United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2223A)
EPA 305-B-00-003
July 2000
4>EPA
Environmental
Screening Checklist
and Workbook for
Airports and Tenant
Operations
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Disclaimer
The environmental screening checklist and workbook are
tools to be used to help you evaluate compliance at your
facility. They do not contain an exhaustive list or
description of all federal environmental regulations that may
apply to your facility. Your facility is responsible for
knowing and complying with all applicable tribal, state, and
local requirements.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-i
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Introduction
TABLE OF CONTENTS
INTRODUCTION W- iv
How Can I Use the Checklist and Workbook? W - iv
How Are the Checklist and Workbook Organized? W - vi
Where Can I Get Help? w -vii
CHECKLIST
SECTION 1.0 MAINTENANCE W - 1
1.1 Hazardous Waste Generation, Storage, and Management . W - 1
1.2 Used Oil and Used Filters W - 9
1.3 Used Antifreeze W-15
1.4 Spent Solvents and Equipment Cleaning W-18
1.5 Used Battery Storage and Disposal W-22
1.6 Painting / Paint Removal Operations W-24
1.7 Air Conditioning Maintenance W-29
1.8 Used Rags/Shop Towels W-32
1.9 Absorbents W-34
1.10 Used Tires W-36
1.11 Used Brakes W-36
1.12 Metal Machining and Machine Cooling W-39
1.13 Metal Finishing and Coating Applications W-40
1.14 Dry Cleaning . . W-43
SECTION 2.0 MATERIALS STORAGE AND HANDLING W-45
2.1 Storage Tanks W-45
2.2 Hazardous/Extremely Hazardous Substances W-52
2.3 Fire Control Agents (Halons) W-56
2.4 PCB-Containing Equipment W-58
2.5 Cargo Loading and Off Loading W-60
SECTION 3.0 FUELING ; W-62
3.1 Aircraft Fueling W-62
3.2 Airport Support Vehicle Fueling W-63
SECTION 4.0 DEICING , . W-67
4.1 Aircraft Deicing . . . W-68
4.2 Runway Deicing W-69
SECTION 5.0 WASTEWATER AND STORM WATER MANAGEMENT W-71
5.1 Wastewater and Storm Water Management at Airports W-71
5.2 Activities Generating Wastewater and/or Storm Water W-78
SECTION 6.0 AIR TRANSPORTATION SUPPORT ACTIVITIES W-80
6.1 Buildings and Groundskeeping W-80
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Introduction
6.2 Nonhazardous Waste Management W-81
6.3 New Construction W-82
6.4 Asbestos (Building Renovation/Demolition) W-84
SECTION 7.0 MANAGEMENT AND ADMINISTRATION W-86
7.1 Recordkeeping W-86
7.2 Training Requirements W-90
GLOSSARY G -1
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-iii
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Introduction
INTRODUCTION
The United States Environmental Protection Agency (EPA) is providing the Environmental
Screening Checklist and Workbook for Airports and Tenant Operations as a' public service to
the air transportation 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 be in or remain in compliance with applicable federal
environmental regulations. The checklist and workbook highlight important or key
environmental requirements as they apply to the various federal environmental programs.
How CAN I USE THE CHECKLIST AND WORKBOOK?
You can use the checklist and workbook to evaluate your facility's compliance with the federal
environmental regulations which are applicable to the air transportation industry. The term
facility refers to, but is not limited to an airport or airport site overseen by owners/operators,
tenants, managers, field personnel, etc. who engage in air transportation 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
Airports and Tenant Operations," is a pictorial representation of specific activities that are
regulated or specific environmental requirements at an air transportation 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 Toil-Free Info-Line: 1-888-459-0656
TERC Internet Address: http://www.transource.org
Please remember that all of these materials are a beginning, not the final word, on
environmental compliance requirements. While federal environmental requirements are
highlighted in the checklist and workbook, a comprehensive discussion of all requirements is
NOT included. In addition to federal requirements, you may be subject to state, tribal, and/or
local requirements. You can use these materials to build a basic understanding or increase
your knowledge of federal environmental requirements, and then seek additional assistance
from various federal, state, tribal, and local agencies.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-iv
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Introduction
How ARE THE CHECKLIST AND WORKBOOK ORGANIZED?
What Is Included? Following this introductory section are the checklist and workbook.
These materials include the following sections:
Section 1.0 Maintenance ,
Section 2.0 Materials Storage and Handling
Section 3.0 Fueling
Section 4.0 Deicing
Section 5.0 Wastewater and Storm Water Management
Section 6.0 Air Transportation Support Activities
Section 7.0 Management and Administration
Following these seven 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 "" 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
air transportation facilities. After
reading each question, pick the
most appropriate response for your
facility. If you are unsure of what is
being asked by the question or what
a response means when using the
checklist, refer to the same question
in the workbook. The workbook
includes some general explanatory
text for each question, as well as explanations of each response. A "" next to a response in
the workbook indicates that it is a preferred response in terms of environmental compliance
(see box). The use of the workbook is encouraged as it will help you and others at your facility
conducting evaluations to respond to the compliance questions consistently and accurately.
Can the checklist be personalized? The checklist can be personalized to fit the needs of
your facility. When evaluating environmental compliance, you or the person conducting it
should record certain information on the checklist, including the date, name of the facility,
name of the person conducting the evaluation, and any comments or questions regarding the
compliance evaluation. Such information will help you monitor your facility's continued
progress towards environmental compliance.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-vi
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Introduction
WHERE CAN I GET HELP?
During the evaluation and everyday operation of your facility, you may need to obtain
additional information on specific environmental requirements. Many resources are available
to you which can provide valuable
information on federal
environmental requirements,
pollution prevention, and other
topics. Some of these resources,
which can be contacted by
telephone or accessed through the
Internet, include publications,
hotlines and information lines, EPA
EMERGENCY RESPONSE & ASSISTANCE
National Response Center (NRC) - U.S. Coast
Guard Oil & Hazardous Material Spills (800-424-
8802)
CHEMTREC operated by Chemical
Manufacturers Association on Health and Safety
(800-424-9300)
Environmental Health Effects: (National Institute
of Health) Information on chemicals in ground and
surface water, hazardous wastes (800-643-4794)
Local Emergency Number: 911
Headquarters and regional offices,
financial assistance information,
and pollution prevention websites.
Publications
Sector Notebooks. The
following sector notebooks,
which may be of interest to
the air transportation
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 Aerospace Industry, EPA/310-R-97-001 (131 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.htrnl
Code of Federal Regulation (CFR) References.
Website: http://www.access.gpo.gov/nara/cfr/index.html
Hotlines and Information Lines
Transportation Environmental Resource Center (TERC) Information Line
Telephone: (888) 459-0656
Website: http://www.transource.org
This resource center is designed to help transportation industries stay on top of
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Introduction
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
This office provides RCRA coordination program information collection
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Introduction
outreach and guidance. For additional information on waste minimization,
check website: http://www.epa.gov/wastemin
National Pesticides Information Line
Telephone: (800) 858-7378
This service provides information relating to pesticide usage, including label
information, incident investigations, emergency human and animal treatment
safety practices, 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 (RCRA/UST), Superfund, and Emergency Planning
and Community Right-to-Know (EPCRA) Hotline
Telephone: (800) 424-9346 or (703) 412-9810
This hotline provides information about the RCRA/UST, Superfund, and EPCRA
programs. Specifically, the hotline responds to inquiries about waste
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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
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 regulations, referrals to companies that provide filter management
services, referrals to state agencies, and a brochure entitled "How to Choose a
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Introduction
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/
Region 5 (IL, IN, Ml, MN, OH, Wl)
Telephone: (312) 353-2000
Toll-free: (800) 621-8431
Website: http://www.epa.gov/region5/
Region 6 (AR, LA, NM, OK, TX)
Telephone: (214) 665-2200
Toll- free: (800) 887-6063
Website: http://www.epa.gov/region6/
Region 7 (IA, KS, MO, NE)
Telephone: (913) 551-7003
Toll- free: (800) 223-0425
Website: http://www.epa.gov/region7/
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July 2000
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Region 8 (CO, MT, ND, SD, UT, WY)
Telephone: (303) 312-6312
Toll-free: (800) 227-8917
Website: http://www.epa.gov/region8/
Reg/on 9 (AZ, CA, HI, NV)
Telephone: (415) 744-1305
Website: http://www.epa.gov/region9/
Reg/on 10 (AK, ID, OR, WA)
Telephone: (206) 553-1200
Toll-free: (800) 424-4372
Website: http://www.epa.gov/region101
Financial Assistance Information
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.
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
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and Workbook for Airports and Tenant Operations
July 2000
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This site provides access to federal publications, OPPT programs and initiatives,
and other information sources related to pollution prevention.
EPA'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.htmWinfo
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.
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
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Operated by EPA's Office of Pollution Prevention and Toxics, this clearinghouse
is a free, non-regulatory service that provides telephone reference and referral,
document distribution for selected EPA documents, and a special collection
available for interlibrary loan.
Pollution Prevention Cooperatives
Coordinated with EPA's Enviro$en$e program, these cooperatives provide easy
access to pollution prevention and cleaner production resources around the
Internet.
(1) U.S. Federal Agency Pollution Prevention Cooperative
Website: http://es.epa.gov/cooperative/federal/
(2) State and Local Government/Business Assistance Cooperative
Website: http://es.epa.gov/cooperative/stateandlocal/
Solvents Alternative Guide (SAGE)
Website: http://clean.rti.org/
This on-line guide provides pollution prevention information on solvent and
process alternatives for parts cleaning and degreasing. It also provides access
to EPA's Air Pollution Prevention and Control Division website.
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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ENVIRONMEISTAL SCREENING CHECKLIST FOR AIRPORTS AND TENANT OPERATIONS
Facility/Location:
Tenant:
Site Reviewer:
Date:
1.0 MAINTENANCE
lazardous
Waste
jeneration
Storage and
Management*
Jsed Oil and
Jsed Filters*
Jsed Antifreeze*
pent Solvents
nd Parts
Ueaning*
fsed Battery
torage and (
lisposal*
ainting/Paint
emoval
iperations*
sed Rags/Shop
owels*
sed Tires
sed Brakes*
letal Finishing
id Coating
pplications*
Does the facility have an EPA hazardous waste generator ID number? (p. W-6)
Does the facility store hazardous waste in appropriate storage containers? (p. W-6)
How does the facility manage/dispose of its hazardous waste? (p. W-7)
Does the facility have a written contingency plan or basic contingency procedures in place for responding to spills
and releases of hazardous wastes? (p.W-8)
Are used oil containers/tanks and associated piping labeled "used oil"? (p. W-10)
Are used oil containers/tanks and associated piping leak free? (p. W-10)
Does the facility prevent the mixing of used oil with hazardous waste? (p. W- 11)
How does the facility manage/dispose of used oil ? (p. W-l 1 )
How does the facility manage/dispose of used oil filters ? (p. W -13)
How does the facility manage/dispose of used fuel filters ? (p. W-l 4)
In terms of storage, does the facility contain, segregate, and label used antifreeze ? (p. W-l 5)
Has the facility determined if it generates any antifreeze mat is hazardous waste? (p. W-16)
If halogenated solvents are used in cleaning equipment, has the facility submitted a notification report to the air
permitting agency? (p. W-20)
Does the facility store spent solvents in labeled containers ? (p. W-20)
How does the facility manage/dispose of spent solvents ? (p. W-2 1)
If storing used batteries, does the facility protect them from storm water contact? (p. W-23)
How does the facility manage/dispose of used batteries? (p. W-23)
Does the facility have any air permits? (p. W-25)
How does the facility dispose of paint stripping wastes and baghouse dusts ? (p. W-26)
How does the facility dispose of paints and painting waste products? (p. W-28)
How does the facility manage used rags and shop towels? (p. W-33)
How does the facility dispose of used tires? (p. W-36)
How does the facility manage asbestos brake pads and other asbestos-containing material (ACM) waste?
(p. W-38)
Is the facility subject to categorical pretreatment standards? (p. W-41)
Does the facility have air permits for metal finishing and/or coating application operations? (p. W-42)
YD ND NAD
YD No NAD
RCRA-permitted TSDF / Recycling facility /
An Interim status facility / On site RCRA-
permitted TSDF / Other / NA
YD ND NAD
Ya ND NAD
YQ N D NA D
Y a N a NA D
Sent off site for recycling /Burned in an on-site
space heater / Burned offsite / Other / NA
Recycle / Service company / Other / NA
Recycle / Service company / Managed as
Y D N D NA D
Y a N a NA a
YD N D NA a
YD N a NA a
Third party vendor / Permitted discharge to
storm sewers or surface waters / Permitted
discharge to sanitary sewer / Other / NA
YD No NA a
Return to supplier / Recycle / Service company
/ Universal waste handler / Send to hazardous
waste landfill / Other / NA
Y" D NO NA D
Recycling / Landfill / Other /NA
Return to supplier / Reuse / Recycle /Other /NA
Laundry service / Burned for heat / Hazardous
waste transporter / Other / NA
Resale / Retread / Recycle / Other / NA
Recycled offsite / Disposed by vendor / EPA-
approved disposal site / Other / NA
YD No NAD
YD No NA a
2.0 MATERIALS STORAGE AND HANDLING
torage Tanks*
Has the facility notified the State/Tribal underground storage tank (UST) program of any USTs located on site?
(p. W-46)
Does the facility conduct leak detection for tanks and piping of all on-sitc USTs? (p. W-47)
Do USTs at the facility meet requirements for spill, overfill, and corrosion protection? (p. W-47)
Does the facility inspect ASTs periodically for leaks and other hazardous conditions? (p. W-49)
Does the facility have a Spill Prevention, Control, and Countermeasures (SPCC) plan signed by a Professional
Engineer? (p. W-50)
Does the facility have the phone number for the National Response Center posted on site for immediate reporting of
YD ND NAD
YD ND NAD
YD ND NAD
YD ND NAD
Y a ND NA D
YD ND
-------
Hazardous/
Extremely
Hazardous
Substances*
Fire Control
Agents
(Haloos)*
Cargo Loading
Loading *
===r
Aircraft Fueling*
Did the facility participate in emergency planning activities when it has extremely hazardous substances (EHSs) in
excess of their threshold planning quantities (TPQs)? (p. W-53)
Did the facility immediately notify the proper authorities after an accidental release of a hazardous or extremely
hazardous substance ? (p. w-53)
How does the facility dispose of halons and halon-containing equipment? (p. W-57)
If the facility loads hazardous materials onto an airplane, does the facility inspect containers for
1) labeling/placarding,
2) signs ot leakage, and
3) compatibility with other hazardous materials? (p. W-61)
YD NO NAD
YD ND NAD
Returns to manufacturer / Returns to fire
equipment distributor / Returns to halon
recycler / Destroys equipment / Other / N A
YD No NAD
YD ND NAD
YD No NA D
3.0 FUELING
Docs the facility use measures to prevent fuel spills during fueling of aircraft? (p. W-62)
YD ND
4.0 DEICING
Aircraft
Dcieing*
Runway
Dcieing*
Does the facility have deicing fluid collection systems that prevent discharge to storm water sewers? (p. W-68)
How docs the facility dispose of spent deicer? (p. W-69)
If discharging deicing wastes to a municipal sanitary sewer or a combined sewer that goes to a Publicly-Owned
Treatment Works (POTW), has the facilfty notified the POTW? (p. W-70)
Docs the facility meet deicing fluid parameter limits/conditions in its NPDES permit? (p. W-70)
YD N D NA a
Recycle / Treats on site / Discharge to POT\
Permitted discharge to surface water / Off-sit
disposal/ Other /NA
YD ND NAD
YD ND NAD
5.0 WASTEWATER AND STORM WATER MANAGEMENT**
Wastewaterand
Storm Water
Management at
Airports*
Activities
Generating
Storm Water*
Can the facility identify the final destination of all its drains? (p. W-72)
If the facility discharges to a surface water, does it have an NPDES permit ? (p. W-74)
Docs the facility have a storm water permit?
If Yes, does the facility have a storm water pollution prevention plan (SWPPP)? (p. W-75)
If discharging to a municipal sanitary sewer, has the facility notified the Publicly-Owned Treatment Works
(POTW) and received approval for discharges? (p. W-76)
How docs the facility manage the sludge from an oil/water separator? (p. W-77)
If the facility stores materials outside, does the facility protect them from contact with storm water? (p. W-79)
Yn ND NAD
YD No NAD
YD ND
YD ND NAD
YD No NAD
Off-site disposal as hazardous waste / Off-si
disposal to other facility / On-site disposal o(
nonhazardous sludge / NA
Y D. N D NA D
7.0 MANAGEMENT AND ADMINISTRATION
Rccordkceping*
NPDES'. Does the facility keep records of NPDES monitoring information for a minimum of 3 years? (p. W-86)
NPDES: As part of the SWPPP, does the facility maintain records of spills, discharges, and other information
describing the quality and quantity of storm water discharges? (p. W-87)
Air: Is the facility keeping records as required by its air permits? (p. W-87)
RCRA: Does the facility keep a copy of its manifest for a minimum of 3 years? (p. W-88)
USTs: Does the facility maintain records of leak detection, spill, overfill, and corrosion protection; corrective
actions; closure; and financial responsibility? (p. W-89)
Pesticides'. Does the facility maintain records of use and storage of pesticides? (p. W-89)
YD ND NAD
YD No NAD -
YD ND NAO
YG No NAO
YD ND NAD
YD ND NAD
* For additional questions regarding these environmental compliance issues refer to the workbook.
** Refer to workbookfor questions in Section 6.0 Air Transportation Support. Activities, including questions regarding, buildings and groundskeeping (p. W-80), nonhazardoiu,
waste management (p. W-81), new construction (p. W-82). asbestos (p. W-84). and training requirements (p. W-90).
In addition, the workbook includes environmental compliance questions regarding air conditioning maintenance (p. W-29), absorbents (p. W-34), metal machining and machine
sooling (p. W-39), PCB-coniaining equipment (p. W-58), airport support vehicle fueling (p. W-63).
-------
Maintenance
SECTION 1.0 MAINTENANCE
I. I Hazardous Waste Generation, Storage, and
Management
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. Does the facility generate hazardous waste? (p. W-3)
b. If yes, how much hazardous waste does the facility generate a month? (p. W-5)
c. Does the facility have an EPA hazardous waste generator ID number?
(p. W-6)
d. Does the facility store hazardous waste in appropriate storage containers?
(p. W-6)
e. Does the facility meet all hazardous waste storage (quantity and time)
requirements? (p. W-7)
f. How does the facility manage/dispose of its hazardous waste? (p. W-7)
g. Does the facility have hazardous waste manifests or DOT shipping papers on
file? (p. W-8)
h. Does the facility have a written contingency plan or basic contingency
procedures in place for responding to spills and releases of hazardous
wastes? (p. W-8)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "") for environmental
compliance.
Identifying Hazardous Waste
An air carrier or airport facility may produce
wastes that are hazardous. Therefore, it is
important that the facility identify and
manage them properly to protect facility
employees and others in the community, as
well as the environment. As a waste
generator, the facility is responsible for all
steps in hazardous waste management,
from generation to final disposal. The
facility can be held liable for any mismanagement of its 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 or not its
waste is hazardous 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 Airports and Tenant Operations
July 2000
W-1
-------
Maintenance
What is Hazardous Waste ?
To be considered "hazardous waste," materials must first meet EPA's definition of "solid waste."
Solid waste is discarded material, including garbage, refuse, and sludge (solids, semisolids,
liquids, or contained gaseous materials). Solid wastes that meet the following criteria are
considered hazardous and subject to regulations under Resource Conservation and Recovery
Act (RCRA) (40 CFR Part 261):
Listed wastes. 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 wastes. If the 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 they leach toxic
chemicals into the soil or groundwater when disposed of on land (40 CFR 261.24).
Examples are 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 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 Airports and Tenant Operations
July 2000
W-2
-------
Maintenance
Universal Waste Rule
In 1995, EPA issued the Universal
Waste Rule as an amendment to RCRA
to reduce the regulatory burden on
businesses by providing an alternative
and less stringent set of management
standards for three types of waste that
potentially would be regulated as
hazardous: (1) batteries (e.g., nickel
cadmium, small sealed lead acid) that are
"' 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.
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
1.1 a Does the facility generate hazardous waste?
a yes
a NO
Facility has gone through the waste determination process or used
process knowledge and determined that is does generate hazardous
waste. See Exhibit 2 for common hazardous wastes generated by air
transportation facilities.
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
hazardous wastes.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-3
-------
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-------
Maintenance
If yes, how much hazardous waste dqes the facility generate a
month? '
When determining the volume of waste generated, only waste 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)
Q No more than 220 Ibs (700 kg) of hazardous waste per month. This is
approximately Y2 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 (700 kg) and 2,200 Ibs
(1,000 kg) of hazardous waste per month.
In this case, the facility generates more than
Vz of a 55 gallon drum of. hazardous waste,
but less than five 55-gallon drum 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.
Over 2,200 Ibs (7,000 kg) of hazardous
waste per month. In this case, the facility
generates approximately five 55-gallon
drums or more of hazardous waste in any
month. In this case, the facility is considered
a large quantity generator (LQG) 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 stores more than that
amount for any period of time,
the facility may manage the
acutely hazardous waste
according to the CESQG
requirements. If the facility
generates more than 2.2 Ibs
(1 kg) of acutely hazardous
waste, the facility must manage
waste according to the LQG
requirements.
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 Airports and Tenant Operations
July 2000
W-5
-------
Maintenance
1.1c Does the facility have an EPA hazardous waste generator ID number?
If the facility is an SQG or LQG (as discussed in Question 1.1 b), 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. This
number must be entered on all hazardous waste manifests. It is usually placed near the
top of the form under the heading, "Generator ID #." If the number is issued by the
state, the number will start with the state abbreviation followed by the number (e.g., NY-
12345678). CESQGs do not need an identification number under federal law. Contact
the state or EPA regulatory agency to obtain a copy of EPA form 8700-12 "Notification
of 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 identification number from EPA or the state
regulatory agency that has been granted regulatory authority by EPA.
Q No Facility has not obtained an EPA identification number.
Q NA Facility is a CESQG and therefore not required to obtain a generator
identification 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 may be 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 the facility 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.
D Yes Facility stores waste in containers that meet the above requirements.
Q A/o 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 Airports and Tenant Operations
July 2000
W-6
-------
Maintenance
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 considered 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 (1,000 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/or
time requirements.
Q NA Facility does not generate hazardous waste.
1.1 f 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 Airports and Tenant Operations
July 2000
W-7
-------
Maintenance
1.1g Does the facility have hazardous waste manifests or DOT shipping
papers on file?
For SQGs and LQGs, a Uniform Hazardous Waste Manifest must accompany each
hazardous waste shipment. [Exception: SQGs are not required to have manifests for
certain recyclable materials such as solvents, and there are some hazardous materials
(e.g., scrap metal) which do not have to be manifested.] Contact the state regulatory
agency for a Uniform Hazardous Waste Manifest form. CESQGs are not required to
use manifests.
A hazardous waste transporter should be able to assist in completing the manifest.
Manifests must be kept for 3 years. Additionally, DOT shipping papers may need to
accompany each hazardous waste shipment. These papers document the shipment
type, quantity, origin, and destination, and must accompany each hazardous waste
shipment. For more information, contact the RCRA/UST, Superfund, and EPCRA
Hotline at 1-800-424-9346, or the state regulatory agency.
Q Yes Facility has manifests and/or shipping papers on file for hazardous wastes
transported.
Q No Facility does not have manifests and/or shipping papers for hazardous
wastes shipments.
D NA Facility does not ship hazardous waste off site.
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 LQG, 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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-8
-------
Maintenance
SQGs are required to have basic contingency procedures which include the following:
Assign an emergency coordinator (employee) who is responsible for coordinating
all emergency response measures.
Post information 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.
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 not required
to meet RCRA's emergency preparedness requirements.
See Section 7.2 for Emergency Response Training Requirements.
1.2 Used Oil and Used Filters
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-10)
b. Does the facility prevent the mixing of used oil with hazardous waste?
(p. W-11)
c. How does the facility manage/dispose of used oil? (p. W-11)
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-12)
e. Does the facility completely drain used oil filters and/or fuel filters before
disposal? (p. W-13)
f. How does the facility manage/dispose of used oil filters? (p. W-13)
g. Has the facility determined if its used fuel filters are hazardous? (p. W-13)
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h. How does the facility manage/dispose of used fuel filters? (p. W-14)
i. Does the facility inspect used oil filter storage areas for oil spills and leaks? (p.
W-14) (H
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.
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 classified as
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 (LIST) 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"?
Note: If the facility uses storage tanks to
store waste oil, such tanks may be
regulated under underground storage
tank (UST) or aboveground storage tank
(AST) regulations.
The facility must store used oil in a leak free
containers with a label 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. Used motor oil may be mixed with
other used oils (hydraulic oils, transmission fluids, brake fluids) and stored in the same
tank.
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 also be labeled
with the words "used oil."
Q Yes Used oil is in a leak free container(s) with a label with the words "used oil."
Q No Used oil is not in a leak free container and/or has not label, "used oil."
D NA Facility does not generate used oil.
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1.2b Does the facility prevent the mixing of used oil with hazardous waste?
The facility should not mix hazardous waste fluids, such as used solvent, gasoline, or
other hazardous substances, with used oil, or the entire volume may be classified as
hazardous waste. For example, while 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
Section 1.1). One may mix used motor oil with other used oils (e.g., transmission fluid or
brake fluid) and stored in the same container/tank. If the facility has 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 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
approaches 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 BTU per hour or less are
used to burn the used oil.
The gases from the space heater are vented outside.
The facility can handle and dispose of used hydraulic oils as used oil and it can be
blended with other used oils, such as engine and lube oils. Recycling and reclamation
are preferred over disposal.
O Sent off site
for recycling
Q Burned in an
on site space heater
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 BTU used to heat the facility or
heat hot water. Note: There may be Clean Air Act (CAA)
requirements that apply when burning used oil. Contact the
state or local air pollution control agency for more information.
Q Burned off site
Q Other
Q NA
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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Q NA
Facility does not generate used oil.
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, it is required to (1) have
an EPA ID number and (2) be licensed as a used oil transporter when transporting used
oil to an approved used oil collection center.
Q Yes 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 is not licensed 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.)
Have been properly drained (i.e., hot-drained) of used oil.
According to federal regulations, filters can be disposed of 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 filter should be removed from a warm engine and
drained immediately. Four distinct methods of hot-draining can be used:
Gravity Draining: When the filter is removed from the engine, it should be placed 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: The filter is crushed by a mechanical, pneumatic, or hydraulic device to
squeeze out the used oil/fuel and compact the remaining filter materials.
Disassembly: The filter is separated into its different parts using a mechanical device.
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: The filter is placed into a device where air pressure forces the used oil/fuel
out of the filter.
Storage containers designated for used oil filters should be protected from storm water with a
cover. In addition, the container should be capable of holding any used oil that seeps from the
filters.
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Used fuel filters: Facilities should properly drain used fuel filters (using the same procedure as
used oil filters) and then tested to determine if they are hazardous. If the fuel filters are
determined to be hazardous, they count toward the facility's generator status (see Section 1.1
for more information). One should store used fuel filters in a separate, marked, fireproof
container. If the facility is a CESQG, it can dispose of used fuel filters in a licensed landfill or
through a hazardous waste hauler. If the facility is an SQG or LQG, then it must use a
hazardous waste hauler with an approved EPA ID number. One can manage metal filters as
scrap metal if properly drained.
Note: Since disposal requirements of used filters may vary by state, please consult the state
regulatory agency to assure 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 NA Facility does not generate used oil or fuel filters.
1.2f How does the facility manage/dispose of used oil filters?
Q Recycle Filters are recycled for scrap metal.
Facility contracts with a service which takes filters.
Q Service
Q Trash
Q Other
Q NA
Filters are disposed of 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 not generate used oil filters.
1.2g Has the facility determined if its used fuel filters are hazardous?
Q Ves Facility has determined through testing if its used fuel filters are hazardous.
Q No Facility has not determined if its used fuel filters are hazardous.
Q NA Facility does not generate used fuel filters.
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1.2h How does the facility manage/dispose of used fuel filters?
Note: If used fuel filters have been determined to be hazardous waste, you must count
them towards the facility's generator status and managed accordingly. See Section 1.1
for more information on hazardous waste management.
Q Recycle
Q Service
Q Managed as
hazardous waste
Q Trash
Q Other
QNA
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 not 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 planes 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 regularly for spills, in areas where oils are received, stored,
used, changed, and potentially spilled. 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. All
spills should be contained and cleaned up immediately after detection. The facility
should consult the Spill Prevention, Control, and Countermeasures (SPCC) plan in the
event of a spill 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.
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1.3 Used Antifreeze
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
antifreeze for compliance with environmental requirements:
a. In terms of storage, does the facility contain, segregate, and label used
antifreeze? (p. W-15)
b. Has the facility determined if it generates any antifreeze that is hazardous
waste? (p. W-16)
c. Does the facility reclaim used antifreeze on site in a closed loop system?
(p. W-17)
d. If not reclaimed in a closed loop system, does the facility count the waste
antifreeze toward the facility generator status? (p. W-17)
e. If facility does not reclaim used antifreeze on site in a closed loop system how
does the facility manage it? (p. W-17)
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.
Used Antifreeze
Aircraft and aviation-support vehicles require regular changing of coolants, such as antifreeze.
To minimize releases to the environment, the facility should drain and replace antifreeze in
areas where there are no connections to storm drains or municipal sewers. They should clean
up minor spills prior to reaching drains. The facility should collect and store antifreeze in
separate containers and not mix with other fluids.
1.3a In terms of storage, does the facility contain, segregate, and label
used antifreeze?
Contained. Containers are closed (e.g., lids are on, caps are screwed on tight, except
when actually adding or removing liquid).
Segregated. Used antifreeze is in its own container and not mixed with other liquids.
Labeled. Labels or color coding indicates that the container holds only antifreeze. In
contrast to used oil, there are no specific labels for antifreeze. To be considered
properly labeled, the drum/container/tank should simply have the words "used
antifreeze," or "waste antifreeze," or "antifreeze only," or similar wording that
distinguishes antifreeze storage from oil and solvent storage. Words can be spray
painted, stenciled, crayoned, or more formally labeled.
Q Yes Used antifreeze.is contained, segregated, and labeled.
O No Used antifreeze is not contained, segregated, and labeled.
Q NA Facility does not generate used antifreeze.
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1.3b Has the facility determined if it generates any antifreeze that is
hazardous waste?
A facility can characterize used antifreeze as hazardous waste through testing or by
process knowledge.
if a facility makes the hazardous/nonhazardous determination solely by testing, it
must test each batch of antifreeze changed from each vehicle serviced.
If a facility uses process knowledge, the 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 new 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
hazardous if it is mixed with a hazardous waste such as certain spent solvents.
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 used antifreeze is hazardous through
testing or from process knowledge.
Q No Facility has not determined whether its used antifreeze is hazardous.
Q NA Facility does not generate used antifreeze.
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1.3c 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 considered to be a 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
considered a hazardous waste and must be stored according to the hazardous waste
provisions of RCRA. Although closed loop systems are preferred for reclaiming/recycling
antifreeze, non-closed systems are also used in maintenance shops.
Q Yes Used antifreeze is reclaimed by a "closed loop" system.
Q No Used antifreeze is not reclaimed in a "closed loop" system.
Q NA Facility does not generate used antifreeze.
1.3d If not reclaimed in a closed loop system, does the facility count the
waste antifreeze toward the facility generator status?
If you have waste antifreeze that is a hazardous waste and not reclaimed in a closed loop
system, you need to consider it as part of the total volume of hazardous waste generated
in any month.
Q Yes Hazardous waste antifreeze that is not reclaimed in a closed loop system is
included in the total volume of hazardous waste generated.
Q A/o Hazardous waste antifreeze is not included.
Q NA Facility does not have hazardous antifreeze.
1.3e If 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
Facility manages used antifreeze in a non-closed
system on site according to RCRA hazardous waste
requirements.
Used antifreeze is recycled off site. Facility has on file
the EPA ID number of the recyder(see the DOT
shipping papers).
Used antifreeze is disposed of at a landfill. Many
landfills have a tank designated for used antifreeze.
"Landfill" does not include antifreeze that is dumped in
the trash.
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Q Mixed with other fluids
Q UlC well
Q Other
QNA
Antifreeze is mixed with used oil, solvents, or other
fluid.
Used antifreeze is discharged into an underground
injection control (UlC) well. Note: The facility should
immediately stop this method of disposal and notify the
EPA regional and/or state UlC authority.
Method of disposal is not listed here.
Facility does not generate used antifreeze.
1.4 Spent Solvents and Equipment Cleaning
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 spent solvents and parts cleaning for compliance with environmental
requirements:
a. Does the facility conduct equipment cleaning? (p. W-19)
b. What kind of cleaning agents does the facility use to conduct equipment
cleaning? (p. W-19)
c. Does the facility keep the lids of solvent cleaning equipment closed? (p. W-19)
d. If the facility uses halogenated solvents in solvent equipment cleaning, has
the facility submitted a notification report to the air permitting agency?
(p. W-20)
e. Does the facility store spent solvents in labeled containers? (p. W-20)
f. How does the facility manage/dispose of spent solvents? (p. W-21)
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.
Spent Solvents and 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. One may generate
hazardous waste, 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).
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/teci
fs22.htm)
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Solvents that are currently being used, such as in a parts cleaning sink, may be under EPA air
regulations, but are not under RCRA since they are not yet a waste.
1.4a Does the facility conduct equipment cleaning?
An air transportation facility may conduct different kinds of equipment cleaning.
* Large scale equipment cleaning typically involves the cleaning of aircraft 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 Ves Facility conducts equipment cleaning.
Q Wo Facility does not conduct equipment cleaning.
1.4b 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
1.4c 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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1.4d If halogenated solvents are used in solvent 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 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 vapor, in-line)
that a facility uses. Contact the state/local air pollution control agency for more
information.
Q Ves Facility has submitted a notification report.
Q No Facility has not submitted a notification report.
D NA Facility does not use halogenated solvents to conduct equipment cleaning.
1.4e Does the facility store 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 must have a label
before the facility transports it for disposal. Note: Solvents that are being used in a
parts washer are not required to be labeled.
Q Yes Spent solvents are stored in labeled containers, as described above.
Q Wo Spent solvents are not stored in labeled containers.
Q NA No solvents are used at the facility.
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1.4f How does the fa cility manage/dispose of 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, they should not
be mixed with nonhazardous wastes such as used
oils. All hazardous waste should be 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
Q Sanitary sewer
Q UIC well
Q Ground
Q Other
UNA
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 an NPDES permit to discharge non-hazardous
waste to storm sewers or to surface waters.
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).
Facility discards spent solvents on the ground which may
affect groundwater or may flow with storm water into storm
sewers and surface waterways. Caution: Most 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.
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1.5 Used Battery Storage and Disposal
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-22)
b. If storing used batteries, does the facility protect them from storm water
contact? (p. W-23)
c. How does the facility manage/dispose of used batteries? (p. W-23)
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.
1.5a 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 come under the
universal wastes category and may have
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 ^^^^^^^^^^^^^^^^mm^^^^
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 in place.
Q Yes Facility has gone through the waste determination process fas discussed in
Section 1.1) to determine whether its batteries should be regulated as
universal or hazardous waste.
Q No Facility has not determined whether its batteries should be regulated as
universal or hazardous waste.
Q NA Facility does not generate used batteries.
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1.5b If storing used batteries, does the facil/ty protect them from storm
water contact?
When placed out-of-service, a 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. The areas
should have: (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. Batteries storage areas may be inside or outside under a tarp or roof. Batteries
should also be stored in a pan or other device so that any leakage cannot enter floor
drains or spill onto the ground. Improperly stored batteries may be regarded as
"abandoned."
Q Yes Used batteries are protected from storm water discharges.
Q No Used batteries are not protected from storm water discharges.
Q NA Facility does not store used batteries.
1.5c How does the facility manage/dispose of used batteries?
Q Return to supplier Facility returns used batteries to supplier.
Facility sends batteries to a recycling facility.
Q Recycle
Q Service
Q Universal waste handler
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
UNA
Method of disposal is not listed here.
Facility does not generate used batteries.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.6 Painting/Paint Removal Operations
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/paint removal operations for compliance with environmental
requirements:
a. Does the facility conduct painting/paint removal operations? (p. W-24)
b. Does the facility have air permits? (p. W-25)
c.
Does the
or sanding
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Maintenance
l.6b Does the facility have air permits?
Air pollution permits are typically issued by states for certain operations such as
painting and surface preparation if certain state regulatory criteria are met. Generally if
air pollution control equipment is used, such as a baghouse or scrubber, a permit must
be in place. 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 NA Permits are not required.
1.6c Does the facility prepare surfaces to be painted by shot or grit
blasting, grinding, or sanding?
Tip: If using chemical strippers containing hazardous
pollutants, be sure the facility meets the Aerospace
National Emission Standards for Hazardous Air
Pollutants (NESHAP) (40 CFR Part 63 Subpart GG).
Contact the local air pollution control agency for more
information about Aerospace NESHAP requirements.
In preparation for painting, a
facility may remove, old paint
on aircraft and support
vehicles by shot or grit
blasting. Grinding and sanding
the surface occurs before the
surface is painted.
Q Vies Facility uses one of the above methods.
Q No Facility does not use one of the above methods.
Q NA Facility is not preparing surfaces for painting at this time.
1.6d 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 the
surfaces and paints should be tested for asbestos and lead.
Q Yes Facility tests surfaces and paints for asbestos and lead.
Q No Facility does not test surfaces and paints for asbestos and lead.
Q NA Facility does not prepare surfaces by shot/grit blasting, grinding, or
sanding.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.6e 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
disperse into the environment; and state/ local agencies may not allow this. Check with
state and local agencies and obtain the required air pollution permits.
Q Yes Facility collects paint chips and metal dusts.
Q No Facility does not collect paint chips and metal dusts.
Q NA Facility does not conduct paint removal operations.
1.6f 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
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 materials at
a municipal or hazardous waste landfill.
Facility disposes of paint wastes and residues on site (e.g.,
landfill).
Method of disposal is not listed here.
Facility does not have paint stripping wastes and/or
baghouse dusts.
1.6g 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 No Facility uses paints with VOC content of 5 Ibs/gallon or higher.
Q NA Facility does not have painting operations.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1. 6h Does the facility mix paint amounts according to need?
Facility should mix paint by the job, as opposed to in large batches, thus reducing
potential paint waste.
Q Ves Facility mixes paint by the job.
Q No Facility mixes paints in large batches.
O NA Facility does not have painting operations.
1.6i 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 a label, HVLP on the
gun. This is not yet a federal regulatory requirement. (Note: Required in some states.)
Q Yes Facility takes steps to minimize overspray.
Q No Facility does not take measures to minimize overspray.
Q NA Facility does not have painting operations.
1.6] Does the facility contain and label paints not in use?
Facilities must ensure that paints that are not in use, are in properly labeled containers.
Paint containers must be closed with tight-fitting lids, and stored so that a spill would not
reach 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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.6k How does the facility manage/dispose of 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. Paint cans (that once contained hazardous waste) that are
classified as "empty" by the RCRA definition and latex paints may be recycled or
disposed off site at an approved facility as nonhazardous waste.
A container is "empty" if all wastes or hazardous residues have been removed that can be
removed using a common practice for that type of container (e.g., pouring, pumping, etc.),
AND
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.
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 using a paint, solvent, or thinner
recycler. (Generally, this will apply to solvents or thinners.)
Q On site disposal
Q Mix with other fluids
D Landfill
Q Drain
Q Other
Q NA
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 landfjll 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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-28
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Maintenance
1.61 How does the facility dispose of spray paint booth air filters?
Filters containing hazardous paints must be disposed of using a hazardous waste
hauler. Facility must maintain records indicating where hazardous filters are sent.
Filters containing nonhazardous paints can be disposed of in a landfill or recycled.
Q Dispose as Facility disposes of filters containing hazardous paints as
hazardous waste hazardous waste.
Q Recycle
Q Landfill
Q Other
Q NA
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.
[ .7 Air Conditioning Maintenance
NOTE: The following questions are not included in the accompanying checklist, however, they
are still important to consider when examining the facility's operations for compliance
with environmental requirements:
a. Does the facility maintain and/or repair CFC-containing equipment? (p. W-30)
b- 9ฐ^?,tne> faciHty remove CFC from equipment prior to maintenance activities?
(p. W-30)
c. Has EPA approved the CFC recovery and/or recycling equipment? (p. W-30)
d. Does the facility have documentation that refrigerants from recovery equipment
are sent to an EPA-approved reclaimer? (p. W-31)
e. Does the facility repair leaks of appliances containing ozone-depleting
refrigerants in a timely manner? (p. W-31)
f. How does the facility manage appliances containing ozone-depletinq
refngerants? (p. W-31)
g. Has the facility ensured that its CFC have been legally purchased? (p. W-32)
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 (CFC)] to the environment. For a list
of ozone-depleting substances, contact the Stratospheric Ozone Information Hotline at 1-
800-296-1996.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-29
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Maintenance
1.7a Does the facility maintain and/or repair CFC-containing equipment?
The most common CFC-containing equipment maintained and repaired at an airport
includes building, aircraft, and support vehicle air conditioners, refrigeration equipment,
and ice machines.
Q Yes Facility maintains and/or repairs CFC-containing equipment.
Q No Facility does not maintain and/or repair CFC-containing equipment.
1.7b Does the facility remove CFC from equipment prior to maintenance
activities?
Equipment repairs that would release CFC should only be performed after the facility
removes and collects the refrigerants.
Q Yes Facility removes and collects CFC from equipment prior to maintenance
activities.
Q No Facility does not remove or collect CFC from equipment prior to
maintenance activities.
O NA Facility does not maintain and/or repair CFC-containing equipment.
1.7c Has EPA approved the CFC recovery and/or recycling equipment?
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 can be 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 appliance-e.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 "ARI / UL approval".
Q NA Facility does not maintain and/or repair CFC-containing equipment.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-30
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Maintenance
1.7d 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.
i.7e 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 Yes 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.
i.7f 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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-31
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Maintenance
1.7g Has the facility ensured that its CFC have been legally purchased?
Warning: If an individual knowingly buys or
possesses CFC smuggled into the United
States, that person is committing a
punishable, criminal offense and could face
severe penalties. For more information
regarding CFC and enforcement actions under
the Clean Air Act (CAA), all EPA's
Stratospheric Ozone Protection Hotline at
1-800-296-1996.
When purchasing CFC, 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 the
facility's responsibility. If the material
was imported, the facility should know when, where, and from whom it was imported.
Check to make sure the packaging for the material is appropriate. Illegally imported
refrigerant is sometimes packaged in wrong size containers or fixed with improper
values.
D Ves Facility has ensured that CFC have been legally purchased.
Q No Facility has not ensured that CFC have been legally purchased.
Q NA Facility has not purchased CFC.
1.8 Used Rags/Shop Towels
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-33)
b. How does the facility store used rags and shop towels on site? (p. W-34)
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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-32
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Maintenance
Used Rags/Shop 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 having
them washed through a laundry service, or disposing
of them through an EPA-licensed hazardous waste
transporter and disposal facility.
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-11,
question 1.2c) According to the used oil regulations,
facilities must 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. Note: After used oil has been removed, the facility may
still need to handle the material 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 rags to a
laundering facility for washing, rather than disposal.
1.8a How does the facility manage used rags and shop towels?
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 to be
solid wastes, even if they are to be sent
for laundering. Check with the state
regulatory agency on requirements for
managing shop rags/towels.
Q Laundry service
Q Burned for heat
Q Hazardous waste
transporter
Q Trash
Q Other
UNA
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 of 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)
and not segregated. If rags/towels are contaminated with
hazardous waste, the facility should not dispose of them with
trash, but manage them according to one of the above options.
Method of disposal is not listed.
Facility does not generate used rags or shop towels.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.8b 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.).
Q Stored as hazardous Facility stores used rags/shop towels contaminated with
waste
Q Shop trash can
Q Floor
QNA
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 are simply scattered.
Facility does not generate used rags/shop towels.
1.9 Absorbents
NOTE: The following questions are not included in the accompanying checklist, however,
they are still important to consider when examining the facility's operations for
compliance with environmental requirements:
a. Does the facility use sawdust, soil, or other commercial absorbents for spills or
leaks? (p. W-34)
b. Does the facility determine it used absorbents are hazardous before disposal?
(p. W-35)
c. How does the facility manage absorbents used for oil spills? (p. W-35)
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 generally involves the use
of materials such as kitty litter type substances (known as "quick dry", "speedi dry", "oil dry"), clay
absorbent, pads, pillows, booms, towels, and other such absorbent materials. Sawdust is
sometimes used as an absorbent in rural areas. The proper absorbent must be used for the
type of chemical spilled. Once used in a cleanup, the facility needs to dispose of these materials
properly.
1.9a 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.
Q No Facility does not use any of the above substances.
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and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.9b Does the facility determine if used absorbents are hazardous before
disposal?
Absorbents are considered hazardous waste if they are contaminated with a hazardous
material such as hazardous solvents. Although used oil is not a hazardous waste if it is
recycled, it could be considered 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 (if it exhibits a hazardous characteristic), even if it is not
mixed with a hazardous waste. For information regarding used oil regulatory
requirements, refer to 40 CFR Part 279.
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.
1.9c How does the facility manage absorbents used for oil spills?
Q Sent to supplier or
Service company
Q Burned for energy
Q Disposed of as
hazardous waste
Q Nonhazardous and
landfilled
Q Other
HNA
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 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 determines that the absorbents are a
nonhazardous solid waste and disposes of them with regular
trash.
Method of management is not listed here.
Facility does not use absorbents.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.10
Used Tires
NOTE: The following question is included in the accompanying checklist to help the
facility examine its operations relating to used tires for compliance with
environmental requirements.
a. How does the facility manage/dispose of used tires? (p. W-36)
This question appears in the following text and is accompanied with a discussion of the
preferred answers (indicated with a V") for environmental compliance.
Used Tires
Although not federally required, a facility should reuse used tires (i.e., resold, retreaded,
recycled) rather than just throw them away. For most cases, retread tires perform under the
same conditions and at the same speeds as new tires with no loss in safety or comfort.
Retreading tires also helps conserve a valuable nonrenewable resource - oil.
1.10a How does the facility manage/dispose of used tires?
Q Resale Facility sells used tires.
Q Retread Facility retreads used tires.
Q Recycle Facility recycles used tires. This may include state or local programs
that shred tires and then use them for asphalt.
Q Other Facility uses some method other than those listed above for disposal.
Q NA Facility does not generate used tires.
I.II
Used Brakes
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
brakes for compliance with environmental requirements:
a. Does the facility label asbestos-containing material (ACM) handling equipment?
(p. W-37)
b. Does the facility manage spent brake washing solvent as hazardous waste?
(p. W-37)
c. Does the facility manage used vacuum filters and brake pads as ACM waste?
(p. W-38)
d. How does the facility manage asbestos brake pads and other asbestos
containing material (ACM) waste? (p. W-38)
These questions appear in the following text and may be accompanied with a discussion
of the preferred answers (indicated with a "") for environmental compliance.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
W-36
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Maintenance
Used Brakes
Asbestos brake pads require proper handling, packaging and disposal in order to protect
workers and the environment. The asbestos National Emission Standard for Hazardous Air
Pollutants (NESHAP) and the proper disposal method for asbestos brake pads are in 40 CFR
Part 61 Subpart M. The Occupational Safety and Health Administration (OSHA) provides rules
for protection of workers during the handling of asbestos-containing material (ACM), which
workers should review prior to working with known or suspect ACM (including brake pads).
Facilities should remove asbestos brake pads using appropriate control measures so that no
visible emissions will be discharged to the outside air. These measures can include wetting,
vacuuming, or a combination of wetting and vacuuming.
1.11a Does the facility label asbestos-containing material (ACM) handling
equipment?
ACM equipment, such as a solvent bath basin and a vacuum, must be labeled with the
words: DANGER - Asbestos, Avoid Creating Dust, Cancer and Lung Hazard. Used
filters from the vacuum as well as the particles collected in the vacuum also must have
labels.
Q Yes Facility labels ACM equipment as described above.
Q No Facility does not label ACM equipment.
Q NA Facility does not have ACM equipment.
1.11b Does the facility manage spent brake washing solvent as
hazardous waste?
In most cases, when a facility removes spent solvent from the brake washing solvent
bath, and determines to be unusable, the facility must manage and dispose of this
material as hazardous waste. This is due to the flammability of the-solvent not the
asbestos content.
Q Yes Facility manages spent solvent as hazardous waste.
Q No Facility does not manage spent solvent as hazardous waste.
Q NA Facility does not generate brake washing solvent.
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and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.11c Does the facility manage used vacuum filters and brake pads as ACM
waste?
Used filters from the vacuum as well as the particles collected in the vacuum must be
contained and disposed of as ACM waste. If wet with solvent or any other wetting agent,
used asbestos pads must be sealed in air-tight containers or in leak-tight wrapping. The
containers or wrapped packages must be labeled using warning labels as described
above.
Q Yes Facility stores used vacuum filters and brake pads as described above.
Q Wo Facility does not store used vacuum filters and brake pads as describe above.
Q NA Facility does not generate used vacuum filters or brake pads.
1.11d How does the facility manage asbestos brake pads and other
asbestos containing material (ACM) waste?
Recycling and reclamation are the preferred methods for discarding asbestos brake
pads. If asbestos is known or suspected of being present, inform the recycling or
reclamation company. If landfilling, make a determination for presence of asbestos prior
to disposal. If asbestos is present, use only landfills or disposal sites approved for
asbestos.
One must dispose of ACM waste as soon as practical at an EPA-approved disposal site.
Label the 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. Maintain the waste shipment records so that the asbestos shipment can be
tracked and substantiated.
Q Recycled off site
Q Disposed by vendor
Q EPA-approved
disposal site
Q Other
Q NA
A manufacturer or a recycling company collects used brake
pads for recycling. -;
A vendor disposes of the brake pads by landfilling or other
means of disposal.
The ACM waste is sent to EPA-approved site for disposal.
Method of disposal is not listed here.
Facility does not generate ACM waste.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.12 Metal Machining and Machine Cooling
NOTE: The questions in this section are not in the accompanying checklist, however, they
are still important to consider when examining the facility's compliance with
environmental requirements:
a. Does the facility store scrap metal in a covered and contained area ? (p. W-39)
b. How does the facility manage metal scraps? (p. W-40)
c. How does the facility manage waste cutting oils and degreasing solvents used in
its metal machining processes? (p. W-40)
These questions appear in the following text and may be accompanied with a discussion
of the preferred answers (indicated with a "") for environmental compliance.
Metal Machining and Machine Cooling
Metal scraps may contain cutting oils, lubricating oils, and grease. Most
metal scraps have economic value and can be recycled or reclaimed.
When storing scrap metal, the facility should containerize the materials
and cover them to prevent the release of pollutants to the ground and
storm water, and 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
with water-soluble cutting oils whenever possible. They should also segregate
to facilitate reuse and recycling.
Tip: A local
scrap metal
recycling plant
may accept the
facility's scrap
metal if sorted
and properly
stored.
oils and solvents
wastes carefully
1.12a Does the facility store scrap metal in a covered and contained area ?
The facility should store metal scraps in a covered and contained area that prevents
soil and water contamination.
Q Yes Facility stores metal scraps in a covered and contained area that prevents
soil and water contamination.
Q No Facility does not store metal scraps in a covered and contained area.
O NA Facility does not have any metal scraps.
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July 2000
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Maintenance
1.726 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
Q NA
Facility does not use one of the methods listed above to manage
metal scraps.
Facility does not have any metal scraps.
1.12c 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 separates waste cutting oils and degreasing solvents which
hazardous waste are placed in drums, labeled as "Hazardous Waste," and disposes
of by a hazardous waste hauler.
Q NA
Facility does not conduct metal machining.
1.13 Metal Finishing and Coating Applications
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 metal
finishing and coating applications for compliance with environmental requirements:
a. Does the facility perform metal finishing operations? (p. W-41)
b. Is the facility subject to the categorical pretreatment standards? (p. W-41)
c. Does the facility perform coating application operations? (W-42)
d. Does the facility have air permits for metal finishing and/or coating
application operations? (p. W-42)
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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
Metal Finishing and Coating Applications
Metal finishing processes are used to prepare the surface of a part for better adhesion,
improved surface hardness, and improved corrosion resistance. Typical metal finishing
operations include chemical conversion coating, anodizing, electroplating, and any operation
that chemically affects the surface layer of a part. Each of these operations has the potential to
significantly impact the. environment by discharging metals, cyanides, phosphates, acids, and
other contaminants to waterways, soil, or groundwater.
Coating Application involves a material being applied to the surface of a part to form a
decorative or functional solid film. The most common coatings are primers and topcoats.
Facilities can apply coatings to aircraft components using several methods of application, which
include spraying, brushing, rolling, flow coating, and dipping. Nearly all coatings contain a
mixture of organic solvents.
1.13a Does the facility perform metal finishing operations?
Q Yes Facility performs metal finishing operations, such as chemical conversion
coating, anodizing, electroplating, or any other operation that chemically
affects the surface layer of a part.
Q No Facility does not perform these activities.
1.13b Is the facility 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 an airport conducts processes such
as electroplating or coating, that facility
may be subject to the metal finishing
categorical standards.
Proposed Categorical Standards: 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.
The categorical standards for facilities that conduct these and other operations (as
described 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.
Q No Facility has not determined whether it has activities that make it subject to
categorical pretreatment standards.
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and Workbook for Airports and Tenant Operations
July 2000
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Maintenance
1.13c Does the facility perform coating application operations?
Q Yes The facility performs coating application operations (e.g., spraying, brushing,
rolling, flow coating, dipping).
Q No Facility does not perform these activities.
1.13d Does the facility have air permits for metal finishing and/or coating
application operations?
Hazardous air pollutant (HAP)
emissions are one of the most
significant environmental aspects of
metal finishing operations. As the
organic chemicals in the processing
solutions evaporate, they may
generate hazardous vapors and
emissions. Evaporation of solution
also occurs from refurbished parts as
they are removed from the processing
tanks. In coating applications,
processes that involve evaporation of
solvents may generate HAP emissions
during mixing, application, and from
overspray, which is exhausted from
spray booths or hangars.
Under the Clean Air Act Amendments (CAAA)
of 1990, EPA has issued the Aerospace
National Emission Standards for Hazardous
Air Pollutants (NESHAP) to control HAP
emissions from the aerospace manufacturing
and rework industry, which includes those
facilities that produce or repair aerospace
vehicles or vehicle parts (e.g., airplanes,
helicopters). Approximately 2,800 aerospace
manufacturing facilities nationwide are
considered major sources of HAPs, and
affected by the regulation. The following
operations are subject to the regulation:
cleaning, primer and topcoat application,
depainting, and chemical milling maskant.
Contact the state or local pollution control
agency for more information regarding the
Aerospace NESHAP.
If the facility emits HAPs (e.g., from
metal finishing or coating application operations) the facility must determine whether it is
required to have an air permit. The type of permit that may be required depends on the
activity being (or to be) performed, the potential amount of emissions, and the location of
each source. Permits can take several forms, including an operating permit (Title V)
and a pre-construction permit. An operating permit specifies operating and monitoring
requirements, including limits on the emission of air pollutants and operating
requirements for pollution control equipment. A pre-construction permit may be required
before a new facility can be built or before any new piece of equipment can be installed
or modified. For more information about which air permits are required, contact the state
or local air pollution control authority.
Q Yes Facility has air permits for metal finishing/coating application operations.
Q No Facility does not have air permits for metal finishing/coating application
operations.
Q NA Air permits are not required.
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and Workbook for Airports and Tenant Operations
July 2000
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Mainte
I.14 Dry Cleaning
NOTE: The following questions are not included in the accompanying checklist, however they
are still important to consider when evaluating the facility's operations relating to dry
cleaning for compliance with environmental requirements:
a. How does the facility maintain aircraft upholstery? (p. W-44)
b. If conducting its own dry cleaning (e.g., for aircraft upholstery), is the facility
familiar with the requirements under the NESHAP rule? (p. W-44)
These questions appear in the following text and may be accompanied with a discussion
of the preferred answer (indicated with a V") for environmental compliance.
Dry Cleaning
For cleaning items, such as aircraft upholstery, airports typically contract with a dry cleaning
service. However, some may have a dry cleaning facility on site. While there are many
compliance obligations for a dry cleaning operation, the main concern for dry cleaners is the use
of perchloroethylene, commonly referred to as "perc". Perc is regulated because it is suspected
to cause cancer in humans, is considered toxic, and causes dizziness, nausea, and headaches
Dry cleaners are the largest source of perc emissions in the U.S.
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Perchloroethylene Dry Cleaning Facilities divides dry cleaners into three separate categories -
small area sources, large area sources, and "major" sources - and contains different
requirements for each category. There are two types of dry cleaning machines: dry-to-dry and
transfer. A dry-to-dry machine consists of one machine, which does both the washing and the
drying of the articles being cleaned. A transfer machine consists of two machines: a washer and
a dryer. Clothing is transferred from the washer to the dryer at transfer machines and this step
is a significant source of perc emissions. The NESHAP requires all new dry cleaning machines
to be dry-to-dry machines. It does not, however, require the replacement of existing transfer
machines with new dry-to-dry machines.
There are two sources of perc emissions at dry cleaning facilities: process vent emissions (i e
the dry cleaning machine vent); and fugitive emissions (e.g., clothing transfer at transfer
machines, equipment leaks, open containers, etc.). NESHAP requirements include control of
process vent emissions at all new dry cleaning facilities and control of process vent emissions at
large area source and major source existing dry cleaning facilities. The rule also requires control
of fugitive emissions at all new dry cleaning facilities and control of fugitive emissions at all
existing dry cleaning facilities with the exception of fugitive emissions from clothing transfer at
transfer machines. Only transfer machines at major source existing dry cleaning facilities are
required to control fugitive emissions from clothing transfer.
The use of refrigerated condensers is required to control (1) process vent emissions at new dry
cleaning facilities, and (2) process vent emissions at existing dry cleaning facilities, except those
existing facilities that have already installed a carbon adsorber for control of process vent
emissions. Existing dry cleaning facilities that currently use a carbon adsorber may continue to
use this carbon adsorber to comply with the requirements of the rule.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Materials Storage and Handling
1.14a How does the facility maintain aircraft upholstery?
Q On-site dry cleaner
Facility conducts its own dry cleaning or uses a central, on-
site dry cleaner at the airport.
Q Sends to contractor Facility sends its upholstery off site to be cleaned by a
contracted dry cleaning service.
Q Other
Facility's method of maintaining aircraft upholstery is not
listed here.
1.14b If conducting its own dry cleaning (e.g., for aircraft upholstery), is the
facility familiar with the requirements under the NESHAP rule?
Q Yes Facility has contacted its state to ensure its dry cleaning operations meet the
requirements under NESHAP.
Q No Facility has not contacted its state.
Q NA Facility does not conduct its own dry cleaning.
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and Workbook for Airports and Tenant Operations
July 2000
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Materials Storage and Handling
SECTION 2.0 MATERIALS STORAGE AND
HANDLING
2.1 Storage Tanks
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 facility notified the state/tribal UST program of any USTs located on
site? (p. W-46)
b-
*ne ferity Conduct leak detection for tanks and piping of all on site
. W-4/J
c. Do USTs at the facility meet requirements for spill, overfill, and corrosion
protection? (p. W-47)
d. Does the facility have aboveground storage tanks (ASTs)? (p. W-48)
e. Do the ASTs meet or exceed National Fire Protection Association (NFPA) 30 A
requirements? (p. W-48) { J
f. Does the facility inspect ASTs periodically for leaks and other hazardous
conditions? (p. W-49)
g. Does the facility's total tank storage capacity make it subject to the Oil Pollution
regulation? (p. W-50)
h- 9OUJ3 fฃ(//ed 0// from the facility reacn navigable waters or adjoining shorelines?
' D<ฐฃZjฃefacil'ty have a sP'n Prevention, Control, and Countermeasures
(SPCC) plan signed by a Professional Engineer? (p. W-50)
j. Does the facility have the phone number for the National Response Center
posted on site for immediate reporting of oil spills? (p. W-51)
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.
Environmental Screening Checklist
and Workbook for Airports and Tenant Operations
July 2000
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Materials Storage and Handling
Underground Storage Tanks (USTs)
Airports may have underground storage
tanks (USTs) to supply fuel for aircraft and
support vehicles. They also use USTs to
store used oil or fuel to run emergency power
generators. A UST is a tank and any
underground piping connected to the tank that
has at least ten percent of its combined
volume underground.
Note: USTs that store flammable and
combustible liquids must meet provisions
under the National Fire Protection
Association (NFPA) 30 Flammable and
Combustible Liquids Code. Requirements
under NFPA 30 include provisions for tank
storage and piping systems. See question
2.1e for more information.
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/.
The Federal regulations do not cover some USTs (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, states, tribes and local
government agencies may regulate 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.
2.1 a Has the facility notified the state/tribal UST program 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. The form includes
certification of compliance with federal requirements for installation, cathodic protection,
release detection, and financial responsibility for UST systems installed after December
22, 1988. For more information on how to obtain and complete the form, call EPA's UST
Hotline at 1-800-424-9346.
Q Ves Facility has submitted a notification form to the responsible state/tribal UST
program
office.
Q Wo Facility has not submitted a notification form to the responsible state/tribal
UST program office.
Q NA Facility has no USTs.
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July 2000
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Materials Storage and Handling
2.1 b Does the facility conduct leak detection for tanks and piping of all on
site USTs?
Facilities with federally regulated
LIST systems must conduct leak
detection. The monthly monitoring
methods for conducting leak
detection of tanks include the
following:
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.
Automatic tank gauging
Monitoring for vapors in soil.
Interstitial monitoring
Groundwater monitoring
Statistical inventory reconciliation
Other methods approved by the regulatory authority.
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 methods described above.
Q No Facility does not conduct leak detection.
Q NA Facility does not have any federally regulated USTs.
2.1 c 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.
All USTs subject to federal regulations
must not cause spills or overflows or
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 Hotline at 1-800-424-9346. 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.
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Materials Storage and Handling
Q No Facility does not have protection devices installed.
Q NA Facility does not have any federally regulated USTs.
Aboveground Storage Tanks
2.1 d Does the facility have aboveground storage tanks (ASTs)?
Q Yes Facility has ASTs.
D No
Facility does not have ASTs.
2.1 e Do the ASTs meet or exceed National Fire Protection Association
(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.
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Materials Storage and Handling
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.
Do the ASTs meet or exceed National Fire Protection Association (NFPA) 30A
requirements?
Q Yes Tanks meet or exceed NFPA requirements.
Q No Tanks do not meet NFPA requirements.
Q NA Facility does not have ASTs.
2.1 f Does the facility inspect ASTs periodically for leaks and other
hazardous conditions?
If regulated under the SPCC program, the facility must inspect ASTs on a periodic basis
for evidence of leaks or other hazardous conditions (e.g., rust, structural deterioration,
etc.). (See Section 4.3 for additional information.)
Q Yes Facility inspects ASTs on a periodic basis.
Q No Facility does not inspect ASTs on a periodic basis.
Q NA Facility does not have aboveground storage tanks, or ASTs are not subject
to SPCC requirements.
Spill Prevention, Control, and Countermeasures Program
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.
Has physical potential to discharge oil in harmful quantities into navigable waters of the
United States.
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Materials Storage and Handling
2.1 g 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 is required to 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-gallon tank with 350
gallons of oil would still count as 1,500 gallons toward the total).
Includes oil stored in drums, buckets, etc. (e.g., 1,600-gallon aboveground tank,
plus a 1,500-gallon aboveground tank, plus five 55-gallon drums would equal
3,375 gallons total storage).
Q Yes Facility exceeds capacity limits indicated above.
Q No Facility storage capacity is less than limits above.
Q NA Facility does not have storage tanks.
2.1h 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 considered to be able to reach navigable
waters. Spills are considered able to reach navigable waters even if man-made
structures (e.g., dikes, berms, storage containers) are present.
Q Yes A spill could reach navigable waters or adjoining shorelines.
Q No A spill could not reach navigable waters or adjoining shorelines.
Q NA Facility does not have storage tanks.
2.1 i Does the facility have a Spill Prevention, Control, and
Countermeasures (SPCC) plan signed by a Professional Engineer?
If the answer to 2.1g and 2. Th is "yes", then the facility must have an SPCC plan. The
SPCC plan must be on site if the facility is normally manned for at least eight hours per
day. Otherwise, the facility can keep it 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.
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Materials Storage and Handling
A prediction of the direction, rate of flow, and total quantity of oil that could be
discharged where experience indicates a potential equipment failure.
2.1 j
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 that has been 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 Yes Facility has an SPCC that has been signed by a professional engineer.
Q No Facility does not have an SPCC plan, or the plan is not signed by a
Professional Engineer.
Q NA Facility is not required to have an SPCC plan.
Does the facility have 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 spill 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), the facility must report an oil spill to the National Response Center (NRC) at
1-800-424-8802.
Q Yes NRC phone number is available on site.
Q No NRC phone number is not available.
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Materials Storage and Handling
2.2 Hazardous/Extremely Hazardous Substances
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/extremely hazardous substances for compliance with environmental
requirements:
a. Did the facility participate in emergency planning activities when it has
extremely hazardous substances (EHSs) in excess of their threshold
planning quantities (TPQs)? (p. W-53)
b. Did the facility immediately notify the proper authorities after an accidental
release of a hazardous or extremely hazardous substance? (p. W-53)
c. When reporting a spill, did the facility include the required information for initial
notification? (p. W-54)
d. After initial notification of any spills and releases, has the facility provided a written
follow-up emergency notice(s) to the proper emergency agencies? (p. W-55)
e. Has the facility met the reporting requirement under Section 311 of EPCRA ?
(p. W-55)
f. Does the facility meet its reporting requirement annually under Section 312 of
EPCRA? (p. W-56)
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.
EPCRA Planning Requirements
Title III of the Superfund Amendments and Reauthorization Act (SARA), also known as
Emergency Planning and Community Right-to-Know Act (EPCRA), establishes requirements for
federal, state, and local governments, and industry regarding emergency planning and
"community right-to-know" reporting of hazardous and toxic chemicals. It requires industry to
report detailed information concerning the use, generation, and release of hazardous and toxic
materials.
The purpose of EPCRA is to: (1) encourage and support industry's emergency planning for
response to chemical accidents (in coordination with state and local governments) through
emergency planning and emergency notification; and (2) provide local governments and the
public with information about possible chemical hazards in their communities by requiring
facilities to report to federal, state and local authorities their hazardous chemical inventory and
toxic chemical releases.
The emergency planning sections (Sections 301-303) of EPCRA are designed to develop
state and local government emergency response and preparedness capabilities through better
coordination and planning, especially with the local community.
Note: The air transportation sector (SIC 45) is not subject to EPCRA Section 313 requirements;
however, it is subject to Sections 302, 304, 311, and 312 EPCRA requirements. For more
information, called the RCRA/UST, EPCRA, and Superfund Hotline at 1-800-424-9346.
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Materials Storage and Handling
2.2a Did the facility participate in emergency planning activities when it
has extremely hazardous substances (EHSs) in excess of their
threshold planning quantities (TPQs)?
Under Section 302 of EPCRA, if a facility has any of the 400
extremely hazardous substances (EHSs) (e.g., ammonia, chlorine,
nitric acid, sulfuric acid) listed in 40 CFR Part 355 in excess of their
threshold planning quantities (TPQs), the facility must notify its
state emergency response commission (SERC) within 60 days that
the facility is subject to emergency planning requirements.
In addition, the facility must participate in the local emergency
process and must provide any information to the local emergency
planning committee (LEPC) deemed necessary for development or
implementation of a local emergency plan.
A threshold planning
quantity (TPQ) is the
amount of an extremely
hazardous substance
(in pounds) at a facility
that triggers a reporting
requirement. EHSs
and their TPQs are
listed in 40 CFR Part
355.
Q Yes The facility did participate in emergency planning activities.
Q Wo The facility did not participate in emergency planning activities.
Q NA The facility does not have any EHSs in excess of their TPQs, and so is not
required to participate in emergency planning activities.
Emergency Notification
2.2b Did the facility immediately notify the proper authorities after an
accidental release of a hazardous or extremely hazardous substance?
Under Section 304 of EPCRA, the facility must immediately notify the Local Emergency
Planning Committees (LEPCs) and the State Emergency Response Commissions
(SERCs) likely to be affected, if there is a release into the environment of a hazardous
substance that exceeds the reportable quantity for that substance (40 CFR Part 355).
The substances (some are common to both"lists) which are subject to these requirements
include:
"Extremely Hazardous Substances" listed in Appendices A and B of 40 CFR
Part 355.
"Hazardous Substances" subject to emergency notification requirements under
CERCLA Section 103(a). These substances and reportable quantities are listed in 40
CFR Section 302.4. Note: There are federally permitted release exemptions of these
substances that may be applicable to the facility. Refer to the appropriate regulatory
agency for more information about these exemptions.
The LEPCs and SERCs will coordinate response activity to the facility's spill or
accident, and prevent harmful effects to the public and community at large. In addition,
if the facility releases a CERCLA hazardous substance, the facility must notify the
National Response Center (NRC) at 1-800-424-8802.
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Q Yes The facility immediately notified the proper authorities.
Q No The facility did not immediately notify the proper authorities.
Q NA The facility did not experience any accidental releases of hazardous or
extremely hazardous substances.
2.2c When reporting a spill, did the facility include the required information
for initial notification?
Under EPCRA, the facility must notify the emergency authorities immediately upon
discovering a reportable spill. (The term immediately is not further defined.) Thus the
person making the report must use good judgement in determining how much time to
spend in collecting information prior to making the notification. Initial notifications can be
made by telephone, radio, or in person. To the extent possible, the following information
should be provided (40 CFR 355.40):
Chemical name/identity of material(s) released
Whether the material(s) is an extremely hazardous or a hazardous substance
Estimate of the quantity of any material that was released
Time and duration of the release
Whether the release was to the air, water, and/or land
Any known or anticipated acute or chronic health risks associated with the
emergency
Proper precautions to take as a result of the release, including evacuation
Name and telephone number of the person(s) to be contacted for further
information.
Q Yes The facility included the information listed above to the extent practicable.
Q No The facility did not include the information listed above to the extent
practicable.
Q NA The facility has not experienced'a spill of a hazardous or extremely hazardous
substance.
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Materials Storage and Handling
2.2d After initial notification of any spills and releases, has the facility
provided a written follow-up emergency notice(s) to the proper
emergency agencies?
After initial notification of spills and releases to the appropriate agencies, the facility must
provide a written follow-up emergency notice(s), as soon as practical after the release.
The follow-up notice(s) must update information provided in the initial notice and provide
information on actual response actions taken and advice regarding medical attention
necessary for exposed individuals.
Q Yes Facility submitted a written follow-up emergency notice(s) to the proper
emergency agencies.
Q No Facility did not submit a written follow-up emergency notice(s) to the proper
emergency facilities.
Q NA The facility has not experienced a spill of a hazardous or extremely hazardous
substance.
EPCRA Hazardous Chemical Reporting
Section 311 of EPCRA requires the facility to report to the SERC, LEPC, and local fire
department the presence of hazardous chemicals in excess of reporting thresholds at the facility
(40 CFR Part 370). This reporting is a one-time requirement unless new information becomes
available that reveals a chemical has an additional hazard. Additionally, this reporting
requirement must be met within 90 days for any new chemical in excess of the reporting
threshold handled on site. The chemicals subject to this requirement include:
EPCRA extremely hazardous substances (EHS) listed at 40 CFR Part 355 Appendix A in
excess of 500 ibs or the threshold planning quantity, whichever is lower (40 CFR 370.20);
and
Any chemical considered a hazardous chemical by the Occupational Safety and Health
Administration (OSHA) in excess of 10,000 Ibs (40 CFR 370.20).
2.2e Has the facility met the reporting requirement under Section 311 of
EPCRA?
To meet the Section 311 reporting requirement, the facility must submit to the LEPC, the
SERC, and the fire department either (1) the MSDSs (or copies), or (2) a list of the
EPCRA extremely hazardous substances and OSHA hazardous chemicals above
threshold quantities on site at the facility (40 CFR 370.21). (The list must include the
chemical or common name of each substance and must identify the applicable hazard
categories.)
Q Yes The facility has met the Section 311 reporting requirement.
Q No The facility has not met the Section 311 reporting requirement.
Q NA The facility has none of the regulated chemicals above the threshold
quantities.
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2.2f Does the facility meet its reporting requirement annually under Section
312 ofEPCRA?
Under Section 312 of EPCRA, the facility must meet an annual reporting requirement for
OSHA hazardous chemicals and EPCRA's EHSs in excess of reporting thresholds (40
CFR Part 370). The reporting thresholds are 500 Ibs or the threshold planning quantity
(TPQ), whichever is lower for EPCRA EHSs and 10,000 Ibs for an OSHA hazardous
chemical. If exceeding the reporting thresholds at any time in the preceding calendar
year, the facility must submit to the LEPC, SERC, and the fire department an
"Emergency and Hazardous Chemical Inventory Form" by March 1 of the following year
for those substances.
States can choose one of two formats for the chemical inventory forms: Tier I and Tier II.
The Tier I form provides aggregate information on hazardous chemicals and includes
estimates of the maximum and average daily amounts present, and the location of the
chemicals. Tier II information is similar to Tier I information, except that it must be
chemical-specific, not aggregate information. Most states use Tier II reporting forms.
Q Yes The facility submitted a Tier I and/or Tier II Form for all OSHA hazardous
chemicals and EPCRA's EHSs in excess of reporting thresholds to the LEPC,
SERC, and the fire department by March 1 of the following year.
Q No The facility did not submit a Tier I and/or Tier II Form for all OSHA hazardous
chemicals and EPCRA's EHSs in excess of reporting thresholds to the LEPC,
SERC, and the fire department by March 1 of the following year.
Q NA The facility has none of the regulated chemicals in excess of threshold
quantities.
2.3 Fire Control Agents (Halons)
NOTE: The following questions, one of which is in the accompanying checklist (highlighted
in bold), will help the facility examine its operations relating to fire control agents for
compliance with environmental requirements:
a. Do technicians servicing halon-containing equipment have halon emissions
reduction training? (p. W-57)
b. How does the facility dispose of halons and halon-containing equipment?
(p. W-57)
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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July 2000
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Materials Storage and Handling
Halons
Halons are gaseous or easily vaporized halocarbons used primarily for fire suppression. Despite
their effectiveness as a fire suppressant, halons are among the most ozone-depleting chemicals
in use today. As a result, EPA issued a final rule relating to the manufacturing and emissions of
halons (63 FR 11084), which was effective on April 6, 1998. Under the final rule, EPA is
promulgating several actions relating to the manufacture and emission of halons, including:
(1) Banning the manufacture of new halon blends. However, due to the safety, health,
and environmental advantages that these products brings to the aviation community,
EPA is exempting the aviation applications from this ban, as long as the manufacturers,
or their designees, follow several requirements relating to recycling of halon blends.
(2) Prohibiting intentional release of halons. For safety reasons, EPA is granting an
exemption from this ban for halon release used as part of the test of fire extinguishing
systems in Class C and D compartments aboard aircraft when such a test is required by
the Federal Aviation Administration (FAA) under its Airworthiness Standards.
(3) Requiring technician training regarding halon emission reduction.
(4) Requiring proper disposal of halons and halon-containing equipment.
2.3a Do technicians servicing halon-containing equipment have halon
emissions reduction training?
Facilities must ensure that the organization hired to service its halon-containing
equipment provides training to its technicians regarding halon emissions reduction. If
not, the facility itself must provide training to the technicians hired to service halon-
containing equipment. For more information call the Stratospheric Protection Hotline
at 1-800-296-1996.
Q Yes Facility ensures that the technicians are trained as indicated above.
Q No Facility does not ensure that technicians servicing halon-containing equipment
are trained as indicated above.
Q NA Facility does not use halon-containing equipment.
2.3b How does the facility dispose of halons and halon-containing
equipment?
Q Returns to manufacturer The facility returns it to the manufacturer.
Q Returns to fire
equipment distributor
Q Returns to halon recycler
The facility returns the halons to a fire equipment
distributor.
The facility returns the halons to a halon recycler
operating in accordance with National Fire
Protection Association (NFPA) 10 and 12A
standards. '
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Q Destroys equipment
Q Other
Q NA
The facility arranges for the destruction of halon-
containing equipment using specified methods (40
CFR 82.270(e)).
Method of disposal is not listed.
Facility does not use halon-containing equipment.
2.4 RGB-Containing Equipment
NOTE: The following questions are not included in the accompanying checklist, however,
they are still important to consider when examining the facility's operations for
environmental compliance:
a. Does electrical equipment contain PCBs? (p. W-58)
b. Is PCB-containing equipment labeled and inspected quarterly? (p. W-59)
c. Does the facility store all out-of-service PCB-containing equipment in a
designated area? (p. W-59)
d. Do trained personnel initiate cleanup of PCB leaks/spills within 24 hours?
(p. W-60)
These questions appear in the following text and may be accompanied with a discussion
of the preferred answers (indicated with a "") for environmental compliance.
2.4a 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).
Equipment manufactured before 1978
should be assumed 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:
Many air transportation 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 PCEJs.
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.
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O Yes Facility has electrical equipment that contains PCBs:
Q No Facility does not have electrical equipment that contains PCBs.
Q Don't Facility has assessed electrical equipment for its potential to contain
know PCBs, and is unsure.
2.4b Is PCB-containing equipment labeled and inspected quarterly?
Facilities must label all electrical equipment (e.g., transformers and capacitors) containing
PCBs with the appropriate PCB classification. The facility should inspect this equipment
quarterly for leaks and to assure the labels are in place.
Q Vies 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.
2.4c Does the facility store all out-of service PCB-containing equipment in a
designated area?
Facilities should store all PCB-containing equipment not in service and awaiting disposal
should be stored in a designated area designed with protection from the rain and 100-
year floods and with complete containment. The floor or pad of the designated area
should be relatively impervious with a 6-inch high curb and no drains. The area should
be marked with a 6" x 6" sign indicating "Caution: Contains PCBs." The facility should
mark all items and doorways with the same sign.
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. If any transformers and other
equipment with PCBs are found to be outside of the designated area, the facility should
move them 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.
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2.4d Do trained personnel initiate clean up all PCB leaks/spills within 24
hours?
All electrical equipment involved in spill or leaks should be assumed to have PCBs unless
sampled and labeled to indicate otherwise. If a spill occurs, initiate a cleanup within 24
hours. Cleanups should be completed within 48 hours, regardless of the regular
business hours. Only trained personnel can perform clean up, and they must complete
the recordkeeping requirements.
If anyone sees transformer spillage and leaks, they should initiate a cleanup immediately.
The facility must develop a program and procedures to ensure that PCB equipment and
transformers are inspected for leaks and cleaned up when found leaking. The program
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 as described above.
Q No Facility does not clean up PCB leaks as described above.
Q NA Facility does not have equipment that contains PCBs.
2.5 Cargo Loading and Off Loading
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 cargo loading and offloading for compliance with environmental requirements:
a. If the facility loads hazardous materials onto an airplane, does the facility
inspect containers for labeling/placarding, signs of leakage, and
compatibility with other hazardous materials? (p. W-61)
b. Is the facility prepared for leaks or spills of hazardous materials during loading or
off-loading activities? (p. W-61)
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.
Cargo Loading and Off Loading
Aircraft loading and off loading includes all activities associated with the movement of materials,
items, and people in and out of airplanes. Aircraft cargo loads consist of several different items,
including but not limited to passengers, baggage, mail, live animals, dangerous goods (including
hazardous materials), and wet cargo (e.g., fresh fish, seafood, meat, casings, etc.). The primary
loading and off loading activity with a potentially significant impact on human health and the
environmental is the loading and off loading of hazardous materials.
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2.5a
If the facility loads hazardous materials onto an airplane, does the
facility inspect containers for labeling/placarding, signs of leakage, and
compatibility with other hazardous materials?
If the facility transports hazardous materials by aircraft, the materials are subject to U.S.
Department of Transportation (DOT) requirements that regulate aircraft inspections,
placement of materials, packaging, and shipping papers (e.g., waybills, manifests).' It is
important to ensure that proper labeling, valve cover placement, stenciling, and shipping
papers are used when transporting hazardous materials and hazardous wastes. Routine
inspections should include examination for spills and leaks of hazardous materials.
Report all spills and leaks promptly to the dispatcher?
Q Yes
a
During loading, facility inspects containers and all required paperwork is
completed.
Facility does not inspect hazardous materials containers on a regular basis
during loading.
Q NA Facility does not transport hazardous materials.
2.5b Is the facility prepared for leaks or spills of hazardous materials during
loading or off-loading activities?
Though a rare occurrence, leaks or spills that occur during loading/off-loading activities
have the potential to contaminate soil, groundwater, or surface water. Facilities minimize
and control these impacts through development and implementation of spill prevention,
control, and countermeasures (SPCC) plans, storm water pollution prevention plans
(SWPPPs), and other emergency response programs.
Q Yes Facility has developed SPCC plans, SWPPPs, and/or other emergency
response programs to prepare for accidental leaks/spills.
Q No Facility has not developed SPCC plans, SWPPPs, and/or other emergency
response programs to prepare for accidental leaks/spills.
Q NA Facility does not have hazardous materials on site.
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Fueling
SECTION 3.0 FUELING
3.1 Aircraft Fueling
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 aircraft
fueling for compliance with environmental requirements:
a. How does the facility fuel its aircraft? (p. W-62)
b. Does the facility use measures to prevent fuel spills during fueling of
aircraft? (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.
Aircraft Fueling
Aircraft fueling operations should focus on the prevention of fuel spillage and the associated air,
water, and hazardous waste pollution. Fuel tank monitoring and automatic shutoff devices are
key spill prevention measures. One technique to prevent fuel spills is to install catchment
basins, including containment at hydrant pits. If anyone finds leaking pipe joints, nozzle
connections, and any damage to the fueling hose (e.g., kinks, crushing, breaks in the carcass,
bulges, blistering, soft spots at the coupling, deep cracks or cuts, spots wet with fuel, or
excessive wear), they must report this, to the extent required by law or permit. The facility must
repair these problems immediately to reduce their potential impact on the environment. Using
dry cleanup methods for the fuel area can reduce water runoff and associated contamination of
groundwater and surface water supplies.
3.1 a How does the facility fuel its aircraft?
Q Truck and hose system Facility uses a truck and hose system to fuel aircraft.
Q Fuel distribution system Facility uses a fuel delivery system to fuel aircraft.
D Other Method of fueling is not listed.
3.1 b Does the facility use measures to prevent fuel spills during fueling of
aircraft?
Q Yes Facility uses preventive measures such as self-locking fueling nozzles and
automatic shutoff devices to minimize the risk of fuel spills during fueling.
Q No Facility does not use preventive measures during fueling.
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Fueling
3.2 Airport Support Vehicle Fueling
NOTE: The following questions are not included in the accompanying checklist, however
they are still important to consider when examining the facility's operations for
environmental compliance:
a. Has the facility installed Stage I vapor recovery equipment for unloading of
gasoline? (p. W-63)
b. Has the facility installed Stage II vapor recovery equipment at the pumps?
(p. W-64)
c. Do fuel delivery records indicate compliance with appropriate fuel requirements?
(p. W-64)
d. Has the facility clearly labeled the pumps with the product they contain? (p. W-65)
e. Does the facility prevent the use of dyed, high-sulfur diesel/kerosene? (p. W-65)
f. Do gasoline pump nozzles comply with 10 gallon per minute flow rate? (p. W-65)
g. Does the facility use overfill protection measures, spill containment methods, and
spill response equipment during fueling? (p. W-66)
These questions appear in the following text and may be accompanied with a discussion
of the preferred answers (indicated with a "") for environmental compliance.
3.2a 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 (i.e., if the facility is in an
non-attainment area).
Stage I vapor recovery equipment captures and
controls gasoline vapors which would normally be emitted to the atmosphere (1) during
the storage of gasoline, or (2) during the loading and unloading of a gasoline delivery
vessel.
Q Yes
a NO
a Don't Know
Q NA
Facility ensures that Stage I vapor recovery equipment is used.
Facility knows that Stage I vapor recovery equipment is not used.
Facility does not know if Stage I vapor recovery equipment is used.
Either the facility is not located in an ozone non-attainment area or
facility does not dispense gasoline.
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3.2b 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 working 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 canopies at dispensing stations.
a yes
a NO
a 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.
3.2c 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.
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 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.
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."
It the facility dispenses diesel fuel to on-the-road vehicles, 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.
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Fueling
3.2d Has the facility clearly labeled the pumps with the product they
contain?
The facility must label the pumps 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 Xes The facility clearly labels the pumps.
Q No The facility does not label pumps.
Q NA Facility does not have pumps.
3.2e Does the facility prevent the use of dyed, high-sulfur diesel/kerosene?
The facility can only dispense low sulfur diesel into motor vehicles used on the
road. Motor vehicles in this case include, but are not limited to, any diesel powered truck
(e.g., diesel tractor trailers, diesel pick-up trucks and diesel automobiles) licensed and
tagged for on-road travel.
Facilities can prevent dyed, high-sulfur diesel/kerosene fuel from being dispensed into
on-road diesel vehicles by (1) securing the pump nozzle with lock and key, (2) monitoring
pump use, or (3) locating the pump in a place where on-road diesel vehicles cannot pull-
up and dispense the fuel.
Q Yes Facility prevents dyed, high-sulfur diesel/kerosene fuel from being dispensed
into on-road diesel vehicles.
Q No Facility does not prevent high-sulfur diesel/kerosene fuel from being
dispensed into on-road diesel vehicles.
Q NA Facility does not have pumps with dyed, high-sulfur diesel/kerosene fuel.
3.2f 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 is introduced 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 nozzles, but they do not comply.
Q Don't Facility does not know if pump nozzles have been tested.
Know
ซ
Q NA Facility does not dispense gasoline or methanol.
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3.2g Does the facility use overfill protection measures, spill containment
methods, and spill response equipment 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
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.
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SECTION 4.0 DEICING
Deicing operations generate spent deicer fluids (e.g., propylene, ethylene glycol and water)
Spraying deicmg fluids onto aircraft and/or runway surfaces may result in the draining of deicing
fluids from aircraft and/or runway surfaces to drains that lead to on-site water treatment facilities
storm drains, or paved surfaces where they may be released directly to the environment In
compliance with Clean Water Act requirements, the facility treats spent deicing fluids either in a
wastewater treatment system, a publicly owned wastewater treatment plant or it goes directly to
surface water in accordance with permit conditions. Airports with deicing operations may
need to have a storm water permit and a storm water pollution prevention plan. For more
information about storm water requirements relating to deicing operations, contact the federal or
state National Pollutant Discharge Elimination System (NPDES) permitting authority.
If discharging deicing fluids into surface water (in accordance
with permit conditions), the facility must be aware of the toxic
effects that deicing fluids may have on surface and ground
waters. Deicing fluids, such as ethylene and propylene
glycol, may consume high levels of oxygen during
decomposition. If the rate of decomposition of glycols in
water is too high, dissolved oxygen in the water decreases.
thereby causing toxic effects on life forms in those waters
(e.g, fish kills). If the rate of oxygen consumption (i.e.,
biochemical oxygen demand) is too high, mitigation
measures may be necessary. Mitigation measures to reduce
glycol levels include construction of deicing facilities, glycol
containment systems, retention ponds, or discharge to
publicly-owned treatment works (POTW).
Tip: It is a good idea to
periodically inspect a facility's
effluent and receiving waters
for signs (e.g., sheens, foams)
of high concentrations of
deicing fluids. In addition,
facilities should collect samples
of runoff during winter storm
events to determine
concentrations of aircraft
deicing fluids.
FAA allows the reuse of deicing fluids that are reformulated and re-certified to meet appropriate
aircraft deicing fluid specifications. Depending on the local weather and airport infrastructure
airports may be able to recycle certain deicing fluids. Some airports have constructed deicing
fluid collection systems that prevent discharge to storm water sewers and segregate spent
deicer from other wastewater for reclamation, recycling, on-site treatment, or disposal off site
Certain reclaimed deicing fluids have value in secondary markets (e.g., windshield deicers for
automobiles).
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Deicing
4.1 Aircraft Deicing
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 aircraft
deicing for compliance with environmental requirements:
a. Does the facility conduct deicing operations of aircraft? (p. W-68)
b. Does the facility have deicing fluid collection systems that prevent
discharge to storm water sewers? (p. W-68)
c. How does the facility dispose of spent deicer? (p. W-69)
d Does the facility meet deicing fluid parameter limits/conditions in its NPDES
permit? (p. W-69)
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.
4.1 a Does the facility conduct deicing operations of aircraft?
Q Yes Facility conducts deicing operations of aircraft.
Q No Facility does not conduct deicing operations of its aircraft.
4.1b Does the facility have deicing fluid collection systems that prevent
discharge to storm water sewers?
Q Ves Facility has a fluid collection system.
Q No Facility does not have a fluid collection system in place.
Q NA Facility does not conduct deicing operations.
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Deicing
4.1 c How does the facility dispose of spent deicer?
Q Recycle
Q Treat on site
Q Discharge to POTW
Q Discharge to
surface water
Q Off-site disposal
a Other
Q NA
Facility sends spent deicer to recycling facility.
Facility treats the spent deicer at the on-site facility
wastewater treatment system.
Facility discharges to POTW with POTW permission.
Facility discharges directly to surface water |n
accordance with NPDES permit conditions.
Facility sends spent deicer to hazardous waste disposal
facility.
Method of disposal is not listed. Check with the state
regulatory authority to make sure it is an acceptable
method of disposal.
Facility does not conduct deicing operations.
4.1 d Does the facility meet deicing fluid parameter limits/conditions in its
NPDES permit?
Q Ves Facility meets permit limits/conditions for deicing fluid parameters.
Q No Facility does not meet permit limits/conditions.
Q NA Facility does not conduct deicing operations.
4.2 Runway Deicing
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 runway
deicing for compliance with environmental requirements:
a. Does the facility conduct deicing operations on its runways? (p. W-70)
b. If discharging deicing wastes to a municipal sanitary sewer or a combined
sewer which goes to a publicly-owned treatment works (POTW), has the
facility notified the POTW? (p. W-70)?
c. Does the facility meet deicing fluid parameter limits/conditions in its NPDES
permit? (p. W-70)
These questions 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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Deicing
Runway Deicing
Airport runways, taxiways, and gate areas are sprayed with deicer and anti-icer to remove and
prevent the buildup of ice and snow that would inhibit taxiing, takeoff, and landing. Runway and
ramp deicing is usually done with one or more substances (e.g., glycol, urea, sodium formate,
and/or potassium acetate). Sand is usually reserved to prevent slippage at the gate area, but
not on taxiways and runways due to the potential for engine ingestion hazards.
Deicing mixtures have the potential to contaminate groundwater and surface water supplies as
they flow from airport runways to storm drains or to waterways as sheet runoff. Deicing
chemicals that mix with storm water discharges must be managed according to the facility's
NPDES storm water permit if one is required. In an effort to control storm water contamination,
many facilities direct storm water to an on-site treatment facility prior to discharge.
4.2a Does the facility conduct deicing operations on its runways?
Q Yes Facility conducts deicing operations.
Q No Facility does not conduct deicing operations.
4.2b If discharging deicing wastes to a municipal sanitary sewer or a
combined sewer which goes to a publicly-owned treatment works
(POTW), has the facility notified the POTW?
Q Vies Facility has notified the POTW or permitting authority of the deicing wastes.
Q No Facility has not contacted the POTW.
Q NA Facility does not conduct deicing operations.
4.2c Does the facility meet the deicing fluid parameter limits/conditions in
its NPDES permit?
Q Yes Facility meets permit limits/conditions for deicing fluid parameters.
Q No Facility does not meet NPDES permit limits/conditions for deicing fluid
parameters.
Q NA Facility does not conduct deicing operations.
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Wastewater and Storm Water Management
SECTION 5.0 WASTEWATER AND STORM
WATER MANAGEMENT
5.1 Wastewater and Storm Water Management at
Airports
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-72)
b. How does the facility manage its wastewater? (p. W-73)
c. How does the facility manage its storm water? (p. W-74)
d' !f th,f, f$?ility discnar9es to a surface water, does it have an NPDES permit?
(p. W-74)
e. Does the facility have a storm water pollution prevention plan fSWPPP) ?
(p. W-75) ''
f.
Is a certification included in the SWPPP? (p. W-75)
' to a municipal sanitary sewer, has the facility notified the
POTW and received approval for discharges? (p. W-76)
h. If discharging to a UIC well, does the facility comply with UlC program
requirements? (p. W-76)
L yฐy,,d'ฐ-e,s the facility manage the sludge from an oil/water separator?
(p. W-77) ^
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
Airport facilities may discharge wastewater as a result of the following activities: repair and
maintenance of dn-site vehicles, vehicle and equipment cleaning, building and grounds
maintenance, chemical storage and handling, fueling of vehicles, and painting and paint
stripping. 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 a U.S. waterway. NPDES permits can be
issued by either EPA or an authorized state. As of September 1999, EPA authorized 43 states
and 1 territory to administer the NPDES program.
Persons responsible for new 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.
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Wastewater and Storm Water Management
Storm Water Discharges
Under the Clean Water Act, it is illegal to discharge any pollutants into navigable waters of the
United States from a point source unless the discharge is authorized by a National Pollutants
Discharge Elimination System (NPDES) permit. Storm water regulations have identified eleven
major categories that are associated with industrial activity (40 CFR ง 122.26 (b) (14) (i - x)).
Those facilities identified under these eleven categories must apply for NPDES permit for storm
water discharge. Transportation facilities are classified as category (viii) which includes activities
such as vehicle maintenance shops, equipment cleaning operations, painting, fueling operations
or airport deicing operations. Contact the state or federal permitting agency for more information
regarding NPDES discharge permitting requirements.
The following discharges do NOT require NPDES permits:
Introduction of sewage, industrial wastes or other pollutants into a publicly owned
treatment works (POTW) by indirect discharges. (Although not federally required, a
POTW may require a permit. A facility should contact the local sewer authority to find out
more about these requirements).
Discharges of dredged or fill material into waters of the United States. (These discharges
are regulated under CWA Section 404 permits.)
Discharges of storm water/wastewater into an underground injection well. [These
discharges are regulated under the Safe Drinking Water Act (SDWA) Underground
Injection Control (UIC)] program. For more information, contact the Safe Drinking Water
Hotline at 1-800-426-4791..
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
referred to 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 required by federal regulations, 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.
5.1 a Can the facility identify the final destination of all its drains?
The 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-primacy state), the 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, the facility may need a UIC well
permit.
If a drain discharges to storm water or surface water, an NPDES permit is
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Wastewater and Storm Water Management
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.
Facility can certify the final destination of all drains (e.g., storm sewer drains,
floor drains, and sanitary sewer drains).
Facility cannot certify the final destination of all drains.
Facility does not have drains.
Q Yes
a NO
a NA
5.1 b 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, or (2) to a sanitary
sewer or combined sewer leading to a POTW. Wastewater treatment may be required
by an NPDES permit or by the POTW.
Q Surface water
Facility discharges effluent directly to surface waters (in
accordance with an NPDES storm water permit (see Question
Q Sanitary sewer
Q UIC well
Q Ground
Q Other
Q NA
Facility discharges to a municipal sanitary sewer or combined
sewer with permission of the POTW (see Question 5.1 g).
Facility discharges to a UIC well, generally via a floor drain (see
Question 5. 7/7). Although there are some exceptions, as a
general rule, discharging industrial wastewater to a UIC well is
NO T 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.
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Wastewater and Storm Water Management
5.1c 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. Wastewater treatment may be necessary because
of an NPDES permit (see Question 5.7d) or by the POTW (see Question 5.1g).
Fuel Testing
FAA requires that fuel samples from air carrier
tanks be tested for contaminants before takeoff.
In the past, fuel samples may have been
discarded onto the ground, but this practice can
contaminate storm water discharges and create
potential for soil and groundwater
contamination. In order to prevent such
pollution, technological advances have
developed a fuel tester called the GATS Jar,
now on the market, which allows pre-flight fuel
samples to be returned to the fuel tank by
separating all non-fuel contaminants as it pours,
thereby only allowing pure fuel to enter the fuel
tank.
Q Surface water
Q Sanitary sewer
Q UIC well
Q Other
Q NA
Storm water discharges go directly to surface waters (in
accordance with an NPDES storm water permit).
Storm water discharges are directed to a municipal sanitary
sewer or combined sewer with permission of the POTW.
Storm water discharges are sent to a UIC 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.
5.1 d If the facility discharges to a surface water, does it have an NPDES
permit?
EPA requires NPDES permits in order to discharge industrial wastewater directly into
surface waters. The wastewater may need to be treated 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 Ves 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.
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5.1 e Does the facility have a storm water pollution prevention plan
(SWPPP)?
If a facility is required to obtain an NPDES storm water permit, it will likely be required to
prepare and implement an SWPPP. Facilities are required to develop SWPPPs to
prevent storm water from coming in contact with potential contaminants.
Q Ves Facility has an SWPPP.
Q No Facility does not have an SWPPP.
Q NA Facility is not required to have an SWPPP.
5.1 f Is certification included in the SWPPP?
Each SWPPP must include a certification, signed by an authorized individual, 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 conducted to detect such discharges
The test method or evaluation criteria used, the dates on which tests or evaluations
were performed, and the on site drainage points directly observed during the test or
evaluation.
If certification is not feasible, because facility personnel do not have access to an outfall,
manhole, or other point of access to the conduit that ultimately receives the discharge,
the SWPPP must describe why certification was not feasible.
Q Yes Facility's SWPPP includes a certification that discharges from the site have
been tested.
Q Wo Facility's SWPPP does not have a certification that discharges from the site
have been tested.
Q NA Facility is not required to have an SWPPP, or certification is not feasible
because of circumstances described above.
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5.1 g If discharging to a municipal sanitary sewer, has the facility notified the
POTW and received approval for discharges?
Facilities should contact the POTW to see if any pretreatment requirements apply to
them. Although contacting the POTW is not required by federal regulations, 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 Yes 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.
5.1h If discharging 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. Air
transportation facilities may 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 that basic inventory information about a Class V well must be submitted 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 contaminants that may
endanger drinking water. Therefore, new requirements went into effect December 7,
1999, which further regulate two (2) types of Class V wells, Large Capacity Cesspools
and Motor Vehicle Waste Disposal Wells. Note: See 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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Wastewater and Storm Water Management
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.
5.1i 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
a NA
Facility disposes of hazardous sludge off site. The facility
stores, manifests, transports, and disposes of it in
compliance with all provisions of RARA, 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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Air Transportation Support Activities
5.2 Activities Generating Wastewater and/or Storm
Water
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 activities
generating wastewater and/or storm wafer for compliance with environmental
requirements:
a. How does the facility clean the floors and surrounding areas? (p. W-78)
b. If the facility stores materials outside, does the facility protect them from
contact with storm water? (p. W-79)
These questions appear in the following text, accompanied with a discussion of the
preferred answers (indicated with a V") for environmental compliance.
5.2a How does the facility clean the floors (such as hangar, maintenance shop,
terminal or other) and surrounding areas?
D Dry Cleanup
Facility uses "dry methods" such as dry mop, broom, rags,
absorbents, etc., thus reducing generation of contaminated
wastewater. See box below.
Q Water
Facility uses a hose or wet mop, thus generating wastewater.
Suggested Dry Cleanup Methods
Small Spills: Use shop towels which are sent to an industrial laundry. Avoid paper towels! If paper towels are
used to pick up hazardous waste, they become hazardous waste.
Medium-Sized Spills: Use absorbent, portable berms as temporary holding areas to contain the liquid while
cleaning. Soak up the liquid and put in containers. Then wipe with a shop towel.
Oil and Water/Antifreeze Spills:
1. Use a hydrophobic mop for cleaning up spills containing oil and recycle recovered oil in a mop bucket
labeled "waste oil."
2. Use a regular mop for cleaning up antifreeze and recycle recovered antifreeze in a mop bucket labeled
"waste antifreeze."
3. If there is a slight film on the ground after steps 1 and 2, use a shop towel to clean it up. Use an
industrial laundry to clean shop towels.
4. Finally, if there is material still on the floor, clean it up with soap and water.
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Air Transportation Support Activities
5.2b If the facility stores materials outside, does the facility protect them
from contact with storm water?
A facility may need to store materials, including drums, trash, and parts, outside of facility
buildings. The facility should protect these materials from coming in contact with storm
water (including rain or snow) or other forms of water (e.g., washing overspray). To
prevent contact with storm water, you can store materials on pallets (or something else
that keeps them off the ground) and covered by a tarp or roof. You can close the
dumpsters and seal them so storm water will not enter or exit the dumpster. You must
store used oil (in some states), hazardous waste, and batteries in an area with secondary
containment, and in a manner that will protect them from storm water.
Q Yes Materials are protected from rain/snow.
Q No Materials are not protected from rain/snow.
Q NA Facility does not store materials outside.
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Air Transportation Support Activities
SECTION 6.0 AIR TRANSPORTATION
SUPPORT ACTIVITIES
6.1 Buildings and Groundskeeping
a.
NOTE: The following questions are not included in the accompanying checklist, however, they
are still important to consider when examining the facility's operations for compliance
with environmental requirements:
Does the facility use pesticides only as directed by their labels? (p. W-80)
b. Are restricted use pesticides (RUPs) applied only by a certified commercial
applicator? (p. W-81)
This questions appear in the following text and may be accompanied with a discussion of
the preferred answers (indicated with a V") for environmental compliance.
Buildings and Groundskeeping
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.
6.1a Does the facility use pesticides only as directed by their labels?
a yes
a NO
a NA
Facility applies all pesticides in accordance with the directions on the
pesticide labels.
Facility does not apply pesticides as directed by pesticide labels.
Facility does not use any pesticides.
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6.1 b Are restricted use pesticides (RUPs) applied only by a 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 Facility does not apply RUPs.
See Section 7.2d for requirements regarding pesticide applicator training and certification
requirements.
6.2 Nonhazardous Waste Management
NOTE:
The following question is not included in the accompanying checklist; however, it is still
important to consider when examining the facility's operations for compliance with
environmental requirements:
a. Does the facility dispose of nonhazardous waste on site in a permitted landfill or
dump? (p. W-82)
This question appears in the following text and is accompanied with a discussion of the
preferred answers (indicated with a V") for-environmental compliance.
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Air Transportation Support Activities
6.2a Does the facility dispose of nonhazardous waste on site in a permitted
landfill or dump?
All waste disposal in an on-site landfill or on-site dump is regulated. Facilities must obtain
local and/or state permits as required. These permits must be kept current for the type of
waste being disposed of and they must be 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 reporting to the EPA. Cleanup actions may be required.
Q Yes
a NO
Facility disposes of nonhazardous waste in an on site landfill or dump, and
all local and/or state permits have been obtained.
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.
6.3 New Construction
NOTE:
The following questions are not included in the accompanying checklist, however, they
are still important to consider when examining the facility's operations for compliance
with environmental requirements:
a.
How does the facility manage its construction wastes? (p. W-83)
b. Are there any endangered species which may be affected by construction
activities? (p. W-83)
c. Has the facility obtained a Section 404 permit for any projects that may impact
wetlands? (p. W-84) > r j t * H
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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6.3a How does the facility manage its construction wastes?
Do not dispose of construction waste, including that from building, tunnel, and bridge
maintenance, on site without proper disposal permits. Some States prohibit open burning
of scrap wood, material bags, aerosol cans, etc. When in doubt, check with the state/local
regulatory 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
Facility hires a licensed disposal contractor to haul the wastes to a
municipal or hazardous waste landfill.
Q Open burning Facility burns construction wastes.
Q On site
Q NA
Facility disposes of construction waste on site. Note: On site
disposal of wastes requires permits.
Facility is not conducting construction activities at this time.
6.3b 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 are found. 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, some form of mitigating action must be
taken to prevent harming the species. There are some exceptions under the ESA and the
local USFWS should always be consulted in cases where species are present. For more
information on the ESA, access USFWS's website at
http://www.fws.gov/r9endspp/endspp.html.
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k,
Air Transportation Support Activities
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.
Q No Facility has not determined whether endangered species are.
Q NA Facility is not conducting construction activities at this time.
6.3c 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
Q No
a NA
Facility has obtained a Section 404 permit.
Facility is conducting construction activities that would impact wetlands
but it has not obtained a Section 404 permit.
Facility is not conducting any construction activities that could impact
wetlands.
6.4 Asbestos (Building Renovation/Demolition)
NOTE:
The following questions do not appear in the accompanying checklist, however, they
are still important to consider when examining the facility's operations 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-85)
b. Does the facility document demolition procedures? (p. W-85)
c. Has the facility inform employees of buildings and structures containing asbestos
and trained them on asbestos-containing material (ACM) ? (p. W-85)
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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Air Transportation Support Activities
6.4a 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. Asbestos inspections must be performed
according to AH ERA guidelines by a certified inspector.
A facility must use state-licensed contractors, transporters, and disposal sites. If planning
a demolition, it is necessary to remove the asbestos materials before starting. In addition,
notify local, state, and federal agencies at least 10 days before the abatement,
demolition, or renovation begins.
Q Yes Facility has assessed all buildings built prior to 1980 for asbestos.
D No Facility has not assessed all buildings built prior to 1980 for asbestos.
Q NA Facility has no buildings built prior to 1980.
6.4b Does the facility document demolition procedures?
Q Yes Facility documents all demolition procedures.
Q No Facility does not document demolition procedures.
D NA Facility has determined that asbestos is not present in any of the buildings.
6.4c Has the facility informed employees of buildings and structures
containing asbestos and trained them on asbestos-containing material?
Inform all employees that may encounter asbestos-containing materials (ACM) of its
existence. In particular, inform all employees required to do repairs, maintenance, and
custodial activities. In addition, train employees to follow the proper procedures on the
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 has informed and trained all employees as described above.
Q No Facility has not informed all employees or trained them as described above.
Q NA Facility has determined that asbestos is not present in any of the buildings.
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Management and Administration
SECTION 7.0 MANAGEMENT AND
ADMINISTRATION
7.1 Record keeping
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
recordkeeping for compliance with environmental requirements:
a. NPDES: Does the facility keep records of NPDES monitoring information for a
minimum of 3 years? (p. W-86)
b. NPDES: As part of the SWPPP, does the facility maintain records of spills,
discharges, and other information describing the quality and quantity of
storm water discharges? (pi W-87)
c. NPDES: As part of the SWPPP, does the facility maintain records documenting
inspections and maintenance activities? (p. W-87)
d. Air: Does the facility keep records as required by its air permitfs)? (p. W-87)
e. CFC: If the facility owns/operates appliances (e.g., motor vehicle air conditioners,
refrigerators, etc.) that contain ozone-depleting refrigerants, does the facility
maintain all required records? (p. W-88)
f. RCRA: Does the facility keep a copy of its manifest for a minimum of 3 years?
(p. W-88)
g. USTs: Does the facility maintain records of leak detection; spill, overfill and
corrosion protection; corrective actions; closure; and financial
responsibility? (p. W-89)
h. Pesticides: Does the facility maintain records of use and storage of
pesticides? (p. W-89)
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.
NPDES Recordkeeping
7.1a Does the facility keep records of NPDES monitoring information for a
minimum of 3 years?
It is extremely important to keep accurate records of monitoring information. Facilities
must report monitoring results for wastewater discharges on a Discharge Monitoring
Report (DMR) form to the NPDES permitting agency. The permit will specify the
monitoring and reporting schedule. Such requirements are determined on a facility-
specific basis. Records of monitoring information generated under the NPDES program
must include:
The date, exact place, method, and time of sampling and the names of the person or
persons taking the samples.
The dates of analyses.
Who performed the analyses.
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Management and Administration
The analytical techniques or methods used.
The results of such analyses.
NPDES permits require that the facility maintain all records related to monitoring at the
facility for at least 3 years. Note: Many states require these records to be maintained for
at least 5 years.
Q Yes Monitoring records include all of the information listed above and are
maintained for at least 3 years.
D Wo Monitoring records do not include all of the information listed above and/or are
not maintained for a minimum of 3 years.
Q NA Facility does not have wastewater discharges.
7.1b As part of the SWPPP, does the facility maintain records of spills,
discharges, and other information describing the quality and quantity of
storm water discharges?
Q Yes Facility maintains records describing the quality and quantity of storm water
discharges.
Q No Facility does not maintain records describing the quality and quantity of storm
water discharges.
Q NA Facility is not required to have an NPDES permit.
7.1c As part of the SWPPP, does the facility maintain records documenting
inspections and maintenance activities?
Q Yes Facility maintains records documenting inspections and maintenance activities.
Q No Facility does not maintain records documenting inspections and maintenance
activities.
Q NA Facility is not required to have an NPDES permit.
Air Permit Recordkeeping
7.1d Does the facility keep records as required by its air permit(s)?
If the facility conducts certain operations (e.g., parts cleaning, painting, paint removal,
burning of fuel, etc.), it may need an air permit. Many air permits require recordkeeping to
verify permit compliance. Contact the local air pollution control agency for more
information.
Q Yes Facility is familiar with the recordkeeping requirements of its air permit(s).
Q No Facility is not familiar with the recordkeeping requirements of its air permit(s).
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Management and Administrate
Q NA Facility is not required to have an air permit.
CFC - Containing Equipment
7.1 e If the facility owns/operates appliances (e.g., motor vehicle air
conditioners, refrigerators, etc.) that contain ozone-depleting
refrigerants, does the facility maintain all required records?
EPA has established recordkeeping requirements for servicing and disposal of air-
conditioning and refrigeration equipment that contains regulated ozone-depleting
refrigerants. If the facility owns or operates appliances containing ozone-depleting
refrigerants, it must maintain the following records:
Dates and types of service.
Date of refrigerant purchase.
Refrigeration technician's certification records ( see 40 CFR Part 82).
Q Yes Facility maintains records as described above.
Q No Facility does not maintain records as described above.
Q NA Facility does not own/operate appliances that contain ozone-depleting
refrigerants.
RCRA Recordkeeping
Various recordkeeping requirements apply to airports as part of their hazardous waste
management obligations. The Uniform Hazardous Waste Manifest Form is a multi-copy shipping
document that reports the contents of the facility's 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 airport facility to verify
that the shipment was received. A copy of the manifest is required to be kept at the facility for 3
years or until a signed copy of the manifest is received from the waste disposal/treatment facility
The signed copy of the manifest is required to be kept on file for 3 years. Generators may have
other recordkeeping and reporting requirements. Contact your State or EPA Region for more "
information.
7.1 f Does the facility keep a copy of its manifest for a minimum of 3 years?
Q Yes Facility maintains a copy of its manifest for at least 3 years.
Q Ato Facility has not maintained a copy of its manifest for at least 3 years.
Q NA Facility does not generate hazardous waste.
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Management and Administration
Underground Storage Tanks
7.1g Does the facility maintain records of leak detection; spill, overfill, and
corrosion protection; corrective actions; closure; and financial
responsibility?
If the facility has a federally, regulated UST, it must keep records that prove it meets
certain requirements. These records must be kept to show the facility's recent compliance
status in five major areas: (1) leak detection; (2) corrosion protection; (3) corrective
actions; (4) closure; and (5) financial responsibility. The facility must submit appropriate
notification information to EPA or the state regulatory agency. Check with the state or
local regulatory agency about particular recordkeeping requirements. Generally, one
should follow this useful rule of thumb for recordkeeping: When in doubt, keep it.
Q Yes Facility maintains all records listed above on site.
Q No Facility does not maintain all records listed above on site.
Q NA Facility does not have a UST.
Records of Pesticide Application
7.1h Does the facility maintain records of use and storage of pesticides?
Federal law requires that facilities keep accurate records of use and storage of restricted
use pesticides (RUPs). Records of use are necessary to track when the next application
should occur to control pest problems. Frequency of application is determined by label
directions. Records of stored (RUP) pesticides allow management to do the inventory, so
that oldest pesticides can be used first, and excess pesticides are not purchased and
stored. In addition, accurate recordkeeping for pesticide storage can be crucial in the
event of an accidental spill or fire, so that emergency responders can know exactly the
hazards posed.
Q Yes Facility maintains accurate records of use and storage of RUP pesticides.
Q No Facility does not maintain accurate records of use and storage of RUP
pesticides.
Q NA Facility does not use pesticides.
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Management and Administratic
7.2 Training Requirements
NOTE: The following questions are not included in the accompanying checklist, however, they
are still important to consider when examining the facility's operations for compliance
with environmental requirements:
a. RCRA: Has the facility trained its employees on procedures for handling hazardous
waste and emergencies? (p. W-90) //c^a/uuus
b- ฃFC: Does the facility employ or hire trained and certified technicians to maintain
CFC-contammg equipment? (p. W-91)
c. CFC: Are all certificates on file? (p. W-91)
d. When applying restricted use pesticides (RUPs) on property, does the facility
ensure that the pesticide applicator is currently certified in the appropriate
category? (p. W-91)
These questions appear in the following text and may be accompanied with a discussion
of the preferred answer (indicated with a V") for environmental compliance.
RCRA Emergency Response
7.2a Has the facility trained its employees on procedures for handling
hazardous waste and emergencies?
Under RCRA, the facility must train its employees on procedures for properly handling
hazardous waste, as well as on emergency procedures. For Large Quantity Generators
(LQGs), the training must be formalized and be completed by employees within six
months of accepting a job involving the handling of hazardous waste. In addition the
facility must provide annual review of the initial training.
Q Yes Facility has trained its employees as described above.
Q No Facility has not trained its employees as described above.
Q NA Facility is not an LQG.
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Management and Administration
Employee Training for Air Conditioning Repair Technicians
7.26 Does the facility employ or hire trained and certified technicians to
maintain CFC-containing equipment?
Technicians that perform a service that may release refrigerant must complete training
and obtain the certification of EPA. 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.
Q No Technicians are not certified.
Q NA Facility does not maintain CFC-containing equipment.
7.2c 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 NA Facility does not maintain CFC-containing equipment.
Pesticide Applicator Certification
7.2d When applying restricted use pesticides on property, does the facility
ensure that the pesticide applicator is currently certified in the
appropriate category?
EPA classifies certain pesticides as restricted use pesticides (RUPs) based on toxicity or
environmental hazard as opposed to non-restricted use pesticides which do not require
certified RUP applicators. The facility will know if the pesticide is classified as a restricted
use pesticide (RUP) by reading the label. These pesticides may be applied only by a
certified applicator or under the direct supervision of a certified applicator. States oversee
the program for the certification of applicators of restricted use pesticides. Facilities that
are interested in having their personnel become certified applicators should contact their
State.
Q Yes The RUP pesticide applicators are currently certified and trained.
Q Wo The RUP pesticide applicators are not certified and trained.
Q NA The facility does not apply restricted use pesticides on its property.
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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.
CFG: Code of Federal Regulations. A codification of the regulations published by federal
government agencies.
Chlorofluorocarbons (CFC): 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."
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.
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Glossary of Terms
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.
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.
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Glossary of Terms
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.
Environmental Protection Agency (EPA): The federal regulatory agency in charge of
administering and enforcing various federal environmental laws.
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 often EPA regions, such as Region
4Tennessee, Kentucky, North Carolina, South Carolina, Georgia, Florida, Alabama, and
Mississippi.
Erosion: The process of being worn away or deteriorated by wind or water.
Evacuation: A personnel or population protection strategy that provides for the orderly
movement of people away from an actual or potential hazard.
Facility: All buildings, structures, equipment, and other stationary items that are located on a
single site or on continuous or adjacent sites and that are owned or operated by the same person
(or by any person which controls, is controlled by, or under common control with such person).
Under certain circumstances, a facility can include rolling stock and other transport vehicles
registration
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 ฐF but below 100ฐF; flammable liquids with flash points below 100ฐF; pyrophoric
chemicals that ignite spontaneously in air at temperatures of 130ฐF.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.
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Glossary of Terms
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.
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.
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Glossary of Terms
Ignitable: Material that has a flashpoint less than 140ฐF, is combustible through friction, is
combustible through absorption of moisture, or can spontaneously combust.
Incident: A release or potential release of a hazardous material, substance, or waste into the
environment.
Indirect Discharge: A discharge which goes to a publicly-owned treatment works (POTW).
Indirect discharges do not need a National Pollutant Discharge Elimination System (NPDES)
permit but must comply with the POTW pretreatment standards.
Influent: Wastewater or other raw or partially treated liquid flowing into a basin, treatment
process, or treatment plant.
Land Disposal: Includes, but is not limited to placement of hazardous waste in a landfill, surface
impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed
formation, underground mine or cave, or concrete vault or bunker intended for disposal purposes.
Land disposal facilities are a subset of treatment, storage, and disposal facilities (TSDFs).
Groundwater monitoring is required at all land disposal facilities. Waste material can only be
disposed of at a permitted facility.
Land Disposal Restrictions: Regulations prohibiting the disposal of hazardous waste on land
without prior treatment of the waste. Land disposal restriction notifications ensure proper
treatment of the waste prior to disposal.
Landfill: A disposal facility or part of a facility where waste is placed in or on land and which is not
a land treatment facility, a surface impoundment, or an injection well.
Large Quantity Generators: One of three classes of hazardous waste generators under RCRA
producing 1,000 kilograms or more of hazardous waste in one calendar month at a given location.
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.
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Glossary of Terms
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.
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.
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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 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 biphenyis (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 standards.
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Glossary of Terms
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).
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 Groundwater Analysis: Tests used to determine the presence of substance
contamination and concentration levels. The analysis may involve soil borings and the
installation of test pits and/or monitoring wells.
Solid Waste: Any garbage, refuse, sludge, or other waste materials not excluded by definition.
Exclusions include domestic sewage and any mixture of other wastes that pass through a sewer
system to a publicly-owned treatment works (POTW); industrial wastewater discharges that are
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Glossary of Terms
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.
Special Waste: A type of waste which is not a hazardous waste but requires more care than a
regular solid waste and may require special disposal procedures. Examples include: certain
sludges, asbestos containing waste materials, and oil waste.
Spill Prevention, Control, and Countermeasure (SPCC) Plan: Plan designed to ensure that a
facility puts in place containment and other control measures that will prevent oil spills from
reaching navigable U.S. waters.
State Emergency Response Commission (SERC): The state agency which must be notified in
the event of an accidental release of an extremely hazardous substance, a CERCLA hazardous
substance, or a chemical with an MSDS above the chemical's threshold planning quantity (TPQ)
or its reportable quantity (RQ).
Stationary Source: Any building, structure, facility, or installation that emits or may emit any air
pollutant.
Storage: The holding of hazardous waste for a temporary period, at the end of which the
hazardous waste is treated, disposed of, or stored elsewhere. Generators are required to have a
RCRA permit for storage of hazardous waste for more than 90 days or 180 days, depending on
the generator's status. Treatment or disposal facilities must be permitted.
Super-fund Amendments and Reauthorization Act (SARA): The amendments to CERCLA
which increased available funds for site cleanups, added cleanup standards, and required
hazardous waste operations training for site workers and emergency response personnel.
Super-fund: 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.)
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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.
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, 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 contajn regulated hazardous substances or
petroleum and has at least 10% of its volume beneath the surface of the ground.
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 or toxicity of wastes generated by
source reduction or recycling. Generators and TSD"facilities 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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