 Brake Repair
(SEE HANDBOOK- PAGE 8)
NOTE: The following question is included in the accompanying checklist to help the
facility examine its operations relating to brake repair for compliance with
environmental requirements:
a. How does the facility manage used brake shoes and/or other locomotive
components? (p. W-30)
This question appears in the following text and is accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Brake Repair
Currently locomotive and freight car brake shoes are produced with steeland composite
materials. In the past, asbestos may have been used in production. The facility should
evaluate if used brake shoes or any other locomotive components (e.g., gaskets and pipe
lagging) contain asbestos materials.
2.1 a. How does the facility manage used brake shoes and/or other
locomotive components?
Recycling and reclamation are the preferred methods for discarding brake shoes. If
asbestos is known or suspected of being present, the facility should notify the recycling
or reclamation company. If landfilling, the facility should seek a determination for
asbestos prior to disposal. If asbestos is present, use only landfills or disposal sites
approved for asbestos.
Asbestos Containing Material (ACM) waste must be disposed of as soon as practical at
an EPA-approved disposal site. The facility must label asbestos containers with the
name and location of the waste generator. Vehicles used to transport the asbestos
must be clearly labeled during loading and unloading. All must maintain the waste
shipment records so that the asbestos shipment can be tracked and substantiated.
Q Recycled Off site
Q Disposed by Vendor
A manufacturer or a recycling company collects used
brake shoes for recycling.
A vendor disposes of the brake shoes by landfilling or
other means of disposal.
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Q EPA-approved
disposal site
Q Other
Q NA
Facility disposes of ACM waste at an EPA-approved
disposal site.
Facility's method of management is not listed. Contact the
regulatory agency to verify that the method of
management is acceptable.
Facility does not discard brake shoes and/or other
locomotive components.
2.2 Equipment Cleaning
(LARGE SCALE - SEE HANDBOOK - PAGES 9-11)
(SMALL SCALE - SEE HANDBOOK - PAGES 12-13)
NOTE: The following questions, one of which is included in the accompanying checklist (highlighted
in bold), will help the facility examine its operations relating to equipment cleaning for
compliance with environmental requirements:
a. Does the facility conduct equipment cleaning? (p. W-32)
b. What kind of cleaning agents does the facility use to conduct equipment cleaning? (p.
c. Does the facility keep the lids of solvent cleaning equipment closed? (p. W-32)
These questions appear in the following text and may be accompanied with a discussion of
the preferred answers (indicted with a "") for environmental compliance.
Equipment Cleaning
A facility may conduct various kinds of equipment
cleaning using solvents. Wastes generated from
equipment cleaning include sludge, wastewater, and
spent chemical solvents. Hazardous waste may result
depending on the cleaning agents used to clean tools,
equipment parts, and other small items, and on the
nature of the material being cleaned.
Facilities are required to follow EPA waste
management regulations for "waste" or "spent"
solvents (i.e., those that have been generated as
wastes). Solvents that are currently in use, such as in
a parts cleaning sink, may be regulated under EPA air
regulations, but are not regulated under RCRA since
they are not yet a waste. (See also the section on
spent solvents on page 17.)
Note: EPA is proposing a regulation,
the Transportation Equipment
Cleaning Industry Effluent
Guidelines and Standards -
Proposed Rule, that will establish
technology-based effluent limitation
guidelines for the discharge of
pollutants into waters of the U.S. and
into POTWs by existing and new
facilities that perform transportation
equipment cleaning operations.
(http://www.epa.gov/OST/guide/te
cifs22.html)
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2.2a Does the facility conduct equipment cleaning?
A short line railroad facility may conduct different kinds of equipment cleaning.
Large scale equipment cleaning typically involves the cleaning of rail cars and
support vehicles.
Small scale equipment cleaning, commonly referred to as parts cleaning, typically
involves the cleaning of engine parts, tools, and other small items. The facility may
conduct parts cleaning using some type of solvent cleaning equipment, such as a
parts washer or a dip tank.
Q Yes Facility conducts equipment cleaning.
Q No Facility does not conduct equipment cleaning.
2.2b What kind of cleaning agents does the facility use to conduct
equipment cleaning?
Various cleaning agents can be used for equipment cleaning, including steam/pressure
water, surfactants (soap), and chemical solvents. If using chemical solvents that are
hazardous, care should be taken to wear protective safety gear and follow good
housekeeping practices (e.g., clear, easy to read labeling of all chemicals and wastes
to avoid misuse and potential injury or contamination).
The facility uses one or more of the following cleaning agents:
Q Water
Q Surfactants
Q Other
Q Steam
Q Chemical solvents
2.2c Does the facility keep the lids of solvent cleaning equipment closed?
Facilities should keep the lids or covers of solvent cleaning equipment (e.g., parts
washers, dip tanks) closed except when actually cleaning parts or adding or removing
liquid to prevent evaporation of solvents.
Q Yes Facility keeps lids of solvent cleaning equipment closed.
Q No Facility does not keep lids of solvent cleaning equipment closed.
Q NA Facility does not conduct parts cleaning using solvent cleaning equipment.
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2.3 Coolant and Antifreeze Disposal (SEE HANDBOOK-PAGES 15-10
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
locomotive coolant and antifreeze disposal for compliance with environmental
requirements:
a. How does the facility manage/dispose of used locomotive coolants?
(p. W-33)
b. Has the facility determined if it generates any antifreeze that is a hazardous
waste?
(p. W-34)
c. Does the facility reclaim used antifreeze on site in a closed loop system?
d. If the facility does not reclaim waste antifreeze in a closed loop system, is waste
antifreeze counted toward the facility generator status? (p. W-35)
e. If the facility does not reclaim used antifreeze on site in a closed loop
system, how does the facility manage it? (p. W-36)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicted with a V") for environmental compliance.
2.3a How does the facility manage/dispose of used locomotive coolants?
To protect locomotives' cooling systems from
corrosion, locomotive coolants contain a dilute
additive package which is basically a mixture of
sodium borate and sodium nitrate. The additive
package usually contains a dye to help identify
leaks.
Such locomotive coolants are nonhazardous and
can go into sanitary sewers with the approval of the
POTW. If the facility treats its wastewater on site
and discharges directly to a receiving waterway, check
discharge permit before disposing of coolant down the
should be recycled whenever feasible, and should not
Tip: Coolants from maintenance
and fleet vehicles should be
recycled. Because this type of
coolant contains ethylene-glycol,
it must not be mixed with
locomotive coolant when
recycling.
with the requirements of the
drain. Locomotive coolants
be discharged onto the ground.
Q Recycle
Q Sanitary sewer
Facility has a regular hauler who takes the used coolant to a
recycling facility.
Facility discharges locomotive coolants to sanitary sewers.
Discharge may require POTW approval and sometimes
pretreatment.
_
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Q On site wastewater
treatment
Q Ground
Q Storm sewer or
surface water
Facility treats wastewater on site and discharges
directly to receiving waterway. Facility has checked the
requirements of the discharge permit to ensure the disposal
of coolant in the drain is acceptable.
Facility discards locomotive coolant to the ground which may
affect groundwater or may flow with storm water into storm
sewers and surface waterways. Caution: Many states forbid
the disposal of coolants onto the ground.
Facility discharges locomotive coolant to storm
sewers or to surface waters.
QNA
Facility does not generate used locomotive coolant.
2.3b Has the facility determined if it generates any antifreeze that is a
hazardous waste?
A facility may characterize antifreeze as hazardous waste through testing or by process
knowledge. If the facility makes the hazardous/nonhazardous determination solely by
testing, the facility must test each batch of antifreeze changed from each vehicle
serviced. If process knowledge is used, the facility's determination must involve a
demonstrated understanding of the potentially hazardous constituents in antifreeze.
Such a demonstrated understanding could include a combination of the information on
the MSDS for the type of antifreeze used, a referral to a previous test that demonstrated
that antifreeze from hew vehicles does not contain metals, and/or having a procedure to
ensure that any suspect antifreeze is segregated from antifreeze known not to be
hazardous. See Section 1.1 a for more information about process knowledge.
In addition to testing and process knowledge, there are two functional indicators that
show the antifreeze is (or is likely to be) a hazardous waste. First, antifreeze is
considered hazardous if it is mixed with a hazardous waste such as certain spent
solvents or if it displays hazardous characteristics (see Section 1.1 discussion for more
information). Second, antifreeze could also be hazardous if it comes from a vehicle
where the antifreeze may have picked up enough metals (primarily lead) to be
characterized as hazardous for metals content.
Q Yes Facility has determined whether its antifreeze is hazardous.
Q No Facility has not determined whether its used antifreeze is a hazardous
waste.
Q NA Facility does not have antifreeze.
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2.3c Does the facility reclaim used antifreeze on site in a closed loop
system?
To avoid having to manage and dispose of used antifreeze as a hazardous waste, a
facility can reclaim used antifreeze in a closed loop system that connects directly to
the radiator, filters the antifreeze and returns the antifreeze directly back into the
vehicle. EPA does not consider such reclaimed material to be a solid waste. Thus,
even though the antifreeze may be hazardous, it is not hazardous waste because the
antifreeze is returned to its original use as a coolant.
Non-closed systems are available that connect to a used antifreeze storage drum.
However, because these are not closed loop systems, the antifreeze in the drum may
be a hazardous waste and the facility must store it according to the hazardous waste
provisions of RCRA. Closed loop systems are preferred for reclaiming/recycling
antifreeze.
Q Yes Facility reclaims used antifreeze in a "closed loop" system.
Q No Facility does not reclaim used antifreeze in a "closed loop" system.
Q NA Facility does not generate used antifreeze.
2.3d If the facility does not reclaim waste antifreeze in a closed loop
system, is waste antifreeze counted toward the facility generator
status?
Waste antifreeze that is a hazardous waste and not reclaimed in a closed loop system,
needs to be considered as part of the total volume of hazardous waste generated in
any month.
Q Yes Facility includes hazardous waste antifreeze that is not reclaimed in a closed
loop system in the total volume of hazardous waste generated.
Q No Facility does not include hazardous waste antifreeze.
Q NA Facility does not generate used antifreeze.
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2.3e If the facility does not reclaim used antifreeze on site in a closed loop
system, how does the facility manage it?
Q Recycled in a non-closed
system on site
Q Recycled off site
Q Landfill
Q Mixed with other fluids
Q. UIC well
Q Other
UNA
Facility manages used antifreeze in a non-closed
system on site according to RCRA hazardous
waste requirements.
Facility recycles used antifreeze off site. Facility
has on file the EPA ID number of the recycler (see
the DOT shipping papers).
Facility disposes used antifreeze at a landfill.
Many landfills have a tank designated for used
antifreeze. "Landfill" does not include antifreeze
that is dumped in the trash.
Facility mixes antifreeze with used oil, solvents, or
other fluid.
Facility discharges used antifreeze into an
underground injection control (UIC) well. Note:
The facility should immediately stop this method of
disposal and notify the EPA regional and/or state
UIC authority.
Method of disposal is not listed here.
Facility does not generate used antifreeze.
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SECTION 3.0 ENGINEERING
OPERATIONS
3.1 Track Ballast Disposal
(SEE HANDBOOK - PAGE 39)
NOTE: The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to track
ballast disposal for compliance with environmental requirements:
a. Does the facility manage used track ballast according to the substance
(e.g., used oil, hazardous materials) with which it is contaminated?
(p. W-37)
b. Does the facility keep track ballast (contaminated and uncontaminated) away
from storm water? (p. W-38)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicted with a V") for environmental compliance.
Track Ballast Disposal
Ballast rock removed from track beds is generally not contaminated and would not require any
special disposal. The ballast may be of economic value and can be reused. However, if the
ballast is contaminated with oil or chemicals (e.g., herbicides), proper disposal should be
arranged in compliance with federal and state waste regulations.
Tip: Contaminated ballast may be amenable to more cost effective treatment and
disposal methods other than landfilling including in situ bioremediation and reuse
as a feed material for asphalt batching plants.
3.1 a Does facility manage used track ballast according to the substance
(e.g., used oil, hazardous materials) with which it is contaminated?
If ballast materials become contaminated by such substances as used oil or hazardous
materials, the facility needs to store and dispose of them according to federal and state
requirements for that particular contaminating substance. Test contaminated ballast to
determine whether is hazardous or not and manage accordingly.
Q Yes Facility manages contaminated track ballast as described above.
Q Wo Facility does not manage contaminated track ballast as described above.
Q NA Facility does not have contaminated track ballast.
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3.1 b Does the facility keep track ballast (contaminated and
uncontaminated) away from storm water?
The facility should protect track ballast from storm water runoff (e.g., stored either
inside or under a tarp or roof). Track ballast should kept from all drains, waterways,
and flood plains.
Q Yes Track ballast is kept away from storm water runoff.
Q No Track ballast is not kept away from storm water runoff.
Q NA Facility does not store track ballast on site.
3.2 Asbestos (Building Renovation/Demolition)
(SEE HANDBOOK - PAGES 40-41,95-98)
NOTE: The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
asbestos for compliance with environmental requirements:
a. Has the facility assessed all buildings and structures built prior to 1980 for
their potential for containing asbestos and treated accordingly? (p. W-38)
b. Does the facility document demolition procedures? (p. W-39)
c. Has the facility informed employees of buildings and structures containing
asbestos and trained them to work on asbestos-containing material? (p. W-39)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
3.2a Has the facility assessed all buildings and structures built prior to
1980 for their potential for containing asbestos and treated
accordingly?
A new OSHA standard issued in 1995 modified the way facilities assess asbestos in
buildings. It was once possible to make subjective judgments ruling out the presence
of asbestos based on the assessor's knowledge. Now, for buildings built prior to 1980,
the materials potentially containing asbestos must be assumed to be asbestos-
containing unless bulk sampling reveals otherwise. Only a certified inspector can
perform asbestos inspections according to AHERA guidelines.
A facility must use State-licensed contractors, transporters, and disposal sites. If
planning a demolition, the facility must first remove the asbestos materials. In addition,
notify local, state, and federal agencies at least 10 days before the abatement,
demolition, or renovation begins.
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Q yes Facility assesses all buildings built prior to 1980 for asbestos.
Q No Facility does not assess all buildings built prior to 1980 for asbestos.
Q NA Facility does not have buildings built prior to 1980.
3.2b Does the facility document demolition procedures?
Q Vies Facility documents all demolition procedures.
Q No Facility does not document demolition procedures.
Q NA Facility has determined that asbestos is not present in any of the buildings.
3.2c Has the facility informed employees of buildings and structures
containing asbestos and trained them to work on asbestos-containing
material?
Inform all employees that may encounter asbestos-containing materials (ACM) of its
existence. In particular, inform all employees who must perform repairs, maintenance,
and custodial activities. In addition, train all employees to follow the proper procedures
on the proper use of protective equipment, and the use of control measures if their
work can disturb asbestos-containing material and release fibers.
Q Yes Facility informs and trains all employees as described above.
Q No Facility does not inform or train all employees as described above.
Q NA Facility determines that asbestos is not present in any of the buildings.
3.3 Construction Activities
(SEE HANDBOOK- PAGE 42)
NOTE:
The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
construction activities for compliance with environmental requirements.
a. How does the facility manage/dispose of its construction wastes? (p. W-40)
b. Are there any endangered species which may be affected by construction
activities? (p. W-40)
c. Has the facility obtained a Section 404 permit for any projects that may impact
wetlands? (p. W-41)
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These questions appear in the following text and may be accompanied with a discussion of
the preferred answers (indicated with a "") for environmental compliance.
3.3a How does the facility manage/dispose of its construction wastes?
Do not dispose of construction waste, including that from building, tunnel, and bridge
maintenance/on site without disposal permits. Some States prohibit open burning of
scrap wood, material bags, aerosol cans, etc. When in doubt, check with your
state/local agencies. Segregate all waste as either trash, industrial nonhazardous solid
waste, or hazardous waste. Some construction materials, such as asphalt, concrete,
brick, and cinder block, may qualify as clean fill. Only licensed contractors should
transport and dispose of construction wastes that are hazardous.
Q Off site
Q Open burning
Q On site
Q NA
Facility hires a licensed disposal contractor to haul the wastes to a
municipal or hazardous waste landfill.
Facility burns construction wastes.
Facility disposes of construction waste on site. Note: On-site
disposal of wastes requires permits.
Facility is not conducting construction activities at this time.
3.3b Are there any endangered species which may be affected by
construction activities?
The Endangered Species Act (ESA) establishes a program for the conservation of
endangered and threatened species and the habitats in which they exist. The ESA
prohibits the taking, possession, import, export, sale, and transport of any listed fish or
wildlife species. The term "taking" includes harassing, harming, hunting, killing,
capturing, and collecting. An individual may obtain a permit from the U.S. Fish &
Wildlife Service (USFWS) to capture or move species under certain conditions.
Loss of habitat can be attributed to many construction-related activities. Persons
engaged in, or planning to engage in, construction activities must be aware if any
endangered or threatened species exist on the property involved, or if the property is
considered part of a listed species' critical habitat. If neither is the case, the ESA does
not apply. However, if the action will "take" or degrade critical habitat, the facility must
take some form of mitigating action to prevent harming the species. There are some
exceptions under the ESA and one can consult with the local USFWS in cases where
species are present. For more information on the ESA, access USFWS's website at
- http://\www.fws.gov/r9endspp/endspp.html.
Q Yes Either facility has identified endangered species present at the site of
construction activities, and has determined what impact construction
activities will have on them or facility has determined that no endangered
species are present.
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Q No Facility has not determined whether endangered species are present.
Q NA Facility is not conducting construction activities at this time.
3.3c Has the facility obtained a Section 404 permit for any projects that
may impact wetlands?
Construction activities that include dredging and filling of wetlands may require the
facility to obtain a CWA Section 404 permit from EPA and U.S. Army Corps of
Engineers. The facility should identify any wetlands that may potentially be impacted
by construction activities, consult with their state wetlands coordinator or EPA wetlands
contact, and obtain a permit from the appropriate regulatory agency, if necessary. For
more information, call the Wetlands Information Hotline at 1-800-832-7828 or 703- .
748-1304.
Q Yes Facility has identified wetlands and taken steps to obtain a Section 404
permit as necessary.
Q No Facility is conducting construction activities that would impact wetlands
but it has not obtained a Section 404 permit.
Q NA Facility is not conducting any construction activities that could impact
wetlands.
3.4 Crossties
(SEE HANDBOOK - PAGE 43-44)
NOTE: The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to crossties
for compliance with environmental requirements.
a. How does the facility manage/dispose of used crossties? (p. W-42)
b. When storing crossties on site, are they protected from contact with storm
water? (p. W-42)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "") for environmental
compliance.
Crossties
Industry uses creosote to treat and protect crossties. Spills of creosote liquid can be a
significant soil contamination source. Therefore, it is especially important not to bury crossties
on site. Workers should handle crossties with the appropriate protective equipment to prevent
skin contact. When practical, use tongs to lift and move creosote treated crossties. Workers
should wear gloves at all times during crosstie handling.
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The preferred method of crosstie disposal is recycling, either for less severe railroad service,
for cogeneration of energy recovery, or for sale to an outside company for recycling services.
Facilities cannot burn crossties without a permit and special air emission controls. The facility
should ensure all incineration units have permits to burn the creosote ties. If a crosstie fire
occurs your facility may face fines for air pollution violations. Although these ties can legally
be given away for landscaping purposes, this practice has been seriously called into question
with regard to potential liability questions. Giving ties away has the potential for exposure to
the public. It may be allowable to dispose of crossties in permitted landfills, but again one
should consider future liability.
Some states regulate used crossties as "residual waste" and limit the time these wastes can be
kept on site. In addition, some states may classify treated wood as hazardous wastes when
disposed.
3.4a How does the facility manage/dispose of used crossties?
3.4b
Q Recycled
Q On-site incineration
Facility reuses crossties on site for less severe railroad
service, for cogeneration for energy recovery, or sells
them to an outside company for recycling purposes.
Facility incinerates crossties on site. Note: Incineration
requires an approved air pollution permit with appropriate
equipment and air pollution controls.
Q Off site incineration Facility discards of crossties by off-site incineration.
Q Sold/given to
the public
Q Off site landfill
Q Other
Facility sells/gives crossties to the public as landscape
timbers. Note: this method may result in future liability
issues.
Facility uses an approved industrial waste facility. Note:
Landfilling may have long-term liability if creosote leaches
into the groundwater.
Method of disposal is not listed. Note: Your facility may
be out of compliance. Contact your state regulatory
agency for assistance.
When storing crossties on site, are they protected from contact with
storm water?
Q Yes Crossties are kept from storm water runoff.
Q No Crossties are not kept from storm water runoff.
Q NA Facility does not store crossties on site.
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3.5 Pesticide Use
(SEE HANDBOOK - PAGES 46,105)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to pesticide
use for compliance with environmental requirements.
a. Does the facility use pesticides only as directed by their labels? (p. W-43)
b. Are restricted use pesticides (RUPs) applied only by a certified commercial
applicator? (p. W-44)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Pesticide Use
Pesticides for non-restricted use (e.g., herbicides, fungicides, rodenticides, insecticides and
disinfectants / antimicrobials) may be used on site for pest control. Under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA register all pesticides used in the
United States. Registered pesticides are properly labeled and if used in accordance with the
label, they will not cause unreasonable harm to the environment. Pesticides can only be
applied in a manner consistent with the label. Do not repackage. Store in original containers,
and keep them out of reach of children.
Most pesticides are classified as non-restricted use and anyone can apply them. Only
commercial certified applicators or someone under the direct supervision of a certified
applicator can purchase and apply restricted use pesticides (RUPs). Pesticide labels will
clearly state whether a particular pesticide is classified as restricted use only.
3.5a Does the facility apply pesticides only as directed by their labels?
Q Ves
Q No
Q NA
Facility applies all pesticides in accordance with the direction on the
labels.
Facility does not apply pesticides as directed by labels.
Facility does not use any pesticides.
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3.5b Are restricted use pesticides (RUPs) applied only by certified
commercial applicator?
Only a certified applicator or someone under the direct supervision of a certified
applicator can apply RUPs. States oversee the program for certification of commercial
(and private) applicators of restricted use pesticides. Facilities that are interested in
having their staff become certified applicators should contact their state. Facilities
should ensure that all vendors and employees applying RUPs are properly certified and
trained.
Q Yes Facility uses certified applicators to apply RUPs.
Q No Facility does not use certified applicators to apply RUPs.
Q NA The facility does not apply RUPs.
3.6 On site Waste Disposal of Nonhazardous Waste
(SEE HANDBOOK - PAGES 47,83-84)
NOTE:
3.6a
a.
The following question is included in the accompanying checklist to help the facility
examine its operations relating to on site waste disposal of nonhazardous waste for
compliance with environmental requirements.
Does the facility dispose of nonhazardous waste on site in a permitted landfill
or dump? (p. W-44)
This question appears in the following text and is accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
Does the facility dispose of nonhazardous waste on site in a
permitted landfill or dump ?
EPA/States regulate all waste disposal in an on-site landfill or on-site dump. Facilities
must obtain local and/or state permits as required. These permits must be current for
the type of waste being disposed of and they must be kept on site. If these conditions
are not met, then disposal on site is prohibited.
On-site disposal of hazardous waste is strictly prohibited if the facility is not a treatment,
storage, and disposal facility (TSDF). (See Section 1.0 for information on proper
disposal of hazardous waste.) Any time hazardous waste is buried, discharged, or
abandoned on site, then the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) requires the facility to report to the EPA. EPA/States may
require cleanup actions.
Q Yes
Facility disposes of nonhazardous waste in an on site landfill or dump,
and all local and/or state permits have been obtained.
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Q No Facility disposes of nonhazardous waste on site, but not in a permitted
landfill or dump.
Q NA Facility does not dispose of nonhazardous wastes on site.
3.7 Trackside Lubricating
(SEE HANDBOOK - PAGE 49)
NOTE: The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to trackside
lubricating for compliance with environmental requirements.
a. Does the facility conduct trackside lubricating using a trackside lubricator or
grease block? (p. W-45)
b. Does the facility place absorbent fabric around rail lubricators to prevent
ground contamination with oil? (p. W-45)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "") for environmental
compliance.
3.7a Does the facility conduct trackside lubricating using a trackside
lubricator or grease block?
Trackside lubricator grease is relatively immobile and is not expected to leach.
However, the accumulation of lubricator grease over time may require cleanup
activities. Some railroads use used motor oil for trackside lubrication. Facilities should
dispose of this ballast according to state regulations during track renovations.
Q Yes Facility conducts trackside lubricating.
Q No Facility does not conduct trackside lubricating.
3.76 Does the facility place absorbent fabric around rail lubricators to
prevent ground contamination with oil?
Q Yes Facility uses absorbent fabric to prevent ground contamination with oil.
Q Wo Facility does not use absorbent fabric.
Q NA Facility does not conduct trackside lubricating.
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3.8 Storage Tanks
(USTs - SEE HANDBOOK - PAGES 53-56,84-85)
(ASTs - SEE HANDBOOK - PAGES 36-37)
(SPILLS -SEE HANDBOOK - PAGES 31-34)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to storage
tanks for compliance with environmental requirements:
a. Has the State/Tribal UST program office been notified of any USTs located
on site? (p. W-47)
b. Does the facility conduct leak detection for tank and piping of all on-site
UST systems? (p. W-47)
c. Do USTs at the facility meet requirements for spill, overfill, and corrosion
protection? (p. W-48)
d. Are records and documentation readily available for leak detection, corrosion
protection, corrective action, closure, and financial responsibility? (p. W-49)
e. Does the facility have aboveground storage tanks (ASTs)? (p. W-49)
f. Do ASTs meet or exceed National Fire Protection Association (NFPA) 30A
requirements? (p. W-50)
g. Does the facility inspect the ASTs daily for leaks and other hazardous
conditions? (p. W-51)
h. Does the facility's total tank storage capacity make it subject to the Oil Pollution
Regulation? (p. W-52)
i Could spilled oil from the facility reach navigable waters or adjoining shorelines?
(p. W-52)
j. Does the facility have a Spill Prevention Control and Countermeasures
(SPCC) plan signed by a Professional Engineer? (p. W-53)
k. Is the phone number for the National Response Center posted on site for
immediate reporting of oil spills? (p: W-54)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "") for environmental
compliance. ,
Underground Storage Tanks
A facility may have underground storage
tanks (USTs) to supply fuel to trains or
support vehicles. USTs also 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. See Question
3.8f for more information.
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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 need 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, but 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 under 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, state, tribe or local regulatory
agency may regulate such USTs. Be sure to ask the state, tribal, or local regulatory agencies
to find out if additional or more stringent requirements apply to the facility.
3.8a Has the State/Tribal UST program office been notified of any USTs
located on site?
Facilities with on-site regulated UST systems must submit a notification form to the
responsible state/tribal Underground Storage Tank (UST) program office. 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 RCRA/UST, Superfund, and EPCRA Hotline at 1-800-424-9346.
Q Yes
Q No
Q NA
Facility has submitted a notification form to the responsible state/tribal
UST program office.
Facility has not submitted a notification form to the responsible
state/tribal UST program office.
Facility has no USTs.
3.8b Does the facility conduct leak detection for tanks and piping of all on-
site USTs?
. Facilities with federally regulated UST systems must conduct leak detection. The
monthly monitoring methods for conducting leak detection of tanks include the
following:
Automatic tank gauging
Monitoring for vapors in soil
Interstitial monitoring
Groundwater monitoring
Statistical inventory
reconciliation
Other methods approved by
the regulatory authority.
Note: Facilities with USTs may use inventory
control and tank tightness testing instead of one of
the monthly monitoring methods for a maximum
of 10 years after the tank is installed or upgraded
with corrosion protection (40 CFR 280.41). Call
the RCRA/UST, Superfund, and EPCRA Hotline
at 1-800-424-9346 for more information.
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3.8C
In addition, any pressurized piping must have: (1) monthly monitoring (as described
above) or annual line testing, and (2) an automatic flow restrictor, an automatic shutoff
device, or a continuous alarm system installed. Check with the State/Tribal UST
program to determine which leak detection methods are acceptable in the state.
Q Yes Facility conducts at least one leak detection method described above.
O No Facility does not conduct leak detection.
Q NA Facility does not have any federally regulated USTs.
Do USTs at the facility meet requirements for spill, overfill, and
corrosion protection?
Now that the December 22,1998 deadline for
all UST systems has passed, owners and
operators of facilities that continue to operate
UST systems not meeting the federal
requirements for leak detection, and spill,
overfill, and corrosion protection are out of
compliance. Besides posing a threat to human
health and the environment, such operation can
subject the owner/operator to considerable
fines.
Facilities must operate all USTs
subject to regulations to ensure that
spills or overflows do not cause
releases into the environment.
Facility owners and operators had
until December 22, 1998, to make
certain that all UST systems met the
federal requirements for leak
detection, and spill, overfill, and
corrosion protection in accordance
with the provisions of 40 CFR Part ^^^^^^^^^^^^^^^^^^^^^^^^^
280. Owners of noncompliant USTs
may close the UST temporarily for up to 12 months (December 22, 1999), as long as
(1) the facility continues to monitor for leaks by maintaining the UST's leak detection
and corrosion protection system; and (2) if temporarily closed for more than 3 months,
the UST must have vent lines open, but all other lines must be capped and secured.
After 12 months of temporary closure, the facility must permanently close the UST. To
find out more about federal UST requirements, call EPA's RCRA/UST, Superfund, and
EPCRA Hotline at 1-800-424-9346 or go to their website:
http://www.epa.gov/OUST/. Check with the state and local regulatory agencies to find
out if there are additional or more stringent state and/or local UST requirements.
Q Yes Facility has spill, overfill, and corrosion protection devices.
Q No Facility does not have protection devices installed.
Q MA Facility does not have any federally regulated USTs. '
Recordkeeping
If the facility has a federally regulated UST, it must maintain all records, including permits,
registrations, and installation or closure records to EPA or the state agency. The facility must
keep records that prove it meets certain requirements. The facility must keep those records
to show the facility's compliance status in five major areas: (1) leak detection, (1) corrosion
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protection, (3) corrective actions, (4) closure, and (5) financial responsibility. Check with the
state and local regulatory agencies about specific recordkeeping requirements.
3.8d Are records and documentation readily available for leak detection,
corrosion protection, corrective action, closure and financial
responsibility?
Leak detection records include past year's monitoring results and most recent
tightness test; copies of performance claims; maintenance, repair, and calibration of
leak detection equipment.
Corrosion protection records include results of the last two tests proving the cathodic
protection system is working and the last three inspections proving that impressed
current systems are operating properly.
Corrective action records document that any releases from USTs have been reported
to the appropriate agency and have been responded to as required.
Closure records document that the facility remove the LIST from service in accordance
with federal requirements for notification and correct, safe closure. Note: Facility must
maintain such records for at least 3 years after closing a UST.
Financial responsibility documentation shows one of the following: the facility
participates in a state financial assurance fund; the facility has insurance coverage; the
facility has a guarantee from another firm; the facility has a surety bond; the facility has
a letter of credit; the facility has passed a financial test; the facility has set up a trust
fund; or the facility uses another financial method(s) of coverage approved by your
state.
Q Yes Records are readily available as described above.
Q No Records are not readily available.
Q NA Facility does not have USTs.
Aboveground Storage Tanks
3.8e Does the facility have abovegroundstorage tanks (ASTs)?
Q Ves Facility has aboveground storage tanks.
Q No Facility does not have aboveground storage tanks.
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3.8f Do ASTs meet or exceed NFPA 30A requirements?
For facilities with fleet vehicle service stations, all ASTs must meet the National Fire
Protection Association (NFPA) requirements under NFPA 30A Automotive and Marine
Service Station Code and NFPA 30 Flammable and Combustible Liquids Code. NFPA
defines a fleet vehicle service station as a "portion of a commercial, industrial,
governmental, or manufacturing property where liquids used as fuels are stored and
dispensed into the fuel tanks of motor vehicles that are used in connection with such
businesses..."
NFPA 30A Automotive and Marine Service Station Code requirements address the
following:
Tank location and capacity
Control of spillage
Vaults
Fire-resistant tanks
Piping and ancillary equipment
Physical protection
Corrosion protection
Tank filling operations.
Requirements under NFPA 30 Flammable and Combustible Liquids Code include the
following:
Tanks
- Design and construction
- Installation
- Storage tank buildings
- Supports, foundations, and anchorage
for all tank locations
- Operating instructions
Piping systems
- Materials for piping, valves, and fittings
- Pipe joints
- Supports
- Protection against corrosion
Sources of ignition
Testing and maintenance
Fire protection and identification
Prevention of overfilling of tanks
Leak detection and inventory
records for underground storage
tanks.
Underground piping
Valves
Testing
Identification.
Note: NFPA 30 also apply to USTs. For more information call NFPA at 617-770-3000
or access their website at http://www.nfpa.org.
Q Yes Tanks meet or exceed NFPA requirements.
Q No Tanks do not meet NFPA requirements.
Q NA Facility does not have ASTs.
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3.8g Does the facility inspect the ASTs daily for leaks and other hazardous
conditions?
If regulated under SPCC requirements, facilities must inspect ASTs daily for evidence
of leaks or other hazardous conditions (e.g., rust, structural deterioration, etc.).
Q yes Facility inspects ASTs daily.
Q No Facility does not inspect ASTs daily.
Q NA Facility does not have ASTs.
Spill Prevention Control, and Countermeasures (SPCC) and
Emergency Response
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 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 ASTs and USTs. In particular,
the regulation applies to facilities that:
Have 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
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.
Could reasonably be expected to discharge oil in harmful quantities into navigable waters
of the United States.
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3.8h Does the facility's total tank storage capacity make it subject to the
Oil Pollution regulation?
If the facility has total gasoline, fuel oil, or lubricating oil storage capacity greater than
1,320 gallons (or greater than 660 gallons in any one tank) in aboveground storage
tanks or total underground tank storage capacity greater than 42,000 gallons, then it is
subject to the Oil Pollution regulation and must have an SPCC plan.
Note that the limits are different for above and below ground tanks. When adding
totals, the capacity:
Includes amount of oil that could be contained (e.g., 1,500-gaIlon 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).
Q Ves Facility exceeds capacity limits indicated above.
Q No Facility storage capacity is less than limits above.
Q NA Facility does not have storage tanks.
3.87 Could spilled oil from the facility reach navigable waters or adjoining
shorelines?
The term "navigable waters" generally means any body of water. If a spill could get to
groundwater, storm water, a creek, etc., it is to be able to reach navigable waters.
Spills are able to eventually reach navigable waters even if man-made structures (e.g.,
dikes, berms, storage containers) are present.
Q Ves A spill could reach navigable waters or adjoining shorelines.
Q Ato A spill could not reach navigable waters or adjoining shorelines.
Q NA Facility does not have storage tanks.
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3.8j Does the facility have a Spill Prevention, Control, and
Countermeasures (SPCC) plan signed by a Professional Engineer?
If the answers to questions 3.8h and 3.8i are "yes," then an SPCC plan must be on site
if the facility is normally attended for at least 8 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
discharge, 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, an alternative system may
be used.
« A complete discussion of the spill
prevention and control measures applicable to the facility and/or its operations.
Facilities must have an SPCC plan signed by a professional engineer. This 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 Vies The facility has an SPCC plan on site that has been signed and sealed by a
professional engineer.
Q No The facility does not have an SPCC plan or the plan is not signed by a
Professional Engineer.
Q NA The facility is not required to have an SPCC plan.
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Note: Facilities must have an SPCC Plan, and must also conduct an initial screening to determine
whether they need to develop a facility response plan. For more information refer to
http://www.epa.gov/oilspHI/netplans.htm or call the RCRA/UST, Superfund and EPCRA Hotline
at 1-800-424-9346.
3.8k Is the phone number for the National Response Center posted on site
for immediate reporting of oil spills?
In addition to an SPCC plan, EPA requires that if a facility has an accidental release of
an oil that meets federal reporting requirements (e.g., a discharge of oil that causes a
discoloration or "sheen" on the surface of water, violates water quality standards, or
causes a sludge or emulsion to be deposited beneath the surface or on adjoining
shorelines), they must report the oil spill to the National Response Center (NRC) at 1-
800-424-8802.
Q Ves NRC phone number is available on site.
Q No NRC phone numbers is not available.
3.9 Wastewater/ Storm Water Management
(SEE HANDBOOK - PAGES 57-60,87-93)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
wastewater and storm water management for compliance with environmental
requirements:
a. Can the facility identify the final destination of all its drains? (p. W-56)
b. How does the facility manage its wastewater? (p. W-57)
c. How does the facility manage its storm water? (p. W-57)
d. Does the facility have an NPDES permit for direct discharges? (p. W-58)
e. If the facility stores materials outside, does the facility protected them from
contact with storm water? (p. W-58)
f. Does the facility have a storm water pollution prevention plan (SWPPP)?
(p. W-59)
g. Is certification included in the SWPPP? (p. W-59)
h. If the facility discharges wastewater to a municipal sanitary sewer, has the
facility notified the publicly-owned treatment works (POTW) and received
approval for pretreatment discharges? (p. W-60)
I. If the facility discharges to a UIC well, does the facility comply with UIC program
requirements? (p. W-60)
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j. How does the facility manage the sludge from an oil/water separator? (p. W-61)
k. Does the facility have activities (e.g., metal finishing) that are subject to
categorical pretreatment standards? (p. W-62)
I. If yes, is the facility in compliance with the categorical standards for the
processes? (p. W-62)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Wastewater Discharges
Short line railroads may discharge wastewater and/or storm water from the following activities:
repair and maintenance of on-site vehicles, vehicle and equipment cleaning, building and
grounds maintenance, chemical storage and handling, fueling of vehicles, and painting and
paint removal operations. Facilities that discharge wastewater must have a National Pollutant
Discharge Elimination System (NPDES) permit and/or state permit if the wastewater is
collected and discharged off site through a distinct pipe or ditch to waters of the United States.
Either EPA or an authorized state can issue NPDES permits. As of September 1999, EPA
authorized 43 states and one territory to administer the NPDES program.
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 is scheduled to begin. Some states do not allow certain
discharges into the environment.
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 CFC § 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.)
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Discharges of storm water/wastewater into an underground injection well. [ These
discharges are 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].
Discharges to Publicly Owned Treatment Works (POTW)
POTWs are treatment plants that receive and treat wastewater through municipal sanitary
sewers prior to discharge to receiving waters (e.g., streams, lakes, rivers). They may also be
called 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. Although contacting
the POTW is not a federal requirement, 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.
3.9a Can the facility identify the final destination of all its drains?
Your facility may have interior and/or exterior drains (e.g., painting booths, waste
storage areas, service areas, fueling areas, etc.). The facility should identify the final
destination of all drains located at the facility.
If a drain discharges to a UIC well and the well has not been inventoried (in a
non-delegated state), your facility must submit an inventory to EPA. If a drain
and/or injection well is located in or near loading docks, storage areas, or
service areas, such that it could receive contaminants, a UIC well permit may
be required.
If a drain discharges to storm water or surface water, an NPDES permit is
required.
If a drain discharges to a municipal sanitary sewer, the facility may need a
permit from the publicly-owned treatment works (POTW), and general
pretreatment requirements may apply.
If an interior drain that may be receiving contaminants discharges onto the
ground surface, the facility must contact the state agency for applicable
permitting requirements.
Q Yes Facility can certify the final destination of all drains (e.g., storm sewer drains,
floor drains, and sanitary sewer drains).
Q No Facility cannot certify the final destination of all drains.
Q NA Facility does not have drains.
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3.9b How does the facility manage its wastewater?
There are several methods a facility can use to manage its wastewater. Wastewater
may contain pollutants (e.g., chemical solvents used for large scale equipment
cleaning). Prior to discharging wastewater, a facility may "treat" the wastewater using
an oil-water separator or some other method of treatment to reduce pollutant
concentrations. Wastewater may go to floor drains inside the facility and then drain to
an oil-water separator prior to discharge either (1) directly to surface waters (requires a
permit), or (2) to a sanitary sewer or combined sewer leading to a POTW. An NPDES
permit or the POTW may require treatment of wastewater.
Q Surface water
Q Sanitary sewer
Q UIC well
Q Ground
Q Other
Q NA
Facility discharges effluent directly to surface waters (in
accordance with an NPDES storm water permit (see Question
3.9d).
Facility discharges to a municipal sanitary sewer or combined
sewer with permission of the POTW (see Question 3.9h).
Facility discharges to a UIC well, generally via a floor drain
(see Question 3.9i). Although there are some exceptions, as
a general rule, discharging industrial wastewater to a UIC well
is NOT appropriate.
Facility discharges onto the ground. Wastewater may affect
groundwater or may flow into storm sewers and surface
waterways. Caution: Many states forbid the disposal of
washwater/rinsewater onto the ground.
Method of disposal is not listed.
Facility does not discharge wastewater.
3.9c How does the facility manage its storm water?
Storm water is a potential source of wastewater at a facility. Storm water discharges
begin when rain comes in contact with potential contaminants, such as spills, waste
containers, or spilled liquids related to vehicle or mechanical parts maintenance. The
pollutants in storm water will be dependent on the type of material(s) the rain comes in
contact with prior to discharge. A facility may "treat" storm water using an oil-water
separator or some other method of treatment to reduce pollutant concentrations prior to
discharge either (1) directly to surface waters, or (2) to a sanitary sewer or combined
sewer leading to a POTW. An NPOES permit (see Question 3.9d) or by the POTW
(see Question 3.9/7) may require treatment.
Q Surface water
Q Sanitary sewer
Storm water discharges go directly to surface waters (in
accordance with an NPDES storm water permit).
Storm water discharges go to a municipal sanitary sewer or
combined sewer with permission of the POTW.
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Q UIC well
Q Other
a NA
Storm water discharges go to a DIG well (via a floor drain).
Although there are some exceptions, as a general rule,
discharging industrial wastewater to a UIC well is NOT
appropriate.
Method of storm water management is not listed.
Facility does not discharge wastewater.
3.9d Does the facility have an NPDES permit for direct discharges?
NPDES permits must be in place in order to discharge industrial wastewater which
may include storm water through a storm sewer or directly into surface waters. The
facility may need to treat the wastewater 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.
Q Yes Facility has an NPDES permit.
Q No Facility does not have an NPDES permit.
Q NA Facility does not discharge wastewater directly from the facility to a body of
water.
3.9e If facility stores materials outside, are they protected from contact
with storm water?
A facility may need to store materials, including drums, cargoes, trash, and parts,
outside of facility buildings. These materials must have protection from contact with
storm water (including rain or snow) or other forms of water (e.g., washing overspray).
To prevent contact with storm water, a facility can store materials on pallets (or
something else that keeps them off the ground) and cover then with a tarp or roof.
Dumpsters should be closed and sealed to the extent that storm water will not enter or
exit the dumpster. Used oil (in some states), hazardous waste, and batteries must be
stored in an area with secondary containment, and in a manner that will protect them
from storm water.
Q Yes Facility protects materials from rain/snow.
Q No Facility does not protect materials from rain/snow.
Q NA Facility does not store any materials outside.
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3.9f Does the facility have a storm water pollution prevention plan
(SWPPP)?
If a facility must obtain an NPDES storm water permit, it will prepare and implement an
SWPPP. Facilities must develop SWPPPs to prevent storm water from coming in
contact with potential contaminants.
Q Yes Facility has an SWPPP.
Q No Facility does not have an SWPPP.
Q AM Facility is not required to have an SWPPP.
3.9g Is a certification included in the SWPPP?
Each SWPPP must include a certification, signed by an authorized individual, stating
that discharges from the site have been tested or evaluated for the presence of non-
storm water discharges. The certification must include the following:
A description of possible significant sources of non-storm water
The results of any test and/or evaluation to detect such discharges
The test method or evaluation criteria, the dates of the tests or evaluations, .and
the on site drainage points.
If certification is not feasible, the SWPPP must describe why (e.g., no access to
discharge sites).
Q Ves
Q A/o
Q AM
Facility's SWPPP includes a certification that discharges from the site have
been tested. -
Facility's SWPPP does not have a certification that discharges from the site
have been tested.
Facility is not required to have an SWPPP or certification is not feasible
because of circumstances described above.
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3.9h If the facility discharges wastewater to a municipal sanitary sewer,
has the facility notified the publicly-owned treatment works (POTW)
and received approval for pretreatment discharges?
Facilities should contact the POTW to see if any pretreatment requirements apply to
them. Although contacting the POTW is not a federal requirement, the facility could be
liable if it discharges a significant amount of oil or other material and those discharge
causes the POTW to violate its own NPDES permit.
Q Ves Facility has contacted POTW and has received approval for its wastewater
discharges.
Q No Facility has not contacted POTW or has not received approval for its
wastewater discharges.
Q NA Facility does not discharge to a POTW.
3.9; If the facility discharges to a 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. Railroad
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. The
UIC program requirements stipulate facilities must submit that 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, the fluids released by certain types of Class V wells have a
high potential to contain elevated concentrations of contaminants that may endanger
drinking water. Therefore, new requirements went into effect December 7, 1999, which
further regulate two types of Class V wells, Large Capacity Cesspools and Motor
Vehicle Waste Disposal Wells. Note: See following page 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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New Rule for Regulating Class V Wells
EPA is further regulating two 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.
3.9j How does the facility manage the sludge from an oil/water separator?
Oil/water separators, which are typically connected to floor drains or wash racks,
remove metals and other pollutants (e.g., oil) from wastewater. Oil-water separators
require periodic servicing to maintain their performance. Prior to cleaning an oil/water
separator, the facility should test the contents of the grit chamber and the oily sludge
for hazardous constituents. If the sludge exhibits any characteristic of a hazardous
waste, the facility should handle it as such. If the sludge is nonhazardous, the facility.
should manage it as a used oil. The facility should not dispose nonhazardous sludge
on site unless it is under a state and/or local permits.
Q Off site disposal
as hazardous waste
Q Off site disposal
to other facility
Q On site disposal
Q Landfill
Q NA
Facility disposes of hazardous sludge off site. The facility
stores, manifests, transports, and disposes of it in compliance
with all provisions of RCRA, including using a permitted
TSDF.
Facility disposes of nonhazardous sludge off site. The
facility disposes of it using an approved transportation,
treatment, and disposal facility.
Facility disposes of nonhazardous sludge on site and has the
required state and/or local permits.
Facility improperly landfills its oil/water separator sludge.
No sludge is produced.
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3.9k
Does the facility have activities (e.g., metal finishing) that are subject
to categorical pretreatment standards?
Under the Clean Water Act,
categorical standards (also known as
effluent limitation guidelines) are
established for specific types of
categories of industries or processes.
For example, if a railroad facility
conducts processes such as
electroplating or coating, that facility
may be subject to the metal finishing
categorical standards.
Finalizing Categorical Standards: EPA is
finalizing 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.
The categorical standards for facilities that conduct these and other operations that are
in the metal finishing categorical regulations include limits for certain pollutants in the
facility's process discharge. (Specific categorical limits apply to the facility's discharge
either if it goes directly to surface water or to a municipal wastewater treatment plant.)
For more information, contact the POTW or state permitting agency.
Q Yes Facility has determined whether it has activities that make it subject to
categorical pretreatment standards.
O No Facility has not determined whether it has activities that make it subject to
categorical pretreatment standards.
3.91 If yes, is the facility in compliance with the categorical standards for
the processes?
The EPA/State or POTW permitting agency will incorporate applicable categorical
standards into the facility's NPDES or POTW permit.
Q Yes Facility is in compliance with applicable categorical standards.
Q No Facility is not in compliance with applicable categorical standards.
Q NA Facility does not conduct any operations or processes that are subject to
categorical standards.
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3.10 Yard Dust Control
(SEE HANDBOOK - PAGE 61)
NOTE: One of the following questions is included in the accompanying checklist
(highlighted in bold) to help the facility examine its operations relating to yard
dust control for compliance with environmental requirements.
a. Does the facility control the road and yard dust emissions by using water or
other dust suppressants? (p. W-63)
b. Does the facility prohibit the use of used oils and other liquid wastes to
suppress dust? (p. W-63)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "") for environmental
compliance.
3.1 Oa Does the facility control the road and yard dust emissions by using
water or other dust suppressants?
Some facilities may have "fugitive dust," including dust from unpaved roads, yards, bulk
material handling, sand towers, etc. Facilities often control dust emissions by the use
of water or other suppressants.
Q Yes Facility controls road and yard dust emissions as described above.
Q No Facility does not control road and yard dust emissions.
3.1 Ob Does the facility prohibit the use of used oils or other liquid wastes
to suppress dust?
Historically, industry and government applied some used oils or other liquid wastes for
dust control. Laws strictly prohibit this practice now. States only allow commercially
available suppressants and in some states the products require specific authorization
from the state environmental agency.
Q Yes Facility does not allow the use of prohibited suppressants.
Q No Facility does not prohibit the use these suppressants. Note: Facility may be
out of compliance and should contact its state regulatory agency for
assistance.
Q NA Facility does not control road and yard dust emissions.
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SECTION 4.0 TRANSPORTATION
OPERATIONS
4.1 Hazardous Material Transport
(SEE HANDBOOK - PAGE 66)
NOTE: The following question is included in the accompanying checklist to help the facility
examine its operations relating to hazardous material transport for compliance with
environmental requirements:
a. Does the facility routinely conduct hazardous material inspections?
(p. W-64)
This question appears in the following text arid is accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
4.1a Does the facility routinely conduct hazardous material inspections?
The Department of Transportation (DOT) regulates hazardous material. DOT and EPA
jointly regulate hazardous waste transportation. EPA requires hazardous waste
manifest. If hazardous materials pass through the yard, the facility should inspect rail
containers for the following:
proper labeling,
valve cover placement,
stenciling, and
shipping papers.
Routine inspections also should include examination for spills and leaks of hazardous
materials. Report all spills and leaks promptly to the dispatcher.
Q Yes Facility conducts hazardous materials inspections routinely.
Q No Facility does not conduct hazardous materials inspections.
Q NA Hazardous materials do not pass through the rail yard.
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4.2 Locomotive Emissions
(SEE HANDBOOK - PAGES 68,97)
NOTE:
Both of the following questions are included in the accompanying checklist to help
the facility examine its operations relating to locomotive emissions for compliance
with environmental requirements:
a. Is the facility familiar with the new emission standards for locomotives?
(p. W-66)
b" °°f t,he&°"il^ minimiz.e locomotive emissions by(1) limiting idling times,
or (2) limiting the areas in which engines can idle? (p. W-66)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicted with a V") for environmental compliance.
Locomotive Emissions
Under Section 213(a)(5) of the Clean Air Act (CAA), EPA must regulate emissions from
locomotives. On April 16, 1998, EPA issued a final rule for emission standards for locomotives
and locomotive engines (63 FR 18977). The primary focus of this rule is to reduce nitrogen
oxide (NOx) emissions, which contributes to the formation of smog. The rule also contains
emission standards for hydrocarbons (HC), carbon monoxide (CO), particulate matter (PM)
and smoke. These standards will take effect in 2000.
The following locomotives are exempted from the new emission standards:
Locomotives manufactured before 1973
Historic steam locomotives
Locomotives powered by engines less than 750 kw (1006 horse power)
Repowered locomotives and switch locomotives using certified nonroad engines
Tier 0 locomotives owned and operated by small businesses
Exported locomotives
Mexican and Canadian locomotives used for border traffic.
In addition to the emission standards, the rule includes a variety of provisions to implement the
standards and to ensure that the standards are met in-use. These provisions include
certification test procedures and assembly-line and in-use compliance testing programs. The
rule also includes an emissions averaging, banking and trading program to improve feasibility
and provide flexibility in achieving compliance with proposed standards. It should be noted
that the regulations in this rule preempt certain state and local requirements relating to the
control of emissions from new locomotives and new locomotive engines. For more information
refer to EPA's website at http://www.epa.gov/oms/locomotv.htm or contact the state or local
air pollution authority.
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4.2a Is the facility familiar with the new emission standards for
locomotives?
Q Yes The facility is familiar with the new emission standards for locomotivesV
Q Wo The facility is not familiar with the new emission standards for
locomotives.
Q NA The new emission standards do not apply to the facility.
4.2/3 Does the facility minimize locomotive emissions by (1) limiting idling
times, or (2) limiting the areas in which engines can idle?
Some state and local governmental jurisdictions regulate the emissions from
locomotives. Primarily the requirements include restrictions on idling times and
locations. Check with your state and local air pollution control agencies to determine
their specific requirements.
Q Yes Facility minimizes locomotive emissions by limiting idling times and/or limiting
the areas in which engines can idle.
Q No Facility does not minimize locomotive emissions through limiting of idling
times and/or limiting of areas in which engines can idle.
4.3 Leaks and Spills
(SEE HANDBOOK - PAGES 31-34,64-65,69-70)
NOTE: The following question is included in the accompanying checklist to help the facility
examine its operations relating to leaks and spills for compliance with environmental
requirements:
a. Are facility crews trained to detect and report all spills and leaks
immediately? (p. W-66)
This question appears in the following text and may be accompanied with a discussion
of the preferred answer (indicted with a "") for environmental compliance.
4.3a Are facility crews trained to detect and report all spills and leaks
immediately?
Q Yes Facility trains crews to report all spills and leaks to the central dispatcher
immediately upon detection.
Q Wo Facility does not train crews.
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Other Operations
SECTION 5.0 OTHER OPERATIONS
5.1 Metal Machining
(SEE HANDBOOK - PAGE 17)
NOTE: The questions in this section are not included in the accompanying checklist,
however, they are still important to consider when examining your facility's
compliance with environmental requirements:
a. Does the facility store scrap metal in a covered and contained area? (p. W-67)
b. How does the facility manage metal scraps? (p. W-68)
c. How does the facility manage waste cutting oils and degreasing solvents used
in its metal machining processes? (p. W-68)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Metal Machining and Machine Cooling
Metal scraps may contain cutting oils, lubricating oils, and grease. Most
metal scraps have economic value for recycling or reclamation. During
storage of scrap metal, the facility should put the materials in container
and cover them to prevent the release of pollutants to the ground and
storm water. There must be no free liquids present.
The major hazardous wastes from metal machining are waste cutting
oils, spent machine coolant, and degreasing solvents. However, scrap
metal also can be a component of hazardous waste produced at a
machine shop. Material substitution and recycling are the two best
means to reduce the volume of these wastes. Facilities should attempt to substitute the oils
and solvents with water-soluble cutting oils whenever possible. They should also segregate
wastes carefully to facilitate reuse and recycling.
5.1a Does the facility store scrap metal in a covered and contained area?
Facilities should store metal scraps in a covered, contained area that prevents soil and
water contamination.
Q Yes Facility stores metal scraps in a covered and contained area.
Q No Facility does not store metal scraps in a covered and contained area.
Q NA Facility does not have any metal scraps.
Tip: Your local
scrap metal
recycling plant
may accept your
scrap metal if
sorted and
properly stored.
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5.1b How does the facility manage metal scraps?
Q Recycle . Facility recycles metal scraps.
Facility reuses metal scraps.
Facility collects metal scraps and sells these to metal recyclers.
Q Reuse
Q Sale
Q Other
D NA
Facility does not use one of the methods listed above to manage
metal scraps.
Facility does not have any metal scraps.
5.1 c How does the facility manage waste cutting oils and degreasing
solvents used in its metal machining processes?
Q Recycling
Q Reuse
Facility recycles waste cutting oils if nonwater-soluble oils must
be used.
Facility reuses and recycles solvents whenever possible.
Q Disposed of as Facility keeps waste cutting oils and degreasing solvents
hazardous waste separately in drums, labeled as "Hazardous Waste," and
disposed of by a hazardous waste hauler.
a NA
Facility does not conduct metal machining.
5.2 Painting/Paint Removal Operations
(SEE HANDBOOK - PAGES 21-25,95-98)
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to painting
and paint removal operations for compliance with environmental requirements:
a. Does the facility conduct painting/paint removal operations? (p. W-69)
b. Does the facility have air permits? (p. W-69)
c. If yes, are air permit conditions being met? (p. W-69)
d. Does the facility prepare surfaces to be painted by shot or grit blasting,
grinding, or sanding? (p. W-70)
e. If yes, does the facility test surfaces and paints for asbestos and lead?
(p. W-70)
f. Does the facility collect paint chips and metal dusts? (p. W-70)
g. How does the facility manage paint stripping wastes and baghouse dusts?
(p.W-71)
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h. Does the facility use low VOC paints in its painting operations? (p. W-71)
i. Does the facility mix paint amounts according to need? (p. W-71)
Does the facility take measures to minimize overspray? (p. W-72)
Does the facility properly contain and label paints not in use? (p. W-72)
J-
k.
I.
How does the facility manage used paints and waste paint products?
(p. W-72)
m. How does the facility dispose of spray paint booth air filters? (p. W-73)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Painting/Paint Removal Operations
5.2a Does the facility conduct painting/paint removal operations?
Facilities may conduct painting in specific areas such as paint booths. Note: The
facility should verify that there are no drains in the areas where painting occurs.
Q Yes Facility conducts painting/paint removal operations.
Q Wo Facility does not conduct painting/paint removal operations.
5.2b Does the facility have air permits?
States typically issue air pollution permits for certain operations such as painting and
surface preparation if certain state regulatory criteria apply. If air pollution control
equipment is installed, such as a baghouse.or scrubber, you must have a permit.
Check with the state for specific criteria and requirements.
Q Yes Facility has air permits and they are current.
Permit No(s).:
Q No Facility has not obtained air permits.
Q AHA Permits are not required.
5.2c If yes, are air permit conditions being met?
Q Yes Facility is meeting all air permit conditions.
Q No Facility is not meeting air permit conditions.
Q NA . Permits are not required.
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5.2d Does the facility prepare surfaces to be painted by shot or grit
blasting, grinding, or sanding?
In preparation for painting of
locomotives or buildings, shot
or grit blasting is used to
remove old paint. Grinding and
sanding are often used to
prepare the surface to be
painted.
Tip: If using chemical strippers containing hazardous
pollutants, be sure the facility is meeting air quality
standards. Contact the state or local air pollution
control agency for more information about air quality
standards.
Q Yes
a NO
a NA
Facility uses one of the above methods.
Facility does not use one of the above methods.
Facility is not preparing surfaces for painting at this time.
5.2e If yes, does the facility test surfaces and paints for asbestos and
lead?
If a facility uses shot or grit blasting, grinding, or sanding to remove old paint, then test
the surfaces and paints for asbestos and lead.
Q Yes
Q No
Q NA
Facility tests surfaces and paints for asbestos and lead.
Facility does not test surfaces and paints for asbestos and lead.
Facility does not prepare surfaces by shot/grit blasting, grinding, or
sanding.
5.2? Does the facility collect paint chips and metal dusts?
An effective practice to assure the optimum collection of paint dusts and chips is to blast
and sand within a booth or enclosure designed with dust collection ventilation and air
pollution control devices (e.g., baghouse). Conducting operations indoors without dust
collection and air pollution controls may expose employees to levels of airborne dust in
excess of the OSHA permissible limits for personal exposure to metals, such as lead
and cadmium. Conducting operations outdoors can allow dusts and paint debris to be
dispersed into the environment and may not be allowed by local and state air pollution
regulations. Check with state and local agencies and obtain the required air pollution
permits.
Q Yes Facility collects paint chips and metal dusts.
Q Wo Facility does not collect paint chips and metal dusts.
Q NA Facility does not conduct paint removal operations.
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5.2g How does the facility manage/dispose of paint stripping wastes and
baghouse dusts?
All materials collected from shot and grit blasting and sanding/grinding operations may
potentially be hazardous waste, depending on the previous paint coatings. If the
previous paints contained lead or chromium, the waste chips, and dusts may be toxic
hazardous waste, depending on Toxicity Characteristic Leaching Procedure (TCLP)
test results. See Section 1.0 for information on TCLP tests.
Q Recycling
Q Landfill
Q On-site disposal
Q Other
Q NA
Facility recycles paint stripping wastes and baghouse
dusts on site or ships them to a recycling facility.
Based on characterization, facility disposes of material at
a municipal or hazardous waste landfill.
Facility disposes of paint wastes and residues on site
(e.g., landfill).
Facility's method of disposal is not listed.
Facility does not have paint stripping wastes and/or
baghouse dusts.
5.2h Does the facility use low VOC paints in its painting operations?
Paint labels or product data sheets (or material safety data sheets [MSDSs]) should
contain the VOC content of the paint. In general, VOC content greater than or equal to
5 Ibs/gallon is high, between 4 and 5 Ibs/gallon is low, and below 4 Ibs/gallon is very
low.
Q Yes Facility uses paints with VOC content less than 5 Ibs/gallon.
Q Wo Facility uses paints with VOC content of 5 Ibs/gallon or higher.
Q NA Facility does not have painting operations.
5.21 Does the facility mix paint amounts according to need?
Facilities should mix paint by the job, as opposed to in large batches, thus reducing
potential paint waste.
Q Yes Facility mixes paint by the job.
Q Wo Facility mixes paints in large batches.
Q NA Facility does not have painting operations.
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5.2j Does the facility take measures to minimize overspray?
Facilities may take various measures, such as air-assisted; airless, high-volume, low
pressure turbine; air atomized electrostatic; and airless, electrostatic application'
techniques to minimize overspray. Another technique is the use of high transfer
efficiency spray applicators. High efficiency sprayers should have label 'HVLP' on the
gun. This is not yet a federal regulatory requirement. (Note: Required in some states.)
Q Ves Facility takes steps to minimize overspray.
Q No Facility does not use measures to minimize overspray.
Q NA Facility does not have painting operations.
5.2k Does the facility properly contain and label paints not in use?
Facilities must ensure that paints that are not in use are in labeled containers. Paint
containers must have tight-fitting lids. Storage must prohibit spills from reaching a drain
or otherwise leave the facility. Containers labels must indicate contents.
Q Yes Facility contains and labels paints as described above.
Q No Facility does not contain and/or label paints as described above.
Q NA Facility does not store paints.
5.27 How does the facility manage/dispose of used paints and painting
waste products?
Facilities should not bury or discard waste paint cans, residuals, or unused paint
products on site. Organic solvent-based paints and residuals may be classified as
hazardous waste and may require manifesting, storage, transportation, and disposal in
full compliance with RCRA. Facilities can recycle paint cans (that once contained
hazardous waste) that are classified as "empty" by the RCRA definition. Facilities can
dispose of latex paints off site at an approved facility as nonhazardous waste.
A container is "empty" if a facility removes all wastes and hazardous residues that can be
removed using a common practice for that type of container (e.g., pouring, pumping, etc.),
No more than 2.5 centimeters (i.e., one inch) of hazardous waste residue remains on
the bottom of the container or inner liner, OR
(A) If the container is < 110 gallons in size, no more than 3 percent by weight of the
total capacity of the container remains in the container or inner liner, OR
(B) If the container is greater than 110 gallons in size, no more than 0.3 percent by
weight of the total capacity of the container remains in the container or inner liner.
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Aerosol cans may be hazardous waste and may require manifesting, storage,
transportation, and disposal in full compliance with RCRA. Aerosol cans that are empty
and depressurized (i.e., all propellant is discharged) may be classified as
nonhazardous solid waste for off-site disposal.
Q Return to supplier
Q Reuse
Q Recycle
Facility returns all unused paints and thinners to the
supplier.
Facility gives leftover/unused paints and thinners to
customers, employees, or at "paint swaps."
Facility recycles items by hiring a paint, solvent, or thinner
recycler. (Generally this will apply to solvents or thinners.)
Facility disposes of paint wastes and residues on site.
Facility mixes materials with other fluids (solvent, used
oil).
Facility disposes materials at a municipal or hazardous
waste landfill based on characterization.
Facility pours leftover paint down the drain. Warning:
This practice must be stopped immediately.
Method of disposal is not listed here.
Facility does not generate used paints and waste paint
products.
5.2m How does the facility dispose of spray paint booth air filters?
Facilities must dispose of filters containing hazardous paints using a hazardous waste
hauler. Facility must maintain records indicating where they send hazardous filters.
Facilities can dispose of filters containing nonhazardous paints in a landfill or recycle
them.
Q On-site disposal
Q Mix with other fluids
Q Landfill
a Drain
Q Other
Q NA
Q Dispose as
hazardous waste
Q Recycle
Q Landfill
Q Other
Q NA
Facility disposes of filters containing hazardous paints as
hazardous waste.
Facility sends nonhazardous filters to a recycling facility.
Facility sends nonhazardous filters to a landfill.
Method of disposal is not listed.
Facility does not use filters.
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Other Operation*
5.3 PCB-Containing Equipment (SEE HANDBOOK -PAGES 50-52, 99-100)
NOTE: The following questions are not included in the accompanying checklist,
however, they are still important to consider when examining your facility's
operations for environmental compliance:
a. Does electrical equipment contain PCBs? (p. W-74)
b. Does the facility label and inspect PCB-containing equipment quarterly?
(p. W-75)
c. Does the facility store all out-of-service PCB-containing equipment in a
designated area? (p. W-75)
d. Do trained personnel cleanup PCB leaks/spills within 24 hours? (p. W-75)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
5.3a Does electrical equipment contain PCBs?
Electrical equipment, such as
electrical light ballasts, transformers,
and capacitors, containing insulating
or dielectric oils, may contain
polychlorinated biphenyls (PCBs).
Assume equipment manufactured
before 1978 to contain PCBs unless
proven otherwise by analytical
testing or other records. If PCBs are
present, the equipment is classified
by the concentration of PCBs in the
oil. The following are the three
classifications:
Some short line railroad facilities have electrical
equipment such as electrical light ballasts.
An electrical light ballast is the primary
component of fluorescent light fixtures. These
items generally are located within the fixture
under a metal cover plate. The function of a
light ballast is to accumulate and hold a charge
of electricity. According to EPA, all small light
ballasts manufactured through 1979 contain
PCBs. Ballasts manufactured after 1979 that
do not contain PCBs are labeled, "No PCBs."
Light ballasts for which no information is known
must be assumed to be PCB-contaminated.
Non-PCB equipment (less than
50 ppm)
PCB contaminated equipment (50- 499 ppm)
PCB (500 ppm or greater).
Facilities must assess all electrical equipment for their potential to contain PCBs. If all
the electrical equipment is found to be free of PCBs, then label all equipment as PCB-
free.
Q Yes Facility has electrical equipment that contains PCBs.
Q No Facility does not have electrical equipment that contains PCBs.
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Q Don't Facility has assessed electrical equipment for its potential to contain
know PCBs, and is unsure.
5.3b Does the facility label and inspect PCs-containing equipment
quarterly?
Facilities must label all electrical equipment (e.g., transformers and capacitors)
containing PCBs with the appropriate PCB classification. They must inspect this
equipment quarterly for leaks and to assure the labels are in place.
Q Yes Facility has labeled all equipment and inspects it quarterly.
Q No Facility has not labeled all equipment or does not inspect it quarterly.
Q NA Facility does not have equipment that contains PCBs.
5.3c Does the facility store all out-of service PCB-containing equipment in
a designated area?
Store all PCB-containing equipment not in service and awaiting disposal in a
designated area designed with protection from the rain and 100-year floods and with
complete containment. Assure the floor or pad of the designated area is relatively
impervious with a 6-inch high curb and no drains. Mark the area with a 6" x 6" sign
indicating "Caution: Contains PCBs." All items and doorways should also be marked.
Store all leaking equipment in an over-pack or suitable non-leaking container filled with
enough sorbent material to soak up all the fluid if released. Move any transformers and
other equipment with PCBs found to be outside of the designated area to a proper
storage area immediately.
Q Yes Facility stores all out-of-service PCB-containing equipment in a designated
area.
Q No Facility does not store out-of-service equipment in a designated area.
Q NA Facility does not have out-of-service PCB-containing equipment.
5.3cf Do trained personnel clean up PCB leaks/spills within 24 hours?
Assume all electrical equipment involved in spill or leaks to have PCBs unless sampled
and labeled to indicate otherwise. If a spill occurs, initiate a cleanup within 24 hours.
Complete cleanups within 48 hours, regardless of the regular business hours. Assure
trained personnel perform all cleanups and they meet recordkeeping requirements.
Initiate a cleanup immediately if one observes there is a transformer spillage and leaks.
The facility must develop a program and procedures to ensure that PCB equipment and
transformers are inspected for leaks and cleaned up when leaks appear. The program
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should detail the specific actions to be taken regarding response, notifications, cleanup,
personal protective equipment, storage, and disposal.
Q Yes Facility cleans up all PCB leaks properly.
Q No Facility does not clean up PCB leaks properly.
Q NA Facility does not have equipment that contains PCBs.
5.4 Air Conditioning Repair
(SEE HANDBOOK - PAGES 38,95-98)
NOTE: The following questions, some of which are included in the accompanying
checklist (highlighted in bold), will help the facility examine its operations
relating to air conditioning repair for compliance with environmental
requirements:
a. Does the facility maintain and/or repair CFC-containing equipment? (p. W-77)
b. Does the facility employ or hire trained and certified technicians to
maintain CFC-containing equipment? (p. W-77)
c. Are certificates on file? (p. W-77)
d. Does the facility remove all CFCs from equipment prior to maintenance
activities? (p. W-77)
e. Has EPA approved the CFC recovery and/or recycling equipment? (p. W-78)
f. Does the facility have documentation that refrigerants from recovery equipment
are sent to an EPA-approved reclaimer? (p. W-78)
g. Does the facility repair leaks of appliances containing ozone-depleting
refrigerants in a timely manner? (p. W-79)
h. How does the facility manage appliances containing ozone-depleting
refrigerants?
(p. W-79)
i. Has the facility ensured that its CFCs have been legally purchased? (p. W-80)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
Air Conditioning Repair
As of July 1, 1992, it became unlawful for any person maintaining, servicing, repairing, or
disposing of any appliance or industrial refrigeration to knowingly vent, release, or dispose of
any ozone-depleting substance [e.g., chlorofluorocarbons (CFCs)] to the environment. For a
list of ozone-depleting substances, contact the Stratospheric Ozone Information Hotline at
1-800-296-1996.
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5.4a Does the facility maintain and/or repair CFC-containing equipment?
The most common CFC-containing equipment maintained and repaired at a railroad
facility includes building and vehicle air conditioners, refrigeration equipment, and ice
machines.
Q Ves Facility maintains and/or repairs CFC-containing equipment.
Q No Facility does not maintain and/or repair CFC-containing equipment.
5.4b Does the facility employ or hire trained and certified technicians to
maintain CFC-containing equipment?
Refrigerant technicians must have EPA approved training. Each technician must have
his/her own certification. Certificates must be posted at the place of business (40 CFR
Part 82).
Q Yes Technicians are certified.
rj No Technicians are not certified.
Q NA Facility does not maintain CFC-containing equipment
5.4c Are certificates on file?
Q Yes Technicians' certificates are on the wall, in a file, or in their wallet.
Q No Technicians' certificates are not on file.
Q AW Facility does not maintain CFC-containing equipment.
5.4d Does the facility remove all CFCs from equipment prior to
maintenance activities?
A facility should only work on equipment repairs that would release CFCs after the
facility removes and collects the refrigerants.
Q Yes Facility removes and collects CFCs from equipment prior to maintenance
activities.
Q No Facility does not remove or collect CFCs from equipment prior to
maintenance activities.
Q NA Facility does not maintain and/or repair CFC-containing equipment.
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5.4e Is CFC recovery and/or recycling equipment EPA approved?
Technicians repairing or servicing air conditioners and other CFC-containing equipment
can only use recovery and/or recycling equipment that is approved by EPA. Currently,
EPA has approved both the Air-Conditioning and Refrigeration Institute (ARI) and
Underwriters Laboratories (UL) to certify recycling and recovery equipment. Certified
equipment is identified by a label reading: "This equipment has been certified by
ARI/UL to meet EPA's minimum requirements for recycling and/ or recovery equipment
intended for use with [appropriate category of appliancee.g., small appliances, HCFC
appliances containing less than 200 pounds of refrigerant, all high-pressure appliances,
etc.]." Lists of certified equipment may be obtained by contacting ARI at 703-524-8800
and UL at 708-272-8800 ext. 42371.
To demonstrate EPA approval, the equipment must have a label stating one of the
following:
1) "THIS EQUIPMENT HAS BEEN CERTIFIED BY [APPROVED EQUIPMENT
TESTING ORGANIZATION] TO MEET EPA'S MINIMUM REQUIREMENTS
FOR RECYCLING OR RECOVERY EQUIPMENT FOR USE WITH
[WHATEVER PROCESS THE EQUIPMENT IS BEING USED FOR];" or
2) "UL approved" or "ARI approved."
Q Yes Equipment has the ARI / UL approval and it has the appropriate labels .
Q No Equipment does not have the ARI / UL approval.
Q NA Facility does not maintain and/or repair CFC-containing equipment.
5.4f Does the facility have documentation that refrigerants from recovery
equipment are sent to an EPA-approved reclaimer?
Facilities that use recovery equipment must provide documentation that the refrigerant
is sent to an EPA-approved reclaimer.
Q Yes Facility maintains documentation that the reclaimer is EPA approved.
Q No Facility does not maintain documentation where refrigerants are sent.
Q NA Facility does not maintain and/or repair CFC-containing equipment.
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5.4g Does the facility repair leaks of appliances containing ozone-
depleting refrigerants in a timely manner?
If the facility's appliances (e.g., air conditioners, refrigerators) contain 50 or more
pounds of refrigerant, the facility must repair leaks in a timely manner and maintain
records of those repairs. See Question 5.2b for recordkeeping requirements.
Q Vies Facility repairs leaks of appliances containing 50 pounds or more of
. refrigerant in a timely manner.
Q No Facility does not repair leaks of appliances containing 50 pounds or more of
refrigerant in a timely manner.
Q NA Facility does not have appliances that contains 50 pounds or more of
refrigerant.
5.4/i How does the facility manage appliances containing ozone-depleting
refrigerants?
Q Landfill
Q Waste hauler
Q Scrap metal
recycler
Q Other
Facility disposes of appliances containing ozone-depleting
refrigerants in a landfill that contains refrigerant-recovery
equipment.
Facility has waste hauler pick up appliances. Waste hauler has
refrigerant-recovery equipment.
Facility sends appliances to scrap metal recycler that has
refrigerant-recovery equipment.
Method of disposal is not listed.
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5.4i Has the facility ensured that its CFCs have been legally purchased?
Warning: If an individual knowingly buys or
possesses CFCs smuggled into the United
States, that person is committing a
punishable, criminal offense and could face
severe penalties. For more information
regarding CFCs and enforcement actions
under the Clean Air Act (CAA), call EPA's
Stratospheric Ozone Protection Hotline at
1-800-296-1996.
When purchasing CFCs, the facility
should know where the specific brand
was produced and the name of the
manufacturer. Ask the seller for
documents of prior ownership of the
product (and a laboratory analysis of
the quality).
Investigating the source of the
material and the chain of ownership
is your responsibility. If the material
was imported, the facility should know when, where, and from whom it was imported.
The facility should also ensure that the packaging for the material is appropriate.
Illegally imported refrigerant is sometimes packaged in wrong size containers or fixed
with improper values.
O Yes Facility has ensured that CFCs have been legally purchased.
Q No Facility has not ensured that CFCs have been legally purchased.
Q NA Facility has not purchased CFCs.
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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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Glossary 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 which involve amounts under the reportable quantities (RQs) are not
emergency responses. (See 40 CFR Part 302)
Emergency Planning and Community Right-to-Know Act (EPCRA): The federal law
requiring corporate disclosure to local communities about certain 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
ATennessee, 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 90°F but below 100°F; flammable liquids with flash points below 100°F; pyrophoric
chemicals that ignite spontaneously in air at temperatures of 130° 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 140°F, 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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Glossary of Terms
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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Glossary of Terms
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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Glossary of Terms
other 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 or 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.
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
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
the RQ within a 24-hour period must be reported to the appropriate authorities (i.e., National
Response Center).
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- Glossary of Terms
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 (Superfund Amendments and Reauthorization Act), 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 Ground water 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.
Source Standards: Standards for emission levels at the source or point of emission.
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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.
Superfund 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 (excluding pesticides) 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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