United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2223A)
EPA 305-B-00-004
August 2000
Environmental
Screening Checklist
and Workbook for
Water Transportation
Industry
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Disclaimer
The environmental screening checklist and workbook are tools to
be used to help you evaluate compliance at your facility. They do
not contain an exhaustive list or description of all federal
environmental regulations that may apply to your facility. In
addition, your facility is responsible for knowing and complying
with all applicable tribal, state, and local requirements.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
W-i
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Table of Contents
TABLE OF CONTENTS
INTRODUCTION VV -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? VV- vii
CHECKLIST
SECTION 1.0 WASTE MANAGEMENT W -1
1.1 HAZARDOUS WASTE MANAGEMENT W -1
1.2 USED OIL AND USED FILTERS W - 9
1.3 USED RAGS/SHOP TOWELS W-14
1.4 ABSORBENTS W-16
1.5 USED BATTERIES W-17
1.6 METAL SCRAPS W-19
1.7 USED ANTIFREEZE W-20
1.8 PCB-CONTAINING EQUIPMENT W-23
SECTION 2.0 WASTEWATER AND STORM WATER MANAGEMENT W-26
2.1 WASTEWATER AND STORM WATER MANAGEMENT AT
WATER TRANSPORTATION FACILITIES W-26
2.2 ACTIVITIES GENERATING WASTEWATER AND/OR STORM WATER W-34
2.3 SLUDGE MANAGEMENT W-36
SECTION 3.0 DOCKSIDE MAINTENANCE AND REPAIR ACTIVITIES W-38
3.1 CARGO LOADING AND OFF LOADING W-38
3.2 PAINTING AND PAINT REMOVAL OPERATIONS W-40
3.3 FACILITY RENOVATION/DEMOLITION - ASBESTOS CONCERNS W-46
3.4 AIR CONDITIONING MAINTENANCE W-47
3.5 FUELING OPERATIONS W-52
3.6 EQUIPMENT CLEANING AND SPENT SOLVENTS W-53
3.7 DISPOSAL OF DREDGE AND FILL MATERIAL W-56
3.8 PESTICIDES W-58
SECTION 4.0 STORAGE TANKS AND SPILL PREVENTION, CONTROL AND
COUNTERMEASURES W-60
4.1 UNDERGROUND STORAGE TANKS (USTs) W-60
4.2 ABOVEGROUND STORAGE TANKS W-63
4.3 SPILL PREVENTION, CONTROL, AND COUNTERMEASURES (SPCC) AND EMERGENCY
RESPONSE W-65
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
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Table of Contents
SECTION 5.0 PLANNING AND ACCIDENTAL RELEASE REPORTING W-69
5.1 EPCRA PLANNING AND REPORTING REQUIREMENTS W-69
5.2 RCRA CONTINGENCY PLAN W-72
5.3 OIL POLLUTION ACT'S FACILITY RESPONSE PLAN W-74
5.4 CAA RISK MANAGEMENT PLAN W-76
SECTION 6.0 VESSELS AND UNDER WAY ACTIVITIES W-78
6.1 MARINE POLLUTION W-78
6.2 OCEAN DUMPING W-86
6.3 DISCHARGING ON SHORE TO WATER TRANSPORTATION FACILITIES W-87
6.4 POLLUTION PREVENTION W-88
GLOSSARY
G-1
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Workbook for the Water Transportation Industry
August 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 the Water Transportation Industry as a public service to
the water transportation facilities. EPA's Office of Compliance, through various meetings with
industry representatives, facility owners, and technicians, determined there is a lack of
information available to facilities to help them 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 water transportation
industry. The term facility refers to, but not
limited to shipping port, shipping sites,
terminals, ships, towboats and barges, -etc.
overseen by owners/operators, tenants,
managers, field personnel, etc. who engage
in water transportation operations. If
problems with compliance are discovered while
conduct a more comprehensive self-audit.
NOTE: If you are the owner of a water
transportation facility, you must ensure that
your contractors comply with all environmental
rules and regulations. Remember: As the
owner, you are ultimately responsible for
compliance at your facility, even for those
activities conducted by your contractors.
completing the checklist, you may want to
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 the
Water Transportation Industry," is a pictorial representation of specific activities that are
regulated or specific environmental requirements at a water 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 Toll-Free Info-Line: 1-888-459-0656
TERC Website Address: http://www.transource.org
Please remember that all of these materials are a beginning, not the final word, on
environmental compliance requirements. While federal environmental requirements are
highlighted in the checklist and workbook, a comprehensive discussion of all requirements is
NOT included. In addition to federal requirements, you may be subject to state, tribal, and/or
local requirements. You can use these materials to build a basic understanding or increase
your knowledge of federal environmental requirements, and then seek additional assistance
from various federal, state, tribal, and local agencies.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 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 Waste Management
Section 2.0 Wastewater and Storm Water Management
Section 3.0 Dockside Maintenance and Repair Activities
Section 4.0 Storage Tanks and Spill Prevention, Control, and Countermeasures (SPCC)
Section 5.0 Planning and Accidental Release Reporting
Section 6.0 Vessels and Underway Activities
Section 6.0 Vessels and Underway Activities includes requirements for vessel activities, such
as marine pollution, ocean dumping, and discharging on shore to marine facilities. While these
operations are not necessarily applicable to water transportation facilities, they may be of
interest as vessel activities have the potential to impact water transportation industries.
Following these six sections, a glossary is provided for your use.
Where Do I Start? You may first want to become familiar with the workbook because it is more
comprehensive than the checklist in terms of environmental compliance information and
issues. Once you have become familiar with the workbook, you can use the checklist by itself
to conduct a compliance evaluation of your facility.
The two page checklist, located after this introductory text, is basically a streamlined version of
the workbook and has been included to help make the evaluation of your facility's compliance
as easy and efficient as possible. Because the checklist was designed to evaluate specific
activities and requirements at your operation, it does NOT include all of the questions or
activities found in the workbook.
Each checklist question will ask you
about key environmental
requirements that are applicable to a
water transportation facility (not
limited to ships, barges etc.). 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 consistently and accurately respond to the compliance
questions.
WHAT DOES THE "" MEAN?
A "" next to a response in the guide indicates that is
the preferred response in terms of environmental
compliance. If you select a response without a V",
you may still be in compliance. However, you should
verify that you are in compliance by contacting the
appropriate federal or state regulatory agency and
discussing your activity with them.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
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Introduction
Can the checklist be personalized? The checklist can be personalized to fit the needs of
your facility. When evaluating environmental compliance, you or the person conducting the
evaluation should record certain information on the checklist, including the date, name of the
facility, name of the person conducting the evaluation, and any comments or questions
regarding the compliance evaluation. Such information will help you monitor your facility's
continued progress towards environmental compliance.
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
Headquarters and regional offices,
financial assistance information,
and pollution prevention websites.
Publications
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
Sector Notebooks. The
following sector notebooks,
which may be of interest to the
water transportation industry,
can be downloaded electronically at: http://es.epa.gov/oeca/sector/index.html.
copies can be ordered from GPO at (202) 512-1800.
Also
- Profile of the Water Transportation Industry (Shipping and Barging),
003 (95 pages)
EPA/310-R-97-
- Profile of the Transportation Equipment Cleaning Industry, EPA/310-R-95-018 (81
pages)
Transportation Equipment Cleaning Industry Effluent Guidelines and Standards - Proposed
Rule. EPA is proposing a regulation that will establish technology-based effluent limitations
guidelines for the discharge of pollutants into waters of the U.S. and into publicly owned
treatment works by existing and new facilities that perform transportation equipment
cleaning operations. For more information, call (202) 260-4992 or check website:
http://www.epa.gov/OST/guide/tecifs22.html
Code of Federal Regulation (CFR) References.
Website: http://www.access.gpo.gov/nara/cfr/index.html
Hotlines and Information Lines
Transportation Environmental Resource Center (TERC) Information Line
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
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Introduction
Telephone: (888) 459-0656
Website: http://www.transource.org
This resource center is designed to help transportation industries stay on top of
environmental requirements and technologies.
U.S. Coast Guard, Office of Boating Safety
Telephone: 1-800-368-5647
Website: http://www.uscg.mil/
This office provides information regarding marine safety, operations, and environmental
protection.
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
Environmental Screening Checklist and
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August 2000
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Introduction
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 a RCRA coordination program information collection outreach and
guidance. For additional information on waste minimization, go to website:
http://www.epa.gov/wastemin
Maritime Administration, DOT
This website provides links and information on the Maritime Administration's
environmental program.
Website: http://www.marad.dot.gov/offices/environmental_activities.html
National Pesticides Information Line
Telephone: (800) 858-7378
This service provides information relating to pesticide usage, including label
information, incident investigations, emergency human and animal treatment safety
practices, clean-up and disposal, laboratory analyses, and regulations.
National Response Center Hotline/Oil and Hazardous Material Spills
Telephone: (800) 424-8802 or (202) 267-2675
Fax: (202) 267-2165
This hotline can be used to report oil and hazardous material spills that (1) violate
applicable water quality standards, (2) cause, a film or "sheen" upon surface waters or
adjoining shorelines, or (3) cause a sludge or emulsion to be deposited beneath
surface waters or upon adjoining shorelines. This hotline is staffed 24 hours a day, 7
days a week, by U.S. Coast Guard officers and marine science technicians.
Pollution Prevention Information Clearinghouse (PPIC)
Telephone: (202) 260-1023
Fax: (202) 260-4659
Website: http://www.epa.gov/opptintr/library/libppic.htm
PPIC is a free, non-regulatory service of EPA that provides answers and referrals in
response to questions from the public concerning pollution prevention.
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.
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Introduction
Safe Drinking Water Hotline
Telephone: (800) 426-4791 or (703) 285-1093
Fax: (703)285-1101
E-mail: hotline-sdwa@epamail.epa.gov
This hotline provides information about EPA's drinking water regulations and other
related drinking water and groundwater topics. Technicians are available to get details
on legislation and regulations or provide important contacts for water resources and
information on drinking water and groundwater.
Small Business Ombudsman Clearinghouse/Hotline
Telephone: (800) 368-5888 or (703) 305-5938
Fax: (703) 305-6462
This hotline provides regulatory and other environmental information concerning small
business assistance to enhance voluntary regulatory compliance and pollution
abatement and control. It also addresses questions covering all media programs within
EPA.
Stratospheric Ozone Information Hotline
Telephone: (800) 296-1996 or (301) 614-3376
Fax: (301)614-3395
This information hotline provides in-depth information on ozone protection regulations
and requirements under Title VI of the Clean Air Act Amendments of 1990. In addition,
the hotline serves as a distribution center and point of referral for an array of
information pertaining to other general aspects of stratospheric ozone protection and
depletion.
Storm Water Hotline
Telephone: (800) 245-6510
This hotline serves as a clearinghouse for information concerning EPA's storm water
general permits. Information specialists are available to answer technical questions
concerning permit eligibility, specific permit requirements, and provide guidance materials.
Toxic Substances Control Act (TSCA) Assistance Information Service
Telephone: (202) 554-1404
Fax: (202) 554-5603
The information service provides technical assistance and general information about
programs implemented under TSCA, including inquiries about import/export of
chemicals under the regulatory program.
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-FlLTER (993-4583)
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Introduction
Website: http://www.filtercouncil.org
This hotline, sponsored by the Filter Manufacturers Council, provides commercial
generators of used oil filters with a summary of the state's filter management
regulations, referrals to companies that provide filter management services, referrals to
state agencies, and a brochure entitled "How to Choose a Filter Management Service."
Wetlands Information Hotline
Telephone: (800) 832-7828 or (703) 748-1304
This information line answers questions concerning the value and function of wetlands
and options for their protection, and accepts requests for certain wetlands publications.
EPA Headquarters and Regional Office Information
EPA Headquarters
Telephone: (202) 260-1090
Fax: (202) 260-0279
Website: http://www.epa.gov/
Region 1 (CT, MA, ME, NH, Rl, VT)
Telephone: (617) 918-1111
Toll-free: (888) 372-7341
Website: http://www.epa.gov/region1/
Region 2 (NJ, NY, PR, VI)
Telephone: (212) 637-3000
Website: http://www.epa.gov/region2/
Region 3 (DC, DE, MD, PA, VA, WV)
Telephone: (215) 814-5000
Toll-free: (800) 438-2474
Website: http://www.epa.gov/region3/
Region 4 (AL. FL, GA, KY, MS, NC, SC. TN)
Telephone: (404)' 562-9900
Toll-free: (800)241-1754
Website: http://www.epa.gov/region4/
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
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Website: http://www.epa.gov/region7/
Region 8 (CO, MT, ND, SD, UT, WY)
Telephone: (303) 312-6312
Toll-free: (800)227-8917
Website: http://www.epa.gov/region8/
Region 9 (AZ, CA, HI, NV)
Telephone: (415) 744-1305
Website: http://www.epa.gov/region9/
Region 10 (AK, ID, OR, WA)
Telephone: (206) 553-1200
Toll-free: (800) 424-4372
Website: http://www.epa.gov/region10/
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
This site provides access to federal publications, OPPT programs and initiatives, and
other information sources related to pollution prevention.
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ERA's Office of Underground Storage Tanks
Website: http://www.epa.gov/OUST/
This site provides access to federal publications and links to other resources about
preventing pollution from underground storage tanks containing petroleum or
hazardous substances.
EPA's Oil Program
Website: http://www.epa.gov/oilspill
This site contains comprehensive information on oil spill prevention, preparedness and
response.
EPA's Brownfields
Website: http://www.epa.gov/swerosps/bf/index.htmltfinfo
EPA's Office of Solid Waste and Emergency Response's Brownfields site provides
information about projects and initiatives, tools, contacts, publications, and other
information regarding Brownfields.
Chemical Emergency Preparedness and Prevention Office
Website: http://www.epa.gov/ceppo/
This site provides information regarding hazardous and extremely hazardous
substances, including planning and reporting requirements.
EPA's Enviro$en$e
Website: http://es.epa.gov
This site provides P2 information, as well as a link to the National P2 Roundtable
described below.
National Fire Protection Association
Website: http://www.nfpa.org
This site contains information on the National Fire Protection Association codes and
standards.
National Pollution Prevention Roundtable Home Page
Website: http://www.p2.org/
This site provides access to the latest information on legislative and regulatory P2
developments, National Roundtable publications, state P2 program websites, and a
directory of industrial P2 publications.
Pollution Prevention Information Clearinghouse
Website: http://www.epa.gov/opptintr/library/libppic.htm
Operated by EPA's Office of Pollution Prevention and Toxics, this clearinghouse is a
free, non-regulatory service that provides telephone reference and referral, document
distribution for selected EPA documents, and a special collection available'for
interlibrary loan.
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Pollution Prevention Cooperatives
Coordinated with EPA's EnviroSenSe program, these cooperatives provide easy access
to pollution prevention and cleaner production resources around the Internet.
U.S. Federal Agency Pollution Prevention Cooperative
Website: http://es.epa.gov/cooperative/federal/
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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EiVWjROlVMENTAL SCREENING CHECKLIST FOR THE WATER TRANSPORTATION INDUSTRY j
acility Name: Site Reviewer:
acilitv Location: Date:
1.0 WASTE MANAGEMENT
azardous Waste
anagement*
sed Oil and Used
Hers*
'sed Rags/Shop
owels*
bsorbents*
'sed Batteries*
[etal Scraps*
Ised .Antifreeze*
How much hazardous waste does the facility generate a month? (p, W-5)
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 dispose of its hazardous waste? (p. W-7)
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-10)
How does the facility manage/dispose of used oil? (p. W-l 1)
How does the facility manage/dispose of oil filters? (p. W-13)
How does the facility manage/dispose of fuel filters? (p. W-13)
How does the facility manage used rags and shop towels? (p. W-l 5)
Does the facility determine if used absorbents are hazardous before disposal? (p. W-16)
If storing used batteries, does the facility protect them from storm water contact? (p. W-l 8)
How does the facility manage/dispose of used batteries? (p. W-18)
How does the facility manage/dispose of scrap metal? (p. W-20)
In terms of storage, does the facility keep used antifreeze segregated and in labeled containers? (p. W-21)
Has the facility determined if it generates any antifreeze that is a hazardous waste? (p. W-21)
1 ) No more than 220 Ibs (CESQG)
2) Between 220 and 2.200 Ibs (SQG)
3) Over 2.200 Ibs (LQG)
Y n N n NA c
YD N D NAD
Ships hazardous waste off site/Disposes of
hazardous waste on site and is RCRA-
permitted/Other/NA
Y o N c NA n
YD No NAD
Y a N a NA a
Sent off site for recycling/Burned in an on-site
space heater/Burned off site/Other'NA
Recycle / Service company / Other ' NA
Recycle / Service company / Hazardous waste . ,
Other / NA >
Laundry service/Burned for heat/Hazardous
waste transporter/ Trash/Other/NA 1
YD NO NAD :
Y n N D NA n :
Return to supplier/Recycle/Service company'
Universal waste handler/Hazardous waste
landfill/Other/NA
Recycle/Reuse/Sale/Other/NA
Y n N D NA D
YD ND NAD
2.0 WASTEWATER AND STORM WATER MANAGEMENT
Vastewater and
itorm Water
ianagement at
Vater
'ransportation
'acilities*
Activities Generating
\Vastewater and'or
Stonn Water*
Sludge
Management*
Can the facility identify the final destination of all its drains? (p. W-28)
Does the facility have an NTDKS permit for direct discharges? (p. W-30)
Does the facility submit its monitoring results for wastewater discharges on a discharge monitoring report
(DMR) form to its permitting agency? (p. W-30)
Does the facility keep accurate records ol" monitoring information for the minimum requirement of 3 years?
(p.W-31)
Does the facility have a storm water permit?
If Yes, does the facility have a storm water pollution prevention plan (SWPPP)? (p. W-32)
If discharging to a municipal sanitary sewer, has the facility notified the publicly-owned treatment works
(POTW) and received approval for discharges? (p. W-32)
How does the facility clean the floors and surrounding areas? (p. W-34)
If the facilitv stores materials outside, are they protected from contact with storm water? (p. W-35)
How does the facility manage the sludge from an oil/water separator? (p. W-36)
YD N a NA a
Y a N a NA n
Y a Na NA a
YD N a NA a
Ya Nn NAD
YD Na NAG
YD N a NA a
Dry Cleanup / Water
Yn N D NA n
Off-site disposal as hazardous sludge / Oil-site
disposal to other facility / On-site disposal '
Other / NA
-------
3.0 DOCKSIDE MAINTENANCE AND REPAIR ACTIVITIES
Cargo Loading and
OtTLoadins*
If hazardous materials are loaded at the facility, are containers inspected for:
(1) proper labeling placarding.
(2) signs of leakage, and
(3) compatibility with other hazardous materials? (p. W-39)
Is the facility familiar with requirements under the Final Rule for Marine Tank Vessel Loading Operations?
(p.\V-40)
fainting and Paint
Removal
Operations*
Air Conditioning
Maintenance*
Fueling Operations
Equipment Cleaning
and Spent Solvents'
How does the facility manage.'dispose of paint stripping wastes and baghouse dusts? (p. W-43)
When not in use, does the facility manage/dispose of paints in labeled containers? (p. W-44)
Arc CFC-containing equipment maintained by certified technicians? (p. W-48)
Pesticides'
How does the facility manage/dispose of used paints and painting waste products? (p. W-44)
Docs the facility have documentation that refrigerants from recovery equipment are sent to an EPA-approved
reclaimer? (p. W-50)
Does the facility use overfill protection measures, spill containment methods, and spill response equipment
used during fueling? (p. W-52)
i i.l
If halogenated solvents are used in cleaning equipment, has the facility submitted a notification report to the
air permitting agency'? (p. W-54)
How does the facility manage/dispose of its spent solvents? (p. W-55)
Does the facility store spent solvents in labeled containers ? (p. W-55)
_
Are restricted use pesticides (RUPs) applied only by a certified commercial applicator? (p. W-59)
Y= Nz NA-
Y n N = NA c
Y = N D NA c
Recycling.' Hazardous waste landfill Otl
V a N a NA a
Return to supplier/ Reuse/' Recycle Othe
YD N a NA o
YD N a NA a
YD - N a
Y a N a NA a
Third party vendor/ Permitted discharge tl
sewer or surface waters/ Sanitary sewer/ (
NA
4.0 STORAGE TANKS AND SPILL PREVENTION. CONTROL, AND COUNTERMEASURES
Y a Na NA a
YD N a NA a
.'ndcrground
Storage Tanks
fl'STs)*
Has the facility notify Slate/Tribe UST program office of any USTs located on site? (p. W-61)
Vbovcground
S'lorage Tank:;
AST*)
==
Spill Prevention.
l. and
Cotintcrmeasurcs
SPCC1
Does the facility conduct leak detection for tank and piping of all on-site USTs? (p. W-61)
Do USTs at the facility meet requirements for spill, overfill, and corrosion protection? (p. W-62)
Does the facility maintain records of leak detection: spill, overfill, and corrosion protection; corrective
actions', closure: and financial responsibility? (p. W-62)
Does the facility iaspecl ASTs on a periodic basis for leaks or other hazardous conditions? (p. W-65)
_
Does the facility have an SPCC plan signed by a professional engineer? (p. W-67)
YD N D NAD
YD ND
YD N D NAD
YD N n NAD
YD Na NAD
YD N a NA a
5.11 PLANNING AND ACCIDENTAL RELEASE REPORTING
EPCRA Planning
and Reporting
Requirements*
RCRA Contingency
Plan*
-^ -
Facility Ktsponsc
Plan (FRP)*
Risk Mgntt Plan
(RMP)*
S55= =
=====^==========:
If the facility has extremely hazardous substances fEHSs> in excess of their threshold planni quantities
(TPQs) has the facility notified its state emergency response commission (SERC) and local emergency
planning committee fl.KI'C)'' (p \V-70)
?=*. 1
Il'thc facility qualifies as a large quantity generator (LQG). does it have a written contingency plan in place
for responding to spills and releases nl'haxardous substances? (p. W-73)
If the facility is a small quantity generator (SQG). does it have basic contingency procedures in place for
responding to spills and releases ofha/ardous substances? (p. W-74)
' -== =====
Does the facility have an FRP? (p, \V-74)
==========================J
Does the facility have an RMP? (p-76)
YD ND
===
YD N D
YD Nn
YD ND
====
YD ND
NAD
===
NAD
NAD
=====
NAD
=====
NAD
* I-or additional questions regarding these environmental compliance issues refer to the workbook.
Note: Refer to the workbook for Section 6.0 Vessels and Underway Activities, including marine pollution (p. W-79) ocean dumping (p W-86) i
(^charging on shore to water transportation facilities (p. W-87), and pollution prevention (p. W-88). In addition, the workbook includes environment
compliance information and questions regarding: PCB-containing equipment (p. W-23). facility renovation/demolition - asbestos concerns (p W-461 al
disposal of dredge and fill material (p. W-56). *
-------
Waste Management
SECTION 1.0 WASTE MANAGEMENT
I. I Hazardous Waste Management
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility exam its operations relating to hazardous
waste generation, storage, and transport for compliance with environmental
requirements:
a. Does the facility generate hazardous wastes? (p. W-3)
b. 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 wastes in appropriate storage
containers? (p. W-6)
e. Does the facility meet all hazardous waste storage (quantity and time)
requirements? (p. I/I/-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 keep copies of its manifests for the 3 year minimum
requirement?
(p. W-8)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
Identifying Hazardous Waste
A water transportation facility may produce
wastes that are hazardous. Therefore, it is
important that the facility identify and
manage them properly to protect facility's
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 the Water Transportation Industry
August 2000
W-1
-------
Waste Management
What is Hazardous Waste
To be considered "hazardous waste," materials must first meet EPA's definition of "solid waste "
Solid waste is discarded material, including garbage, refuse, and sludge (solids, semisolids,
liquids, or contained gaseous materials). Solid wastes that meet the following criteria are
hazardous and subject to regulations under Resource Conservation and Recovery Act (RCRA)
(40 CFR Part 261): '
Listed waste. Waste is considered hazardous if it appears on one of four lists of
hazardous wastes published in 40 CFR Part 261 Subpart D. Currently, more than 400
wastes are listed. Wastes are listed as hazardous because they are known to be
harmful to human health and the environment when not properly managed. Even when
properly managed, some listed wastes are so dangerous that they are called "acutely
hazardous wastes." Examples of acutely hazardous wastes include wastes generated
from some pesticides that can be fatal to humans even in low doses.
Characteristic waste. If 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 it leaches
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 the 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 the Water Transportation Industry
August 2000
W-2
-------
Waste Management
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.
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
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) or by
the registrant; and (3) mercury thermostats including temperature control devices containing
metallic mercury. Check with the state regulatory agency to see if it has adopted the Universal
Waste Rule.
1.1 a Does the facility generate hazardous wastes?
Note: Under RCRA, vessels are not considered hazardous waste generators. Rather,
the generators of on-board vessel wastes, such as bilge water and used oil, are the
facilities that remove the wastes from the ships and manage it on shore.
Q Yes Facility has gone through the waste determination process or used
process knowledge and determined that it does generate hazardous
waste. See Exhibit 2 for common hazardous wastes generated by water
transportation facilities.
Q Wo Facility has determined that it does not generate hazardous waste.
Q NA / Not Facility has not gone through this process. Note: Facility must
determined immediately conduct this process to determine if it is generating a
hazardous waste.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
W-3
-------
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-------
Waste Management
1.1b How much hazardous waste does the facility generate a month?
Generation occurs when a substance becomes a waste. When determining the
volumes of waste generated, only waste that is in a container or other unit waiting to be
disposed of is considered "generated." Thus, solvent stored in a drum waiting for
disposal or recycling is "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 1/2
of a 55-gallon drum or less of hazardous
waste in any month. In this case, the facility
is a conditionally exempt small quantity
generator (CESQG) and an EPA
identification (ID) number is not required.
Q 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
V2 of a 55 gallon drum of hazardous waste,
but less than 5 (five) 55-gallon drums of
hazardous waste in any month. In this
case, the facility is a small quantity
generator (SQG) and must have an EPA ID
number.
Note: If the facility is a CESQG
and generates no more than 2.2
Ibs (7 kg) of acutely hazardous
waste (or 220 Ibs [700 kg] of
acutely hazardous waste spill
residues) in a calendar month,
and never store more than that
amount for any period of time,
the facility may manage the
acutely hazardous waste
according to the CESQG
requirements. If the facility
generates more than 2.2 Ibs (7
kg) of acutely hazardous waste,
it must be managed according
to the LQG requirements.
Q Over 2,200 Ibs (7,000 kg) of hazardous waste per month. In this case, the
facility generates approximately 5 (five) 55-gallon drums or more of hazardous
waste in any month. In this case, the facility is a large quantity generator
(LQG) and must have an EPA ID number.
The total weight of hazardous waste generated includes only waste (1) defined as
hazardous by EPA regulations, (2) determined to be hazardous by the facility, and (3)
not otherwise exempt from counting. For example, used oil that has not been mixed
with anything and is destined for recycling does not have to be counted.
Generators who periodically exceed or fall below their normal generation limits in any
given calendar month are called episodic generators. If the amount of waste
generated in a given calendar month places the generator in a different category, the
generator is responsible for complying with all applicable requirements of that category
for all waste generated during that calendar month. For example, if a generator
produces 300 kg of hazardous waste in March, that waste is subject to SQG
requirements; if the same generator produces 1,500 kg of hazardous waste in April,
that waste is subject to LQG requirements.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
W-5
-------
Waste Management
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 1.1b), it must have an EPA
hazardous waste generator ID number. This requirement applies even for 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 state issues the number,
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
Q No
Q NA
Facility is an SQG or an LQG and has obtained an identification number
from EPA or the state regulatory agency.
Facility is an SQG or an LQG and has not obtained an EPA identification
number.
Facility does not generate hazardous waste or is a CESQG.
1.1d Does the facility store hazardous waste in appropriate storage
containers?
Containers must meet the following requirements (40 CFR 262.34):
Clearly marked with the words "Hazardous Waste" and the date when waste
accumulation began. Labels for this purpose maybe available from the waste
hauler.
Kept in good condition and stored in a manner that minimizes risks of ruptures,
leaks, or corrosion.
Kept closed except when being filled or emptied, except if volatile explosion is
possible and emergency ventilation is needed.
Inspected at least once per week for leaks or corrosion. Note: Some states may
require facilities to keep a written record of these inspections. Any problems
should be corrected immediately. If any corrections are made, they should be
noted in a permanent record and kept on file for at least 3 years.
Stored in a manner that minimizes the potential for accidental mixing of
.incompatible materials.
Q Yes Facility stores waste in containers that meet the above requirements.
D No Facility stores waste in containers that do not meet the above requirements.
Q NA Facility does not generate hazardous waste.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
W-6
-------
Waste Management
1.1e Does the facility meet all hazardous waste storage (quantity and time)
requirements?
Hazardous waste generators must store hazardous waste according to the following
requirements:
LQGs may accumulate any amount of hazardous waste for no more than 90 days.
SQGs can accumulate no more than 13,228 Ibs (6,000 kg) of hazardous waste on
site for up to 180 days without permit (or up to 270 days if the facility must transport
the hazardous waste more than 200 miles away for recovery, treatment, or
disposal). If these limits are exceeded, the facility is a treatment, storage, and
disposal facility (TSDF) and must obtain an operating permit.
CESQGs have no maximum on-site time limits for storage, but cannot accumulate
more than 2,200 Ibs (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 time
requirements.
Q NA Facility does not generate hazardous waste.
1.1f How does the facility manage/dispose of its hazardous waste?
Q Ships hazardous waste off site to:
A RCRA-permitted TSDF
A recycling facility
An interim status facility or
An exempt facility.
Q Disposes of hazardous waste on site and is a RCRA-permitted TSDF.
Q Other Note: If not managing hazardous waste by one of the above options, facility
is out of compliance and must rectify the situation immediately.
Q NA Facility does not generate hazardous waste.
Environmental Screening Checklist and
Workbook for the Water Transportation Industry
August 2000
W-7
-------
Waste Management
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 do not need 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 do not need to use
manifests.
A hazardous waste transporter should be able to assist in completing the manifest.
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 Vies 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.
Q NA Facility does not ship hazardous waste off site.
1.1h Does the facility keep copies of its manifests for the 3 year minimum
requirement?
The facility must meet various recordkeeping requirements as part of hazardous waste
management obligations. The Uniform Hazardous Waste Manifest Form is a multi-copy
shipping document that reports the contents of its shipment, the transport company
used, and the treatment/disposal facility receiving the wastes. The hazardous waste
generator, the transporter, and the treatment/disposal facility must each sign this
document and keep a copy. The waste disposal/treatment facility also must send a
copy back to the hazardous waste generator, so that the generator can be sure that its
shipment was received. A copy of the manifest is required to be kept at the facility for 3
years.
O yes Facility maintains a copy of its manifest for a minimum of 3 years.
Q No Facility has not maintained a copy of its manifest for a minimum of 3 years.
Q NA Facility does not generate hazardous waste.
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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-10)
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-11)
e. Does the facility completely drain used oil filters and/or fuel filters before
disposal? (p. W-12)
f. How does the facility manage/dispose of its used oil filters? (p. W-13)
g. Has the facility determined if its used fuel filters are hazardous? (p. W-13)
h. How does the facility manage/dispose of its used fuel filters? (p. W-13)
i. Does the facility inspect used oil filter storage areas for spills and leaks?
(p.W-14)
These questions appear in the following text and may be accompanied with discussions
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 OH
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 (UST) standards. Contact the state
regulatory agency to determine the used oil disposal requirements. Facilities should maintain
all records on their used oil storage and recycling activities.
Under the Used Oil Standards (40 CFR Part
279), Used oil produced on vessels from
normal shipboard operations is considered to
be generated at the time it is transported
ashore. The owner or operator of the vessel
and the person(s) removing or accepting used
oil from the vessel are co-generators of the
used oil and are both responsible for managing
the waste. Once the used oil is transported on
shore, the co-generators may decide among
them which party will fulfill the requirements.
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1.2a Are used oil containers/tanks and associated piping leak free and
labeled "used oil"?
Facilities must store used oil in leak free containers
that have labels with the words "used oil." No
special labels are necessary, provided that the
words "used oil" are visible at all times. Spray
painting, crayon, or handwritten (preferably not in
pencil) labels are okay. One can mix used motor
oil with other used oils (hydraulic oils, transmission
fluids, brake fluids) and stored in the same tank.
Note: If a facility uses storage
tanks to store waste oil, such
tanks may be regulated under
underground storage tank (LIST)
or aboveground storage tank
(AST) regulations.
Some facilities have pipes that connect to the used oil storage tank. Piping runs from
the inside of the building to the outside disposal point (i.e., tank). This way, technicians
can pour their oil in a funnel or small bucket which is attached to the piping, and the oil
goes directly to the tank. In this case, the funnel/bucket or piping should also be
labeled with the words "used oil."
Q Yes Used oil is in a leak free container(s) labeled with the words "used oil."
Q No Used oil is not in a leak free container(s) and/or is not labeled "used oil."
Q NA Facility does not generate used oil.
1.2b Does the facility prevent the mixing of used oil with hazardous
waste?
You 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). Used motor oil may be mixed with other used oils (e.g., transmission fluid
or brake fluid) and stored in the same container/tank. For questions about which
specific products may be mixed with used oil, call the RCRA/UST, Superfund, and
EPCRA Hotline at 1-800-424-9346.
Q Vies Hazardous wastes are not mixed with used oil.
Q No Hazardous wastes are mixed with used oil.
Q NA Facility does not generate "used oil."
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1.2c How does the facility manage/dispose of its used oil?
Recycling and burning (for energy recovery) of used oil that has not been mixed with
any other waste are the most environmentally protective, and often the most
economical 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 BTUs 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.
Q 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 BTUs 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
Facility has a hauler or takes its own oil to a used oil
burner.
Q Other
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.
a 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.
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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, facilities can dispose of filters as solid waste (in some states)
provided that the filter has been hot-drained to remove residual used oil. This means that no
matter what draining option is used, one should remove the filter 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, place the filter 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. Drain the filter for 12 to 14 hours.
Crushing: Crush filter by a mechanical, pneumatic, or hydraulic device to squeeze out
the used oil/fuel and compact the remaining filter materials.
Disassembly: Separate filter 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: Place filter in a device where air pressure forces the used oil/fuel out of
the filter.
Protect storage containers designated for used oil filters from storm water with a cover. In
addition, assure the container is capable of holding any used oil that seeps from the filters.
Used fuel filters: Used fuel filters should be properly drained (using the same procedure as
used oil filters) and then tested to determine if they are hazardous. If the fuel filters are
hazardous, they must count toward the facility's generator status (see Section 1.1 for more
information). Store used fuel filters in a separate, marked, fireproof container. If the facility is
a CESQG, it may dispose of used fuel filters in a licensed landfill or give them to 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. Metal filters may be managed as scrap metal if properlv
drained.
Note: Since disposal requirements of used filters may vary by state, a facility should 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?
D yes Facility completely drains filters (i.e., no visible signs of free-flowing oil
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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 managed/disposed its used oil filters?
Q Recycle Filters are recycled for scrap metal.
Q Service Facility contracts with a service which takes filters.
Q Trash Filters are disposed of in the dumpster (e.g., not segregated from other
waste such as paper, plastics, food, etc.).
Q Other Method of disposal is not listed above. Note: The facility may be out of
compliance. Contact the state regulatory agency for assistance.
Q NA Facility does not generate used oil filters.
1.2g Has the facility determined if its used fuel filters are hazardous?
Q Yes Facility has determined through testing or process knowledge whether 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.
1.2h How does the facility managed/disposed its used fuel filters?
Note: If you determine used fuel filters to be hazardous waste, they must be counted
towards the facility's generator status and managed accordingly. See Section 1.1 for
more information on hazardous waste management.
O Recycle
Q Service
Q Managed as
hazardous waste
Q Trash
Q Other
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.
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Does the facility inspect used oil
filter storage areas for oil spills
and leaks?
Engine oil can enter the environment when
one changes and stores oil filters and when
engines drip crankcase and lube oils. Take
preventive measures to minimize oil
dripping by regular maintenance of vessels
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.
Shop Rag/Towel Laundering
Many states do not consider rags going
for laundering to be hazardous waste
(although laundering could generate
hazardous waste). This is because the
rag/towel, even if contaminated with
hazardous waste, is not 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 go to a laundry. Check with the
state regulatory agency on requirements
for managing shop rags/towels.
All areas where oils are received, stored, used, changed, and potentially spilled need
regular inspections for spills. Use one of the following indicators to identify oil spills: (1)
sheen on water, (2) stained soil, (3) lack of vegetation, or (4) visible leaks. Contain all
spills and clean up immediately after detection. The facility should consult the Spill
Prevention, Control, and Countermeasures (SPCC) plan in the event of a spill or leak.
The SPCC plan contains detailed information on spill cleanup and remediation. In
addition, if any oil enters surface waterways and produces a sheen, notify the National
Response Center (1-800-424-8802) and state emergency response agency
immediately.
Q Yes Facility inspects storage areas for oil spills.
Q No Facility does not inspect storage areas for oil spills.
Q NA Facility does not have storage areas for used oil and filters.
1.3 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 used shop towels for compliance with environmental requirements:
a. How does the facility manage used rags and shop towels? (p. W-15)
b. How are used rags and shop towels stored while on site? (p. W-15)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
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Used Shop Rags and Towels
A facility must manage used shop rags and towels as hazardous waste if they are
contaminated with a hazardous waste or display a hazardous characteristic due to the presence
of gasoline or metal-contaminated antifreeze. EPA allows facilities to manage these used rags
and towels by using a laundry service, or disposing of them through an EPA-licensed
hazardous waste transporter and disposal facility.
You can recycle used shop rags and towels contaminated with used oil only. You can burn
them for energy recovery under the same Used Oil Management Standards existing for burning
used oil. (See page W-12, question 1.2c) According to the used oil regulations, you should
handle oil-contaminated rags and towels as used oil until the oil is removed from them (40 CFR
Part 279). EPA considers used oil satisfactorily removed when no visible sign of free flowing oil
remains in the rags/towels. Note: After used oil has been removed, 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.
1.3a How does the facility manage used rags and shop towels?
Q Laundry service
Q Burned for heat
Q Hazardous waste
transporter
Q Trash
Q Other
QA//A
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 them through an EPA-licensed hazardous waste
transporter and disposal facility.
Facility disposes used rags/towels with trash (in a dumpster)
and not segregated. If rags/towels are contaminated with
hazardous waste, they should not be disposed of with trash,
but managed according to one of the above options.
Method of disposal is not listed.
Facility does not generate used rags or shop towels.
1.3b How are used rags and shop towels stored on site?
Q Separate container In a container (e.g., bucket, can, barrel, on a shelf or bench,
etc.) that only contains rags.
Q Stored as
hazardous waste
Store used rags/towels contaminated with hazardous waste
according to hazardous waste requirements (see Section 1.1).
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Q Shop trash can
Q Floor
Q Other
QNA
Can/dumpster that contains all shop waste (not segregated).
On the floor, in a pile, or simply scattered.
Method of storage is not listed.
Facility does not generate used shop rags or towels.
1.4 Absorbents
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
absorbents for compliance with environmental requirements:
a. Does the facility determine if used absorbents are hazardous before
disposal? (p. W-16)
b. How does the facility manage/dispose of absorbents used for oil spills?
(p. W-17) ^ '
These questions appear in the following text and may be accompanied with discussions
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.
Facilities use sawdust sometimes as an absorbent in rural areas. Use proper absorbent for the
type of chemical spilled. Once used in a cleanup, dispose of these materials properly.
1.4a
Does the facility determine if used absorbents are hazardous before
disposal?
Absorbents are considered hazardous waste if: (1) they are contaminated with a
hazardous material (e.g., solvents or gasoline), or (2) they are characterized as
hazardous by the facility.
Although used oil is not considered a hazardous waste if it is recycled, it is a hazardous
waste if it is disposed of in a landfill and has hazardous characteristics. Thus, anything
that absorbs used oil and is thrown in the trash could be considered a hazardous waste
(if it exhibits a hazardous characteristic), even if it is not mixed with a hazardous waste.
For more 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.
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Q No Facility does not characterize its absorbents.
Q NA Facility does not use absorbents.
1.4b How does the facility manage/dispose of 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
DMA
Facility returns used absorbents to its supplier or pays
service company to pick up used absorbents.
Facility burns absorbents used to soak up used oil for
energy recovery in a space heater with maximum heating
capacity of less than 0.5 million BTU per hour.
Facility puts hazardous absorbents in drums, labeled as
"Hazardous Waste," and disposes of them by a
haz.ardous waste hauler.
Facility has determined 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..
1.5 Used Batteries
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 batteries for
compliance with environmental requirements:
a. Has the facility determined whether its batteries should be regulated as universal
waste or hazardous waste? (p. W-l 7)
b. If storing used batteries, does the facility protect them from storm water contact?
(p. W-l8)
c. How does the facility manage/dispose of used batteries? (p. W-T8)
These questions are repeated in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
1.5a Has the facility determined whether its batteries should be regulated
as universal waste or hazardous waste?
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these batteries may be hazardous waste (see Section 1.1) if they are not properly
handled.
Under the Universal Waste Rule (40 CFR Part 273), if batteries do not exhibit
hazardous waste characteristics (see Section 1.1), they may be under universal
wastes rules and subject to 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 universal wastes. Most alkaline
batteries are not considered hazardous waste under RCRA and one can dispose of as
general trash. Check with the local waste authority to see if they have a battery
collection program in place.
Q Yes
Q/Vo
Facility has gone through the waste determination process (as discussed in
Section 1.1) to determine whether its batteries should be regulated as
universal or hazardous waste.
Facility has not determined whether its batteries should be regulated as
universal or hazardous waste.
Q NA Facility does not generate used batteries.
1.5b If storing used batteries, does the facility protect them from storm
water contact?
When placed out-of-service, transport batteries to an accumulation area specifically
designed for storage prior to removal from the site. The storage accumulation area
should protect the batteries from weather and storms. It should have (1) secondary
containment to prevent any spillage or leakage from contaminating the soil or surface
waters; and (2) no floor drains that could receive spills and deliver them to the storm
sewer, sanitary sewer, surface water, or injection well. Store batteries inside or outside
under a tarp or roof. They can be in a pan or other device so that any leakage cannot
enter floor drains or spill onto the ground. Improper storage results in batteries being
considered "abandoned."
Q Yes Facility protects used batteries from storm water discharges.
Q No Facility does not protect used batteries 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
Q Recycle
Q Service
Facility returns used batteries to supplier.
Facility sends batteries to a recycling facility.
Facility pays service company to pick up used
batteries.
Q Universal waste handler Facility sends used batteries classified as universal
waste to a universal waste handler.
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Q Hazardous waste landfill
Q Other
Q NA
Facility sends used batteries to a hazardous waste
landfill. Facility has records of where and how many
batteries were sent.
Method of disposal is not listed here.
Facility does not generate used batteries.
1.6 Metal Scraps
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
scraps for compliance with environmental requirements:
a. Are scrap metals stored in a covered and contained area? (p. W-19)
b. How does the facility manage/dispose of scrap metal? (p. W-20)
c. How does the facility manage waste cutting oils and degreasing solvents used
in its metal machining processes? (p. W-20)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
Metal Scraps
Metal scraps may contain cutting oils, lubricating oils, and grease. Most
metal scraps have economic value and you can recycle or reclaim them.
During storage of scrap metal, place the materials in containers and
cover to prevent the release of pollutants to the ground and storm water.
There must be no free liquids present.
The major hazardous wastes from metal machining are waste cutting
oils, spent machine coolant, and degreasing solvents. However, scrap
metal also can be a component of hazardous waste produced at a
machine shop. Material substitution and recycling are the two best means to reduce the
volume of these wastes. Facilities should attempt to substitute the oils and solvents with
water-soluble cutting oils whenever possible. They should also segregate wastes carefully to
facilitate reuse and recycling.
1.6a Are scrap metals stored in a covered and contained area?
The facility should store scrap metals in a covered and contained area to prevent soil
and water contamination.
Q Yes Facility stores metal scraps in a covered and contained area.
Q A/o Facility does not store metal scraps in a covered and contained area.
Q NA Facility does not have any metal scraps.
Tip: The local
scrap metal
recycling plant
may accept
scrap metal if
sorted and
properly stored.
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1.6b How does the facility manage/dispose of scrap metal?
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.
1.6c How does the facility manage waste cutting oils and degreasing
solvents used in its metal machining processes?
Q Recycling
Q Reuse
Facility recycles waste cutting oils if nonwater-soluble oils must
be used.
Facility reuses and recycles solvents whenever possible.
Q Disposed of as Facility keeps waste cutting oils and degreasing solvents in
hazardous waste separate drums, labeled as "Hazardous Waste," and disposes of
them by a hazardous waste hauler.
Q Other
Q NA
Facility does not use one of the methods listed above.
Facility does not have any metal scraps.
[ .7 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:
^ In labefed
b. Has the facility determined if it generates any antifreeze that is a
hazardous waste? (p. W-21)
ฐ' ?ฐty 22) fac'llty reclaim used Antifreeze on site in a closed loop system?
d. If not reclaimed in a closed loop system, is the waste antifreeze counted toward
the facility generator status? (p. W-22)
e. If used antifreeze is not reclaimed on site in a closed loop system how is it
managed? (p. W-22) '
These questions are repeated in the following text and may be accompanied with
discussions of the preferred answers (indicated with a "") for environmental
compliance.
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Used Antifreeze
Water transportation 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. Minor spills should
be cleaned prior to reaching drains. Collect used antifreeze and store in separate containers.
1.7a In terms of storage, does the facility keep used antifreeze segregated
and in labeled containers?
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. One can spray paint,
crayon, stencil words or more formally labeled.
Q Yes Used antifreeze is segregated and in labeled containers.
Q No Used antifreeze is not in segregated, labeled containers.
Q NA Facility does not generate used antifreeze.
1.7b Has the facility determined if it generates any antifreeze that is a
hazardous waste?
One may characterized 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 for more information about
process knowledge.
In addition to testing and process knowledge, there are two functional indicators
that show the antifreeze is (or is likely to be) a hazardous waste. First, antifreeze is
considered hazardous if it is mixed with a hazardous waste such as certain spent
solvents. 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
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characterized as hazardous for metals content.
Q yes
Q No
Q NA
Facility has determined whether its used antifreeze is hazardous by testing
or from process knowledge.
Facility has not determined whether its used antifreeze is hazardous.
Facility does not generate used antifreeze.
1.7c 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 loop systems are also used in maintenance
shops.
Q Yes
Q No
QNA
Used antifreeze is reclaimed in a "closed loop" system.
Used antifreeze is not reclaimed in a "closed loop" system.
Facility does not generate,used antifreeze.
1.7d If not reclaimed in a closed loop system, is waste antifreeze counted
toward the facility generator status?
Waste antifreeze that is a hazardous waste and not reclaimed in a closed loop system
is included as part of the total volume of hazardous waste generated in any month.
Q Yes
a A/O
QAM
Hazardous waste antifreeze that is not reclaimed in a closed loop system is
included in the total volume of hazardous waste generated.
Hazardous waste antifreeze is not included.
Facility does not generate used antifreeze.
1. 7e If used antifreeze is not reclaimed on site in a closed loop system
how is it managed?
Q Recycled in a non-closed
system on site
Facility manages used antifreeze in a non-closed
system on site according to RCRA hazardous
waste requirements.
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Waste Management
Q Recycled off site
Q Landfill
Q Mixed with other fluids
Q UIC well
Q Other
Q MA
Used antifreeze is recycled off site. Facility has the
EPA ID number of the recycler (see the 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.
Facility mixes antifreeze with used oil, solvents, or
other fluid.
Used antifreeze is discharged into an underground
injection control (UIC) well. Note: The facility
should immediately stop this method of disposal
and notify the EPA regional and/or state UIC
authority for assistance.
Method of disposal is not listed here.
Facility does not generate used antifreeze.
1.8 PCB-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-24)
b. Does the facility inspect labeled PCB-conta/n/ng equipment quarterly? (p. W-24)
c. Does the facility store all out-of-service PCB-conta/n/ng equipment in a designated
area? (p. W-25)
d. Do trained personnel initiate cleanup of PCB leaks and spills within 24 hours?
(p. W-25)
These questions appear in the following text and may be accompanied with discussions of
the preferred answers (indicated with a "") for environmental compliance.
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Waste Management
PCB-Containing Equipment
1.8a 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
classification depends on the
concentration of PCBs in the oil.
The following are the three
classifications:
Many water 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 PCBs. Ballasts manufactured after
1979 that do not contain PCBs are labeled, "No
PCBs." Light ballasts for which no information
is known must be assumed to be PCB-
contaminated.
Non-PCB equipment (less than
50 ppm)
PCB contaminated equipment (50- 499 ppm)
PCB (500 ppm or greater).
Facilities must assess all electrical equipment for their potential to contain PCBs. If all
the electrical equipment is free of PCBs, then label all equipment as PCB-free.
Q Yes Facility has electrical equipment that contains PCBs.
Q No Facility does not have electrical equipment that contains PCBs.
Q Don't Facility has assessed electrical equipment for its potential to contain
know PCBs, and is unsure.
1.8b 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. Inspect this equipment
quarterly for leaks and to assure the labels are in place.
D Yes Facility has labeled all equipment and inspects it quarterly.
Q No Facility has not labeled all equipment or does not inspect it quarterly.
Q NA Facility does not have equipment that contains PCBs.
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1.8c Does the facility store all out-of-service PCB-containing equipment in
a designated area?
Store all PCB-containing equipment not in service and awaiting disposal in a
designated area 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. Place a 6" x 6" sign in the area indicating
"Caution: Contains PCBs." Also, place signs on all items and doorways.
Store all leaking equipment in an over-pack or suitable non-leaking container filled with
enough sorbent material to soak up all the fluid if released. Move any transformers and
other equipment with PCBs found outside of the designated area to a proper storage
area immediately.
Q Yes Facility stores all out-of-service PCB-containing equipment in a designated
area.
Q No Facility does not store out-of-service equipment in a designated area.
Q NA Facility does not have out-of-service PCB-containing equipment.
1.8d Do trained personnel initiate cleanup of PCB leaks and spills within
24 hours?
Assume all electrical equipment involved in spill or leaks to have PCBs unless sampled
and labeled to indicate otherwise. If a spill occurs, initiate a cleanup within 24 hours.
Complete your cleanups within 48 hours, regardless of the regular business hours.
Only trained person can perform all cleanups and the recordkeeping requirements must
be met.
If you observe transformer spillage and leaks, 'initiate a cleanup immediately. The
facility must develop a program and procedures to ensure that PCB equipment and
transformers are inspected for leaks. Clean up when leak occurs. 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 properly.
O No Facility does not clean up PCB leaks properly.
Q NA Facility does not have equipment that contains PCBs.
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Wastewater and Storm Water Management
SECTION 2.0 WASTEWATER AND
STORM WATER MANAGEMENT
2.1 Wastewater and Storm Water Management at
Water Transportation Facilities
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-28)
b. How is wastewater managed? (p. W-29)
c. How is storm water managed? (p. W-29)
d. Does the facility have an NPDES permit for direct discharges? (p. W-30)
*
e. Does the facility submit its monitoring results for wastewater discharges
on a Discharge Monitoring Report (DMR) form to its permitting agency?
(p. W-30)
f. Does the facility keep accurate records of monitoring information for the
minimum requirement of 3 years? (p. W-31)
g. Has the facility followed all of the reporting requirements specified by its NPDES
permit? (p. W-31)
h. Does the facility have a storm water pollution prevention plan (SWPPP)?
(p. W-32)
I. Is a certification included in the SWPPP? (p. W-32)
j. If discharging to a municipal sanitary sewer, has the facility notified the
POTW and received approval for discharges? (p. W-32)
k. If discharging to a UIC well, does the facility comply with UIC program
requirements? (p. W-33)
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.
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August 2000
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Wastewater and Storm Water Management
Wastewater and Storm Water Management
In June 1998, EPA proposed a rule applicable to
specific categories of barges and tankers called
the Transportation Equipment Cleaning
Industry Effluent Guidelines and Standards -
Proposed Rule. It establishes technology-based
effluent limitations and pretreatment standards for
the discharge of pollutants into waters of the U.S.
and into publicly-owned treatment works by
existing and new facilities that perform tank
interior cleaning. The final rule will be published
on August 14, 2000. For more information call
(202) 260-4992.
Water transportation facilities generate a
significant amount of wastewater and storm
water. Activities which may generate
wastewater include the following:
Repair and maintenance of on site
vehicles and vessels
Vehicle and equipment cleaning
Vessel cleaning
Building and grounds maintenance
Chemical storage and handling
Fueling of on-site vehicles and ^^^^^^^^^^^^^^^^^^__11^^__
vessels ^^^^^^^^^^^^^^^^^^mmt^^mmm
Painting and paint stripping
Discharges from vessel tanks storing bilge slops and sanitary wastes into on-shore
holding tanks.
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, ditch, etc. to waters of the United States. NPDES permits can be
issued by either EPA or an authorized state. As of September 1999, EPA authorized 43 states
and one territory to administer the NPDES program.
Persons responsible for wastewater discharges requiring an NPDES permit must apply for an
individual permit or seek coverage under a general permit (if available) at least 180 days
before discharge of wastewater is scheduled to begin. Some states do not allow certain
discharges into the environment.
Storm Water Discharges
Under the Clean Water Act. it is illegal to discharge any pollutants into navigable waters of the
United States from a point source unless the discharge is authorized by a National Pollutants
Discharge Elimination System (NPDES) permit. Storm water regulations have identified eleven
major categories that are associated with industrial activity (40 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.)
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Wastewater and Storm Water Management
Discharges of storm water/waste water 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 a federal requirements, the facility could be liable if it discharges a significant
amount of oil, or other fluid, and those discharges cause the POTW to violate its own NPDES
permit.
2.1a 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 is not on the inventory (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, obtain an NPDES permit.
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 receive contaminants discharges to the ground
surface, the facility must contact the state agency for applicable permitting
requirements.
Q Yes Facility can certify the final destination of all drains (e.g., storm sewer drains,
floor drains, and sanitary sewer drains).
Q A/o Facility cannot certify the final destination of all drains.
Q NA Facility does not have drains.
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Wastewater and Storm Water Management
2.1b How is wastewater managed?
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
Q Sanitary sewer
Q UIC well
Q Ground
a Other
Facility discharges effluent directly to surface waters (in
accordance with an NPDES storm water permit (see Question
2.1 d).
Facility discharges to a municipal sanitary sewer or combined
sewer with permission of the POTW (see Question 2.1J).
Facility discharges to a UIC well, generally via a floor drain
(see Question 2.1k). Although there are some exceptions, as
a general rule, discharging industrial wastewater to a UIC well
is NOT appropriate.
Facility discharges onto the ground. Wastewater may affect
groundwater or may flow into storm sewers and surface
waterways. Caution: Many states forbid the disposal of
washwater/rinsewater onto the ground.
Method of disposal is not listed.
Q NA Facility does not discharge wastewater.
2.1c How is storm water managed?
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 required by an NPDES
permit (see Question 2.1d) or by the POTW (see Question 2.1k).
D Surface water
Q Sanitary sewer
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.
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Wastewater and Storm Water Management
Q UIC well
Q Other
Q NA
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.
2.1 d Does the facility have an NPDES permit for direct discharges?
NPDES permits are required in order to discharge industrial wastewater which may
include storm water through a storm sewer or directly into surface waters. The facility
may need to treat the, wastewater on site to reduce pollutant concentrations prior to
discharge to be in compliance with NPDES permit limits. Note: Some NPDES permits
may include both wastewater and storm water discharge requirements. Other facilities
have a separate permit for each type of discharge.
Q Yes Facility has an NPDES permit.
Q No Facility does not have an NPDES permit.
Q NA Facility does not discharge wastewater directly from the facility to a body of
water.
2.1 e Does the facility submit its monitoring results for wastewater
discharges on a Discharge Monitoring Report (DMR) form to its
permitting agency?
Facilities must report monitoring results for wastewater discharges and sludge analysis
on a Discharge Monitoring Report (DMR) to the permitting authority (state or EPA).
Note: Permitting authority may provide separate forms for reporting results of monitoring
of sludge use or disposal practices.
Q Yes Facility has submitted its monitoring results for wastewater and sludge
analysis.
Q No Facility has not reported its monitoring results for wastewater and sludge
analysis.
Q NA Facility does not discharge wastewater or is not required to monitor its
wastewater discharges.
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Wastewater and Storm Water Me
2. if Does the facility keep accurate records of monitoring information for
the minimum requirement of 3 years?
It is extremely important to keep accurate records of monitoring information Records
of monitoring information generated under the NPDES program must include:
The date, exact place, and time of sampling or measurements
The individual(s) who performed the sampling or measurements
The date(s) analyses were performed
The individual(s) who performed the analyses
The analytical techniques or methods used
The results of such analyses (40 CFR 122.41).
NPDES permits require that all records related to monitoring must be maintained at the
facility for at least 3 years. Note: Many states require these records to be maintained
for at least 5 years.
Q Yes
Q No
Q NA
Facility keeps monitoring records that include all of the information listed
above and maintains them for at least 3 years.
Facility does not keep monitoring records that include all of the information
listed above and/or does not maintain them for a minimum of 3 years.
Facility does not discharge wastewater, or is not required to conduct
monitoring.
2.1g Has the facility followed all of the reporting requirements specified by
its NPDES permit?
There are some reporting requirements that apply to all facilities. These requirements
are summarized below:
Event
Reporting Time Frame
vpnri J'hnฐfthWitVKhe Permlt that Within 24 hฐurs ฐf becomin9 aware of violation; written
may endanger health or the environment submission within 5 days
Other noncompliance
Any planned physical alterations or
additions to the facility
Any planned changes in the discharge
that may result in noncompliance
Notify the permitting authority of the
transfer of the facility to a new owner
At the time the facility's monitoring reports are submitted.
As soon as possible
In advance of changes
As soon as possible
Q Yes Facility has complied with the above reporting requirements within the
required time frame.
Q No Facility has not reported the above events within required time frame.
Q NA None of the above requirements apply to the facility.
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Wastewater and Storm Water Management
2.1 h Does the facility have a storm water pollution prevention plan
(SWPPP)?
If a facility must obtain an NPDES storm water permit, it will likely be required to
prepare and implement an SWPPP. Facilities must develop SWPPPs to prevent storm
water from coming in contact with potential contaminants.
Q Yes Facility has an SWPPP.
Q No Facility does not have an SWPPP.
Q NA Facility is not required to have an SWPPP.
2.1 i Is a certification included in the SWPPP?
Each SWPPP must include a certification, signed by an authorized individual, stating
that discharges from the site have been tested or evaluated for the presence of non-
storm water discharges. The certification must include the following:
Description of possible significant sources of non-storm water,
Results of any test and/or evaluation conducted to detect such discharges,
The test method or evaluation criteria used, the dates on which tests or
evaluations were performed, and the on site drainage points directly observed
during the test or evaluation.
If certification is not feasible, the SWPPP must describe why (e.g., no access to
discharge sites).
Q Vies Facility's SWPPP includes a certification.
Q No Facility's SWPPP does not include a certification, or certification is not
feasible and facility has included an explanation in the SWPPP.
Q NA Facility is not required to have an SWPPP.
2.1 j If discharging to a municipal sanitary sewer, has the facility notified
the POTWand received approval for discharges?
Facilities should contact the POTW to see if any pretreatment requirements apply to
them. Although contacting the POTW is not a federal requirements, 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.
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Wastewater and Storm Water Management
2.1k If discharging to a UIC well, does the facility comply with UIC program
requirements?
Note: As a general rule,
the discharge of
industrial wastewaterto
UIC wells is MOT
appropriate.
Facilities that discharge industrial wastewater to
underground injection control (UIC) wells must comply with
the rules established under the UIC program. Water
transportation facilities may typically use Class V UIC wells.
Generally, Class V wells include shallow non-hazardous
industrial waste injection wells, septic systems and storm
water drainage wells. Class V UIC wells (e.g., septic "^^^^
systems, storm water drainage wells) are authorized by rule provided they do not
endanger underground sources of drinking water and meet certain minimum
requirements. UIC program requirements stipulate that facilities must submit basic
inventory information about a Class V well to the EPA or the primacy state agency. In
addition, many UIC primacy state programs have additional prohibitions or permitting
requirements. However, the fluids released by certain types of Class V wells have a
high potential to contain elevated concentrations of contaminants that may endanger
drinking water. Therefore, New requirements went into effect December 7, 1999, which
further regulate two (2) types of Class V wells, Large Capacity Cesspools and Motor
Vehicle Waste Disposal Wells. Note: See below for information relating to EPA's New
rule regarding Class V wells.
Q Ves 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.
New Rule for Regulating Class V Wells
EPA is further regulating two (2) types of UIC Class V wells in Source Water Protection Areas for
community and non-transient non-community water systems that use groundwater as follows:
Large-Capacity Cesspools. New cesspools are prohibited nationwide as of April 5, 2000 and
existing cesspools will be phased out nationwide by April 5, 2005.
Motor Vehicle Waste Disposal Wells. New wells are prohibited nationwide as of April 5, 2000
Existing wells in regulated areas will be phased out, but owners and operators can seek a waiver
and obtain a permit. For more information about this New rule, contact the SDWA Hotline at 1-
800-426-4791.
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Waste water and Storm Water Management
2.2 Activities Generating Wastewater and/or Storm
Water
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 activities
generating wastewater and/or storm water for compliance with environmental
requirements:
a. How does the facility clean the floors and surrounding areas? (p. W-34)
b. If the facility stores materials outside, are they protected from contact with
storm water? (p. W-35)
c. Does the facility have activities (e.g., metal finishing) that are subject to
categorical pretreatment standards? (p. W-35)
d. If yes, is the facility in compliance with the categorical standards for the
processes?
(p. W-36)
These questions appear in the following text and may be accompanied with discussions
of the preferred answer (indicated with a "") for environmental compliance.
Activities Generating Wastewater and Storm Water
Many facilities wash vessel and equipment at water transportation facilities, including the
cleaning of vehicles. Various cleaning agents can be used, including steam/pressure water,
surfactants (soap), and chemical solvents.
All states have requirements for washwater. Waste washwater may contain pollutants
depending on the type of materials being washed and the washing agents used. Be sure to
check with the state and/or federal regulatory agency for more information.
2.2a How does the facility clean the floors and surrounding areas?
Q Dry Cleanup Facility uses "dry methods" such as dry mop, broom, rags,
absorbents, etc., thus reducing generation of contaminated
wastewater. See box below.
Water
Facility uses a hose or wet mop, thus generating wastewater.
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Wastewater and Storm Water Management
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 a liquid
While cleaning. Soak up the liquid and containerize. 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 something still on the floor, clean it up with soap and water.
2.2b If the facility stores materials outside, are they protected from contact
with storm water?
A facility may need to store materials, including drums, trash, and parts, outside of
facility buildings. It should protect these materials from contact with storm water
(including rain or snow) or other forms of water (e.g., washing overspray). To prevent
contact with storm water, materials can be stored on pallets (or something else that
keeps them off the ground) and covered them by a tarp or roof. Close dumpsters so
that storm water will not enter or exit the dumpster. 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.
D Yes Materials are protected from rain/snow.
O No Materials are not protected from rain/snow.
Q NA Facility does not store materials outside.
2.2c Does the facility have activities (e.g., metal finishing) that are subject
to categorical pretreatment standards?
Under the Clean Water Act,
categorical standards (also known as
effluent limitation guidelines) are
established for specific types of
categories of industries or processes.
For example, if a trucking facility
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 that are
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 whether it goes directly to surface water or to a municipal
wastewater treatment plant.) For more information, contact the POTW or state
permitting agency.
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Wastewafer and Storm Water Management
Q Vies 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.
2.2d If yes, is the facility in compliance with the categorical standards for
the processes?
A state or POTW permitting agency will incorporate applicable categorical standards
into the facility's NPDES or POTW permit.
Q Yes Facility is in compliance with applicable categorical standards.
Q No Facility is not in compliance with applicable categorical standards.
Q NA Facility does not conduct any operations or processes that are subject to
categorical standards.
2.3 Sludge Management
NOTE: The following question is included in the accompanying checklist to help the facility
examine its operations relating to sludge management for compliance with
environmental requirements:
How does the facility manage the sludge from an oil/water separator?
(p. W-36)
This question appears in the following text and is accompanied with a discussion of the
preferred answers (indicated with a "") for.environmental compliance.
2.3 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, test the contents of the grit chamber and the oily sludge for hazardous
constituent. If the sludge exhibits any characteristic of a hazardous waste, it should be
handled as such. If the sludge is nonhazardous, managed it as a used oil. On-site
disposal of nonhazardous sludge is not allowed unless covered by state and/or local
permits.
Q Off-site disposal
as hazardous waste
Q Off-site disposal
to other facility
Facility disposes of hazardous sludge off site. It is stored,
manifested, transported, and disposed of in compliance with
all provisions of RCRA, including using a permitted TSDF.
Facility disposes of nonhazardous sludge off site.
Disposal is arranged using an approved transportation,
treatment, and disposal facility.
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Q On-site disposal
Q Landfill
Q Other
Q NA
Facility disposes of nonhazardous sludge on site arid has the
required state and/or local permits.
Facility improperly landfills its oil/water separator sludge.
Method of management is not listed.
No sludge is produced.
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Dockside Maintenance and Repair
SECTION 3.0 DOCKSIDE MAINTENANCE
AND
REPAIR ACTIVITIES
Vessel maintenance is one of the maritime industry's major environmental concerns. The
major waste streams are chemical paint stripping wastes, abrasive blast and surface
preparation wastes, painting and painting equipment cleaning wastes, solvent wastes, and
engine overhauling and repair wastes.
Engine repairs and other types of vessel repairs are usually done while ships or barges are
tied up to a pier or are in a dry dock, unless, of course, they are done at sea. Engine repairs
may vary from small automotive-type engines of smaller vessels to repairs on large boilers and
turbines of tankers or other cargo vessels. Typical wastes from engine repair shops include
solvents, waste turbine oils, and batteries. Other repairs may include sheet metal work, metal
finishing, or other specialty operations.
3.1 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 off loading for compliance with environmental requirements.
a. If hazardous materials are loaded at the facility, are containers inspected
for (1) proper labeling/placarding, (2) signs of leakage, and (3)
compatibility with other hazardous materials? (p. W-39)
b. Does the facility immediately respond to leaks and spills of hazardous materials
during loading and off-loading activities? (p. W-39)
c. Has the facility taken steps to control dust and air emissions? (p. W-39)
d. Is the facility familiar with requirements under the Final Rule for Marine
Tank Vessel Loading Operations? (p. W-40)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
Cargo Loading and Off Loading
Cargo loading and off loading includes all activities associated with the movement of materials,
items and people in and out of vessels. Cargo loads may consist of several different items,
including but not limited to passengers, baggage, 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 environment is the loading and off loading of hazardous materials.
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3.1 a
If hazardous materials are loaded at the water transportation facility,
are containers inspected for (1) proper labeling/placarding, (2) signs
of leakage, and (3) compatibility with other hazardous materials?
Transport of hazardous material is under the Department of Transportation (DOT) rules.
Hazardous waste transportation is jointly regulated by DOT and EPA. It is important to
ensure that you use 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 Y"es
During loading, Facility inspects containers and all required paperwork is
completed.
Q No Facility does not inspect hazardous material containers on a regular basis.
Q NA Facility does not handle hazardous cargo.
3.1b Does the facility immediately respond to leaks or spills of hazardous
materials during loading and off-loading activities?
Though a rare occurrence, leaks or spills that occur during loading/offloading activities
have the potential to contaminate soil, groundwater, or surface water. Facilities
minimize and control these impacts through development and implementation of
emergency response programs. See Section 5.0 for more information about
emergency response programs.
D Yes Facility takes immediate action.
Q No Facility does not take Immediate action.
Q NA No spills of hazardous materials have occurred.
3.1c Has the facility taken steps to control dust and air emissions?
Both dry and liquid bulk-transfer operations generate hazardous air emissions either as
dust generated when cargo is transferred or hydrocarbon emissions which are readily
converted into photochemical smog by ultraviolet radiation from the sun. A facility can
reduce dust emissions by pneumatic conveyors and slurry pipelines. Additional steps
to control air emissions include enclosing the conveyor transfer points in the buildings
using steam or spray as a sealant over the open end of the hopper, placing the loading
chute as close as possible to the cargo pile in the hold, and installing telescoping
chutes which eliminate the need for slingers.
Q Yes Facility has taken steps to control dust and air emissions.
Q No Facility has not taken steps to control dust and air emissions.
Q NA Facility does not handle cargo.
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3.1 d Is the facility familiar with requirements under the Final Rule for
Marine Tank Vessel Loading Operations?
Under authority of the Clean Air Act Amendments (CAAA), EPA issued a final rule to
reduce emissions of air toxics and volatile organic compounds (VOC) that result from
marine tank vessel loading operations (40 CFR Part 63, Subpart Y). Specifically, the
rule requires that:
Terminals with an annual marine bulk loading throughput greater than or equal to 10
million barrels per year of gasoline or 200 million barrels of crude oil apply reasonably
available control technology (RACT) to control emissions of VOCs and HAPs resulting
from the loading of gasoline or crude oil;
Facilities not subject to RACT but which have HAP emissions exceeding 10 tons of
one or 25 tons or more of aggregate HAPs be subject to the NESHAP and required to
apply maximum achievable control technology (MACT);
Facilities controlling loading emissions under RACT or MACT using a combustion
device operate the device at 98% efficiency; and
Facilities controlling loading emissions under RACT using a recovery device operate
the device at 95% efficiency or, for gasoline vapors, reduce the control device outlet
concentration to 1,000 parts per million or less. In addition, vessels which load at a
facility affected by this provision must pass one or two vapor tightness tests or be
loaded at less than atmospheric pressure.
The rule also contains specific monitoring, recordkeeping and reporting requirements.
Q Yes Facility is aware of the requirements under the rule.
Q No Facility is not aware of the requirements under the rule
Q NA Facility does not meet any of the criteria listed above.
3.2 Painting and 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
and paint removal operations for compliance with environmental requirements.
a. Does the facility conduct painting/paint removal operations? (p. W-41)
b. Does the facility have any air permits? (p. W-41)
c. Does the facility meet air permit conditions? (p. W-42)
d. Does the facility prepare surfaces to be painted by shot or grit blasting,
grinding, or sanding? (p. W-42)
e. If yes, are surfaces and paints tested for asbestos and lead? (p. W-42)
f. Does the facility collect paint chips and metal dusts? (p. W-43)
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g. How does the facility manage/dispose of paint stripping wastes and
baghouse dusts? (p. W-43)
h. Does the facility use low VOC paints in its painting operations? (p. W-43)
I. Does the facility mix paint amounts according to need? (p. W-44)
Does the facility take measures to minimize overspray? (p. W-44)
in use, does the facility store paints in labeled containers?
j.
k.
(p. W-44)
I.
How does the facility manage/dispose of used paints and painting waste
m. How does the facility dispose of spray paint booth air filters? (p. W-46)
These questions appear in the following text and may be accompanied with discussions of
the preferred answers (indicated with a V") for environmental compliance.
Painting and Paint Removal Operations
Painting a vessel and dockside facilities to improve appearance and performance and to
prevent corrosion and marine organism growth is an important maintenance practice. Prior to
applying new paint, however the facility must clean the surface and remove old paint. Facility
usually use chemical paint stripper to remove the old paint. The most common strippers are
based on methylene chloride, although the industry increasingly is using less toxic agents such
as dibasic esters, semi-aqueous terpene-based products, aqueous solutions of caustic soda
and detergent-based strippers that are currently available on the market. Another option is
abrasive blasting. Blasting is used primarily because the blasting medium is not hazardous- it
may be garnet flint grit, or steel shot.
3.2a Does the facility conduct painting/paint removal operations?
Facility may do their painting in specific areas such as paint booths. Note: The facility
should verify that there are no drains in the areas where painting occurs.
Q Ves Facility conducts painting/paint removal operations.
Q No Facility does not conduct painting/paint removal operations.
3.2b Does the facility have air permits?
States typically issue air pollution permits for certain operations such as painting and
surface preparation if certain state regulatory criteria are met. Generally if air pollution
control equipment is used, such as a baghouse or scrubber, a state requires a permit.
Check with the state for specific criteria and requirements.
Q Yes Facility has air permits and they are current.
Permit No(s).:
Q No Facility has not obtained air permits.
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Q NA Permits are not required.
3.2c Does the facility meet air permit conditions?
Q Yes Facility is meeting ail air permit conditions.
Q No Facility is not meeting air permit conditions.
Q NA Permits are not required.
3.2d Does the facility prepare surfaces to be painted by shot or grit
blasting, grinding, or sanding?
In preparation for painting, a
facility may remove old paint on
vessels and support vehicles
by shot or grit blasting.
Grinding and sanding are often
used to prepare the surface to
be painted.
Tip: If using chemical strippers containing hazardous
pollutants, be sure the facility is meeting air quality
standards. Contact the local air pollution control
agency for more information about air quality
requirements.
Q Yes 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.
3.2e If yes, are surfaces and paints tested for asbestos and lead?
If a facility uses shot or grit blasting, grinding, or sanding to remove old paint, then test
the surfaces and paints for asbestos and lead.
Q Yes Facility tests surfaces and paints for asbestos and lead.
Q Wo 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.
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3.2f Does the facility collect paint chips and metal dusts?
An effective practice to assure the optimum collection of paint dusts and chips is to
blast and sand within a booth or enclosure designed with dust collection ventilation and
air pollution control devices (e.g., baghouse). Conducting operations indoors without
dust collection and air pollution controls may expose employees to levels of airborne
dust in excess of the OSHA permissible limits for personal exposure to metals, such as
lead and cadmium. Conducting operations outdoors can allow dusts and paint debris
to be dispersed into the environment but local and state air pollution regulations 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.
3.2g How does the facility manage/dispose of paint stripping wastes and
baghouse dusts?
All materials collected from shot and grit blasting and sanding/grinding operations may
potentially be hazardous waste, depending on the previous paint coatings. If the
previous paints contained lead or chromium, the waste chips and dusts may be
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 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.
3.2/7 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.
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Q NA Facility does not have painting operations.
3.27 Does the facility mix paint amounts according to need?
Mix paint by the job, as opposed to in large batches, thus reducing potential paint
waste.
Q Yes Facility mixes paint by the job.
Q No Facility mixes paints in large batches.
Q NA Facility does not have painting operations.
3.2y 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 be labeled 'HVLP' on the
gun. This is not yet a federal regulatory requirement. (Note: Required in some states.)
Q Yes Facility takes measures to minimize overspray.
Q No Facility does not take measures to minimize overspray.
Q NA Facility does not have painting operations.
3.2k When not in use, does the facility store paints in labeled containers?
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. Container 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.
3.2/ How does the facility manage/dispose of used paints and painting
waste products?
Facilities should not bury or discard waste paint cans, residuals, or unused paint
products on site. Organic solvent-based paints and residuals may be hazardous waste
and may require manifesting, storage, transportation, and disposal in full compliance
with RCRA. Recycle paint cans (that once contained hazardous waste) that are
classified as "empty" by the RCRA definition. Recycle latex paints or dispose of them
off site at an approved facility as nonhazardous waste.'
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A container is considered "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 nonhazardous solid waste
for off-site disposal.
Q Return to supplier
Q Reuse
Q Recycle
Q On-site disposal
Q Mix with other fluids
Q Landfill
Q Drain
Q Other
Q NA
Facility returns all unused paints and thinners to the
supplier.
Facility gives away leftover paints and thinners to
customers, employees, or at "paint swaps."
Facility sends items to a paint, solvent, or thinner recycler.
(Generally this will apply to solvents or thinners.)
Facility disposes of paint wastes and residues on site.
Facility mixes materials with other fluids (solvent, used
oil).
Based on characterization, facility disposes materials at a
municipal or hazardous waste landfill.
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.
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3.2m How does the facility dispose of spray paint booth air filters?
Facility must dispose of filters containing hazardous paints 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.
3.3 Facility Renovation/Demolition - Asbestos
Concerns
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. Has the facility assessed all buildings and structures built prior to 1980 for their
potential for containing asbestos and treated accordingly? (p. W-46)
b. Does the facility document demolition procedures? (p. W-47)
c. Has the facility inform employees of buildings and structures containing
asbestos and trained them to work on asbestos-containing material (ACM)?
(p. W-47)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
3.3a 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 one assesses 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,
one must assume the materials potentially containing asbestos unless bulk sampling
reveals otherwise. A certified inspector must perform the asbestos inspections
according to AHERA guidelines.
NOTE: EPA's asbestos NESHAP (40 CFR Part 61 subpart M) requires a thorough
inspection for the presence of asbestos prior to a demolition or renovation. It is
generally expected that this inspection will require sampling regardless of the date of
construction of the facility. The definition of facility includes ships.
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A facility must use state-licensed contractors, transporters, and disposal sites. If
demolition is planned, assure that the asbestos materials are removed prior to start of
the demolition. In addition, notify local, state, and federal agencies at least 10 days
before the abatement, demolition, or certain renovation activities begin.
Q Ves Facility has assessed all buildings built prior to 1980 for asbestos.
Q A/o Facility has not assessed all buildings built prior to 1980 for asbestos.
Q NA Facility has no buildings built prior to 1980.
3.3b Does the facility document demolition procedures?
Q Ves Facility documents all demolition procedures.
Q No Facility does not document demolition procedures.
Q NA Facility has determined that asbestos is not present in any of the buildings.
3.3c Has the facility inform employees of buildings and structures
containing asbestos and trained to work with asbestos-containing
material (ACM)?
Inform all employees that may encounter asbestos-containing materials (ACM) of its
existence. In particular, inform all employees who perform repairs, maintenance, and
custodial activities. In addition, train employees on how to follow proper procedures on
the proper use of protective equipment, and the use of control measures if their work
can disturb asbestos-containing material and release fibers.
Q Ves 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.
3.4 Air Conditioning Maintenance
NOTE: The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to air
conditioning maintenance for compliance with environmental requirements.
a. Does the facility maintain and/or repair CFC-containing equipment? (p. W-48)
b. Are CFC-containing equipment maintain by certified technicians?
(p. W-48)
c. Are certificates on file? (p. W-48)
d. Does the facility remove all CFCs from equipment prior to maintenance
activities? (p. W-49)
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e. Is CFC recovery and/or recycling equipment EPA approved? (p. W-49)
f. Does the facility have documentation that refrigerants from recovery
equipment are sent to an EPA-approved reclaimer? (p. W-50)
g. Does the facility repair leaks of appliances containing ozone-depleting
refrigerants in a timely manner? (p. W-50)
h. How does the facility manage appliances containing ozone-depleting
refrigerants?
(p. W-50)
I. Has the facility ensured that its CFCs have been legally purchased? (p. W-51)
These questions are repeated in the following text and may be accompanied with
discussions of the preferred answers (indicated with a V") for environmental
compliance.
Air Conditioning Maintenance
As of July 1, 1992, it became unlawful for any person maintaining, servicing, repairing, or
disposing of any appliance or industrial refrigeration to knowingly vent, release, or dispose of
any ozone-depleting substance [e.g., chlorofluorocarbons (CFCs)] to the environment. For a
list of ozone-depleting substances, contact the Stratospheric Ozone Information Hotline at
1-800-296-1996.
3.4a Does the facility maintain and/or repair CFC-containing equipment?
The most common CFC-containing equipment maintained and repaired at a water
transportation facility includes building and 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.
3.4b Is CFC-containing equipment maintained by certified technicians?
Technicians that perform a service that may release refrigerant must have EPA
approved training and certification. Each technician must have his/her own
certification. Certificates must be posted at the place of business (40 CFR Part 82).
Q Ves Technicians are certified.
Q No Technicians are not certified.
Q NA Facility does not maintain CFC-containing equipment.
3.4c Are certificates on file?
Q Yes Technicians' certificates are on the wall, in a file, or in their wallet.
Q No Technicians' certificates are not on file.
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Q NA Facility does not maintain CFC-containing equipment.
3.4d Are all CFCs removed from equipment prior to maintenance
activities?
Certified technicians should perform equipment repairs that would release CFCs only
after the refrigerants are removed and collected.
D
Q No
Facility removes and collects CFCs from equipment prior to maintenance
activities.
Facility does not remove or collect CFCs from equipment prior to
maintenance activities.
Q NA Facility does not maintain and/or repair CFC-containing equipment.
3.4e Is CFC recovery and/or recycling equipment EPA approved?
Technicians repairing or servicing air conditioners and other CFC-containing equipment
can only use recovery and/or recycling equipment that is approved by EPA. Currently,
EPA has approved both the Air-Conditioning and Refrigeration Institute (ARI) and
Underwriters Laboratories (UL) to certify recycling and recovery equipment. Certified
equipment 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 .
D No Equipment does not have "ARI / UL approval".
Q NA Facility does not maintain and/or repair CFC-containing equipment.
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3.4f Does the facility have documentation that refrigerants from recovery
equipment are sent to an EPA-approved reclaimer?
Facilities that use recovery equipment must provide documentation that they send the
refrigerant to an EPA-approved reclaimer.
Facility maintains documentation that they send refrigerants to an EPA
approved reclaimer.
Q yes
a NO
a NA
Facility does not maintain documentation where they send refrigerants.
Facility does not maintain and/or repair CFC-containing equipment.
3.4g Does the facility repair leaks of appliances containing ozone-
depleting refrigerants in a timely manner?
If the facility's appliances (e.g., air conditioners, refrigerators) contain 50 or more
' pounds of refrigerant, the facility must repair leaks in a timely manner and maintain
records of those repairs. See Question 5.2b for recordkeeping requirements.
Q 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.
3.4/i How does the facility manage appliances containing ozone-depleting
refrigerants?
Q Landfill
Q Waste hauler
Q Scrap metal
recycler
Q Other
Facility disposes of appliances containing ozone-depleting
refrigerants in a landfill that contains refrigerant-recovery
equipment.
Facility has waste hauler pick up appliances. Waste hauler has
refrigerant-recovery equipment.
Facility sends appliances to scrap metal recycler that has
refrigerant-recovery equipment.
Method of disposal is not listed.
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3.4i Has the facility ensured that its CFCs have been legally purchased?
Warning: If an individual knowingly buys or
possesses CFCs smuggled into the United
States, that person is committing a
punishable, criminal offense and could face
severe penalties. For more information
regarding CFCs and enforcement actions
under the Clean Air Act (CAA), all EPA's
Stratospheric Ozone Protection Hotline at
1-800-296-1996.
When purchasing legal CFCs, the
facility should know where the specific
brand was produced and the name of
the manufacturer. Before purchasing
CFCs, 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. The facility should also ensure that the packaging for the material is
appropriate. Illegally imported refrigerant is sometimes packaged in wrong size
containers or fixed with improper values. Remember, if an individual purchases or
possesses CFCs that entered the United States illegally, the U.S. Customs Service
can confiscate the product. Other potential consequences of purchasing or
possessing illegal CFCs include becoming the subject of an investigation by the
Customs Service, EPA, and the Internal Revenue Service (IRS) (e.g., to audit the
facility regarding payment of excess taxes on CFCs).
Q Ves Facility has ensured that CFCs have been legally purchased.
Q No Facility has not ensured that CFCs have been legally purchased.
Q NA Facility has not purchased CFCs.
3.5 Fueling Operations
NOTE: The following question is included in the accompanying checklist to help the facility
examine its fueling operations for compliance with environmental requirements:
Does the facility use overfill protection measures, spill containment methods
and spill response equipment during fueling? (p. W-52)
This question appears in the following text and is accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Fueling Operations
Air and water pollution resulting from fuel spillage are the major environmental concerns
associated with water transportation facility fueling operations. Fueling vessel of any size can
discharge oil and petroleum wastes into water bodies through spills. Fuel emissions from this
type of fueling introduces pollutants into the air. However, one can substantially reduce
possible accidental spillage by maintaining fuel tanks, lines, and fueling systems.
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3.5 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.
a NA
Facility does not have fueling operations.
3.6 Equipment Cleaning and Spent Solvents
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 equipment cleaning and spent solvents for compliance with environmental
requirements.
a. Does the facility clean equipment? (p. W-53)
b. What kind of cleaning agents does the facility use to conduct equipment
cleaning? (p. W-53)
c. Does the facility keep the lids of solvent cleaning equipment closed? (p. W-54)
d. If halogenated solvents are used in cleaning equipment, has the facility
submitted a notification report to the air permitting agency? (p. W-54)
e. Does the facility store spent solvents in labeled containers? (p. W-55)
f. How does the facility manage/dispose of its spent solvents? (p. W-55)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
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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.
Equipment Cleaning and Spent Solvents
A facility may conduct various kinds of equipment
cleaning using solvents. Wastes generated from
equipment cleaning include sludge, wastewater, and
spent chemical solvents. A facility 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 must follow EPA waste management
regulations for "waste" or "spent" solvents (i.e., those
that have been generated as wastes). Solvents that
are currently being used, such as in a parts cleaning
sink, may be under EPA air regulations, but are not
regulated under RCRA since they are not yet a waste.
3.6a Does the facility clean equipment?
A water transportation facility may conduct different kinds of equipment cleaning.
* Large scale equipment cleaning typically involves the cleaning of vessels 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 No Facility does not conduct equipment cleaning.
3.6b What kind of cleaning agents does the facility use to conduct
equipment cleaning?
A facility can use various cleaning agents 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
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3.6c 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.
3.6d If halogenated solvents are used in cleaning equipment, has the
facility submitted a notification report to the air permitting agency?
Although most water transportation 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 i 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 Yes Facility has submitted a notification report.
Q No Facility has not submitted a notification report.
Q NA Facility does not use halogenated solvents to conduct equipment cleaning.
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3.6e 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. 9 ' P
A faci!!ty st use labeled Containers for spent solvents that are hazardous
/ t?n,sported for dlsPฐsal' Note: Solvents that are in a parts washer do not
Q Yes
a NO
Q NA
Facility stores spent solvents in labeled containers.
Facility does not store spent solvents in labeled containers.
Facility does not use solvents at the facility.
3.6f How does the facility manage/dispose of its spent solvents?
If a facility does not use a vendor for disposal, the facility must classify the spent
matena s and sludges as either nonhazardous or hazardous waste. If the spent
matenals are hazardous, they should be in separate container and not mixed in with
mTrSS rfT W3SteS fCh 3S US6d ฐils- A" ^dous waste should be stored
S ^nSP ,f 3nd disPฐsed of in fL<ป compliance with RCRA. Use treatment
storage, and d.sposal facilities (TSDFs) for disposal of hazardous waste.
Q Third party vendor 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.
Q Storm sewers or
surface waters
Q Sanitary sewer
Q UIC well
Q Ground
Q Other
HNA
Facility has obtained an NPDES permit to discharge
nonhazardous waste to storm sewers or to surface waters, v
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: Many states forbid
the disposal of hazardous spent solvents on the ground.
Method of disposal is not listed.
Facility does not generate spent solvents or sludge.
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3.7 Disposal of Dredge and Fill Material
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. Is the facility performing any construction activities that may generate dredge
and fill materials? (p. W-56)
b. If yes, are dredge and fill materials being disposed of or placed in waters of the
United States, which include wetlands? (p. W-57)
c. If yes, is the facility in compliance with Section 404 permit requirements?
(p. W-57)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
Dredge and Fill Material
The construction of new water transportation facilities often involves dredging (i.e., the removal
of materials such as sand, silt, and clays) in an existing navigation channel. Maintenance
dredging is performed periodically to remove bottom sediment that has been naturally
deposited through time. Activities such as soil remediation, demolitions, and new building,
pier, road, or utility construction generally produce large amounts of dredged or fill material. If
the placement or disposal of dredged material takes place in waters of the United States,
including wetlands, the facility needs to apply for a Section 404 permit.
Note: If discharging dredge and fill
material into the ocean, see Section
6.2 for more information about the
Marine Protection, Research, and
Sanctuaries Act.
Section 404 Permit Program. Dredged and fill
material discharged into waters of the United States,
including wetlands, are regulated under Section 404 of
the Clean Water Act (if into inland waters) and under
Section 103 of the Marine Protection, Research, and
Sanctuaries Act (if into the ocean). Section 404 of the
Clean Water Act establishes a permit program to
prevent discharge of fill material from regulated
activities if a practicable alternative exists. The U.S. Army Corps of Engineers (Corps) is the
federal agency responsible for administering and enforcing the program including individual
permit decisions and jurisdictional determinations. However, some States have approved
Section 404 programs and issue these permits themselves. The EPA establishes guidelines
used in evaluating activities regulated under Section 404 and also enforces its provisions.
Jointly, the EPA and the Corps designate areas for the placement or disposal of dredged and
fill materials.
3.7a Is the facility performing any construction activities that may generate
dredge and fill materials?
Q Vies Facility is performing construction activities that may generate dredge and fill
materials.
Q A/o Facility is not performing construction activities that generate dredge and fill
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materials.
3.7b If yes, are dredge and fill materials being disposed of or placed in
waters of the United States, which include wetlands?
Q Yes Facility generates dredged or fill materials, and they are disposed of or
placed in waters of the United States, which include wetlands.
Q No Facility generates dredged or fill materials, and they are not disposed of or
placed in waters of the United States, which include wetlands.
Q NA Facility discharges dredge and fill materials to the ocean.
3.7c If yes, is the facility in compliance with Section 404 permit
requirements?
The facility can comply with Section 404 permit requirements by doing the following:
1. If discharging dredged or fill material to a wetland, identify if the wetland is
subject to the Section 404 permit program. The EPA and the Corps use a
guidance manual, the 1987 Corps of Engineers Wetlands Delineation Manual,
and a 1992 technical supplement to identify wetlands subject to the Section 404
program. Contact the Corps for a wetland delineation if there are any questions
regarding whether an activity is within a regulated wetland area.
2. Apply for an individual or general Section 404 permit. If the facility is
carrying out a major project, contact the Corps district office closest to the
facility or the state regulatory agency (if Section 404 permit program has been
delegated to the state) for a pre-application consultation and complete an
individual permit. A Section 404 permit application is processed at the same
time by federal, state and local agencies, and a permit will not be granted
without a certification from the affected state(s). General Section 404 permits
are issued on a nationwide, regional, or statewide basis to facilities whose
discharge of dredged or fill materials is determined to have minimal adverse
environmental effects. This latter permit is issued for particular categories of
activities (e.g., minor road crossings, utility line backfill and bedding) and
expedites the permitting process.
Q Yes Facility is in compliance with Section 404 permitting requirements.
Q No Facility is not in compliance with Section 404 permitting requirements.
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3.8 Pesticides
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 pesticides only as directed by their labels? (p. W-58)
b. Are restricted use pesticides (RUPs) applied only by a certified
commercial applicator? (p. W-59)
This questions appear in the following text and may be acc.ompanied with a discussion
of the preferred answers (indicated with a V") for environmental compliance.
Pesticides
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 under direct supervision can purchase and apply restricted
use pesticides (RUPs). Pesticide labels will clearly state whether a particular pesticide is
classified as restricted use only. For a list of state FIFRA/Pesticide contacts, refer to EPA's
website at http://www.transource.org/Shared_Files/fifrah1.html.
3.8a Does the facility apply pesticides only as directed by their labels?
Q Yes
Q No
Q 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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3.8b 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 Vies Facility uses certified applicators to apply RUPs.
D No Facility does not use certified applicators to apply RUPs.
Q NA Facility does not apply RUPs.
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Storage Tanks and SPCC
SECTION 4.0 STORAGE TANKS AND
SPILL PREVENTION CONTROL AND
COUNTERMEASURES
4.1 Underground Storage Tanks (USTs)
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 underground storage tanks for compliance with environmental
requirements.
a. Has the facility notify State/Tribe UST program office of any USTs located
on site? (p. W-61)
b. Does the facility conduct leak detection for tank and piping of all on site
USTs? (p. W-61)
c. Do USTs at the facility meet requirements for spill, overfill, and corrosion
protection? (p. W-62)
d. Does the facility maintain records of leak detection; spill, overfill, and
corrosion protection; corrective actions; closure; and financial
responsibility? (p. W-62)
e. Does the facility report suspected/actual leaks to its state/tribal UST regulatory
authority? (p. W-63)
These questions appear in the following text and may be accompanied with
discussions of the preferred answers (indicated with a "") for environmental
compliance.
Underground Storage Tanks
Many water transportation facilities have
underground storage tanks (USTs) to
supply fuel for vessels, trucks, or other
vehicles. Facilities 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
4.1e 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/.
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wherel h el? ' HฐtS d? n0t CฐVeL Sฐme USTS (e'9" tanks Stฐring heatin9 oil used on
where it is stored, tanks on or above the floor of underground areas, such as basements or
tunnels, emergency spill and overflow fill tanks); however, state, tribal, or local regulatory
agency may regulate such USTs. Be sure to ask the state, tribal, or local regulatory agencies
to rind out if additional or more stringent requirements apply to the facility.
4.1 a Has the facility notify State/Tribal UST program office 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
SSL I0*'0"' and financial responsibility for UST systems installed after December
^, 1988. For more information on how to obtain and complete the form call EPA's
RCRA/UST, Superfund, and EPCRA Hotline at 1-800-424-9346
Q yes
Q No
Q NA
Facility has submitted a notification form to the responsible state/tribal
UST program office.
Facility has not submitted a notification form to the responsible
state/tribal UST program office.
Facility has no USTs.
4.1b Does the facility conduct leak detection for tanks and piping of all on-
site c/o is?
Facilities with federally regulated UST systems must conduct leak detection A facility
may use the monthly monitoring methods to conduct leak detection of tanks They
include the following: '
Automatic tank gauging
Monitoring for vapors in soil.
Interstitial monitoring
Groundwater monitoring
Statistical inventory
reconciliation
Other methods approved by
the regulatory authority.
Note: Facilities with USTs may use inventory
control and tank tightness testing instead of one of
the monthly monitoring methods for a maximum
of 10 years after the tank is installed or upgraded
with corrosion protection (40 CFR 280.41). Call
the RCRA/UST, Superfund, and EPCRA Hotline
at 1-800-424-9346 for more information.
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
Check with the State/Tribal UST program to determine which leak detection methods
the state accepts.
Q Yes
Facility conducts at least one leak detection methods described above.
S
Q No
D NA
Facility does not conduct leak detection.
Facility does not have any federally regulated USTs.
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4.1 c
Do USTs at the facility meet requirements for spill, overfill, and
corrosion protection?
Now that the December 22, 1998 deadline for
ail LIST systems has passed, owners and
operators of facilities that continue to operate
UST systems not meeting the federal
requirements for leak detection, and spill,
overfill, and corrosion protection are out of
compliance. Besides posing a threat to human
health and the environment, such operation can
subject the owner/operator to considerable
fines.
Facilities must operate all USTs
subject to federal regulations to
ensure that spills or overflows do not
cause releases into the environment.
Facility owners and operators had
until December 22, 1998, to make
certain that all UST systems met the
federal requirements for leak
detection, and spill, overfill, and
corrosion protection in accordance
with the provisions of 40 CFR Part ^^^^^^-^^-a^-
280. Owners of noncompliant USTs
may close the UST temporarily for up to 12 months (December 22, 1999), as long as
(1) the facility continues to monitor for leaks by maintaining the UST's leak detection
and corrosion protection system; and (2) if temporarily closed for more than 3 months,
the UST must have vent lines open, but all other lines must be capped and secured.
After 12 months of temporary closure, the facility must permanently close the UST. To
find out more about federal UST requirements, call EPA's RCRA/UST, Superfund, and
EPCRA Hotline at 1-800-424-9346. Check with the state and local regulatory
agencies to find out if there are additional or more stringent state and/or local UST
requirements.
Facility has spill, overfill, and corrosion protection devices.
Facility does not have protection devices installed.
Facility does not have any federally regulated USTs.
a
a
a NA
Recordkeeping
4.1 d 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. Keep these records 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 UST records as described above.
Q No Facility does not maintain all UST records.
Q NA Facility does not have USTs.
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4.1 e Does the facility report suspected/actual leaks to its state/tribal UST
regulatory authority?
The facility must report suspected and actual leaks to its state UST regulatory authority
within 24 hours. After reporting a suspected release, the facility must immediately
investigate and confirm such a release. Check with the state/tribal regulatory agency
for additional requirements.
Q Vies Facility reports suspected/actual leaks to its state/tribal UST regulatory
authority.
Q No Facility does not report suspected/actual leaks to its state/tribal UST
regulatory authority.
Q NA Facility does not have USTs.
4.2 Aboveground 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
aboveground storage tanks for compliance with environmental requirements.
a. Does the facility have aboveground storage tanks (ASTs)? (p. W-63)
b. Do ASTs meet or exceed NFPA 30A requirements? (p. W-64)
c. Does the facility inspect ASTs on a periodic basis for leaks or other
hazardous conditions? (p. W-65)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Aboveground Storage Tanks (ASTs)
4.2a Does the facility have aboveground storage tanks (ASTs)?
Q Yes Facility has ASTs.
Q No Facility does not have ASTs.
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4.2b Do ASTs meet or exceed NFPA 30A requirements?
If the facility has a marine service station, all ASTs at the facility 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 marine service station as " where liquids used as fuels are stored and
dispensed from equipment on shore, piers, wharves, or floating docks into the fuel
tanks of self-propelled craft..."
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
address the following:
Tanks
- Design and construction
- Installation
- Storage tank buildings
- Supports, foundations, and anchorage
for all tank locations
- Operating instructions
Piping systems
- Materials for piping, valves, and fittings
- Pipe joints
- Supports
- Protection against corrosion
Sources of ignition
Testing and maintenance
Fire protection and identification
Prevention of overfilling of tanks
Leak detection and inventory
records for underground storage
tanks.
Underground piping
Valves
Testing
Identification.
Note: NFPA 30 also apply to USTs. For more information call NFPA at 617-770-3000
or access their website at http://www.nfpa.org.
Q Yes Tanks meet or exceed NFPA requirements.
Q No Tanks do not meet NFPA requirements.
Q NA .Facility does not have ASTs.
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4.2c Does the facility inspect ASTs on a periodic basis for leaks or other
hazardous conditions?
If regulated under the SPCC program, a 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
Q No
Q NA
Facility periodically inspects ASTs.
Facility does not inspect ASTs.
Facility does not have aboveground storage tanks.
4.3 Spill Prevention, Control, and Countermeasures
(SPCC) and Emergency Response
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 spill
prevention, control, and countermeasures (SPCC) and emergency response for
compliance with environmental requirements.
a. Does the facility's total tank storage capacity make it subject to the Oil Pollution
regulation? (p. W-66)
b. Could spilled oil reach navigable waters or adjoining shorelines? (p. W-66)
ฐ" 9<ฐ^$e ,fac///*y haYe a Spill Prevention, Control, and Countermeasures
(bPCC) plan signed by a professional engineer? (p. W-67)
d. Is the phone number for the National Response Center available on site for
immediate reporting of oil spills? (p. W-68)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a V") for environmental compliance.
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
Has physical potential to discharge oil in harmful quantities into navigable waters of the
United States.
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On December 2, 1997, EPA proposed a rule called the Oil Pollution Prevention and
Response; Non-Transportation Related On-shore and Off-shore 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 September 2000. For more information, call EPA's RCRA/UST,
Superfund, and EPCRA Hotline at 1-800-424-9346.
4.3a Does the facility's total tank storage 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-galion drums would equal 3,375
gallons total storage).
Q Yes Facility exceeds capacity limits indicated above.
Q Wo Facility storage capacity is less than limits above.
Q NA Facility does not have storage tanks.
4.3b Could spilled oil 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 may be able to reach navigable waters.
Spills are considered able to eventually 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 A/o A spill could not reach navigable waters or adjoining shorelines.
Q NA Facility does not have storage tanks.
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4.3c
je Tanks and SPCC
Does the facility have a Spill Prevention, Control and
Countermeasures (SPCC) plan signed by a professional engineer?
^^^^^f^< then the f IHy must have an SPCC plan. The
site if the facility is normally manned for at least eight hours per
be kept at the nearest field office. An SPCC plan is a written
" "- operations comply with the prevention guidelines under
'-'.ion. Each SPCC plan, while
"
teten "and^T5 ฐ' """ ?'"* ^""'^ Withi
taKen, and plans for preventing their recurrence
Within the past
Actions
H direction' rate of flow. and total quantity of oil that could
where experience indicates a potential equipment failure.
A description of secondary containment
and/or diversionary structures or
equipment to prevent discharged oil from
reaching navigable waters.
If containment and/or diversionary
equipment or structures are not practical,
a strong oil spill contingency plan and a
written commitment of manpower,
equipment, and materials to quickly
control and remove spilled oil.
Secondary Containment
Under SPCC guidelines, all storage tank
installations should have secondary
containment 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, then use an
alternative system.
spi" prevention and control
ThfeifnTthe sae ^ P'a" 'hat haS bee" S'9ned by a anea.
http://www.epa.gov/oerrpage/oilspill/spccplan.htm.
Q Ves
0
Q NA
The facility has an SPCC that has been signed by a professional engineer.
an spcc plan' or the plan is not signed
The facility is not required to have an SPCC plan.
Note: Facilities required to have an SPCC Plan must also conduct an initial screen/no
to determine whether they need to develop a facility response plan SeeSeaonTI
for add,tional information about FRP requirements
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4.3d Is the phone number for the National Response Center available 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 oil spill must be reported to the National Response Center
(NRC) at 1-800-424-8802.
Q Vies NRC phone number is available on site.
Q No NRC phone number is not available.
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Planning and Accidental Release Reporting
SECTION 5.0 PLANNING AND
ACCIDENTAL
RELEASE REPORTING
5.1 EPCRA Planning and Reporting Requirements
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 EPCRA
planning and reporting for compliance with environmental requirements.
a. If the facility has extremely hazardous substances (EHSs) in excess of
their threshold planning quantities (TPQs), has the facility notified its state
emergency response commission (SERC) and local emergency planning
committee (LEPQ? (p. W-70)
b. If the facility experienced an accidental release of a hazardous or extremely
hazardous substance, did the facility immediately notify the proper authorities?
(p. W-70)
c. After initial notification of any spills and releases, has the facility provided a
written follow-up emergency notice(s) to the proper emergency agencies?
(p. W-71)
d. Has the facility submitted copies of its MSDSs or a list of its MSDS chemicals to
the LEPC, SERC, and local fire department? (p. W-71)
e. Does the facility meet its reporting requirement annually under Section 312 of
EPCRA? (p. W-71)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
EPCRA Planning and Reporting 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.
EPCRA requires all facilities (no matter how small) to appoint an emergency response
coordinator and participate in emergency planning activities. It also establishes reporting
requirements for facilities that store and manage specific chemicals.
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5.1a
If the facility has extremely hazardous substances (EHSs) in excess
of their threshold planning quantities (TPQs), has the facility notified
its state emergency response commission (SERC) and local
emergency planning committee (LEPC) ?
A threshold planning quantity
(TPQ) is the amount of an extremely
hazardous substance (EHS) at a
facility that triggers a reporting
requirement. EHSs and their TPQs
are listed in 40 CFR Part 355,
Appendices A and B, or call EPA's
RCRA/UST, Superfund, and EPCRA
Hotline at 1-800-424-9346.
Under Section 302 of EPCRA, if a facility has
any of the 400 extremely hazardous substances
(EHSs) (e.g., ammonia, chlorine, nitric acid,
suifuric 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.
Q yes Facility notified its SERC and LEPC.
Q No Facility did not notify its SERC and LEPC.
Q NA Facility does not have EHSs in excess of their TPQs.
5.1 b If the facility experienced an accidental release of a hazardous or
extremely hazardous substance, did the facility immediately notify the
proper authorities?
Under Section 304 of EPCRA, a facility is required to
immediately notify its LEPC and SERC likely to be
affected if there is a release into the environment of
an 1) "extremely hazardous substance" or a 2)
"hazardous substance" under CERCLA Section 103
that exceeds its reportable quantities. Some of the
substances are common to both lists.
The LEPC and SERC will coordinate response activity
for the 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 is required to notify the National Response
Center (NRC) at 1-800-424-8802.
A reportable quantity (RQ) is
the amount of an extremely
hazardous substance (EHS) or
CERCLA hazardous
substance released to the
environment which must be
reported. EHSs and their RQs
are listed in 40 CFR Part 355,
Appendices A and B.
CERCLA hazardous
substances and their RQs are
listed in 40 CFR Part 302,
Table 302.4.
D Ves Facility immediately notified the proper authorities.
D No Facility did not immediately notify the proper authorities.
Q NA Facility did not experience any accidental releases of CERCLA hazardous or
extremely hazardous substances.
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5.1 c After initial notification of any spills and releases, has the facility
provided a written follow-up emergency notice(s) to the proper
emergency agencies?
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 practicable 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 has submitted a written follow-up emergency notice(s) that
included all of the information described above to the proper emergency
agencies.
Q No Facility did not submit a written follow-up emergency notice(s) or did not
submit one that included all of the information described above to the
proper emergency facilities.
Q NA Facility has not experienced any spills or releases.
5.1 d Has the facility submitted copies of its MSDSs or a list of its MSDS
chemicals to the LEPC, SERC, and local fire department?
EPCRA Section 311 requires facilities that must maintain material safety data sheets
(MSDSs) under OSHA regulations to submit either copies of their MSDSs or a list of
MSDS chemicals to the LEPC, SERC. and local fire department. This reporting is a
one-time requirement unless new information becomes available that reveals a
chemical has an additional hazard. This reporting requirement must be met within 90
days for any new chemical in excess of the reporting threshold handled on site (40 CFR
370.21).
Q Yes Facility has submitted copies of its MSDSs or a list of its MSDS
chemicals to the LEPC, SERC, and local fire department.
Q Wo Facility has not submitted copies of all of its MSDSs or a complete list of
its MSDS chemicals to the LEPC, SERC, and local fire department.
Q NA Facility is not required to have MSDSs.
5.1e Does the facility meet its reporting requirement annually under
Section 312 of EPCRA ?
Under Section 312 of EPCRA, the facility must submit an "Emergency and Hazardous
Chemical Inventory Form" to the LEPC, the SERC, and the local fire department for
all OSHA hazardous chemicals that were present at the facility at any time during the
previous calendar year above specified thresholds and which required an MSDS to be
prepared.
The facility must submit the Emergency and Hazardous Chemical Inventory Form
by March 1 of each year (for the preceding year). There are two formats for the
Emergency and Hazardous Chemical Inventory Form: Tier I and Tier
The Tier I form
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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
rather than aggregate information. Check with the state regulatory agency to find out
which form is required.
Q Yes
Q No
D NA
Facility submitted a Tier I or Tier II Form for all OSHA hazardous chemicals
to the LEPC, SERC, and the fire department by March 1 of the following
year.
Facility did not submit a Tier I or Tier II Form for all OSHA hazardous
chemicals to the LEPC, SERC, and the fire department by March 1.
Facility is not required to submit an emergency and hazardous chemical
inventory form.
5.2 RCRA Contingency Plan
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 RCRA
contingency plans for compliance with environmental requirements.
a.
b.
If the facility qualifies as an LQG, does it have a written contingency plan
/ซ *?& TO i resPฐndm9 to spills and releases of hazardous substances?
(p. W-/JJ
c.
the facility submit its written contingency plan to the appropriate
authonties? (p. W-73)
If the facility is an SQG, does it have basic contingency procedures in
place for responding to spills and releases of hazardous substances? (p.
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a V") for environmental compliance.
RCRA Contingency Plan
If the facility is a small or large quantity generator of
hazardous waste, the emergency preparedness
requirements under RCRA require that the facility
develop a contingency plan for responding to spills
or releases of hazardous wastes. If the facility is a
large quantity generator (LQG), it must have a
written contingency plan. The facility is an LQG if it
generates:
What is hazardous waste?
Waste is considered hazardous if (1) it
appears on one of four lists published
in the hazardous waste regulations (40
CFR Part 261); (2) demonstrates one
of the four hazardous waste
characteristics of ignitability,
corrosivity, reactivity, or toxicity; or (3)
is a mixture of a listed hazardous
waste and other wastes. See Section
1.1 for more information.
2,200 Ibs or more of hazardous waste per
month;
2.2 Ibs or more of acutely hazardous waste
per month.
220 Ibs or more of spill residues from acutely hazardous waste per month.
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If the facility is a small quantity generator (SQG), it must have basic contingency procedures
in place. The facility is an SQG of hazardous waste if it generates more than 220 Ibs but less
than 2,200 Ibs of hazardous waste per month. Although a written contingency plan is not
federally required for SQGs or conditionally exempt small quantity generators (CESQGs), it
is strongly recommended. It is also important to check with the state and local authorities for
any additional contingency plan or emergency preparedness requirements.
A contingency plan usually answers a set of "what if" questions such as "what if one of the
vapor degreasers leaks," or "what if there is an explosion and/or fire at a hazardous waste
storage area"?
5.2a If the facility qualifies as an LQG, does it have a written contingency
plan in place for responding to spills and releases of hazardous
substances?
A written contingency plan for an LQG must contain the following:
Instructions on what to do in the event of a fire, explosion, or release
The arrangements agreed to by local police and fire departments, hospitals, and
State and local emergency response teams to provide emergency services
An emergency coordinator (employee) who is responsible for assessing emergency
situations and making decisions to respond
The names, addresses, and phone numbers of all persons qualified to act as the
emergency coordinator
All emergency equipment at the facility
An evacuation plan.
Q Yes Facility has a written contingency plan that addresses all of the requirements
listed above.
O No Facility does not have a written contingency plan.
Q NA Facility does not qualify as an LQG, and so is not required to have a written
contingency plan.
5.26 Did the facility submit its written contingency plan to the appropriate
authorities?
The facility must submit copies of the written contingency plan to the local police and
fire departments, hospitals, and State and local emergency response teams that may
be called upon to provide emergency services. The facility should maintain
documentation showing that local authorities have been notified.
Q Yes Facility submitted copies of the contingency plan to the appropriate
authorities.
Q No Facility has not submitted copies of the contingency to the appropriate
authorities.
a NA
Facility is not required to have a written contingency plan.
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5.2c If the facility is an SQG, does it have basic contingency procedures in
place for responding to spills and releases of hazardous substances?
SQGs must have basic contingency procedures to follow in the event of an emergency.
These procedures include the following:
An emergency coordinator (employee) either at the facility or on call who is
responsible for coordinating all emergency response measures;
Information posted next to the telephone, including: (1) the name and number of the
emergency coordinator; (2) the locations of the fire extinguishers and spill control
material; and (3) the telephone number of the fire department.
Ensure that all employees are thoroughly familiar with proper waste handling and
emergency procedures.
D Vies Facility has basic contingency procedures as described above.
Q A/o Facility does not have the basic contingency procedures.
D NA Facility is not an SQG, and so is not required to follow basic contingency
procedures.
5.3 Oil Pollution Act's Facility Response Plan (FRP)
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 facility
response plans for compliance with environmental requirements.
a. Does the facility have an FRP? (p. W-74)
b. Does the facility's FRP include all required elements? (p. W-75)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a "") for environmental compliance.
5.3a Does the facility have an FRP?
Under the Oil Pollution Act (OPA), a facility response plan (FRP) is required if the
facility could cause "substantial harm" to the environment. A facility has the potential to
cause substantial harm if (40 CFR 112.20(f)(1)):
(1) The facility transfers oil over water to or from vessels and has a total oil storage
capacity, including both aboveground storage tanks (ASTs) and underground
storage tanks (USTs), greater than or equal to 42,000 gallons; or
(2) The facility's total oil storage capacity, including both ASTs and USTs, is greater
than or equal to one million gallons and one of the following is true:
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The facility does not have secondary containment for each aboveground
storage area sufficient to contain the capacity of the largest AST within each
storage area plus freeboard to allow for precipitation;
The facility is located at a distance such that a discharge could cause injury to
an environmentally sensitive area;
The facility is located at a distance such that a discharge would shut down a
public drinking-water intake; or
The facility has had a reportable spill greater than or equal to 10,000 gallons
within the last five years.
The determination as to whether the facility could cause substantial harm to the
environment may be made through two methods:
(1) Through a self-selection process (EPA has established criteria located in 40 CFR
Part 112, Appendix C, to assist facilities in making that determination).
(2) By determination of the EPA Regional Administrator (which is based on factors
similar to the self-selection factors, and also type of transfer operations at the
facility, the facility's oil storage capacity, lack of secondary containment, proximity to
environmentally sensitive areas, or drinking-water intakes, and/or the facility's spill
history).
Q Yes Facility has an FRP.
Q No Facility does not have an FRP.
Q NA Facility is not required to have an FRP.
5.3b Does the facility's FRP include all required elements?
FRPs must address certain critical items. It must:
Be consistent with the National Contingency Plan (NCP) and the Area Contingency
Plan covering the facility's location
Identify a qualified individual having full authority to implement removal actions, and
require immediate communication between that person and the appropriate federal
authorities and responders
Identify and ensure availability of resources to remove, to the maximum extent
practicable, a worst-case discharge
Describe training, testing, unannounced drills, and response actions of persons at the
facility
Be updated periodically, and
Be submitted for approval with each significant change.
Q yes Facility's FRP addresses all of the critical items listed above.
Q No Facility's FRP does not address all of the critical items listed above.
Q NA Facility is not required to have an FRP.
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5.4 CAA Risk Management Plan
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 risk management plans for compliance with environmental requirements.
a. Does the facility have an RMP? (p. W-76)
b. Does the RMP include all of the required elements? (p. W-77)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a V") for environmental compliance.
Risk Management Plans (RMPs)
Under Section 112(r) of the CAA, EPA must establish a program to prevent accidental
chemical releases (Chemical Accidental Release Rule). The main goal of this regulation is to
communicate potential risks to the public and to ensure that facilities have implemented a
baseline safety management program to reduce the possibility of a release. The primary tool
to accomplish this goal is the Risk Management Plan (RMP).
The plan the facility submits to EPA summarizes the facility's program and it is available to the
public. Once the plan is submitted, EPA reviews it for accuracy and completeness. EPA,
state, or local officials may conduct a site visit at the facility to determine whether the plan
accurately reflects the facility's risk management program in operation. For more information
about risk management planning requirements, see EPA's Chemical Emergency
Preparedness and Prevention Office's webpage at http://www.epa.gov/ceppo/.
5.4a Does the facility have an RMP?
The facility must develop an RMP if it stores any of the 140 regulated substances (e g
propane) identified under the CAA's Section 112(r) at or above specific threshold
quantities for those chemicals. Sources should have complied with the rule by June 20
1999. If the facility does not already have an RMP, it should develop one as soon as
possible.
Q Yes Facility has prepared an RMP. i/
Q No Facility has not prepared an RMP.
Q NA Facility is not required to have an RMP.
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5.4b Does the RMP include all of the required elements?
Under Section 112(r) of the CAA, the RMP must include the following:
Documentation of process safety information
Process hazard analysis of the off-site impact of an accident
Documentation of operating procedures
Training program
Pre-startup reviews
Maintenance program
Management of Change Program
Accident investigation
Emergency response program
Safety audits
Registration with the Chemical Safety and Hazard Investigation Board
A hazard assessment of a worst-case scenario
Submission of RMP to EPA, SERC, LEPC, and available for public review.
Q Yes Facility's RMP includes all of the elements listed above.
Q No Facility's RMP does not include all of the elements listed above.
Q NA Facility is not required to have an RMP.
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Vessels and Underway Activities
SECTION 6.0 VESSELS AND UNDERWAY
ACTIVITIES
Note: Section 6.0 Vessels and Underway Activities applies to vessels and sea-related
activities. The purpose of this section is to make the water transportation facility
owner/operator aware of vessel activities that could potentially impact the environment
surrounding on-shore facilities.
6.1 Marine Pollution
NOTE: The following questions are not included in the accompanying checklist, however,
they are still important to consider when examining the vessel's operations for
compliance with environmental requirements.
a. Is the vessel operator familiar with requirements under Annex I of MARPOL?
(p. W-79)
b. Does the vessel have a Shipboard Oil Pollution Emergency Plan? (p. W-80)
c. If transporting noxious liquid substances (NLSs), is the vessel operator familiar
with requirements under Annex II of MARPOL? (p. W-81)
d. Does the vessel dispose of garbage at sea in accordance with Annex V of
MARPOL? (p. W-81)
e. Are placards for MARPOL garbage dumping restrictions posted in prominent
locations and in sufficient numbers so crew and passengers can read them?
(p. W-82)
f. Does the vessel have a waste management plan and logbook? (p. W-83)
g. Does the vessel's waste management plan include all of the required elements?
(p. W-83)
h. Does the vessel maintain records of garbage, including sewage, discharge or
disposal operations? (p. W-83)
I. Is the vessel operator familiar with MARPOL reporting requirements? (p. W-84)
j. If the vessel intends to transport municipal or commercial waste, does the
vessel have a conditional permit, with the permit number displayed on the
vessel? (p. W-84)
k. For vessels that carry ballast water to U. S. waters after operating beyond the
U. S. Exclusive Economic Zone, does the vessel employ ballast management
practices?
(p. W-85)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a V") for environmental compliance.
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Marine Pollution
While EPA has responsibility for regulating water
transportation facilities, the U.S. Coast Guard
regulates all sea-related activities of vessels.
The Coast Guard ensures that all sea-going
vessels comply with U.S. law and international
treaties and conventions. The primary regulatory
framework for vessels originates from the
International Convention for Prevention of
Pollution from Ships (enacted in 1973 and
modified in 1978), which is also known as the
Marine Pollution (MARPOL) Act. MARPOL is an
international agreement designed to address the
problem of marine pollution from vessels. It
consists of five annexes, each of which
addresses a different type of marine pollution:
Annex VI of MARPOL
The International Maritime Organization
recently adopted a new Annex VI to
MARPOL. This annex establishes NOx
emission limits applicable to propulsion
and auxiliary engines greater than 130kw
installed in ships constructed on or after
January 1. 2000. Although requirements of
the Annex will not go into force until it is
ratified by a certain number of states, it is
expected that vessels constructed on or
after January 1, 2000 will be equipped with
engines that meet the NOx requirements.
Annex I: Oil
Annex II: Noxious liquids carried in bulk
Annex III: Harmful substances in packaged form
Annex IV: Sewage from ships.
Annex V: Garbage from ships.
Annexes I and II are mandatory for all signatories, including the United States, to MARPOL.
Annexes III, IV, and V are considered optional and not binding unless the signatory has
specifically accepted those Annexes. The United States is party to Annexes III and V, but not
to Annex IV. Congress enacted the Act for the Prevention of Pollution by Ships in 1980 to
implement Annexes I and II, and the Marine Plastic Pollution Research and Control Act of 1987
to implement Annex V. The Hazardous Materials Transportation Act of 1974 was amended to
incorporate the provisions of Annex III.
6.1 a Is the vessel operator familiar with requirements under Annex I of
MARPOL?
Annex I of MARPOL requirements includes the following:
Forbids the discharge at sea of oil in certain "special areas" (e.g., Mediterranean
Sea, Black Sea, Baltic, Sea. Red Sea) where threat to the marine environment is
especially great and limits other discharges to 1/30,000 of the cargo.
Discharges from machinery spaces (e.g., bilge water) must occur more than 12
miles from land and the oil content must be less than 100 ppm.
Oil tankers must be constructed and equipped to retain oily residues on board until
they can be discharged into shore reception facilities. New oil tankers of 70,000
deadweight tons and above must be provided with the segregated ballast tanks
(SBTs) of sufficient capacity to enable them to operate safely on ballast voyages
without recourse to the use of cargo tanks for ballast purposes (except in severe
weather).
All ships of 400 gross tons and above must be equipped with oily-water separating
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equipment, or a filtering system for discharges from machinery space bilges,
together with on-board tanks for retention of oily residues from separators and
purifiers. Vessels in excess of 10,000 gross tons must be equipped with oil
discharge monitoring and control systems.
Tankers and other ships must carry and maintain an Oil Record Book in which all
operations involving oil are recorded. Authorities of any State which is a Party to
the Convention can inspect the book.
Q Yes Vessel operator is familiar with Annex I requirements under MARPOL
Q No Vessel operator is not familiar with Annex I requirements under MARPOL.
Q NA Annex I of MARPOL does not apply to the vessel.
6.1b Does the vessel have a Shipboard OH Pollution Emergency Plan?
All vessels subject to MARPOL must have a Shipboard Oil Pollution Emergency Plan
(SOPEP) available on board in English and in the working language of the master and
officers of the ship, if other than English. The SOPEP must include numerous
elements, such as the following:
Ship's name, call sign, official number, International Maritime Organization (IMO)
international number, and principal characteristics
Reporting requirements and notification form
Who to contact
Steps to control oil discharges
National and local coordination information.
For more information on shipboard oil pollution emergency plan requirements, refer to
33 CFR 151.26.
O Yes Vessel has a shipboard oil pollution emergency plan that includes all
elements listed above.
Q No Vessel does not have a shipboard oil pollution emergency plan, or the
emergency plan does not include all elements listed above.
Q NA Vessel is not required to have a shipboard oil pollution plan.
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6.1 c
If transporting noxious liquid substances (NLSs), is the vessel
operator familiar with requirements under Annex II ofMARPOL?
Annex II of MARPOL contains regulations for discharges of noxious liquid substances
(NLSs) (i.e., bulk liquid chemicals) listed in 33 CFR Parts 151 and 153. The
substances are divided into four categories (i.e., A, B, C, D) according to the hazard
they present to marine resources, human health, or amenities. To date, more than 250
NLSs have been evaluated and regulated. Such substances cannot be discharged to
reception facilities, unless certain requirements are met. Because there are numerous
regulations, refer to 33 CFR 151.31 for information regarding where to find regulations
for the four categories of NLSs.
Q Ves
a A/O
a NA
Vessel operator is familiar with requirements under Annex II of
MARPOL.
Vessel operator is not familiar with requirements under Annex II of
MARPOL.
Annex II of MARPOL does not apply to the vessel.
6.1d Does the vessel dispose of garbage at sea in accordance with Annex
V of MARPOL?
Annex V establishes specific minimum distances for the disposal of garbage at sea.
The most important component of this annex is the complete prohibition on the disposal
of plastics into the sea. The Marine Plastic Pollution Research and Control Act
(MPPRCA) of 1987 is the federal law implementing MARPOL Annex V in all U.S.
waters. Under MPPRCA. it is illegal to throw plastic trash off any vessel within the U.S.
Exclusive Economic Zone. It is also illegal to throw any other garbage, including food,
paper plates, glass jars, and even monofilament fishing line, overboard while navigating
in inland waters. See table below. Note that state and local regulations may have
even stricter regulations.
Q Ves
Q A/o
D NA
Q Don't Know
Vessel disposes of garbage .in accordance with requirements
under Annex V.
Vessel does not dispose of garbage in accordance with
requirements under Annex V.
Vessel does not dispose of garbage, including plastics, at sea.
Vessel operator is not familiar with Annex V requirements.
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Summary of Garbage Discharge Restrictions for All Vessels
(Except Fixed or Floating Platforms and Associated Vessels)
Garbage Type
Outside special areas 1
In special areas
Plastics (including synthetic
ropes, fishing nets, plastic bags)
Dunnage, lining and packing
materials that float.
Paper, rags, glass, etc. and
similar refuse.
Paper, rags, glass, etc.
comminuted or ground.2
Victual (food) waste not
comminuted or ground.
Victual waste comminuted or
ground.
Disposal prohibited.
Disposal prohibited less than 25 miles
from nearest land and in the navigable
waters of the U.S.
Disposal prohibited less than 12 miles
from the nearest land and in the
navigable waters of the U.S.
Disposal prohibited less than 3 miles
from nearest land and in the navigable
waters of the U.S.
Disposal prohibited less than 12 miles
from nearest land and in the navigable
waters of the U.S.
Disposal prohibited less than 3 miles
from nearest land and in the navigable
waters of the U.S.
Disposal prohibited.
Disposal prohibited.
Disposal prohibited.
Disposal prohibited.
Disposal prohibited.
Disposal prohibited.
1 Special areas under Annex V are the Mediterranean, Baltic, Black, Red, and
Gulfs areas.
2 Comminuted or ground garbage must be able to pass through a screen with
25mm (one inch).
North Seas areas and
a mesh size no larger than
6.1e Are placards for MARPOL garbage dumping restrictions posted in
prominent locations and in sufficient numbers so crew and
passengers can read them?
Boats 26 feet or longer must prominently post at least one MARPOL garbage dumping
restrictions placard, a 9" x 4" sticker that explains dumping restrictions (33 CFR
151.59). Placards may be obtained from the Office of Response, U.S. Coast Guard,
2100 Second Street, SW, Washington, DC 20593 or at website:
http://www.uscg.mil/hq/g-m/nmc/seapart.htm
Q Yes Placards are prominently displayed.
Q No Placards are not prominently displayed.
Q NA The vessel is not required to display garbage restrictions placards.
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6.1 f Does the vessel have a waste management plan and logbook?
Vessels 40 feet or longer must have a written waste management plan that describes
the proper handling of refuse onboard as well as a waste logbook that details disposal
and waste discharge operations.
Q Ves
Q No
Q NA
Vessel has a waste management plan and logbook.
Vessel does not have a waste management plan and logbook.
Vessel is not required to have a waste management plan and logbook.
6.1g Does the vessel's waste management plan include all of the required
elements?
Written waste management plans need to include the following (40 CFR 151.57):
2) Procedures used for collecting, processing, storing and discharging the vessel's
garbage properly (in accordance with MARPOL Annex V laws); and
3) Name of the person in charge of carrying out the plan.
It is also a good idea to mention how many of the crew and passengers are educated
to the plan since MARPOL regulations say that the vessel shall not be operated unless
each person handling garbage follows the waste management plan.
a yes
a NO
a NA
Vessel's waste management plan includes all required elements.
Vessel's waste management plan does not include all required elements.
Vessel is not required to have a waste management plan.
6.1h Does the vessel maintain records of garbage, including sewage,
discharge or disposal operations?
The person in charge of the vessel must ensure that a written record is maintained on
the ship of each of the following garbage discharge or disposal operations (40 CFR
151.55):
Discharge overboard
Discharge to another ship
Discharge to a reception facility
Incineration on the ship
Type, date, and time of operation
If the operation was conducted at a port, the name of the port.
If the operation was not conducted at a port, the latitude and longitude of the
location where the operation happened and the estimated distance of that location
from shore.
If the location involved off-loading to another ship, the identity of the receiving ship
by name and official number.
Amount of garbage involved (in cubic meters).
For discharges into the sea, a description of the contents of the garbage, described
by the following categories: (1) plastic material; (2) floating dunnage, lining, or
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packing material; (3) ground paper products, rags, glass, metal, bottles, crockery;
(4) unground paper products, rags, glass, metal, bottles, crockery, or other similar
garbage; (5) food wastes; (6) incinerated ash; (7) incinerated plastic residue.
As records are prepared, the person in charge of the vessel must certify them as
correct and maintain them on the ship for two years following the operation.
Q Yes Vessel maintains records of garbage discharge operations.
Q No Vessel does not maintain records of garbage discharge operations.
Q NA Vessel does not discharge garbage.
6.1 i Is the vessel operator familiar with MARPOL reporting requirements?
The person in charge of the vessel must notify the port or terminal, at least 24 hours
before entering the port or terminal, of (1) name of the ship and the estimated volume
of garbage requiring disposal; and (2) if any of the following types of garbage are to be
discharged:
Garbage regulated by Animal and Plant Health Inspection Service
Medical Wastes
Hazardous wastes (as defined in 40 CFR 261.3).
Q Yes Vessel is familiar with MARPOL reporting requirements.
Q No Vessel is not familiar with MARPOL reporting requirements.
Q NA Vessel does not have garbage requiring disposal.
6.1j If the vessel intends to transport municipal or commercial waste,
does the vessel have a conditional permit, with the permit number
displayed on the vessel?
Vessels intended to transport municipal or commercial waste must have (1) a
conditional permit to transport municipal or commercial waste; and (2) must display its
number under the following conditions (33 CFR 151.1009):
Is clearly legible
Has a contrasting background
Is readily visible from either side of the vessel
Is in block figures at least 18 inches in height.
Q Vies Vessel has a conditional permit, with the permit number displayed on the
vessel.
Q No Vessel does not have a conditional permit, and/or does not have its
permit number displayed on the vessel.
Q NA Vessel is not transporting municipal or commercial waste.
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6.1k For vessels that carry ballast water to U.S. waters after operating
beyond the U.S. Exclusive Economic Zone, does the vessel employ
ballast management practices?
Ballast water is seawater which is
introduced into the vessel's ballast
tanks to adjust a vessel's draft,
buoyancy, trim, and list, and to
improve stability under various
operating conditions (e.g., to replace
the weight of off-loaded cargo or
expended fuel oil). Vessels that carry
ballast water after operating beyond
the Exclusive Economic Zone (EEZ)
and then, at any point during its
voyage, enters the Snell Lock at
Massena, New York, or navigates
north of the George Washington
Bridge on the Hudson River, must
employ one of the following ballast
management practices:
Invasive Species
Ballast water has the potential to contain
plants and animals, including
microorganisms and pathogens. When
ballast water is transported and discharged
into another port or coastal area, the
surviving organisms have the potential to
threaten the local ecosystem. In attempt to
reduce the risk of exotic species invasions,
the National Invasive Species Act (NISA) of
1996 requests that all ships arriving to U.S.
ports from outside the exclusive economic
zone (EEZ) follow voluntary guidelines for
open-ocean exchange of ballast tanks that are
to be discharged in U.S. waters.
(1) Carry out an exchange of ballast water on the waters beyond the EEZ, in a depth
exceeding 2000 meters, prior to entry into the Snell Lock at Massena, New York, or
prior to navigating on the Hudson River, north of the George Washington Bridge, such
that, at the conclusion of the exchange, any tank from which ballast water will be
discharged contains water with a minimum salinity level of 30 parts per thousand.
- Retain the vessel's ballast water on board the vessel. The Captain of the Port
(COTP) may seal any tank or hold containing ballast water on board the vessel for
the duration of the voyage within the waters of the Great Lakes or the Hudson
River, north of the George Washington Bridge.
- Use an alternative environmentally sound method of ballast water management that
has been submitted to, and approved by, the Commandant of the U.S. Coast Guard
prior to the vessel's voyage. Requests for approval of alternative ballast
management must be sent to:
Commandant (G-M)
U.S. Coast Guard Headquarters
2100 Second Street. SW
Washington. DC 20593-0001.
Q Yes Vessel employs ballast management practices.
Q No Vessel does not employ ballast management practices.
Q NA Vessel is not required to employ ballast management practices.
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6.2 Ocean Dumping
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. If permitted to dispose of materials into the ocean, does the vessel follow permit
requirements? (p. W-87)
This question appears in the following text and is accompanied with a discussion of the
preferred answer (indicated with a "") for environmental compliance.
Ocean Dumping
The Ocean Dumping Act regulates the intentional ocean disposal of materials. The act
consists of the first two titles of the Marine Protection, Research, and Sanctuaries Act
(MPRSA) of 1972. The act basically prohibits all ocean dumping (e.g, radiological, chemical,
medical, sewage, and industrial wastes), except that allowed by permits, in U.S. ocean waters.
Under MPRSA, EPA's environmental criteria states no ocean dumping will be allowed if (1) the
dumping will cause significant effects; or (2) the material proposed to be dumped is not
adequately characterized (i.e., there is not enough information to make the above
determination).
Dredged Material. Virtually all ocean dumping occurring today is dredged material of
sediments removed from the bottom of waterbodies to maintain navigation channels and
berthing areas. Ocean dumping of material cannot occur unless a permit is issued under
MPRSA. In the case of dredged material, the US Army Corps of Engineers must decide
whether or not to issue a permit, using EPA's environmental criteria and subject to EPA's
concurrence. EPA is also responsible for designating recommended ocean disposal sites for
use under such permits. For more information about ocean dumping requirements, refer to 40
CFR Part 220.
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6.2a If permitted to dispose of materials into the ocean, does the vessel
follow permit requirements?
Currently, all ocean disposal of wastes must occur at a site at least 106 miles offshore.
Permits issued under the Ocean Dumping Act specify the following:
Type of material to be dumped
Amount to be transported for dumping
Location of the dumpsite
Length of time the permit is valid
Any special provisions for surveillance.
Recently the act was amended giving the states authority to adopt dumping standards
that are more stringent than federal requirements and to require that permits conform
with long-term management plans for designated dumpsites to ensure permitted
activities are consistent with expected uses of the site.
Q yes Vessel is in compliance with all requirements of its ocean dumping
permit.
Q No Vessel is not in compliance with all requirements of its ocean dumping
permit.
6.3 Discharging On shore to Water Transportation
Facilities
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 vessel discharge bilge and other vessel discharges to on-shore tanks
supplied by the water transportation facility? (p. W-87)
b. Has the owner/operator cleaned all cargo tanks after unloading of cargo to
remove any residue left by the cargo? (p. W-88)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a V") for environmental compliance.
6.3a Does the vessel discharge bilge and other vessel discharges to on-
shore tanks supplied by the water transportation facility?
The bilge, which is a collection area located at the bottom of any vessel, collects fuel,
oil, on-board spills, and wash waters generated during the daily operation of any
vessel. Bilge waste is pumped to a bilge waste holding tank on the vessel when the
level in the bilge gets too high for safe operation. Once in port, a vessel must
discharge all bilge and other vessel discharges (e.g., sewage, ballast water, cleaning
wastes) to on-shore tanks usually supplied by the water transportation facility.
Q Yes
Vessel discharges its bilge and other discharges to on-shore tanks.
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Q No
Vessel does not discharge to on-shore tanks.
6.3b Has the owner/operator cleaned all cargo tanks after unloading of
cargo to remove any residue left by the cargo?
After a vessel has unloaded its cargo, the owner/operator must clean all cargo tanks to
remove any residue left by the cargo. The degree to which the tanks are cleaned
usually depends on the nature of past and future cargos carried on the vessel. Cargos
that are compatible (e.g., grains, ores, or petroleum products) may not require as
strenuous a cleaning as those cargos that should not be mixed.
A high-pressure water spray is the primary method for tank cleaning. The pressurized
water spray system is either operated by a person or some vessels are now equipped
with automated systems. Upon completion of the high-pressure cleaning, the
washwater is pumped into a "slop" tank where it is held until discharged on shore.
Q Yes All cargo tanks have been cleaned after unloading of cargo.
Q No Not all cargo tanks have been cleaned after unloading of cargo.
Q NA Vessel is not carrying cargo.
6.4 Pollution Prevention
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 vessel have a fuel/air separator in the fuel tank's air vent line to
prevent spills during and after fill up? (p. W-88)
b. Does the vessel operator routinely check for and fix fuel leaks? (p. W-89)
c. Does the vessel operator place a drop pan placed under the engine? (p. W-89)
d. Does the vessel minimize occurrences of contaminated bilge water discharges?
(p. W-89)
These questions appear in the following text and may be accompanied with discussions
of the preferred answers (indicated with a V") for environmental compliance.
6.4a Does the vessel have a fuel/air separator in the fuel tank's air vent line
to prevent spills during and after fill up?
Q Yes Vessel has a fuel/air separator in the fuel tank's air vent line to prevent
spills during and after fill up.
Q No Vessel does not have a fuel/air separator in the fuel tank's air vent line to
prevent spills during and after fill up.
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6.4b Does the vessel operator routinely check for and fix fuel leaks?
Q Yes Vessel operator routinely checks for and fixes fuel leaks.
Q No Vessel operator does not routinely check for and fix fuel leaks.
6.4c Does the vessel operator place a drop pan placed under the engine?
Q Vies Drop pan has been placed under the engine to catch fuel drips and
leaks.
Q No Drop pan has not been placed under the engine to catch fuel drips and
leaks.
6.4d Does the vessel minimize occurrences of contaminated bilge water
discharges?
The lowest inner part of the hull where liquid drains from the interior spaces and the
upper decks of the vessel is referred to as the bilge. The primary sources of drainage
into the bilge are the main engine room(s) and the auxiliary machinery rooms(s), which
house the vessel's propulsion system and auxiliary systems (i.e., steam boilers and
water purification systems).
Oil and grease from operation and maintenance of inboard engines are sources of
petroleum in bilges. Methods of minimizing occurrences of contaminated bilgewater
discharges include the following:
/ Use oil/water separators in the bilge pump discharge line to prevent discharge of
oily water.
v' Use a catch pan containing absorbent pads to use in bilges.
/ Fix leaks that allow fuel or oil to drip into the bilge: inspect lines and hoses for
deterioration, and secure and prevent lines from chafing.
Q Yes Vessel minimizes occurrences of contaminated bilgewater discharges.
Q No Vessel does not minimize occurrences of contaminated bilgewater
discharges.
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Glossary of Terms
GLOSSARY OF TERMS
Aboveground storage tank: Any tank or other container that is aboveground. partially buried,
bunkered, or in a subterranean vault. This includes floating fuel system.
Acute Hazardous Waste: Commercial chemical products and manufacturing intermediates
having the generic names listed in 40 CFR 261.33; off-specification commercial chemical
products and manufacturing chemical intermediates which, if they met specification, would
have the generic names listed; any residue or contaminated soil, water, or other debris
resulting from the cleanup of a spill of any of these substances; any residue remaining in
containers that are not empty by RCRA standards (40 CFR 261.7)
Aquifer: A saturated water bearing formation of permeable rock, sand, or gravel.
Ambient Standards: Standards for the quality of outdoor air.
Asbestos: A naturally occurring fibrous mineral used in buildings for its heat retarding
properties that may cause serious respiratory problems if inhaled. CAA regulates removal and
disposal.
Caustic: Any substance which can burn, dissolve, corrode, or eat away by chemical reaction.
CERCLA Hazardous Substances: CERCLA Section 101(14), as amended, defines
"hazardous substance" by referencing other environmental statutes, including: CWA Sections
311 and 307(a); CAA section 112; RCRA Section 3001; and TSCA Section 7. A list of over
600 CERCLA hazardous substances is provided in 40 CFR 302.4. EPA has the authority to
designate additional hazardous substances not listed under the statutory provisions cited
above.
CFR: Code of Federal Regulations. A codification of the regulations published by federal
government agencies.
Chlorofluorocarbons (CFCs): The chemical group found in refrigerants such as freon and in
propellants for aerosol containers. These chemicals have been determined to be partially
responsible for depletion of ozone levels in the upper atmosphere.
Civil Penalties: Monetary penalties which can be imposed on companies and individuals for
violations of civil laws and regulations.
Clean Air Act (CAA): The federal law designed to improve air quality by regulating air pollution
emission from stationary and non-stationary sources. The Act includes National Ambient Air
Quality Standards (NAAQS) for specific pollutants.
Cleanup: Actions taken to deal with a release or threat of a hazardous substances release
that could affect people or the environment. The term "cleanup" is sometimes used
interchangeably with the terms "remedial action," "removal action," "response action," "remedy,"
"remediation," or "correction action."
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.
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Glossary of Terms
Disposal Facility: A facility or part of facility at which solid or hazardous waste is intentionally
placed into or on any land or water, and at which waste will remain after closure.
Effluent: Any gaseous, liquid, or solid waste material that is released into the environment.
Emergency Response: A response effort by employees from outside the immediate release
area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to
an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous
substance. Responses to incidental releases of hazardous substances which can be
absorbed, neutralized, or otherwise controlled at the time of release by employees in the
immediate release area, or by maintenance personnel, are not considered to be emergency
responses within the scope of the OSHA HAZWOPER standard. Responses to releases of
hazardous substances involving no potential safety or health hazard (i.e., fire, explosion, or
chemical exposure) are not considered to be emergency responses.
Emergency Planning and Community Right-to-Know Act (EPCRA): The federal law
requiring corporate disclosure to local communities about the chemicals used by the company.
It also requires the notification of certain spills and releases.
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 of ten EPA regions, such as Region
4Tennessee, Kentucky, North Carolina, South Carolina, Georgia, Florida, Alabama, and
Mississippi.
Erosion: The process of being worn away or deteriorated by wind or water.
Evacuation: A personnel or population protection strategy that provides for the orderly
movement of people away from an actual or potential hazard.
Facility: All buildings, structures, equipment, and other stationary items that are located on a
single site or on continuous or adjacent sites and that are owned or operated by the same
person (or by any person which controls, is controlled by, or under common control with such
person). Under certain circumstances, a facility can include rolling stock and other transport
vehicles.
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): The federal law which
regulates the sale, distribution, and use of pesticides and establishes requirements for
registration, labeling, use, and disposal of these products.
Fire Hazards: Hazardous chemicals, including flammable chemicals, that are liable to cause
fire through friction, absorption, spontaneous chemical changes, retained heat, or which can
be ignited readily and burn vigorously and persistently; combustible liquids having flashpoints
at or above 90ฐF but below 100ฐF; flammable liquids with flash points below 100ฐF; pyrophoric
chemicals that ignite spontaneously in air at temperatures of 130ฐ F or below; and oxidizers
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Glossary of Terms
that can promote combustion in other materials, causing fire either by themselves or through
the release of oxygen or other gases.
Freeboard: The vertical distance from the normal water surface to the top of the confining
wall.
Friable Asbestos Material: Any material that contains more than one percent asbestos by
weight, and can be crumbled, pulverized, or reduced to powder by hand pressure.
Fugitive Emissions: Air emissions not normally vented through a stack, chimney, vent, or
equivalent opening. Fugitive emissions includes emissions from ponds, lagoons, landfills, and
piles of stored materials.
Generator of Hazardous Waste: Entity that produces hazardous waste. Generators are
classified by how much hazardous waste they produce in a given time period. In general,
there are three classes of waste generators: conditionally exempt small quantity generators,
small quantity generators, and large quantity generators. The generator is required to
determine if a waste is hazardous. If the waste is hazardous, the generator must apply for and
obtain an EPA ID number before transporting the waste to an approved treatment, storage,
and disposal facility. The generator must also use a hazardous waste manifest to track the
hazardous waste, must package and label the hazardous waste, and must keep records of its
shipments for 3 years.
Groundwater: Water below the land surface in a zone of saturation.
Hazard: A circumstance or condition that can do harm. Hazards are categorized into four
groups: biological, chemical, radiation, and physical.
Hazard Classes: These are descriptive terms prescribed by the Department of Transportation
to categorize the nature of DOT regulated materials. There are nine numeric classes and two
word classes as follows: Class 1 (explosives). Class 2 (gases), Class 3 (flammable liquids),
Class 4 (flammable solids and substances), Class 5 (oxidizing substances), Class 6
(poisonous and infectious substances), Class 7 (radioactive), Class 8 (corrosive), and Class 9
[miscellaneous substances, and Combustible Liquids, ORM-D (consumer commodities)].
Hazardous Material: A substance designated by the Department of Transportation as posing
a potential hazard when transported. See 49 CFR 171.101 for a list of DOT hazardous
materials. Hazardous wastes requiring a manifest are considered hazardous materials.
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:
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Glossary of Terms
The material has been listed as a hazardous waste by regulations.
It is ignitable, corrosive, reactive, or toxic.
It is a mixture of a listed hazardous waste and a non-hazardous waste.
Hazmat: A contraction of Hazardous Materials.
Ignitable: Material that has a flashpoint less than 140ฐF, is combustible through friction, is
combustible through absorption of moisture, or can spontaneously combust.
Incident: A release or potential release of a hazardous material, substance, or waste into the
environment.
Indirect Discharge: A discharge which goes to a publicly-owned treatment works (POTW).
Indirect discharges do not need a National Pollutant Discharge Elimination System (NPDES)
permit but must comply with the POTW pretreatment standards.
Influent: Wastewater or other raw or partially treated liquid flowing into a basin, treatment
process, or treatment plant.
Land Disposal: Includes, but is not limited to placement of hazardous waste in a landfill,
surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt
bed formation, underground mine or cave, or concrete vault or bunker intended for disposal
purposes. Land disposal facilities are a subset of treatment, storage, and disposal facilities
(TSDFs). Groundwater monitoring is required at all land disposal facilities. Waste material can
only be disposed of at a permitted facility.
Land Disposal Restrictions: Regulations prohibiting the disposal of hazardous waste on land
without prior treatment of the waste. Land disposal restriction notifications ensure proper
treatment of the waste prior to disposal.
Landfill: A disposal facility or part of a facility where waste is placed in or on land and which is
not a land treatment facility, a surface impoundment, or an injection well.
Large Quantity Generators: One of three classes of hazardous waste generators under
RCRA producing 1,000 kilograms or more of hazardous waste in one calendar month at a given
location.
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.
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August 2000
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Glossary of Terms
Material Safety Data Sheets (MSDS): Information sheets which provide workers with details
on the health and physical hazards of chemicals to which they may be exposed in the
workplace.
Maximum Achievable Control Technology (MACT): Generally, the best available control
technology, taking into account cost and technical feasibility.
Milligrams per Kilogram (mg/kg): Weight of a substance, measured in milligrams, contained
in a weight of the total material, measured in kilograms. A concentration used to measure
solid materials such as contamination in soil.
Milligrams per Liter (mg/l): Weight of a substance, measured in milligrams, contained in a
volume of solution measured in liters. A concentration used for liquid substances.
Monitoring: The process of measuring certain environmental parameters on a real-time basis
for spatial and time variations. For example, air monitoring may be conducted with direct
reading instruments to indicate relative changes in air contaminant concentration at various
times.
National Ambient Air Quality Standards (NAAQS): Standards established by the Clean Air
Act for air quality of an area in terms of allowable levels of specific pollutants.
National Emission Standards for Hazardous Air Pollutants (NESHAP): The EPA regulations
which govern specific processes which could possibly emit certain hazardous pollutants such
as asbestos into the air.
National Pollutant Discharge Elimination System (NPDES): A permitting system under the
CWA established for regulating direct discharges of wastewater from industries and
municipalities into surface waters of the United States.
National Priority List (NPL): The prioritized list required by CERCLA of abandoned or
uncontrolled hazardous waste sites.
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.
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August 2000
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Glossary of Terms
Operator: The person responsible for the overall operation of a facility or process.
Occupational Safety and Health Administration (OSHA): A federal agency which protects
worker health and safety under the Occupational Safety and Health Act and plays an important
role in environmental issues such as chemical exposure in the workplace.
Outfall: The mouth of a drain or sewer which flows directly into surface water.
Owner: The person who owns a facility or part of a facility.
Parts per Million (ppm): A standard or measurement for concentrations of pollutants. A ratio
(volume/volume or weight/weight) usually used for airborne concentration of gases or vapors,
for concentrations of chemicals in water, or concentrations of chemicals in soil.
Permit: A written document issued by the government that establishes standards and/or
pollutant limits for water discharges, air emissions, or for the handling, treating, storing, or
disposing of hazardous waste.
Pesticide: Any substance or mixture of substances intended for preventing, destroying,
repelling or mitigating any pest; any substance/mixture of substances intended as a plant
regulator, defoliant or desiccant.
pH: A measure of alkalinity or acidity on a scale whose values range from 0 to 14 with 7
representing neutral. Numbers less than 7 correspond to increasing acidity. Numbers greater
than 7 correspond to increasing alkalinity.
Point Source Discharges: Any discernible, confined, and discrete conveyance, including but
not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling
stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other
floating craft from which pollutants are or may be discharged. This term does not include return
flows from irrigated agriculture or agricultural storm water runoff.
Pollutant or Contaminant: Any element, substance, compound, or mixture which after release
into the environment and upon exposure, ingestion, inhalation, or assimilation into any
organism, either directly from the environment or indirectly by ingesting through food chains, will
or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer,
genetic mutation, physiological malfunctions, or physical deformation in such organisms or their
offspring. It presents an imminent and substantial danger to public health or welfare.
Pollution Prevention: Any source reduction activity that results in the reduction of total volume
of waste, reduction of toxicity of waste, or both, as long as the reduction is consistent with the
goal of minimizing present and future risks to public health and the environment. Transfer of
hazardous constituents from one environmental medium to another does not constitute waste
minimization (see waste minimization).
Polychlorinated biphenyls (PCBs): A hazardous chemical once widely used in electrical
transformer oil and now subject to a manufacturing ban and use restrictions under TSCA.
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.
Environmental Screening Checklist and
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Glossary of Terms
Reasonably Available Control Technology (RACT): Control technology that is reasonably
available and both technologically and economically feasible. Usuall
nฐnattainment areas= in st ซ 'ess stringent than
set forth by the EPA,
hazardous substances into the environment. This includes the abandonment oTbaaels
contamers, and other closed receptacles containing any hazardous substance o po futant
Under environmental laws, the term "release" does not include releases wNch resuฐ in
a *" which sX'ersons may
qUantity ฐf a CERCLA hazardous substance or
mซnซnm Ctฐ'??rVai!?n 3nd Recoverv Act (RCRA): The federal act which regulates the
Sedimentation: The act or process of depositing sediment.
Site Inspection: The collection of information from a Superfund site to determine the extent
aslessS. 2afdS PฐSed ^ the Site" U fฐIIOWS and is mฐre extensive ^an a prelimlnafy
Sฐ'id; sem,i-solid- or licluid materia' Produced by the process of settling or sinkina
by gravity. Sludges are generally waste products and are commonfy generate bv
municipal and mdustnal water treatment processes and air pollution contro processes
^ ซ ซปซ ^es must^eTe^d to
Small Quantity Generators (SQGs): One of the three classes of hazardous waste generators
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Glossary of Terms
under RCRA. SQGs produce between 100 and 1,000 kilograms of hazardous waste at a given
location.
Soil and Groundwater Analysis: Tests used to determine the presence of substance
contamination and concentration levels. The analysis may involve soil borings and the
installation of test pits and/or monitoring wells.
Solid Waste: Any garbage, refuse, sludge, or other waste materials not excluded by definition.
Exclusions include domestic sewage and any mixture of other wastes that pass through a
sewer system to a publicly-owned treatment works (POTW); industrial wastewater discharges
that are point source discharges subject to regulation under the Clean Water Act; irrigation
return flows; nuclear materials defined by the Atomic Energy Act; and "in situ" or "in position"
mining materials. Note that wastewaters being collected, stored, or treated before discharge
and sludges generated by wastewater treatment are not excluded. EPA defines hazardous
waste as a subset of solid waste.
Solvent: Any substance that can dissolve another substance. The term is most often used to
mean petroleum-based solvents, capable of dissolving greases, oils, tars, and asphalts. Many
petroleum-based solvents are volatile, flammable, may be hazardous, and may be regulated as
an air pollutant. Used solvents being disposed of (even if recycled) must be manifested as
hazardous waste unless exempted.
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.
Superfund Amendments and Reauthorization Act (SARA): The amendments to CERCLA
which increased available funds for site cleanups, added cleanup standards, and required
hazardous waste operations training for site workers and emergency response personnel.
Superfund: The common name for CERCLA. It also refers to the fund that is to be used for
cleaning up hazardous substance sites.
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Glossary of Terms
Toxic Substances Control Act (TSCA): The federal law designed to evaluate the human
health and environmental effects of all chemical substances entering the U.S. market, to
establish an inventory of existing chemicals, and to regulate the use and disposal of toxic
substances. PCBs are regulated under TSCA.
Toxicity Characteristic Leaching Procedure (TCLP): A physical/chemical analytical
procedure used to determine if a substance is classified as a toxic hazardous waste. If the test
results show that a solid waste exceeds any of the limits prescribed for 39 specific
contaminants, the waste is deemed to be a characteristically toxic hazardous waste. (The other
three characteristics are corrosivity, ignitability and reactivity.)
Transporter of Hazardous Waste: Entity that moves or transports hazardous waste by truck,
rail, boat, or plane and has received an EPA hazardous waste transporter ID number. Some
states also require proper permits. (On-site movement of hazardous waste does not apply.)
Transporters of hazardous waste must properly manifest and record movement as part of
"cradle-to-grave" tracking required by RCRA. In addition, transporters must follow Department
of Transportation (DOT) Hazardous Materials regulations and must immediately notify the
appropriate officials if a release or incident occurs. Transporters are responsible for
undertaking emergency response to any accident that occurs during transportation.
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 contain 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 TSDFs operating under RCRA permits are required to
certify annually that they have waste minimization plans in place and that the plans are being
implemented at their facilities. Generators must also sign a waste minimization statement when
signing the manifest.
Waste Pile: Any non-containerized accumulation of solid, non-flowing hazardous waste that is
used for treatment or storage.
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Glossary of Terms
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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