xvEPA
United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2223A)
EPA 305-B-00-005
August 2000
Environmental
Screening Checklist
and Workbook for
Trucking 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 state,
local, and tribal requirements.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-i
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Table of Contents
TABLE OF CONTENTS
INTRODUCTION W - III
How Can I Use the Checklist and Workbook? W - iii
How Are the Checklist and Workbook Organized? W- v
Where Can I Get Help? W - vi
CHECKLIST
SECTION 1.0 WASTE MANAGEMENT W- 1
1.1 Hazardous Waste Generation, Storage and Transport W -1
1.2 Used Oil and Filters W-9
1.3 Used Antifreeze W-15
1.4 Used Battery Storage and Disposal W-18
1.5 Used Shop Rags/Towels W-20
1.6 Absorbents W-22
1.7 Used Tires W-23
1.8 Brake Repair W-24
1.9 Metal Machining W-26
SECTION 2.0 WASTEWATER AND STORM WATER MANAGEMENT W-28
2.1 Wastewater and Storm Water Management W-28
2.2 Activities Generating Wastewater and/or Storm Water W-34
SECTION 3.0 MAINTENANCE ACTIVITIES W-37
3.1 Equipment Cleaning and Spent Solvents W-37
3.2 Fueling W-41
3.3 Asbestos Concerns - Building Renovation/Demolition W-44
3.4 Construction Activities W-46
3.5 Pesticide Use W-48
3.6 On-Site Waste Disposal of Nonhazardous Waste W-49
3.7 Yard Dust Control W-50
3.8 Painting/Paint Removal W-51
3.9 PCB-Containing Equipment . W-56
3.10 Air Conditioning Repair W-58
SECTION 4.0 STORAGE TANKS, SPCC, and EMERGENCY RESPONSE W-63
4.1 Underground Storage Tanks (USTs) W-63
4.2 Aboveground Storage Tanks (ASTs) W-65
4.3 Spill Prevention, Control, and Countermeasures (SPCC) and
Emergency Response W-67
SECTION 5.0 RECORDKEEPING W-71
5.1 NPDES Recordkeeping W-71
5.2 Recordkeeping for Air Emissions , W-72
5.3 RCRA Recordkeeping ". . W-73
5.4 Recordkeeping for Underground Storage Tanks W-74
5.5 Records of Pesticide Application . W-77
GLOSSARY OF TERMS G -1
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W- ii
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Introduction
INTRODUCTION
The United States Environmental Protection Agency (EPA) is providing the Environmental
Screening Checklist and Workbook for the Trucking Industry as a public service to the trucking
industry. EPA's Office of Compliance, through various meetings with industry representatives,
facility owners, and technicians, determined there is a need for clear information for facilities to
help them attain or remain in compliance with applicable federal environmental regulations.
The checklist and workbook highlight important or key environmental requirements as they
apply to the various federal environmental programs.
How CAN I USE THE CHECKLIST AND WORKBOOK?
You can use the checklist and workbook to evaluate your facility's compliance with the federal
environmental regulations which are applicable to the trucking industry. The term facility
refers to , but is not limited to, trucking terminals, truck maintenance shops, etc. overseen by
owners/operators, managers, field personnel, etc. who engage in trucking operations. If
problems with compliance are discovered while completing the checklist, you may want to
conduct a more comprehensive self-audit.
You can use the checklist and workbook to evaluate the compliance of either specific activities
or areas of your facility or your entire facility. Specific areas of your facility that you may want
to review are shown in Exhibit 1. This exhibit, "Index of Activities and Requirements for the
Trucking Industry," is a pictorial representation of specific activities that are regulated or
specific environmental requirements at a trucking facility. A page reference is included next to
each activity/requirement which takes you to the appropriate section of the workbook where
this topic is discussed. In addition, this exhibit also includes hotlines that you can contact to
obtain more information on applicable environmental requirements. As indicated on the
exhibit, one good source of environmental information for the transportation sector is the
Transportation Environmental Resource Center (TERC). You can reach TERC to request
more information on environmental issues or get answers to your transportation-related
environmental questions by phone or on the world wide web:
TERC Toil-Free Info-Line: 1-888-459-0656
TERC Internet Address: http://www.transource.org
Please remember that all of these materials are a beginning, not the final word, on
environmental compliance requirements. While federal environmental requirements are
highlighted in the checklist and workbook, a comprehensive discussion of all requirements is
NOT included. In addition to federal requirements, you may be subject to state, tribal, and/or
local requirements. You can use these materials to build a basic understanding or increase
your knowledge of federal environmental requirements, and then seek additional assistance
from various federal, state, tribal, and local agencies.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Introduction
How ARE THE CHECKLIST AND WORKBOOK ORGANIZED?
What Is Included? Following this introductory section are the checklist and workbook.
These materials include the following sections:
• Section 1.0 Waste Management
• Section 2.0 Wastewater and Storm Water Management
• Section 3.0 Maintenance Activities
• Section 4.0 Storage Tanks, SPCC, and Emergency Response
• Section 5.0 Recordkeeping
Following these five sections, a glossary is provided for your use.
Where Do I Start? You may first want to become familiar with the workbook because it is more
comprehensive than the checklist in terms of environmental compliance information and
issues. Once you have become familiar with the workbook, you can use the checklist by itself
to conduct a compliance evaluation of your facility.
The two page checklist, located after this introductory text, is basically a streamlined version of
the workbook and has been included to help make the evaluation of your facility's compliance
as easy and efficient as possible. Because the checklist was designed to evaluate specific
activities and requirements at your operation, it does NOT include all of the questions or
activities found in the workbook.
Each checklist question will ask you about key environmental requirements that are applicable
to a trucking facility. After reading each question, pick the most appropriate response for your
facility. If you are unsure of what is being asked by the question or what a response means
when using the checklist, refer to the same question in the workbook. The workbook includes
some general explanatory text for
each question, as well as
A
explanations of each response.
"•" 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 V" next to a response in the guide indicates
that is the preferred response in terms of
environmental compliance. If you select a
response without a "•", you may still be in
compliance. However, you should verify that you
are in compliance by contacting the appropriate
federal or state regulatory agency and discussing
your activity with them.
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.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Introduction
WHERE CAN I GET HELP?
During the evaluation and everyday operation of your facility, you may need to obtain
additional information on specific environmental requirements. Many resources are available
to you which can provide valuable
information on federal
environmental requirements,
pollution prevention, and other
topics. Some of these resources,
which can be contacted by
telephone or accessed through the
Internet, include publications,
hotlines and information lines, EPA
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 trucking industry, can be
downloaded electronically at: http://es.epa.gov/oeca/sector/index.html Also copies
can be ordered from GPO at (202) 512-1800.
Profile of the Ground Transportation Industry - Railroad, Trucking, and Pipeline,
EPA/310-R-97-002 (134 pages)
Profile of the Transportation Equipment Cleaning Industry, EPA/310-R-95-018
(81 pages)
Transportation Equipment Cleaning Industry Effluent Guidelines and Standards -
Proposed Rule. EPA is proposing a regulation that will establish technology-based
effluent limitations guidelines for the discharge of pollutants into waters of the U.S. and
into publicly owned treatment works by existing and new facilities that perform
transportation equipment cleaning operations. For more information, call (202) 260-
4992.
Code of Federal Regulation (CFR) References.
Website: http://www.access.gpo.gov/nara/cfr/index.html
Hotlines and Information Lines
• Transportation Environmental Resource Center (TERC) Information Line
Telephone: (888) 459-0656
Website: http://www.transource.org
This resource center is designed to help transportation industries stay on top of
environmental requirements and technologies.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Introduction
American Trucking Associations
Telephone: (703) 838-1700
Website: http://www.greentruck.com
ATA is a trade association representing trucking interests before government on
a wide variety of issues.
Air Risk Information Support Center Hotline
Telephone: (919) 541-0888
Fax: (919) 541-0245
This hotline provides technical assistance and information in areas of health,
risk, and exposure assessment for toxic and air pollutants.
Emergency and Remedial Response Fax-On Demand Service
Telephone: (202) 651-2062
This service offers one-way fax documents about Emergency and Remedial
Response programs.
Emergency and Remedial Response Information
Telephone: (703) 603-8960 or (800) 424-9346 (RCRA/UST, Superfund, and
EPCRA Hotline below)
Environmental Justice Hotline
Telephone: (800) 962-6215
This hotline provides environmental assistance and information relating to
environmental justice issues, including brownfields. See "Brownfields" listing
under Pollution Prevention Websites below for more information.
Hazardous Waste Generator and Recycling
Telephone: (703) 308-8850
This office provides information regarding regulations and guidance concerning
hazardous waste generators, including RCRA manifest and the definitions.
Hazardous Waste - Permits and State Programs
Telephone: (703) 308-8404
This office provides outreach and coordination of RCRA hazardous waste
programs implementation, including permitting, clean up and technical
approach.
Hazardous Waste - Risk Assessment and Economic Analysis
Telephone: (703) 308-8855
This office provides toxicology and exposure data; health and ecological risk
assessment; and sampling, statistical, and analytical methods.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Introduction
Hazardous Waste Information
Telephone: (703) 308-8482
This office provides RCRA Government Performance Results Act (GPRA)
coordination program information collection outreach and guidance.
Hazardous Waste Permits
Telephone: (703) 308-8196
This office provides information regarding regulations and guidance for RCRA
hazardous waste permitting program for waste treatment, storage, and disposal.
National Pesticides Information Line
Telephone: (800) 858-7378
This service provides callers information relating to pesticide usage, including
label information, incident investigations, emergency human and animal
treatment safety practices and clean-up and disposal.
National Response Center Hotline/Oil and Hazardous Material Spills
Telephone: (800) 424-8802 or (202) 267-2675
Fax:(202)267-2165
This hotline can be used by callers to report oil and hazardous material spills
that (1) violate applicable water quality standards, (2) cause a film or "sheen"
upon surface waters or adjoining shorelines, or (3) cause a sludge or emulsion
to be deposited beneath surface waters or upon adjoining shorelines. This
hotline is staffed 24 hours a day, 7 days a week, by U.S. Coast Guard officers
and marine science technicians.
Pollution Prevention Information Clearinghouse (PPIC)
Telephone: (202) 260-1023
Fax: (202) 260-4659
Website: http://www.epa.gov/opptintr/library/libppic.htm
PPIC is a free, non-regulatory service of EPA that provides answers and
referrals in response to questions from the public concerning pollution
prevention.
Resource Conservation and Recovery Act (RCRA) Information
Telephone: (415) 744-2074
This hotline responds to requests for information on hazardous waste
identification; generators; transporters; treatment, storage, and disposal
facilities; recycling sites; and export and import.
RCRA/Underground Storage Tanks (RCRA/UST), Superfund, and Emergency Planning
and Community Right-to-Know (EPCRA) Hotline
Telephone: (800) 424-9346 or (703) 412-9810
This hotline provides information about the RCRA/UST, Superfund, and EPCRA
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Introduction
programs Specifically, the hotline responds to inquiries about waste
minimization programs required under RCRA, source reduction and hazardous
waste combustion, and other components of the waste management regulatory
programs.
Safe Drinking Water Hotline
Telephone: (800) 426-4791 or (703) 285-1093
Fax:(703)285-1101
E-mail: hotline-sdwa@epamail.epa.gov
This hotline provides information about EPA's drinking water regulations and
other related drinking water and groundwater topics. Technicians are available
to get details on legislation and regulations or provide important contacts for
water resources and information on drinking water and groundwater.
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.
Environmental Screening Checklist
and Workbook for the Trucking Industry
Augui
2000
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Introduction
• Underground Storage Tanks
Telephone: (703) 603-9900
Website: http://www.epa.gov/OUST/
This office directs callers on where to obtain information regarding underground
storage tanks.
• Used Filter Hotline
Telephone: (800) 99-FILTER (993-4583)
Website: http://www.filtercouncil.org
This hotline, sponsored by the Filter Manufacturers Council, provides
commercial generators of used oil filters with a summary of the state's filter
management regulations, referrals to companies that provide filter management
services, referrals to state agencies, and a brochure entitled "How to Choose a
Filter Management Service."
• Wetlands Information Hotline
Telephone: (800) 832-7828 or (703) 748-1304
This information line answers questions concerning the value and function of
wetlands and options for their protection, and accepts requests for certain
wetlands publications.
EPA Headquarters and Regional Office Information
EPA Headquarters
Telephone: (202) 260-1090
Fax: (202) 260-0279
Website: http://www.epa.gov/
Region 1 (CT, MA, ME, NH, Rl, VT)
Telephone: (617) 918-1111
Toll-free: (888) 372-7341
Website: http://www.epa.gov/region1/
Region 2 (NJ, NY, PR, VI)
Telephone: (212) 637-3000
Website: http://www.epa.gov/region2/ '
Region 3 (DC, DE, MD, PA, VA, WV)
Telephone: (215) 814-5000
Toll-free: (800) 438-2474
Website: http://www.epa.gov/region3/
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Telephone: (404) 562-9900
Toll-free: (800) 241-1754
Website: http://www.epa.gov/region4/
Region 5 (IL, IN, Ml, MN, OH, Wl)
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Introduction
Telephone: (312) 353-2000
Toll-free: (800) 621-8431
Website: http://www.epa.gov/region5/
Region 6 (AR, LA, NM, OK, TX)
Telephone: (214) 665-2200
Toll- free: (800) 887-6063
Website: http://www.epa.gov/region6/
Region 7 (IA, KS, MO, NE)
Telephone: (913) 551-7003
Toll- free: (800) 223-0425
Website: http://www.epa.gov/region7/
Region 8 (CO, MT, ND, SD, UT, WY)
Telephone: (303) 312-6312
Toll-free: (800)227-8917
Website: http://www.epa.gov/region8/
Region 9 (AZ, CA, HI, NV)
Telephone: (415) 744-1305
Website: http://www.epa.gov/region9/
Region 10 (AK, ID, OR, WA)
Telephone: (206) 553-1200
Toll-free: (800) 424-4372
Website: http://www.epa.gov/region10/
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.
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August 2000
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Introduction
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.
EPA's Office of Underground Storage Tanks
Website: http://www.epa.gov/OUST/
This site provides access to federal publications and links to other resources
about preventing pollution from underground storage tanks containing
petroleum or hazardous substances.
EPA's Oil Program
Website: http://www.epa.gov/oilspill
This site contains comprehensive information on oil spill prevention,
preparedness, and response.
EPA's Brownfields
Website: http://www.epa.gov/swerosps/bf/index.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.
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August 2000
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introduction
National Pollution Prevention Roundtable Home Page
Website: http://www.p2.org/
This site provides access to the latest information on legislative and regulatory
P2 developments, National Roundtable publications, state P2 program
websites, and a directory of industrial P2 publications.
Pollution Prevention Information Clearinghouse
Website: http://www.epa.gov/opptintr/library/libppic.htm
Operated by EPA's Office of Pollution Prevention and Toxics, this clearinghouse
is a free, non-regulatory service that provides telephone reference and referral,
document distribution for selected EPA documents, and a special collection
available for interlibrary loan.
Pollution Prevention Cooperatives
Coordinated with EPA's Enviro$en$e program, these cooperatives provide easy
access to pollution prevention and cleaner production resources around the
Internet.
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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Facility Name:
Facility Location:
Site Reviewer:
Date:
Hazardous Waste
Generation,
Storage, and
Transport*
Used Oil and
Filters*
Used Antifreeze*
Used Battery
Storage and
Disposal*
Used Shop
Rags/Towels*
Absorbents*
Used Tires
Brake Repair*
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)
Does the facility meet all hazardous waste storage (quantity and time) requirements? (p. W-7)
How does the facility dispose of its hazardous waste? (p. W-7)
Does the facility have a written contingency plan or basic contingency procedures in place for
responding to spills and releases of hazardous waste? (p. W-8)
Are used oil containers/tanks and associated piping labeled "used oil?" (p. W-10)
Are used oil containers/tanks and associated piping leak free?" (p. W-10)
Does the facility prevent the mixing of used oil with hazardous waste? (p. W-10)
How does the facility manage/dispose of used oil? (p. W-l 1)
How does the facility manage/dispose of used oil filters? (p. W-l 3)
How does the facility manage/dispose of used fuel filters? (p. W-14)
In terms of storage, is used antifreeze contained, segregated, and labeled? (p. W-l 5)
Has the facility determined if it generates any antifreeze that is hazardous waste? (p. W-16)
If storing used batteries, does the facility protect them from storm water contact?(p. W-l 9)
How does the facility manage/dispose of used batteries? (p. W-l 9)
How does the facility manage/dispose of used shop rags and towels? (p. W-21)
Does the facility determine if used absorbents are hazardous before disposal? (p. W-22)
How does the facility manage/dispose of used tires? (p. W-23)
How does the facility manage asbestos brake pads and asbestos-containing material (ACM)
waste? (p. W-25) '
YD N D NA D
Y a No NA a
YD No NA a
Ships haz. waste off site/ Disposes
of hazardous waste on-site and is ;
RCRA-permitted TSDF/Other/NA
Ya No NAn
YD No NA o
YD No NA o
YD N D NA o
Sent off site for recycling / Bumec
in on-site space heater /Burned
off site/ Other /NA
Recycle/Srvc.company/Other/NA
Recycle /Srvc.company/ Managed
as hazardous waste /Other / NA
YD No NA o
YD No NA o
YD No NAD
Return to supplier/ Recycle /Srvc
company/ Sent to Universal wasti
handler/ Sent to hazardous waste
landfill/ Other/ NA
Laundry service / Burned for hea'
/ Other/ NA
YD No NA D
Resale/Retread/Recycle/Other/N,
Recycled off site/ Disposed bv
vendor/ EPA-approved disposal
site/ Other/ NA
2.0 WASTEWATER AND STORM WATER MANAGEMENT
Wastewater and
Storm Water
Management*
Activities
Generating
Wastewater/
Storm Water*
Can the facility identify the final destination of all its drains? (p. W-29)
If the facility discharges to a surface water does it have an NPDES permit? (p. W-3 1 )
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)
If discharging to an underground injection control (UIC) well, does the facility comply with UIC
program requirements? (p. W-33)
How does the facility manage the sludge from an oil/water separator? (p. W-34)
If the facility stores materials outside, are thev protected from contact with storm water?
(p. W-35) ' '
YD N D NA c
Yo No NA D
YD N D NA o
YD No NA D
YD No NA D
YD No NAD
Off-site disposal as hazardous
waste / Off-site disposal to othei
facility / On-site disposal / NA
YD No NA o
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Equipment
Cleaning and
Spent Solvents*
ENVIRONMENTAL SCREENING CHECKLIST FOR THE TRUCKING INDUSTRY
3.0 MAINTENANCE ACTIVITIES * *
If halogenated solvents are used in cleaning equipment, has the facility submitted a notification
report To the air permitting agency? (p. W-39)
Fueling*
Asbestos
Concerns*
Construction
Activities*
Pesticide Use*
Yard Dust
Control*
—
Painting/
Paint Removal*
How does the facility manage/dispose of spent solvents? (p. W-40)
Do fuel delivery records indicate compliance with appropriate fuel requirements? (p. W-42)
Does the facility use overfill protection measures, spill containment methods, and spill response
equipment during fueling? (p. W-44)
Has the facility assessed all buildings and structures built prior to 1980 for their potential for
containing asbestos and treated accordingly? (p. W-45) ^^^
— __ i
Are there any endangered species which may be affected by construction activities? (p. W-47)
Has the facility obtained a Section 404 permit for any projects that may impact wetlands?
(p. W-47)
——.. i
Are restricted use pesticides (RUPs) applied only by a certified commercial applicator? (p. W-49)
=_^_^_________===========================================
Does the facility prohibit the use of used oils or other liquid wastes to suppress dust? (p. W-51)
YD N D NA n
Third party vendor / Permit]
discharge to storm sewers c
surface waters / Sanitary se
with POTW approval / ™-
YD N D NA
N D NA
ND NAD
=====
NO NAD
YD No NA D
Air Conditioning
Repair*
Underground
Storage Tanks
_... —
Does the facility have air permits? (p. W-52)
How does the facility manage/dispose of paint stripping wastes and baghouse dusts? (p. W-53)
When not in use, does the facility store paints in labeled container? (p. W-54)
How does the facility manage/dispose of used paints and painting waste products? (p. W-55)
•^=^^r^^=====================^=============:==========:=:
How does the facility dispose of appliances containing ozone-depleting refrigerants? (p. W-61)
YD
YD
ND NAD
ND NAD
YD N D NA D
Recycle / Municipal or ha
landfill/ Other /NA
YD N D NA D
Abovcground
StorageTanks"
— ———
SPCC and
Emergency
Response*
4.0 STOI^GET^VKS, SPCC. ANDEMERGENCYRESPONSE
Has the State/Tribal UST program office been notified of any USTs located on site? (p. W-64)
Does the facility conduct leak detection for tank and piping of all on-site USTs? (p. W-64)
Do USTs at the facility meet requirements for spill, overfill,and corrosion protection? (p. W-65)
Does the facility inspect ASTs on a periodic basis for leaks and other hazardous conditions?
(p. W-67)
Does the facility have a Spill Prevention, Control, and Countermeasures (SPCC) plan signed by a
T\ f~ !__._1 f?_*«« AA.-O f-n \I7 /^C^
Professional Engineer? (p. W-69)
Is the phone number for the National Response Center posted on site for immediate reporting of
oil spills? (p. W-70)
Return to supplier / Reuse!
Recycle / Other / NA
Landfill / Waste hauler / S<|
metal recycler / Other / N/
YD N D NA
YD N D NA D
NAD
— —
NAD
YD N D NA D
YD ND
Rccordkeeping
NPDES: Does the facility keep accurate records of monitoring information for the minimum
requirement of 3 years? (p. W-71)
Air: Does the facility meet the recordkeeping requirements of its air permit(s)? (p. W-72)
Air If the facility owns/operates appliances that contain ozone-depleting refrigerants, does the
facility maintain all required records? (p. W-73) -
RCRA- Does the facility keep copies of its manifests for the 3 year minimum requirement?
(p. W-73)
USTs: Does the facility maintain leak detection records ? (p. W-75)
USTs: Does the facility maintain corrosion protection records ? (p. W-75)
onal questions regarding these environmental compliance issues, refer to the workbook.
- in aaauion, the workbook includes environmental compliance questions regarding metal machining i
(p. W-49). and PCB-containing equipment (p. W-56).
YD ND- NAD
YD N D NA D
YD N D NA D
YD N D NA D
YD N D NA D
YD N D NA D
>> °n-
-------
Waste Management
SECTION 1.0 WASTE MANAGEMENT
I. I Hazardous Waste Generation, Storage, and
Transport
NOTE- The following questions, some of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
hazardous waste generation, storage, and transport for compliance with
environmental requirements:
a. Does the facility generate hazardous wastes? (p. W-4)
b. How much hazardous waste does the facility generate per month? (p. W-5)
c Does the facility have an EPA hazardous waste generator ID number?
(p. W-6)
d Does the facility store hazardous waste in appropriate storage containers?
(p. W-6)
e. Does the facility meet all hazardous waste storage (quantity and time)
requirements? (p. W-7)
f. How does the facility manage/dispose of its hazardous waste? (p. W-7)
g Does the facility have hazardous waste manifests or shipping papers on file?
(p. W-8)
h Does the facility have a written contingency plan or basic contingency
procedures in place for responding to spills and releases of hazardous
wastes? (p. W-8)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Identifying Hazardous Waste
As a trucking facility with service and
maintenance activities, the facility may produce
wastes that are hazardous. Therefore, It is
important that the facility identify and manage
hazardous wastes properly to protect itself,
coworkers, and others in the community, as well
as the environment. As a waste generator, the
facility is responsible for all steps in hazardous
waste management, from generation to final
disposal. A facility can be held liable for any
mismanagement of its wastes, even after the wastes leave the facility. Therefore, it is
important for every facility to know the facts. Some of these hazardous wastes are listed in
Exhibit 2.
If a facility thinks its waste is hazardous,
but is unsure, the facility should call the
RCRA/UST, Superfund, EPCRA Hotline
at 1-800-424-9346, or the Chemical
Referral Service Hotline at 1-800-262-
8200, which is maintained by the National
Chemical Manufacturer's Association.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-1
-------
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CM co -^r
-------
Waste Management
What is Hazardous Waste?
To be considered "hazardous waste," materials must first meet EPA's definition of "solid waste."
Solid waste is discarded material, such as garbage, refuse, and sludge, and it can include
solids, semisolids, liquids, or contained gaseous materials. Solid wastes that meet the following
criteria are considered hazardous and subject to regulations under the Resource Conservation
and Recovery Act (RCRA) (40 CFR Part 261):
• Listed waste. Waste is hazardous if it appears on one of four lists of hazardous wastes
published in 40 CFR Part 261 Subpart D. Currently, more than 400 wastes are listed.
Wastes are listed as hazardous because they are known to be harmful to human health and
the environment when not properly managed. Even when properly managed, some listed
wastes are so dangerous that they are called "acutely hazardous wastes." Examples of
acutely hazardous wastes include wastes generated from some pesticides that can be fatal
to humans even in low doses.
• Characteristic waste. If waste does not appear on one of the hazardous waste lists, it still
might be considered hazardous if it demonstrates one or more of the following
characteristics:
- Ignitable: Ignitable wastes can create fire under certain conditions (e.g., temperature,
pressure) or are spontaneously combustible (40 CFR 261.21). Examples include certain
used paints, degreasers, oils and solvents.
- Corrosive: Corrosive wastes are acids or bases that are capable of corroding metal,
such as storage tanks, containers, drums, and barrels (40 CFR 261.22). Examples
include rust removers, acid or alkaline cleaning fluids, and battery acid.
Reactive: Reactive wastes are unstable and explode or produce toxic fumes, gases,
and vapors when mixed with water (40 CFR 261.23). Examples include lithium-sulfide
batteries and explosives.
- Toxic: Toxic wastes are harmful or fatal when ingested or absorbed, or leach toxic
chemicals into the soil or groundwater when disposed of on land (40 CFR 261.24).
Examples include wastes that contain high concentrations of heavy metals, such as
cadmium, lead, or mercury.
A facility can determine if its waste is toxic by having it tested using the Toxicity
Characteristic Leaching Procedure (TCLP), or by process knowledge. TCLP can
be done at a laboratory. It is designed to replicate the leaching process and other
effects that occur when wastes are buried in a typical municipal landfill. If the leachate
from the waste contains any of the regulated contaminants at concentrations equal to or
greater than the regulatory levels, then the waste exhibits the toxicity characteristic.
Process knowledge is detailed information on wastes obtained from existing published
or documented waste analysis data or studies conducted on hazardous wastes
generated by similar processes. For example, EPA's lists of hazardous wastes in 40
CFR Part 261 (as discussed above) can be used as process knowledge.
Universal Waste Rule
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-3
-------
Waste Management
Universal Waste Rule
In 1995 EPA issued the Universal Waste Rule as an amendment to RCRA to reduce the
requlatory burden on businesses by providing an alternative and less stringent set of
management standards for three types of waste that potentially would be under hazardous
waste rules : (1) batteries (e.g., nickel cadmium, small sealed lead acid) that are spent (i.e will
not be reclaimed or regenerated at a battery recycling/reclamation facility); (2) pesticides that
have been suspended or canceled,
including those that are part of a
voluntary or mandatory recall under
the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA); and
(3) mercury thermostats including
temperature control devices
containing metallic mercury. Check
with the state regulatory agency to
see if it has adopted the Universal
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.
Waste Rule. For more information,
check website:
http://www.epa.gov/epaoswer/hazwa
ste/id/univwast. htm
1.1 a Does the facility generate hazardous waste?
Q Yes Facility has gone through the waste determination process or used
process knowledge and determined that it does generate hazardous
waste. See Exhibit 2 for common hazardous wastes generated by
trucking facilities.
Q No Facility has determined that it does not generate hazardous waste.
Q NA / Not Facility has not gone through this process. Note: Facility must
determined immediately conduct this process to determine if it is generating a
hazardous waste.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-4
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Waste Management
1.1b How much hazardous waste does the facility generate per month?
Generation occurs when a substance becomes a waste. When determining the volume
of waste generated, only waste that is in a container or other unit waiting to be
disposed of is considered "generated." Thus, solvent stored in a drum waiting for
disposal or recycling is "generated," while solvent in a parts washer that is currently in
use is not yet a waste and the facility has not generated it.
The facility generates: (Pick one)
Q
No more than 220 Ibs (100 kg) of hazardous waste per month. This is
approximately Yz 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.
Between 220 Ibs (100 kg) and 2,200 Ibs
(1,000 kg) of hazardous waste per month.
In this case, the facility generates more
than 1/4 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.
Over 2,200 Ibs (1,000 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.
Note: If the facility is a CESQG
and generates no more than 2.2
Ibs (1 kg) of acutely hazardous
waste (or 220 Ibs [100 kg] of
acutely hazardous waste spill
residues) in a calendar month,
and never store more than that
amount for any period of time, the
facility may manage the acutely
hazardous waste according to the
CESQG requirements. If the
facility generates more than 2.2
Ibs (1 kg) of acutely hazardous
waste, it must be managed
according to the LQG
requirements.
The total weight of hazardous waste generated
includes only waste (1) defined as hazardous by EPA regulations, (2) determined to be
hazardous by the facility, and (3) not otherwise exempt from counting. For example,
used oil that has not been mixed with anything and is destined for recycling does not
have to be counted.
Generators who periodically exceed or fall below their normal generation limits in any
given calendar month are called episodic generators. If the amount of waste
generated in a given calendar month places the generator in a different category, the
generator is responsible for complying with all applicable requirements of that category
for all waste generated during that calendar month. For example, if a generator
produces 300 kg of hazardous waste in March, that waste is subject to SQG
requirements; if the same generator produces 1,500 kg of hazardous waste in April,
that waste is subject to LQG requirements.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-5
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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), must have an EPA
hazardous waste generator ID number. This requirement applies even to episodic
generators who may fall into the SQG or LQG categories for one month only. This
number must appear 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 or 703-412-9810.
Q Yes Facility has obtained an 8-digit ID number from EPA or the state regulatory
agency that has been granted authority by EPA. •
Q No Facility has not obtained an EPA ID number.
Q NA Facility is a CESQG and therefore is not required to obtain an EPA ID
number.
1.1d Does the facility store hazardous waste in appropriate storage
containers?
Containers must meet the following requirements (40 CFR 262.34):
• Clearly marked with the words "Hazardous Waste" and the date when waste
accumulation began. Labels for this purpose maybe available from the hauler.
• Kept in good condition and stored in a manner that minimizes risks of ruptures,
leaks, or corrosion.
• Kept closed except when being filled or emptied, except if volatile explosion is
possible and emergency ventilation is needed.
• Inspected at least once per week for leaks or corrosion. Note: Some states may
require facilities to keep a written record of these inspections. Any problems
should be corrected immediately. If any corrections are made, they should be
noted in a permanent record and kept on file for at least 3 years.
• Stored in a manner that minimizes the potential for accidental mixing of
incompatible materials.
Q Yes Facility stores waste in containers that meet the above requirements. •
Q No Facility stores waste in containers that do not meet the above requirements.
Q NA Facility does not generate hazardous waste.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-6
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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 considered a treatment,
storage, and disposal facility (TSDF) and must obtain an operating permit.
• CESQGs have no maximum on-site time limits for storage but cannot accumulate
more than 2,200 Ibs (1,000 kg) of hazardous wastes or 2.2 Ibs (1 kg) of acutely
hazardous waste, or 220 Ibs (100 kg) of acutely hazardous waste spill residues, at
any time.
Q Vies Facility complies with all hazardous waste storage quantity and time
requirements. •
Q Wo Facility does not comply with all hazardous waste storage quantity and time
requirements.
Q NA Facility does not generate hazardous waste.
1.1 f How does the facility manage/dispose of its hazardous waste?
Q Ships hazardous waste off site to:
• A RCRA-permitted TSDF. •
• A recycling facility. •
• An interim status facility or •
• An exempt facility. •
Q Disposes of hazardous waste on site and is a RCRA-permitted TSDF. •
Q Other Note: If not managing hazardous waste by one of the above options, facility
is out of compliance and must rectify the situation immediately.
Q NA Facility does not generate hazardous waste.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-7
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Waste Management
1.1g Does the facility have hazardous waste manifests or shipping papers
on file?
For SQGs and LQGs, a Uniform Hazardous Waste Manifest must accompany each
hazardous waste shipment. [Exception: SQGs are not required to have manifests for
certain recyclable materials such as solvents, and there are some hazardous materials
(e.g., scrap metal) which do not have to be manifested.] Contact the state regulatory
agency for a Uniform Hazardous Waste Manifest form. CESQGs are not required to
use manifests.
A hazardous waste transporter should be able to assist in completing the manifest.
Manifests must be kept for 3 years (see "RCRA Recordkeeping" in Section 5.0).
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
EPA's RCRA/UST, Superfund, and EPCRA Hotline at 1-800-424-9346 or the state
regulatory agency.
Q Yes Facility has manifests and/or shipping papers on file for hazardous waste
transported. •
Q No Facility does not have manifests and/or shipping papers for hazardous
waste shipments.
Q NA Facility does not ship hazardous waste off site.
1.1h Does the facility have a written contingency plan or basic
contingency procedures in place for responding to spills and releases
of hazardous wastes?
If a facility is an LQG, it must have a written contingency plan that includes the
following elements (40 CFR 262.34):
• Instructions on what to do in the event of a fire, explosion, or release.
• The arrangements agreed to by local police and fire departments, hospitals, and
State and local emergency response teams to provide emergency services.
• The names, addresses, and phone numbers of all persons qualified to act as
emergency coordinator.
• Location of all emergency equipment at the facility and
• An evacuation plan.
Although a written contingency plan is not federally required for SQGs or CESQGs. it is
strongly recommended.
SQGs are required to have basic contingency procedures, which include the
following:
• An emergency coordinator (employee) who is responsible for coordinating all
emergency response measures.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-8
-------
Waste Management
• Information posted next to the telephone, including: (1) name and number of the
emergency coordinator; (2) locations of the fire extinguishers and spill control
material; and (3) telephone number of the fire department.
• Ensure that all employees are thoroughly familiar with proper waste handling and
emergency procedures.
It is also important to check with the state and local authorities for any additional
contingency plan or emergency preparedness requirements.
Q Yes Facility has a written contingency plan or basic contingency procedures in
place. •
Q No Facility does not have a written contingency plan or basic contingency
procedures in place.
Q NA Facility is not an SQG or an LQG (i.e., facility is a CESQG) and is not
required to meet RCRA's emergency preparedness requirements.
1.2 Used Oil and 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 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 used fuel filters before
disposal? (p. W-13)
f. How does the facility manage/dispose of used oil filters? (p. W-13)
g. Has the facility determined if its used fuel filters are hazardous? (p. W-13)
h. How does the facility manage/dispose of used fuel filters? (p. W-14)
I.
Does the facility inspect used oil filter storage areas for oil spills and leaks?
(p. W-14)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-9
-------
Waste Management
Used Oil
Facilities should consider several environmental issues when performing any oil handling
activities such as oil changes or oil/fuel filter replacement to motor vehicles, maintenance
equipment, and other motors. Most facilities recycle or reclaim used oil. Used oils are
regulated under the Used Oil Standards (40 CFR Part 279), and are typically not classified as
hazardous wastes at the federal level. However, some states may have stricter disposal
requirements. In addition, used oil generators are also subject to all applicable Spill
Prevention, Control and Countermeasures (SPCC) and underground storage tank (UST)
standards. Contact the state regulatory agency to determine the used oil disposal
requirements. Facilities should maintain all records on their used oil storage and recycling
activities.
1.2a
Are used oil containers/tanks and associated piping leak free and
labeled "used oil"?
Used oil must be stored in leak free containers and
be labeled with the words "used oil." No special
labels are necessary, provided that the words "used
oil" are visible at all times. Spray painting, crayon,
or handwritten (preferably not in pencil) labels are
okay. Used motor oil may be mixed 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 (UST)
or aboveground storage tank
(AST) regulations.
Some facilities have pipes that connect to the used oil storage tank. Piping runs from
the inside of the building to the outside disposal point (i.e., tank). This way, technicians
can pour their oil in a funnel or small bucket which is attached to the piping, and the oil
goes directly to the tank. In this case, label the funnel/bucket or piping 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?
A facility should not mix hazardous waste fluids, such as used solvent, gasoline, or
other hazardous substances, with used oil, or the entire volume may be classified as
hazardous waste. For example, while mixing a listed hazardous waste with used oil will
result in a hazardous waste, mixing a characteristic hazardous waste with used oil will
not result in a hazardous waste, unless it exhibits a hazardous characteristic (see
Section 1.1). One may mix used motor oil with other used oils (e.g., transmission fluid
or brake fluid) and stored in the same container/tank. A facility with questions about
which specific products may be mixed with used oil should call the RCRA/UST,
Superfund, and EPCRA Hotline at 1-800-424-9346.
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Q Yes Facility prevents the mixing of used oil with hazardous waste. •
Q No Facility does not prevent the mixing of used oil with hazardous waste.
Q NA Facility does not generate used oil.
1.2c How does the facility manage/dispose of its used oil?
Recycling and burning (for energy recovery) of used oil that has not been mixed with
any other waste are the most environmentally protective and often the most
economical approach to handling used oil.
Under Used Oil Management Standards, generators can burn used oil as long as:
• The used oil is generated on site.
• Space heaters with maximum heating capacity of 0.5 million BTUs per hour or less
are used to burn the used oil.
• The gases from the space heater are vented outside.
A facility may dispose of used hydraulic oils as used oil and it can blend them with
other used oils, such as engine and lube oils. Recycling and reclamation are preferred
over disposal.
Q Sent off site
for recycling
Facility has a regular hauler who takes the used oil to a
recycling facility. •
Q Burned in an Facility burns its used oil in an on-site heater with maximum
on site space heater 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. •!
Burned off site
Q Other
Q NA
Facility has a hauler or takes its own oil to a used oil
burner. •
Facility does not use any of the methods described above.
Note: Used oil should not be disposed of in sewers, drains,
dumpsters, on the ground, or used as dust suppressants.
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 to an approved used oil
collection center, it is required to (1) have an EPA ID number and (2) be licensed as a
used oil transporter.
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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 transporter.
Q NA Facility does not transport more than 55 gallons of used oil off site at one
time.
Used Filters
Used Oil Filters: Used oil filters are exempt from federal hazardous waste requirements as
long as the filters:
• Are not terne-plated. (Terne is an alloy of tin and lead. The lead in the terne-
plating makes the filters hazardous.)
• Have been properly drained (i.e., hot-drained) of used oil.
According to federal regulations, a facility 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, it should be placed
with its gasket side down in a drain pan. If the filter has an anti-drain valve, the
"dome end" of the filter should be punctured with a screwdriver (or similar device)
so that oil can flow freely. Then allow the filter to drain for 12 to 14 hours.
• Crushing: Crush the filter by using a mechanical, pneumatic, or hydraulic device to
squeeze out the used oil/fuel and compact the remaining filter materials.
• Disassembly: Separate the filter into its different parts using a mechanical device.
This allows most of the used oil/fuel to drain from the filter, and the metal, rubber,
and paper parts of the filter to be recycled separately.
• Air Pressure: Place the filter into 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, make sure the container can hold any used oil that seeps from the filters.
Used fuel filters: Drain used fuel filters properly (using the same procedure as used oil
filters) and then test 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, 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. Manage metal filters as scrap metal if they are properly
drained.
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Note: Since disposal requirements of used filters may vary by state, consult the state
regulatory agency to assure proper disposal. For more information regarding state filter
management regulations, and referrals to state agencies and companies that provide filter
management services, refer to the Used Filter Hotline at 1-800-993-4583. This hotline is
sponsored by the Filter Manufacturers Council.
1.2e Does the facility completely drain used oil filters and/or used fuel
filters before disposal?
Q Yes Facility completely drains filters (i.e., no visible signs of free-flowing oil
remains) prior to disposal. •
Q No Facility does not completely drain filters prior to disposal.
Q NA Facility does not generate used oil or fuel filters.
1.2f How does the facility manage/dispose of used oil filters?
Q Recycle Filters are recycled for scrap metal. •
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.
Q NA Facility does not generate used oil filters.
1.2g Has the facility determined if its used fuel filters are hazardous?
Q Yes
a NO
Q NA
Facility has determined through testing if its used fuel filters are
hazardousV
Facility has not determined if its used fuel filters are hazardous.
Facility does not generate used fuel filters.
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•7.2/7 How does the facility manage/dispose of used fuel filters?
Note: If the facility determined used fuel filters are hazardous waste, they are counted
towards the facility's generator status and managed accordingly. See Section 1.1 for
more information on hazardous waste management.
Q Recycle
Q Service
Facility recycles used fuel filters. •
Facility contracts with a service which takes used fuel filters as
they are. •
Q Managed as Facility manages used fuel filters as hazardous waste. •
hazardous waste
Q Trash
Q Other
UNA
Facility discards filters in the dumpster (e.g., not segregated from
other waste such as paper, plastics, food, etc.).
Method of disposal is not listed above. Note: The facility may be
out of compliance. Contact the state regulatory agency for
assistance.
Facility does not generate used fuel filters.
1.21 Does the facility inspect used oil filter storage areas for oil spills and
leaks?
Engine oil can enter the environment when oil filters are changed and stored and when
engines drip crankcase and lube oils. Implement preventive measures to minimize oil
dripping by regular maintenance of trucks and other support vehicles. Take care not to
store used oil and used oil filters near floor drains. Many facilities keep absorbent
materials close to oil drums or oil handling locations in order to protect nearby areas
from contamination.
A facility should regularly inspect all areas where oils are received, stored, used,
changed, and potentially spilled 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.
All spills should be contained and cleaned up immediately after detection. The facility
should consult its Spill Prevention, Control, and Countermeasures (SPCC) plan in the
event of a spill or leak. The SPCC plan contains detailed information on spill cleanup
and remediation. In addition, if any oil enters surface waterways and produces a
sheen, notify the National Response Center (1-800-424-8802) and state emergency
response agency immediately.
Q Yes Facility inspects storage areas for oil spills. •
Q No Facility does not inspect storage areas for oil spills.
Q NA Facility does not have storage areas for used oil and filters.
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1.3 Used Antifreeze
NOTE: The following questions, some of which are included in the accompanying
checklist (highlighted in bold), will help the facility examine its operations
relating to used antifreeze for compliance with environmental requirements:
a. In terms of storage, does the facility contain, segregate, and label used
antifreeze? (p. W-15)
b. Has the facility determined if it generates any antifreeze that is hazardous
waste? (p. W-16)
c. Does the facility reclaim used antifreeze on site in a closed loop system?
(p. W-16)
d. If not reclaimed in a closed loop system, does the facility count waste antifreeze
counted the facility generator status? (p. W-17)
e. If facility does not reclaim used antifreeze on site in a closed loop system, how
does the facility manage it? (p. W-17)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Used Antifreeze
Trucks require regular changing of coolants, such as antifreeze. To minimize releases to the
environment, the facility should drain and replace antifreeze in areas where there are no
connections to storm drains or municipal sewers. They should clean up minor spills prior to
reaching drains. The facility should collect and store antifreeze in separate containers and not
mix with other fluids.
1.3a In terms of storage, does the facility contain, segregate, and label
used antifreeze?
Contained. Containers are closed (e.g., lids are on, caps are screwed on tight, except
when actually adding or removing liquid).
Segregated. Used antifreeze is in its own container and not mixed with other liquids.
Labeled. Labels or color coding indicates that the container holds only antifreeze. In
contrast to used oil, there are no specific labels for antifreeze. To be considered
properly labeled, the drum/container/tank should simply have the words "used
antifreeze," or "waste antifreeze," or "antifreeze only," or similar wording that
distinguishes antifreeze storage from oil and solvent storage. Words can be spray
painted, stenciled, crayoned, or more formally labeled.
Q Yes Used antifreeze is contained, segregated, and labeled. •
Q Wo Used antifreeze is not contained, segregated, and labeled.
Q NA Facility does not generate used antifreeze.
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1.3b Has the facility determined if it generates any antifreeze that is
hazardous waste?
Used antifreeze may be characterized as hazardous waste through testing or by
process knowledge.
If a facility makes the hazardous/nonhazardous determination solely by testing, it
must test each batch of antifreeze changed from each vehicle serviced.
• If a facility uses process knowledge, the determination must involve a demonstrated
understanding of the potentially hazardous constituents in antifreeze. Such a
demonstrated understanding could include a combination of the information on the
MSDS for the type of antifreeze used, a referral to a previous test that
demonstrated that antifreeze from new vehicles does not contain metals, and/or
having a procedure to ensure that any suspect antifreeze is segregated from
antifreeze known not to be hazardous. See Section 1.1 (a) for more information
about process knowledge.
In addition to testing and process knowledge, there are two functional indicators
that show the antifreeze is (or is likely to be) a hazardous waste. First, antifreeze is
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
characterized as hazardous for metals content.
Q Yes Facility has determined whether its used antifreeze is hazardous by testing
or from process knowledge. •
Q No Facility has not determined whether its used antifreeze is hazardous.
Q NA Facility does not generate used antifreeze.
1.3c Does the facility reclaim used antifreeze on site in a closed loop
system?
To avoid having to manage and dispose of used antifreeze as a hazardous waste, a
facility can reclaim used antifreeze in a closed loop system that connects directly to
the radiator, filters the antifreeze and returns the antifreeze directly back into the
vehicle. EPA does not consider such reclaimed material to be a solid waste. Thus,
even though the antifreeze may be hazardous, it is not 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. Closed loop systems are preferred for reclaiming/recycling
antifreeze.
Q Ves Facility reclaims used antifreeze in a "closed loop" system. •
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Q No Facility does not reclaim used antifreeze in a "closed loop" system.
Q NA Facility does not generate used antifreeze.
1.3d If not reclaimed in a closed loop system, does the facility count
waste antifreeze toward the facility generator status?
Waste antifreeze that is a hazardous waste and not reclaimed in a closed loop system
needs to be considered as part of the total volume of hazardous waste generated in any
month.
Q Yes Facility includes hazardous waste antifreeze that is not reclaimed in a closed
loop system in the total volume of hazardous waste generated. •
Q No Facility does not include hazardous waste antifreeze.
Q NA Facility does not generate used antifreeze.
1.3e If facility does not reclaim used antifreeze on site in a closed loop
system, how does the facility manage it?
Q Recycled in a non-closed
system on site
Q Recycled off site
Q Landfill
Mixed with other fluids
Q UIC well
Q Other
Q NA
Facility manages used antifreeze in a non-closed
system on site according to RCRA hazardous
waste requirements. •
Facility sends used antifreeze for recycling off site.
Facility has on file the EPA ID number of the
recycler (see the shipping papers). •
Facility disposes of used antifreeze at a landfill.
Many landfills have a tank designated for used
antifreeze. "Landfill" does not include antifreeze
that is dumped in the trash.
Facility mixes used antifreeze with used oil,
solvents, or other fluid.
Facility discharges used antifreeze into an
underground injection control (UIC) well. Note:
The facility should immediately stop this method of
disposal and notify the EPA regional and/or state
UIC authority.
Method of disposal is not listed here.
Facility does not generate used antifreeze.
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1.4 Used Battery Storage and Disposal
NOTE: The following questions, some of which are included in the accompanying
checklist (highlighted in bold), will help the facility examine its operations
relating to used battery storage and disposal for compliance with environmental
requirements:
a. Has the facility determined whether its batteries are regulated as universal
waste or hazardous waste? (p. W-18)
b. If storing used batteries, does the facility protect them from storm water
contact? (p. W-19)
c. How does the facility manage/dispose of used batteries? (p. W-19)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a "•") for environmental compliance.
1.4a Has the facility determined whether its batteries are regulated as
universal waste or hazardous waste?
There are many types of used batteries with different disposal requirements. Some of
these batteries may be classified as hazardous waste (see Section 1.1) if they are not
properly handled.
For more information on how batteries
are covered under the Universal Waste
Rule, contact the RCRA/UST,
Superfund, and EPCRA Hotline at 1-
800-424-9346. Note: Because the
Universal Waste Rule is less stringent
than RCRA, some states have not
adopted it. Check with the state
regulatory agency to see if it has adopted
the Universal Waste Rule.
Under the Universal Waste Rule (40 CFR
Part 273), if batteries do not exhibit
hazardous waste characteristics (see
Section 1.1), they may be regulated as
universal wastes and subject to 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 under universal wastes rules. Most
alkaline batteries are not hazardous waste
under RCRA and can be disposed of as general trash. Check with the local waste
authority to see if they have a battery collection program in place.
Q Yes Facility has gone through the waste determination process fas discussed in
Section 1.1) to determine whether its batteries should be regulated as
universal or hazardous waste. •
Q Wo Facility has not determined whether its batteries should be regulated as
universal or hazardous waste.
Q NA Facility does not generate used batteries.
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1.4b If storing used batteries, does the facility protect them from storm
water contact?
When placed out-of-service, the facility should transport batteries to an accumulation
area specifically designed for storage prior to removal from the site. The storage
accumulation area should protect the batteries from weather and storms. It should be
designed (1) with secondary containment to prevent any spillage or leakage from
contaminating the soil or surface waters; and (2) without floor drains that could receive
spills and deliver them to the storm sewer, sanitary sewer, surface water, or injection
well. One may store batteries inside or outside under a tarp or roof. Store batteries 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.
1.4c How does the facility manage/dispose of used batteries?
Q Return to supplier
Q Recycle
Q Service
Q Universal waste handler
Q Hazardous waste landfill
Q Other
QAM
Facility returns used batteries to supplier. •
Facility sends batteries to a recycling facility. •
Facility pays service company to pick up used
batteries. •
Facility sends used batteries classified as universal
waste to a universal waste handler. •
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.
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[ .5 Used Shop Rags/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 shop rags and towels for
compliance with environmental requirements:
a. How does the facility manage/dispose of used shop rags and towels ?
21)
b. How does the facility store used shop rags and towels on site? (p. W-21)
(p.W-
These questions appear in the following text, accompanied with a discussion of the preferred
answer (indicated with a "•") for environmental compliance.
Used Shop Rags and Towels
A facility must manage used shop rags and towels
as hazardous waste if they are contaminated with
a hazardous waste or display a hazardous
characteristic due to the presence of gasoline or
metal-contaminated antifreeze. EPA allows
facilities to manage these used rags and towels by
having them washed through a laundry service, or
disposing of them through an EPA-licensed
hazardous waste transporter and disposal facility.
A facility can recycle used shop rags and towels
contaminated with used oil; burn for energy
recovery under the same Used Oil Management
Standards existing for burning used oil. (See page
W-11, question 1.2c); or disposed of. According to
the used oil regulations, facilities 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, one may still need to handle the material as a hazardous waste if it contains a
hazardous waste or exhibits any property of hazardous waste. See Section 1.1 for more
information regarding hazardous wastes. Many facilities avoid the hazardous waste
determination process by sending rags to a laundering facility for washing, rather than disposal.
Shop Rag/Towel Laundering
Many states do not consider rags going
for laundering to be hazardous waste
(although a hazardous waste could be
generated by the launderer). This is
because the rag/towel, even if
contaminated with hazardous waste, is
not being discarded and therefore, the
hazardous waste requirements do not
apply. Keep in mind that some states
may consider these rags/towels to be
solid wastes, even if they go to a
laundry. Check with the state regulatory
agency on requirements for managing
shop rags/towels.
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1.5a How does the facility manage/dispose of used shop rags and towels?
Q Sent to supplier or Facility returns used absorbents to its supplier or pays
Service company service company to pick up used absorbents. •
Q Laundry service
Q Burned for heat
Q Hazardous waste
transporter
Q Trash
Q Other
QAM
Facility sends used rags/towels off site to be laundered, often
with technicians' uniforms. •
Facility mixes used rags/towels with used oil and burned in a
shop space heater with maximum heating capacity 0.5 million
BTUs 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 of through an EPA-licensed hazardous waste
transporter and disposal facility.
Facility disposes of used rags/towels with trash (in a
dumpster) and they are not segregated. If rags/towels are
contaminated with hazardous waste, the facility should not
dispose them of with trash, but manage them according to
one of the above options.
Method of disposal is not listed.
Facility does not generate used rags or shop towels.
1.5b How does the facility store used shop rags and towels stored on site?
Q Separate container Facility stores used rags/shop towels in a container (e.g.,
bucket, can, barrel, on a shelf or bench, etc.). •
Q Stored as hazardous Facility stores used rags/shop towels contaminated with
waste
Q Shop trash can
Q Floor
QNA
hazardous waste according to hazardous waste
requirements. • See Section 1.1.
Facility disposes used rags/shop towels in a can/dumpster
that contains all shop waste and not segregated.
Facility places use rags/shop towels on the floor, in a pile, or
they are simply scattered.
Facility does not generate used rags/shop towels.
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1.6 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 use sawdust, soil, or other commercial absorbents for spills or
leaks? (p. W-22)
b. Does the facility determine if used absorbents are hazardous before
disposal? (p. W-22)
c. How does the facility manage absorbents used for oil spills? (p. W-23)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
1.6a Does the facility use sawdust, soil, or other commercial absorbents
for spills or leaks ?
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," or "oil dry"), clay absorbent, pads, pillows, booms, towels, and other such
absorbent materials. Sawdust is also sometimes used as an absorbent. A facility must
use the proper absorbent for the type of chemical spilled. Once used in a cleanup,
dispose of these materials properly.
Q Yes Facility uses one or more of the above substances. •
Q No Facility does not use any of the above substances.
1.6b 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 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 determines if used absorbents are hazardous before disposal. •
Q No Facility does not characterize its absorbents.
Q NA Facility does not use absorbents.
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1.6c How does the facility manage absorbents used for oil spills?
Q Sent to supplier or
Service company
Q Burned for energy
D Disposed of as
hazardous waste
Q Nonhazardous and
landfilled
Q Other
Q/V4
Facility returns used absorbents to its supplier or pays
service company to pick up used absorbents. •
Facility burns absorbents used to soak up used oil for
energy recovery in a space heater with maximum heating
capacity of 0.5 million BTU per hour. •
Facility places hazardous absorbents in drums labeled as
"Hazardous Waste," and disposes of them through a
hazardous waste hauler. •
Facility determines that the absorbents are a
nonhazardous solid waste and disposes of them with
regular trash. •
Method of management is not listed here.
Facility does not use absorbents.
1.7 Used Tires
NOTE: The following question, which is included in the accompanying checklist, will help the facility
examine its operations relating to used tires for compliance with environmental
requirements:
a. How does the facility manage/dispose of used tires? (p. W-23)
This question appears in the following text and is accompanied with a discussion of the
preferred answer (indicated with a "•") for environmental compliance.
1.7a How does the facility manage/dispose of used tires?
Q Resale
Q Retread
Q Recycle
Q Other
QNA
Facility sells used tires. •
Facility retreads used tires. •
Facility recycles used tires. This may include state or local programs
that shred tires and then use them for asphalt. •
Facility uses some method other than those listed above for disposal.
Facility does not generate used tires.
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1.8 Brake Repair
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 brake
repair for compliance with environmental requirements:
a. Does the facility label asbestos-containing material (ACM) handling equipment?
(p. W-24)
b. Does the facility dispose of spent brake washing solvent as hazardous waste?
(p. W-25)
c. Does the facility manage used vacuum filters and brake pads as ACM waste?
(p. W-25)
d. How does the facility manage asbestos brake pads and asbestos-
containing material (ACM) waste? (p. W-25)
These questions are repeated in the following text, accompanied with a discussion of
the preferred answer (indicated with a V") for environmental compliance.
Brake Repair
Asbestos brake pads require proper handling, packaging and disposal in order to protect
workers and the environment. The asbestos National Emission Standards for Hazardous Air
Pollutants (NESHAP) and the proper disposal method for asbestos brake pads are outlined in
40 CFR Part 61 Subpart M. The Occupational Safety and Health Administration (OSHA)
provides rules for protection of workers during the handling of asbestos-containing material
(ACM), which should be reviewed prior to working with known or suspect ACM (including brake
pads).
Remove asbestos brake pads using appropriate control measures so that no visible emissions
will be discharged to the outside air. These measures can include wetting, vacuuming, or a
combination of wetting and vacuuming.
1.8a Does the facility label asbestos-containing material (ACM) handling
equipment?
ACM-handling equipment, such as a solvent bath basin and a vacuum, must have label
with the words: DANGER - Asbestos, Avoid Creating Dust, Cancer and Lung
Hazard. Facility must also label used filters from the vacuum as well as the particles
collected in the vacuum.
Q Ves Facility labels ACM equipment as described above. •
Q No Facility does not label ACM equipment.
Q NA Facility does not have ACM equipment.
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1.8b Does the facility dispose of spent brake washing solvent as
hazardous waste?
In most cases, the facility must manage the spent solvent removed from the brake
washing solvent bath once it is determined to be unusable. The facility must dispose of
it as hazardous waste. This is due to the flammability of the solvent, not the asbestos
content.
O Yes Facility manages spent solvent as hazardous waste. •
Q No Facility does not manage spent solvent as hazardous waste.
Q NA Facility does not generate brake washing solvent.
1.8c Does the facility manage used vacuum filters and brake pads as ACM
waste?
The facility must collect used filters from the vacuum as well as the particles in the
vacuum and dispose of them as ACM waste. If wet with solvent or any other wetting
agent, seal used asbestos pads in air-tight containers or in leak-tight wrapping. Label
the containers or wrapped packages using warning labels as described above.
O Yes Facility stores used vacuum filters and brake pads as described above. •
Q No Facility does not store used vacuum filters and brake pads as describe
above.
Q NA Facility does not generate used vacuum filters or brake pads.
1.8d How does the facility manage asbestos brake pads and asbestos-
containing material (ACM) waste?
Recycling and reclamation are the preferred methods for discarding asbestos brake
pads. If asbestos is known or suspected of being present, inform the recycling or
reclamation company. If landfilling, make a determination for presence of asbestos
prior to disposal. If asbestos is present, use only landfills or disposal sites approved for
asbestos.
One must dispose of ACM waste as soon as practical at an EPA-approved disposal
site. Label the asbestos containers with the name and location of the waste generator.
Vehicles used to transport the asbestos must be clearly labeled during loading and
unloading. Maintain the waste shipment records so that the asbestos shipment can be
tracked and substantiated.
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Waste Management
Q Recycled off site
Q Disposed by vendor
Q EPA-approved
disposal site
Q Other
Q NA
A manufacturer or a recycling company collects used
brake pads for recycling. •
A vendor disposes of the brake pads by landfilling or other
means of disposal. •
The ACM waste is sent to EPA-approved site for disposal.
Method of disposal is not listed here.
Facility does not generate ACM waste.
1.9 Metal Machining
NOTE: The following questions, which are not included in the accompanying checklist,
will help the facility examine its operations relating to metal machining for
compliance with environmental requirements:
a. Does the facility store scrap metal in a covered and contained area? (p. W-27)
b. How does the facility manage metal scraps? (p. W-27)
c. How does the facility manage waste cutting oils and degreasing solvents used
in its metal machining processes? (p. W-27)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a "•") for environmental
compliance.
Metal Machining and Machine Cooling
Metal scraps may contain cutting oils, lubricating oils, and grease. Most
metal scraps have economic value and a facility can recycle or reclaim
them. During storage of scrap metal, protect and cover the materials 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.
Tip: The local
scrap metal
recycling plant
may accept
scrap metal if
sorted and
properly stored.
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Waste Management
1.9a Does the facility store scrap metal in a covered and contained area?
Facilities should store metal scraps in a covered and contained area that prevents soil
and water contamination.
Q Vies Facility stores metal scraps in a covered and contained area. •
Q No Facility does not store metal scraps in a "covered and contained area.
Q NA Facility does not have any metal scraps.
1.9b How does the facility manage metal scraps?
Q Recycle Facility recycles metal scraps. •
Facility reuses metal scraps. •
Facility collects metal scraps and sells these to metal recyclers. •
Q Reuse
D 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 .Be How does the facility manage waste cutting oils and degreasing
solvents used in its metal machining processes?
Q Recycling
O Reuse
Q Disposed of as
hazardous waste
Q NA
Facility recycles waste cutting oils if nonwater-soluble oils
must be used. •
Facility reuses and recycles solvents whenever possible. •
Facility separates waste cutting oils and degreasing
solvents which are placed in drums, labeled as "Hazardous
Waste," and disposes of them by hazardous waste hauler. •
Facility does not conduct metal machining.
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Wastewater and Storm Water Management
SECTION 2.0 WASTEWATER AND
STORM WATER MANAGEMENT
2.1 Wastewater and Storm Water Management
NOTE: The following questions, some of which are included in the accompanying
checklist (highlighted in bold), will help the facility examine its operations
relating to wastewater and storm water management for compliance with
environmental requirements.
a. Can the facility identify the final destination of all its drains? (p. W-29)
b. How does the facility manage its wastewater? (p. W-30)
c. How does the facility manage its storm water? (p. W-31)
d. If the facility discharges to a surface water does it have an NPDES permit?
(p. W-31)
e. Does the facility have a storm water pollution prevention plan (SWPPP)?
(p. W-32)
f. Is a certification included in the SWPPP? (p. W-32)
g. If discharging to a municipal sanitary sewer, has the facility notified the
POTW and received approval for discharges? (p. W-32)
h. If discharging to an underground injection control (UIC) well, does the
facility comply with UIC program requirements? (p. W-33)
i. How does the facility manage the sludge from an oil/water separator?
(p. W-34)
These questions appear in the following text, accompanied with discussion of the
preferred answer (indicated with a "•") for environmental compliance.
Wastewater and Storm Water Management
Trucking facilities may discharge wastewater and/or storm water from the following activities:
repair and maintenance of on-site vehicles, vehicle and equipment cleaning, building and
grounds maintenance, chemical storage and handling, fueling of vehicles, and painting and
paint removal operations. Facilities that discharge wastewater are required to have a National
Pollutant Discharge Elimination System (NPDES) permit and/or state permit if the
wastewater is collected and discharged off site through a distinct pipe or ditch to waters of the
United States. EPA or an authorized state issues NPDES permits. As of September 1999,
EPA authorized 43 states and one territory to administer the NPDES program.
Persons responsible for wastewater discharges requiring an NPDES permit must apply for an
individual permit or seek coverage under a general permit (if available) at least 180 days
before discharge of wastewater begins. Some states do not allow certain discharges into the
environment.
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Wastewater and Storm Water Management
Storm Water Discharges
Under the Clean Water Act, it is illegal to discharge any pollutants into navigable waters of the
United States from a point source unless the discharge is authorized by a National Pollutants
Discharge Elimination System (NPDES) permit. Storm water regulations have identified eleven
major categories that are associated with industrial activity (40 CFR § 122.26 (b) (14) (i - x)).
Those facilities identified under these eleven categories must apply for NPDES permit for
storm water discharge. Transportation facilities are classified as category (viii) which includes
activities such as vehicle maintenance shops, equipment cleaning operations, painting, fueling
operations or airport deicing operations. Contact the state or federal permitting agency for
more information regarding NPDES discharge permitting requirements.
The following discharges do NOT require NPDES permits:
• Introduction of sewage, industrial wastes or other pollutants into a publicly owned
treatment works (POTW) by indirect discharges. (Although not federally required, a
POTW may require a permit. A facility should contact the local sewer authority to find
out more about these requirements).
• Discharges of dredged or fill material into waters of the United States. (These
discharges are regulated under CWA Section 404 permits.)
• Discharges of storm water/wastewater into an underground injection well. [These
discharges are regulated under the Safe Drinking Water Act (SDWA) Underground
Injection Control (UIC)] program. For more information, contact the Safe Drinking
Water Hotline at 1-800-426-4791].
Discharges to Publicly Owned Treatment Works (POTW)
POTWs are treatment plants that receive and treat wastewater through municipal sanitary
sewers prior to discharge to receiving waters (e.g., streams, lakes, rivers). They may also be
referred to as municipal wastewater treatment plants (WWTPs). POTWs may implement a
pretreatment program and regulate discharges to the sanitary sewer through prohibitions on
certain discharges, discharge limits, and discharge permits. Facilities should contact their local
POTW to see if any pretreatment requirements or limits apply to them. Although contacting
the POTW is not a federal requirement, the facility could be liable if it discharges a significant
amount of oil, or other fluid, and those discharges cause the POTW to violate its own NPDES
permit.
2.1 a Can the facility identify the final destination of all its drains?
The facility may have interior and/or exterior drains (e.g., painting booths, waste
storage areas, service areas, fueling areas, etc.). The facility should identify the final
destination of all drains located at the facility.
• If a drain discharges to a UIC well and the well is not on an inventory (in a non-
primacy state), the facility must submit an inventory to EPA. If a drain and/or
injection well is in or near loading docks, storage areas, or service areas, such
that it could receive contaminants, the facility may need a UIC well permit.
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Wastewater and Storm Water Management
Q Ves
If a drain discharges to storm water or surface water, the facility needs an
NPDES permit.
If a drain discharges to a municipal sanitary sewer, the facility may need to
apply for a permit from the publicly owned treatment works (POTW), and
general pretreatment requirements may apply.
If an interior drain that may be receiving contaminants discharges onto the
ground surface, the facility must contact the state agency for applicable
permitting requirements.
Facility can certify the final destination of all drains (e.g., storm sewer drains,
floor drains, and sanitary sewer drains). •
Q Wo Facility cannot certify the final destination of all drains.
Q NA Facility does not have drains.
2.1b How does the facility manage its wastewater?
There are several methods a facility can use to manage its wastewater. Wastewater
may contain pollutants (e.g., chemical solvents used for large scale equipment
cleaning). Prior to discharging wastewater, a facility may "treat" the wastewater using
an oil-water separator or some other method of treatment to reduce pollutant
concentrations. Wastewater may go to floor drains inside the facility and then drain to
an oil-water separator prior to discharge either (1) directly to surface waters, or (2) to a
sanitary sewer or combined sewer leading to a POTW. Wastewater treatment may be
required by an NPDES permit or by the POTW.
Q Surface water
Q Sanitary sewer
Q UIC well
Facility discharges effluent directly to surface waters (in
accordance with an NPDES storm water permit (see Question
Q Ground
Q Other
Q NA
Facility discharges to a municipal sanitary sewer or combined
sewer with permission of the POTW (see Question 2. 1g). •
Facility discharges to a UIC well, generally via a floor drain
(see Question 2. 7/7). Although there are some exceptions, as
a general rule, discharging industrial wastewater to a UIC well
is NOT appropriate.
Facility discharges onto the ground. Wastewater may affect
groundwater or may flow into storm sewers and surface
waterways. Caution: Many states forbid the disposal of
washwater/rinsewater onto the ground.
Method of disposal is not listed.
Facility does not discharge wastewater.
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Wastewater and Storm Water Management
2.1c How does the facility manage its storm water?
Storm water is a potential source of wastewater at a facility. Storm water discharges
begin when rain comes in contact with potential contaminants, such as spills, waste
containers, or spilled liquids related to vehicle or mechanical parts maintenance. The
pollutants in storm water depends on the type of material(s) the rain comes in contact
with prior to discharge. A facility may "treat" storm water using an oil-water separator or
some other method of treatment to reduce pollutant concentrations prior to discharge
either (1) directly to surface waters, or (2) to a sanitary sewer or combined sewer
leading to a POTW. An NPDES permit (see Question 2.1d) or the POTW (see
Question 2.1g) may require wastewater treatment.
Q Surface water
Q Sanitary sewer
Q UIC well
Q Other
D NA
Storm water discharges go directly to surface waters (in
accordance with an NPDES storm water permit). •
Storm water discharges are directed to a municipal sanitary
sewer or combined sewer with permission of the POTW. •
Storm water discharges go 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.
2.1d If the facility discharges to a surface water, does it have an NPDES
permit?
A facility needs an NPDES permits to discharge industrial wastewater directly into
surface waters. The wastewater may need treatment on site to reduce pollutant
concentrations to meet the 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 Vies Facility has an NPDES permit. •
Q No Facility does not have an NPDES permit.
Q NA Facility does not discharge wastewater directly to a body of water.
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Wastewater and Storm Water Management
2.1 e 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.
2.1f 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 of the tests/evaluations, and
the on site drainage points directly observed during the test or evaluation.
If certification is not feasible, the SWPPP must describe why (e.g., no access to
discharge sites).
Q Yes Facility's SWPPP includes a certification. •
Q No Facility's SWPPP does not include a certification, or certification is not
feasible and facility has included an explanation in the SWPPP.
Q NA Facility is not required to have an SWPPP.
2.1 g If discharging to a municipal sanitary sewer, has the facility notified
the POTW and received approval for discharges?
Facilities should contact the POTW if any pretreatment requirements apply to them.
Although contacting the POTW is not a federal requirement, the facility could be liable if
it discharges a significant amount of oil or other material and that discharge causes the
POTW to violate its own NPDES permit.
Q Yes Facility has contacted POTW and has received approval for discharges. •
Q No Facility has not contacted POTW or received approval for discharges.
Q NA Facility does not discharge to a POTW.
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Wastewater and Storm Water Management
2.1 h If discharging to a underground injection control (UIC) well, does the
facility comply with UIC program requirements?
Note: As a general rule, the
discharge of industrial wastewater
to UIC wells is NOT appropriate.
Facilities that discharge industrial wastewater to
underground injection control (UIC) wells must
comply with the rules established under the UIC
program. Trucking 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 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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Wastewater and Storm Water Management
2.1i How is the sludge from an oil/water separator managed?
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
constituents. If the sludge exhibits any characteristic of a hazardous waste, the facility
should handle it. If the sludge is nonhazardous, manage it as used oil. A facility must
obtain state and/or local permits for on site disposal of nonhazardous sludge.
Q Off site disposal
as hazardous waste
Q Off site disposal
to other facility
Q On site disposal
Q Landfill
Q NA
Facility disposes of hazardous sludge off site. 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 through an approved transportation, treatment,
and disposal facility. •
Facility disposes of nonhazardous sludge on site and has the
required state and/or local permits. •
Facility improperly landfills its oil/water separator sludge.
No sludge is produced.
2.2 Activities Generating Wastewater and/or Storm
Water
NOTE: The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
activities generating wastewater and/or storm wafer for compliance with
environmental requirements:
a. How does the facility clean the floors and surrounding areas? (p. W-35)
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-36) '_
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, accompanied with discussion of the
preferred answer (indicated with a "•") for environmental compliance.
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Wastewater and Storm Water Management
2.2a How does the facility clean the floors and surrounding areas?
Q Dry Cleanup
Q Water
Facility uses "dry methods" such as dry mop, broom, rags,
absorbents, etc., thus reducing generation of contaminated
wastewater. • See box below.
Facility uses a hose or wet mop, thus generating wastewater.
Suggested Dry Cleanup Methods
Small Spills: Use shop towels and then send them 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 put in containers. Then wipe with a shop towel.
Oil and Water/Antifreeze Spills:
Use a hydrophobic mop for cleaning up spills containing oil and recycle recovered oil in a mop
bucket labeled "waste oil."'
Use a regular mop for cleaning up antifreeze and recycle recovered antifreeze in a mop bucket
labeled "waste antifreeze."
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.
Finally, if there is something still on the floor, clean it up with soap and water.
2.26 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. 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, store materials on pallets (or something else that keeps them off the
ground) and covered by a tarp or roof. Close dumpsters and seal them to the extent
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.
Q Ves Facility protects materials from rain/snow. •
Q No Facility does not protect materials from rain/snow.
Q NA Facility does not store materials outside.
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— Wastewater and Storm Water Management
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) apply to
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 either if it goes directly to surface water or to a municipal wastewater
treatment plant.) For more information, contact the POTW or state permitting agency.
Q Yes Facility has determined whether it has activities that make it subject to
categorical pretreatment standards. •
Q A/o 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?
Applicable categorical standards will be incorporated into the facility's NPDES or
POTW permit by the state or POTW permitting agency, respectively.
Q Yes Facility is in compliance with applicable categorical standards. •
Q A/o Facility is not in compliance with applicable categorical standards.
Q NA Facility does not conduct any operations or processes that are subject to
categorical standards.
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Maintenance Activities
SECTION 3.0 MAINTENANCE ACTIVITIES
3.1 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 conduct equipment cleaning? (p. W-38)
b. What kind of cleaning agents does the facility use? (p. W-38)
c. Does the facility keep the lids of solvent cleaning equipment closed? (p. W-38)
d. If halogenated solvents are used in cleaning equipment, has the facility
submitted a notification report to the air permitting agency? (p. W-39)
e. Does the facility store solvents in labeled containers? (p. W-39)
f. How does the facility manage/dispose of spent solvents? (p. W-40)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
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. Hazardous waste may be
generated 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.
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
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Maintenance Activities
3.1a Does the facility conduct equipment cleaning?
A trucking facility may conduct different kinds of equipment cleaning.
* Large scale equipment cleaning typically involves the cleaning of trucks and support
vehicles.
* Small scale equipment cleaning, commonly referred to as parts cleaning, typically
involves the cleaning of engine parts, tools, and other small items. The facility may
conduct parts cleaning using some type of solvent cleaning equipment, such as a
parts washer or a dip tank.
Q Yes Facility conducts equipment cleaning.
Q No Facility does not conduct equipment cleaning.
3.1b What kind of cleaning agents does the facility use?
Various cleaning agents can be used for equipment cleaning, including stearn/pressure
water, surfactants (soap), and chemical solvents. If using chemical solvents that are
hazardous, 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
3.1c 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.
D NA Facility does not conduct parts cleaning using solvent cleaning equipment.
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Maintenance Activities
3.1 d If halogenated solvents are used in cleaning equipment, has the
facility submitted a notification report to the air permitting agency?
Although most facilities use soap and water
for parts cleaning, some facilities use
halogenated solvents. On December 2,
1994, EPA issued national emission
standards for hazardous air pollutants
(NESHAP) to control toxic air pollutant
emissions from solvent cleaning equipment
(including dip tanks and parts washers) that
use any of six halogenated solvents. These
halogenated solvents include:
Tip: A facility can tell if these chemicals
are contained in the solvent by reading
the label on the container or reading a
Material Safety Data Sheet (MSDS) that
should accompany any hazardous
material the facility has on site. If the
facility does not have an MSDS, one
may be requested from its vendor.
Methylene chloride
1,1,1-Trichloroethane
Chloroform
- Perchloroethylene
- Trichloroethylene
- Carbon tetrachloride.
All owners and operators of solvent cleaning equipment that use these solvents must
submit an initial notification report to its 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 Vies 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.
3.1 e Does the facility store 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.
Keep containers close (e.g., lids are on, caps are screwed on tight) except when
actually adding or removing liquid.
Labeled. Label containers holding spent solvents that are hazardous and those that
are transported for disposal. Note: Solvents in a parts washer do not need labels.
a yes
a NO
a NA
Spent solvents are stored as described above. •
Spent solvents are not stored as described above.
No solvents are used at the facility.
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Maintenance Activities
3.1f How does the facility manage/dispose of spent solvents?
If a vendor is not assuring proper handling and
disposal, the facility must determine if the spent
solvents are hazardous. If the spent solvents are
hazardous, do not mix them with nonhazardous
wastes such as used oils. All hazardous waste
must be stored, manifested, transported and
disposed of in compliance with RCRA
requirements. Only treatment, storage, and
disposal facilities (TSDFs) should dispose of hazardous waste.
Sludges: Facilities must also
determine if sludges, which may
generated during parts cleaning,
are hazardous. If so, they must be
managed in accordance with
RCRA.
Q Third party vendor
Q Storm sewers or
surface waters
Q Sanitary sewer
Q UIC well
Q Ground
Q Other
UNA
Facility uses a third party vendor. Many facilities elect to use
third party vendors providing "turn key" assistance. These
vendors typically provide the solvents and parts washers, and
collect the spent solvents, provide transportation, and recycle
or dispose of the waste. •
Facility has obtained an NPDES permit to discharge
nonhazardous waste to storm sewers or to surface waters. •
Facility has obtained approval from the POTW to discharge
nonhazardous waste to sanitary sewers. Discharge may
require pretreatment. •
Facility discharges nonhazardous waste to an underground
injection control (UIC) well. The facility complies with UIC
program requirements (40 CFR Part 144).
Facility discards spent solvents on the ground which may
affect groundwater or may flow with storm water into storm
sewers and surface waterways. Caution: Most states forbid
the disposal of hazardous spent solvents on the ground.
Method of disposal is not known.
Facility does not generate spent solvents or sludge.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Maintenance Activities
3.2 Fueling
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 fueling for compliance with environmental requirements:
a. Has the facility installed Stage I vapor recovery equipment for unloading of
gasoline? (p. W-41)
b. Has the facility installed Stage II vapor recovery equipment at the pumps?
(p. W-42)
c. Do fuel delivery records indicate compliance with appropriate fuel
requirements? (p. W-42)
d. Has the facility clearly labeled the pumps with the product they contain ?
(p. W-43)
e. Does the facility prevent the use of dyed, high-sulfur diesel/kerosene? (p. W-43)
f. Do gasoline pump nozzles comply with 10 gallon per minute flow rate?
(p. W-43)
g. Does the facility use overfill protection measures, spill containment
methods, and spill response equipment during fueling? (p. W-44)
These questions appear in the following text and may be accompanied with a
discussion of the preferred answers (indicated with a V") for environmental
compliance.
3.2a Has the facility installed Stage I vapor recovery equipment for loading
of gasoline?
If a facility dispenses gasoline on site for its
vehicles, and is located within an ozone non-
attainment area. Stage I vapor recovery
equipment MUST be used by the gasoline
delivery truck driver while filling the facility's
gasoline storage tanks.
Tip: Contact the local air pollution
control authority to determine if air
releases from fueling operations
are regulated (i.e., if a facility is in
an non-attainment area).
Stage I vapor recovery equipment captures and controls gasoline vapors which would
normally be emitted to the atmosphere (1) during the storage of gasoline, or (2) during
the loading and unloading of a gasoline delivery vessel.
Q Yes Facility ensures that Stage I vapor recovery equipment is used. •
Q No Facility knows that Stage I vapor recovery equipment is not used.
Q Don't Know Facility does not know if Stage I vapor recovery equipment is
used.
a NA
Either the facility is not located in an ozone non-attainment area or
facility does not dispense gasoline.
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and Workbook for the Trucking Industry
August 2000
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Maintenance Activities
3.2b Has the facility installed Stage II vapor recovery equipment at the
pumps?
If facility dispenses gasoline and is located in a serious or above ozone non-
attainment area, it must install Stage II vapor recovery equipment at each nozzle which
dispenses gasoline at the facility. Stage II vapor recovery captures the vapors from the
automobile tank and returns them to the storage tank. Stage II vapor recovery is the
"black boot" on the gasoline nozzle and black hose extending to the upper fuel pump
canopies at dispensing stations.
Q Ves
a NO
Q Don't Know
Q NA
Facility has installed Stage II equipment. •
Facility has not installed Stage II equipment.
Facility does not know if it installed Stage II equipment.
Facility is either not located in a serious or above ozone non-
attainment area or does not dispense gasoline.
3.2c Do fuel delivery records indicate compliance with appropriate fuel
requirements?
Fuel delivery tickets (i.e., product transfer documents) are receipts the facility receives
from the fuel deliverer which indicate the type of fuel (e.g., gasoline, diesel, kerosene),
how much was received, when it was received, and whether the delivered fuel complies
with appropriate fuel requirements.
Contact the local air pollution
control authority to determine
if the facility is located in an
ozone nonattainment area and
if air releases from fueling
operations are regulated.
If the facility is located within an ozone
nonattainment area and dispenses gasoline, the fuel
delivery ticket MUST say "RFG, certified for use in
an ozone nonattainment covered area" or "RFG."
RFG stands for reformulated gasoline.
If the facility is NOT located within an ozone
nonattainment area, the fuel delivery ticket should
say "CONVENTIONAL GASOLINE. This product does not meet the requirements
for reformulated gasoline, and may not be used in any reformulated gasoline
covered areas" or "CONVENTIONAL."
If the facility dispenses diesel fuel to on-the-road vehicles, the fuel delivery ticket MUST
say "LOW SULFUR" or "LOW SULFUR DIESEL FUEL."
Q Ves Delivery records indicate compliance with appropriate fuel requirements. •
Q No Delivery tickets do not indicate compliance with fuel requirements.
Q NA Facility does not receive fuel.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Maintenance Activitie.
3.2d Has the facility clearly labeled the pumps with the product they
contain?
The facility must label the pumps to indicate a description of the product (e g gasoline
diesel, kerosene), product grade (e.g., regular, mid-grade, premium), and octane (e q
87 octane) that is being dispensed from the nozzle.
Q yes Facility clearly labels the pumps. •
Q No Facility does not label pumps.
Q NA Facility does not have pumps.
3.2e Does the facility prevent the use of dyed, high-sulfur diesel/kerosene?
The facility can only dispense low sulfur diesel into motor vehicles used on the
road. Motor vehicles in this case include, but are not limited to, any diesel powered
truck (e.g., diesel tractor trailers, diesel pick-up trucks and diesel automobiles) licensed
and tagged for on-road travel.
Facilities can prevent dyed, high-sulfur diesel/kerosene fuel from being dispensed into
on-road diesel vehicles by (1) securing the pump nozzle with lock and key (2)
monitoring pump use, or (3) locating the pump in a place where on-road diesel vehicles
cannot pull-up and dispense the fuel.
Q yes Facility prevents dyed, high-sulfur diesel/kerosene fuel from being
dispensed into on-road diesel vehicles. •
Q No Facility does not prevent high-sulfur diesel/kerosene fuel from being
dispensed into on-road diesel vehicles.
Q NA Facility does not have pumps with dyed, high-sulfur diesel/kerosene fuel.
3.2f Do gasoline pump nozzles comply with 10 gallon per minute flow
rate?
After January 1, 1996, every retailer handling over 10,000 gallons of fuel per month
must equip each pump from which gasoline or methanol is introduced into vehicles with
a nozzle that dispenses fuel at a flow rate not to exceed 10 gallons per minute After
January 1, 1998, this requirement applies to every retailer.
Q Ves
Q No
Facility has tested the pump nozzles, and they comply. •
Facility has tested the pump nozzles, but they do not comply.
Q Don't Facility does not know if pump nozzles have been tested
Know
Q NA Facility does not dispense gasoline or methanol.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
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Maintenance Activities
3.2g Does the facility use overfill protection measures, spill containment
methods, and spill response equipment during fueling?
When fueling vehicles, facilities should use overfill protection, spill containment, and
spill response equipment to prevent overflows and spills.
Overfill protection. Facilities can prevent fuel overflows during tank filling by
installing preventive measures, such as self-locking fuel measures and regularly
monitoring transfers. In addition, a facility can prevent spills that result from
"topping off tanks by training employees on proper fueling techniques.
• Spill containment. Facilities should clean leaks and spills immediately using dry
methods such as absorbent wipes.
• Spill response. Portable absorbent booms should be readily available for a quick
response to spills. Use dry absorbent materials such as kitty litter or organic-based
absorbents to absorb oil and grease. Dispose of used absorbent properly in
accordance with federal and state regulations.
Q Yes Facility uses the measures, methods, and equipment described above. •
O No Facility does not use the measures, methods, or equipment described
above.
QAM
Facility does not have fueling operations.
3.3 Asbestos Concerns - Building
Renovation/Demolition
NOTE: The following questions, one of which is included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to
asbestos for compliance with environmental requirements:
a. Has the facility assessed all buildings and structures built prior to 1980 for
their potential for containing asbestos and treated accordingly? (p. W-45)
b. Does the facility document demolition procedures? (p. W-45)
c. Has the facility informed employees of buildings and structures containing
asbestos and trained them to work with asbestos-containing material? (p. W-45)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-44
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Maintenance Activities
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 asbestos in buildings is
assessed. It was once possible to make subjective judgments ruling out the presence
of asbestos based on the assessor's knowledge. Now, for building built prior to 1980,
one must assume the materials used may potentially contain asbestos unless bulk
sampling reveals otherwise. A certified inspector must perform asbestos inspections
according to AHERA guidelines.
A facility must use state-licensed contractors, transporters, and disposal sites must be
used and established procedures are required. If demolition is planned, remove the
asbestos materials 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 No 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 Yes 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 informed employees of buildings and structures
containing asbestos and trained them to work with asbestos-
containing material?
Inform all employees that may encounter asbestos-containing materials of its existence.
In particular, inform all employees required to perform repairs, maintenance, and
custodial activities. In addition, train employees in the proper procedures to follow, the
protective equipment to use, and the control measures to employ if their work can
disturb asbestos-containing material and release fibers.
Q Yes Facility has informed and trained all employees as described above. •
Q No Facility has not informed all employees or trained them as described above.
Q NA Facility has determined that asbestos is not present in any of the buildings.
Environmental Screening Checklist
and Workbook for the Trucking Industry
August 2000
W-45
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Maintenance Activities
3.4 Construction Activities
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 construction
activities for compliance with environmental requirements:
a. How does the facility manage construction wastes? (p. W-46)
b. Are there any endangered species which may be affected by construction
activities? (p. W-47)
c. Has the facility obtained a Section 404 permit for any projects that may impact
wetlands? (p. W-47)
These questions appear in the following text, accompanied with a discussion of the preferred
answer (indicated with a "•") for environmental compliance.
3.4a How does the facility manage construction wastes?
Do not dispose of all construction waste, including that from building, tunnel, and bridge
maintenance on site without disposal permits. States usually prohibit open burning of
scrap wood, material bags, aerosol cans, etc. Check your state/local regulatory
agencies. Segregate all waste as either trash, industrial nonhazardous solid waste, or
hazardous waste. Some construction materials, such as asphalt, concrete, brick, and
cinder block, may qualify as clean fill. Licensed contractors can transport and dispose
of construction wastes that are hazardous.
Q Off site
Q Open burning
Q On site
Q NA
Facility hires a licensed disposal contractor to haul the wastes to a
municipal or hazardous waste landfill. •
Facility burns construction wastes.
Facility disposes of construction waste on site. Note: On-site
disposal of wastes requires permits.
Facility is not conducting construction activities at this time.
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August 2000
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Maintenai
Activitit
3.4b Are there any endangered species which may be affected by
construction activities?
The Endangered Species Act (ESA) establishes a program for the conservation of
endangered and threatened species and the habitats in which they are found The ESA
prohibits the taking, possession, import, export, sale, and transport of any listed fish or
wildlife species. The term "taking" includes harassing, harming, hunting killing
capturing, and collecting. An individual may, by permit, be allowed an incidental taking
to an otherwise lawful activity if the applicant submits, and the U.S. Fish & Wildlife
Service (USFWS) approves, a conservation plan addressing the impact of the taking
mitigation measures, funding, and alternative actions considered.
Many construction-related activities have been identified as contributing to habitat loss
which can cause the acts that are prohibited under the ESA. Persons engaged in or '
planning to engage in, construction activities must be aware if any endangered or'
threatened species exist on the property involved, or the property is considered part of
a listed species' critical habitat. If neither is the case, the ESA does not apply
However, if the action will "take" or degrade critical habitat, some form of mitigating
action must be taken to prevent harming the species. There are some exceptions
under the ESA and the local USFWS should always be consulted in cases where
species are present. For more information on the ESA, access USFWS's website at
http://www.fws.gov/r9endspp/endspp.html.
Q Yes Either facility has identified endangered species present at the site of
construction activities, and has determined what impact construction
activities will have on them or facility has determined that no endangered
species are present. •
Q No Facility has not determined whether endangered species are present.
Q NA Facility is not conducting construction activities at this time.
3Ac Has the facility obtained a Section 404 permit for any projects that
may impact wetlands?
Construction activities that include dredging and filling of wetlands may require the
facility to obtain a CWA Section 404 permit from EPA and U.S Army Corps of
Engineers. The facility should identify any wetlands potentially impacted by
construction activities, consult with their state wetlands coordinator or EPA wetlands
contact, and obtain a Section 404 permit if necessary. For more information call the
Wetlands Information Hotline at 1-800-832-7828 or 703-748-1304.
Facility has identified wetlands and taken steps to obtain a Section 404
permit as necessary. •
Facility is conducting construction activities that would impact wetlands
but it has not obtained a Section 404 permit.
Q Yes
a A/O
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and Workbook for the Trucking Industry
August 2000
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Maintenance Activities
Q NA Facility is not conducting any construction activities that coulcl impact
wetlands.
3.5 Pesticide Use
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 pesticide
use for compliance with environmental requirements:
a. Does the facility apply pesticides only as directed by their labels? (p. W-48)
b. Are restricted use pesticides (RUPs) applied only by a certified commercial
applicator? (p. W-49)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (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 someone under the direct supervision of a certified
applicator can purchase and apply restricted use pesticides (RUPs). Pesticide labels will
clearly state whether a particular pesticide is classified as restricted use only. For a list of state
FIFRA/Pesticide contacts, refer to American Trucking Associations' website at
http://www.greentruck.com/reference/contacts/fifrah.html.
3.5a Does the facility apply pesticides only as directed by their labels?
Q Yes Facility applies all pesticides in accordance with the directions on the
labels. •
Q No Facility does not apply pesticides as directed by labels.
Q NA Facility does not use any pesticides.
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and Workbook for the Trucking Industry
August 2000
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Maintenance Activitie
3.5b Are restricted use pesticides 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
Q Ves Facility uses certified applicators to apply RUPs. •
Q No Facility does not use certified applicators to apply RUPs.
Q NA Facility does not apply RUPs.
3.6 On-Site Waste Disposal of Nonhazardous Waste
NOTE:
« £"owing question, which is not included in the accompanying checklist will
help the facility examine its operations relating to on site waste disposal for
compliance with environmental requirements:
SScSJiHStion app?arJ in th,e following text, accompanied with a discussion of the
preferred answer (indicated with a "•*') for environmental compliance
On Site Disposal of Nonhazardous Waste
All waste disposal in an on site landfill or on site dump is regulated. Facilities must obtain local
and/or state permits as required. These permits must be kept current for the type of waste
being[disposed of and they must be kept on site. If these conditions are not met then laws
prohibit disposal on site.
On site disposal of hazardous waste is strictly prohibited unless the facility is a treatment
storage, and disposal facility (TSDF). (See Section 1.0 for information on proper disposal of
hazardous waste.) If it is known that hazardous waste was buried, discharged or abandoned
on site at any time in the past, then the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) requires reporting to the EPA and cleanup actions
may be required.
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and Workbook for the Trucking Industry
August 2000
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Maintenance Activities
3.6a Does the facility dispose of nonhazardous waste on site in a
permitted landfill or dump?
Q Yes Facility disposes of nonhazardous waste in an on-site landfill or dump,
and all local and/or state permits have been obtained. •
Q No Facility disposes of nonhazardous waste on site, but not in a permitted
landfill or dump.
Q NA Facility does not dispose of nonhazardous wastes on site.
3.7 Yard Dust Control
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 yard dust
control for compliance with environmental requirements:
a. Does the facility control road and yard dust emissions with water or other dust
suppressants? (p. W-50)
b. Does the facility prohibit the use of used oils or other liquid wastes to
suppress dust? (p. W-51)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
3.7a Does the facility control road and yard dust emissions with water or
other dust suppressants?
Some facilities may have "fugitive dust," including dust from unpaved roads, yards,
bulk material handling, sand towers, etc. Water and other suppressants are often use
to control dust emissions.
Q Yes Facility controls road and yard dust emissions as described above. •
Q Wo Facility does not control road and yard dust emissions.
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and Workbook for the Trucking Industry
August 2000
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Maintenance Activitiet
3.7b Does the facility prohibit the use of used oils or other liquid wastes to
suppress dust?
Historically, industries and government applied some used oils or other liquid wastes for
dust control. This practice is now strictly prohibited. Facilities can only use
commercially available suppressants and in some states the products used require
specific authorization from the state environmental agency.
Facility does not allow the use of prohibited suppressants. •
Facility does not prohibit the use these suppressants. Note: Facility may be
out of compliance and should contact its state regulatory agency for
assistance.
a
a NO
Q NA Facility does not control road and yard dust emissions.
3.8 Painting/Paint Removal
NOTE:
a.
b.
c.
The following questions, some of which are included in the accompanying
checklist (highlighted in bold), will help the facility examine its operations
relating to painting/paint removal for compliance with environmental
requirements:
Does the facility conduct painting/paint removal operations? (p. W-52)
Does the facility have air permits? (p. W-52)
If yes, does the facility meet air permit conditions? (p. W-52)
d. Does the facility prepare surfaces to be painted by shot or grit blasting
gnndmg, or sanding? (p. W-52)
f.
9-
h.
I.
j-
k.
I.
; does tne facility test surfaces and paints for asbestos and lead?
(p. W-53)
Does the facility collect paint chips and metal dusts collected? (p. W-53)
How does the facility manage/dispose of paint stripping wastes and
baghouse dusts? (p. W-53)
Does the facility use low VOC paints in its painting operations? (p. W-54)
Does the facility mix paint amounts according to need? (p. W-54)
Does the facility take measures to minimize overspray? (p. W-54)
When not in use, does the facility store paints in labeled container?
(p. W-54)
How does the facility manage/dispose of used paints and painting waste
products? (p. W-55)
m. How does the facility dispose of spray paint booth air filters? (p. W-56)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
Environmental Screening Checklist ~ August 2000
and Workbook for the Trucking Industry W-51
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Maintenance Activities
3.8a Does the facility conduct painting/paint removal operations?
Facilities may conduct painting in specific areas such as paint booths. Note: The facility
should verify that there are no drains in the areas where painting occurs.
Q Yes Facility conducts painting/paint removal operations.
Q No Facility does not conduct painting/paint removal operations.
3.8/j 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 a facility must
have a permit if air pollution control equipment is used, such as a baghouse or scrubber.
Check with the state for specific criteria and requirements.
Q Vies Facility has air permits and they are current. •
Permit No(s).:
Q Wo Facility has not obtained air permits.
Q NA Permits are not required.
3.8c If yes, does the facility meet air permit conditions?
Q Yes Facility is meeting all air permit conditions. •
Q No Facility is not meeting air permit conditions.
Q NA Permits are not required.
3.8d Does the facility prepare surfaces to be painted by shot or grit
blasting, grinding, or sanding?
In preparation for painting, facilities may remove old paint on trucks and trailers by shot
or grit blasting. Grinding and sanding are often used to prepare the surface to be
painted.
Q Yes Facility uses one of the above methods.
Q No Facility does not use one of the above methods.
O NA Facility is not preparing surfaces for painting at this time.
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and Workbook for the Trucking Industry
August 2000
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Maintenance Activities
3.8e If yes, does the facility test surfaces and paints for asbestos and
lead?
chrtlll., ... , - ^ - ~ J, or sanding to remove old paint, then
should test the surfaces and paints for asbestos and lead.
Q yes Facility tests surfaces and paints for asbestos and lead. •
Q No Facility does not test surfaces and paints for asbestos and lead.
Q NA Facility does not prepare surfaces by these methods.
3.8f Does the facility collect paint chips and metal dusts?
An effective practice to assure the optimum collection of paint dusts and chips is to
b ast and sand wrthin a booth or enclosure designed with dust collection ventilation and
a pollution control devices (e.g., baghouse). Conducting operations indoors without
dust collection and air pollution controls may expose employees to levels of airborne
Hart L" HXCT °f theJ°S?A Permissible limits f°r Personal exposure to metals, such as
lead and cadmium. Conducting operations outdoors can allow dusts and paint debris
to disperse into the environment. Local and state air pollution regulations may not
»"««/ this. Check with state and local agencies and obtain the required air pollution
Q Vies 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.
3.8g How does the facility manage/dispose of paint stripping wastes and
baghouse dusts?
be daSmpri « h? H .? 9 ting 3nd Sandin9/9rinding operations may
be classified as hazardous waste, depending on the previous paint coatings If the
previous pa.nts contained lead or chromium, the waste chips and dusts may be
hazardous waste, depending on Toxicity Characteristic Leaching Procedure (TCLP)
test results. See Sectionl.0 for information on TCLP tests.
Q Recycle Facility recycles materials on site or ships them to a
recycling facility. •
Q Landfill Based on characterization, facility disposes materials at a
municipal or hazardous waste landfill. •
Q On-site disposal Facility disposes of paint wastes and dusts on site.
Q otner Method of disposal is not listed here.
a NA Facility does not have these wastes.
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Maintenance Activities
3.8/7 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.
Q NA Facility does not have painting operations.
3.87 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.
3.87 Does the facility take measures to minimize overspray?
Facilities may take various measures, such as air-assisted; airless, high-volume, low
pressure turbine; air atomized electrostatic; and airless, electrostatic application
techniques to minimize overspray. Another technique is the use of high transfer
efficiency spray applicators. High efficiency sprayers should have a label "HVLP" on
the gun. This is not yet a federal regulatory requirement. (Note: Required in some
states.)
Q Ves Facility takes measures to minimize overspray. •
Q No Facility does not take measures to minimize overspray.
Q NA Facility does not have painting operations.
3.8k When not in use, does the facility store paints in labeled container?
Facilities must ensure that paints that are not in use are properly contained and
labeled. Paint containers must be closed with tight-fitting lids, and stored so that a spill
would not reach a drain or otherwise leave the facility. Containers labels must indicate
contents.
Q Ves Facility contains and labels paints as described above. •
Q No Facility does not contain and/or label paints as described above.
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Maintenance Activitit
Q AW Facility does not store paints.
3.87 How does the facility manage/dispose of used paints and paintina
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. One may recycle latex paints and paint cans (that once contained
hazardous waste) that are classified as "empty" by the RCRA definition or dispose of
them off site at an approved facility as nonhazardous waste
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 H y'
* H° m°~e than 2'5 centimeters O.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 classified as hazardous waste and may require manifesting
storage, transportation, and disposal in full compliance with RCRA. Aerosol cans'that
are empty and depressurized (i.e., all propellant is discharged) may be classified as
nonhazardous solid waste for off-site disposal.
Q Return to supplier
Q Reuse
Q Recycle
Q On-site disposal
Q Mix with other fluids
Q Landfill
Q Drain
Facility returns all unused paints and thinners to the
supplier. •
Facility gives away leftover paints and thinners to
customers, employees, or at "paint swaps." •
Items are recycled by a paint recycler. •
Facility disposes of paint wastes on site.
Facility mixes materials with other fluids (solvent used
oil).
Based on characterization, facility disposes of materials
at a municipal or hazardous waste landfill.
Facility pours leftover paint down the drain. Warning:
This practice must be stopped immediately.
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O Other Method of disposal is not listed here.
Q NA Facility does not generate these wastes.
3.8m How does the facility dispose of spray paint booth air filters?
Facility hires a hazardous waste hauler to dispose of filters containing hazardous
paints. 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.
3.9 PCB-Containing Equipment
NOTE: The following questions, which are not included in the accompanying checklist,
will help the facility to examine its operations relating to PCB-containing
equipment for compliance with environmental requirements:
a. Does electrical equipment contain PCBs? (p. W-57)
b. Is PCB-containing equipment labeled and inspected quarterly? (p. W-57)
c. Does the facility store all out-of-service PCB-containing equipment in a
designated area? (p. W-57)
d. Does the facility clean up all PCB leaks/spills within 24 hours and with
trained personnel? (p. W-58)
These questions appear in the
following text and are accompanied
with a discussion of the preferred
answer (indicated with a "•") for
environmental compliance.
PCB-Containing Equipment
Electrical equipment, such as electrical light
ballasts, transformers, and capacitors,
containing insulating or dielectric oils, may
contain polychlorinated biphenyls (PCBs).
Assume equipment manufactured before
1978 to contain PCBs unless proven
otherwise by analytical testing or other
Many trucking 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.
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Maintenance Activities
records. If PCBs are present, the equipment is classified by the concentration of PCBs in the
oil. The following are the three classifications: (1) non-PCB equipment (less than 50 ppm)- (2)
PCB-contammated equipment (50- 499 ppm); and (3) PCBs (500 ppm or greater).
Facilities must assess all electrical equipment for their potential to contain PCBs. If all the
electrical equipment has been assessed and found to be free of PCBs then label all
equipment as PCB-free.
3.9a Does electrical equipment contain PCBs?
Q Vies 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.
3.9b 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.
Q Ves 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.
3.9c Does the facility store all out-of service PCB-containing equipment in
a designated area?
Store all PCB-containing equipment not in service and awaiting disposal in a
designated area designed with protection from the rain and 100-year floods and with
complete containment. The floor or pad of the designated area should be relatively
impervious with a 6-inch high curb and no drains. Mark the area with a 6" x 6" sign
indicating "Caution: Contains PCBs." All items and doorways should also be marked.
Store all leaking equipment in an over-pack or suitable non-leaking container filled with
enough sorbent material to soak up all the fluid if released. Move any transformers and
other equipment with PCBs found to be outside of the designated area to a proper
storage area immediately.
Q Yes
a NO
a NA
Facility stores equipment as described above. •
Facility does not store equipment as described above.
Facility does not have out-of-service PCB-containing equipment.
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3.9d Does the facility clean up all PCB leaks/spills within 24 hours and with
trained personnel?
One should assume that all electrical equipment involved in spill or leaks have PCBs
unless sampled and labeled to indicate otherwise. If a spill occurs, initiate a cleanup
within 24 hours. Complete cleanups within 48 hours, regardless of the regular business
hours. A trained person must perform all cleanups and they must meet the
recordkeeping requirements.
If transformer spillage and leaks occur, initiate a cleanup immediately. The facility
must develop a program and procedures to ensure that PCB equipment and
transformers are inspected for leaks and cleaned up when found leaking. The program
should detail the specific actions to be taken regarding response, notifications, cleanup,
personal protective equipment, storage, and disposal.
Q Yes Facility cleans up all PCB leaks properly. •
Q No Facility does not clean up PCB leaks properly.
Q NA Facility does not have equipment that contains PCBs.
3.10 Air Conditioning Repair
NOTE: The following questions, some of which are included in the accompanying
checklist (highlighted in bold), will help the facility examine its operations
relating to air conditioning repair for compliance with environmental
requirements:
a. Does the facility maintain and/or repair CFC-containing equipment? (p. W-59)
b. Does the facility employ or hire trained and certified technicians to maintain
CFC-containing equipment? (p. W-59)
c. Does the facility have the certificates on file? (p. W-59)
d. Does the facility remove all CFCs from equipment prior to maintenance
activities? (p. W-60)
e. Does the facility have CFC recovery and/or recycling equipment that is EPA
approved? (p. W-60)
f. Does the facility have documentation that refrigerants from recovery equipment
are sent to an EPA-approved reclaimer? (p. W-61)
g. Does the facility repair leaks of appliances containing ozone-depleting
refrigerants in a timely manner? (p. W-61)
h. How does the facility dispose of appliances containing ozone-depleting
refrigerants? (p. W-61)
i. Has the facility ensured that its CFCs have been legally purchased? (p. W-62)
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Slen«?uesS°ns apPe-arj.n the foll°wing text and are accompanied with a discussion of
the preferred answer (indicated with a V") for environmental compliance u.bcussion or
Air Conditioning Repair
As of July 1, 1992, it became unlawful for any person maintaining, servicing, repairing or
disposing of any appliance or industrial refrigeration to knowingly vent, release or dispose of
any ozone-depleting substance [e.g., chlorofluorocarbons (CFCs)] to the environment For a
°Z!;«?letin9 substances' contact the Stratospheric Ozone Information Hotline at
-1 996.
3.1 Oa Does the facility maintain and/or repair CFC-containing equipment?
The most common CFC-containing equipment maintained and repaired at a trucking
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. lob Does the facility employ or hire trained and certified technicians to
maintain CFC-containing equipment?
Technicians that perform a service that may release refrigerant must have 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.iOc Does the facility have certificates on file?
Q Ves Technicians' certificates are on the wall, in a file, or in their wallet. •
Q A/o Technicians' certificates are not on file.
Q NA Facility does not maintain CFC-containing equipment.
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3.1Od Does the facility remove all CFCs from equipment prior to
maintenance activities?
Equipment repairs that would release CFCs should only be performed after the
refrigerants are removed and collected.
Q Yes Facility removes and collects CFCs from equipment prior to maintenance
activities. •
Q No Facility does not remove or collect CFCs from equipment prior to
maintenance activities.
Q NA Facility does not maintain and/or repair CFC-containing equipment.
3.1 Oe Does the facility have CFC recovery and/or recycling equipment that
is EPA approved?
Technicians repairing or servicing air conditioners and other CFC-containing equipment
can only use recovery and/or recycling equipment that is EPA-approved. Currently,
EPA has approved both the Air-Conditioning and Refrigeration Institute (ARI) and
Underwriters Laboratories (UL) to certify recycling and recovery equipment. Certified
equipment has 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.]."
Obtain lists of certified equipment by contacting ARI at 703-524-8800 and UL at
708-272-8800 ext. 42371.
To demonstrate EPA approval, the equipment must have a label stating one of the
following:
1) "THIS EQUIPMENT HAS BEEN CERTIFIED BY [APPROVED EQUIPMENT
TESTING ORGANIZATION] TO MEET EPA'S MINIMUM REQUIREMENTS
FOR RECYCLING OR RECOVERY EQUIPMENT FOR USE WITH
[WHATEVER PROCESS THE EQUIPMENT IS BEING USED FOR];" or
2) "UL approved" or "ARI approved."
Q Yes Equipment has the "ARI / UL approval", and it has the appropriate labels . •
Q No Equipment does not have "ARI / UL approval".
Q NA Facility does not maintain and/or repair CFC-containing equipment.
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3.1 Of Does the facility have documentation that refrigerants from recovery
equipment are sent to an EPA-approved reclaimer?
Facilities that use recovery equipment must provide documentation that the refrigerant
is sent to an EPA-approved reclaimer.
Q Yes Facility maintains documentation that the reclaimer is EPA approved. •
Q No Facility does not maintain documentation where refrigerants are sent.
Q NA Facility does not maintain and/or repair CFC-containing equipment.
3.1Og 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/Vo
UNA
Facility does not repair leaks of appliances containing 50 pounds or more of
refrigerant in a timely manner.
Facility does not have appliances that contains 50 pounds or more of
refrigerant.
3.1 Oh How does the facility dispose of appliances containing ozone-
depleting refrigerants?
Q Landfill
Q Waste hauler
Q Scrap metal
recycler
a Other
UNA
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.
Facility does not have appliances containing ozone-depleting
refrigerants.
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3.101 Has the facility ensured that its CFCs have been legally purchased?
To make sure the facility purchases or
possesses legal CFCs, it should know
where the specific brand was produced
and the name of the manufacturer.
Before buying CFCs, the facility should
ask the seller for documents of prior
ownership of the product (and a
laboratory analysis of the quality).
Warning: If a facility knowingly buys or
possesses CFCs smuggled into the United
States, it is committing a punishable, criminal
offense and could face severe penalties. For
more information regarding CFCs and
enforcement actions under the Clean Air Act
(CAA), call EPA's Stratospheric Ozone
Protection Hotline at 1-800-296-1996.
Investigating the source of the
material and the chain of ownership is the facility's responsibility. If the material
was imported, a facility should know when, where, and from whom it was imported. It
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 a facility 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 Yes Facility has ensured that CFCs have been legally purchased. •
Q No Facility has not ensured that CFCs have been legally purchased.
Q NA Facility has not purchased CFCs.
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Storage Tanks, SPCC, and Emergency Response
SECTION 4.0 STORAGE TANKS, SPCC,
AND
EMERGENCY RESPONSE
4.1 Underground Storage Tanks (USTs)
NOTE:
The following questions, all of which are included in the accompanying checklist
w' 'help the facility examine its operations relating to underground storage tanks
(USTs) for compliance with environmental requirements:
a. Has the facility notified the state/tribal UST program office of any USTs
located on site? (p. W-64)
b- P,o^s P? ff£'£9f conduct leak detection for tank and piping of all on-site
L/oISr (p. W-64)
c. Do USTs at the facility meet requirements for spill, overfill, and corrosion
protection? (p. W-65)
These questions appear below and are accompanied with a discussion of the preferred
answer (indicated with a V") for environmental compliance.
Underground Storage Tanks
A facility may have underground storage
tanks (USTs) to supply fuel for trucks or
other vehicles. USTs are also used to store
used oil or fuel to run emergency power
generators. A UST is a tank and any
underground piping connected to the tank
that has at least ten percent of its combined
volume underground.
Note: USTs that store flammable and
combustible liquids must meet provisions
under the National Fire Protection
Association (NFPA) 30 Flammable and
Combustible Liquids Code. Requirements
under NFPA 30 include provisions for tank
storage and piping systems. See Question
4.2b 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/.
Some USTs are not covered by federal regulations (e.g., tanks storing heating oil used on
premises where it is stored, tanks on or above the floor of underground areas, such as
basements or tunnels, emergency spill and overflow fill tanks); however, such'USTs may be
regulated by the state, tribal, or local regulatory agency. Be sure to ask these agencies to find
out if additional or more stringent requirements apply to the facility.
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4.1a Has the facility notified the 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,
release detection, and financial responsibility for UST systems installed after December
22, 1988. For more information on how to obtain and complete the form, call EPA's
UST Hotline at 1-800-424-9346.
Q Yes Facility has submitted a notification form to the responsible state/tribal
UST program office. •
Q No Facility has not submitted a notification form to the responsible
state/tribal UST program office.
Q NA Facility has no USTs.
4.1b Does the facility conduct leak detection for tanks and piping of all on-
site USTs?
Facilities with federally regulated UST systems must conduct leak detection. The
monthly monitoring methods that may be used to conduct leak detection of tanks
include the following:
Automatic tank gauging
Monitoring for vapors in soil
Interstitial monitoring
Groundwater monitoring
Statistical inventory
reconciliation
Other methods approved by
the regulatory authority.
Note: Facilities with USTs may use inventory
control and tank tightness testing instead of one of
the monthly monitoring methods for a maximum
of 10 years after the tank is installed or upgraded
with corrosion protection (40 CFR 280.41). Call
the RCRA/UST, Superfund, and EPCRA Hotline
at 1-800-424-9346 for more information.
In addition, any pressurized piping
must have: (1) monthly monitoring (as described above) or annual line testing, and (2)
an automatic flow restrictor, an automatic shutoff device, or a continuous alarm system
installed. Check with the state/tribal UST program to determine which leak detection
methods are acceptable in the state.
Q Yes Facility conducts at least one leak detection method described above. •
Q No Facility does not conduct leak detection.
Q NA 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
all UST systems has passed, owners and
operators of facilities that continue to operate
UST systems not meeting the federal
requirements for leak detection, and spill,
overfill, and corrosion protection are out of
compliance. Besides posing a threat to human
health and the environment, such operation can
subject the owner/operator to considerable
fines.
A facility 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
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
A« ?T Vent Hnes °pen' but a" other lines must be caPPed and secured '
After 12 months of temporary closure, the facility must permanently close the UST To
5ox °^ m0re ab°Ut federal UST requirements, call EPA's RCRA/USTHotline at 1-800-
424-9346. Check with the state and local regulatory agencies to find out if there are
additional or more stringent state and/or local UST requirements
Q Yes
a NO
Facility has spill, overfill, and corrosion protection devices. •
Facility does not have protection devices installed.
Q NA Facility does not have any federally regulated USTs.
Note: UST recordkeeping requirements are in Section 5.4.
4.2 Aboveground Storage Tanks (ASTs)
NOTE:
The following questions, one of which is included in the accompanvino checklist
(highlighted in bold), will help the facility examine its operates Sng to
9G tankS (ASTS) f°r 'omP|iance with envir^nmentaT
a.
Does the facility have aboveground storage tanks (ASTs) ? (p. W-66)
b. Do ASTs meet or exceed NFPA 30 A requirements? (p. W-66)
a periodic basis for leaks and other
£tolSyestlons a-ppjiar injhe Allowing text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance
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4.2a Does the facility have aboveground storage tanks (ASTs)?
Q Ves Facility has aboveground storage tanks.
Q No Facility does not have aboveground storage tanks.
4.2b Do ASTs meet or exceed NFPA 30A requirements?
For facilities with fleet vehicle service stations, all ASTs must meet the National Fire
Protection Association (NFPA) requirements under NFPA 30A Automotive and
Marine Service Station Code and NFPA 30 Flammable and Combustible Liquids
Code. NFPA defines a fleet vehicle service station as a "portion of a commercial,
industrial, governmental, or manufacturing property where liquids used as fuels are
stored and dispensed into the fuel tanks of motor vehicles that are used in
connection with such businesses..."
NFPA 30A Automotive and Marine Service Station Code requirements address the
following:
• Tank location and
capacity
• Control of spillage
• Vaults
• Fire-resistant tanks
Piping and ancillary equipment
Physical protection
Corrosion protection
Tank filling operations.
Requirements under NFPA 30 Flammable and Combustible Liquids Code include
the following:
Tanks
- Design and construction
- Installation
- Storage tank buildings
- Supports, foundations, and anchorage
for all tank locations
- Operating instructions
• Piping systems
- Materials for piping, valves, and fittings
- Pipe joints
- Supports
- Protection against corrosion
Sources of ignition
Testing and maintenance
Fire protection and identification
Prevention of overfilling of tanks
Leak detection and inventory
records for underground storage
tanks.
Underground piping
Valves
Testing
Identification.
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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 Ves Tanks meet or exceed NFPA requirements. •
Q No Tanks do not meet NFPA requirements.
Q NA Facility does not have ASTs.
4.2c Does the facility inspect ASTs on a periodic basis for leaks and other
hazardous conditions?
If regulated under the SPCC program, facilities 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
a NO
a NA
Facility inspects ASTs on a periodic basis. •
Facility does not inspect ASTs on a periodic basis.
Facility does not have aboveground storage tanks, or ASTs are not
subject to SPCC requirements.
4.3 Spill Prevention, Control, and Countermeasures
(SPCC) and Emergency Response
N°TE: 7hShf?nhteJ9 qKe.5i°nSM ^°m6L°f ^hi?h are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to SPCC and
emergency response for compliance with environmental requirements:
^^ St0m9e capaoity make '* subJect to the Oil Pollution
b- 9OUwfffJled oil reach navi93ble waters or adjoining shorelines?
C' fS£5/#e ,fac/7/?y ***** a s£'7/ Prevention, Control, and Countermeasures
(SPCC) plan signed by a Professional Engineer? (p. W-69)
d. Is the phone number for the National Response Center posted on site for
immediate reporting of oil spills? (p. W-70)
r^H ost'°ns aPPear jn the following text, accompanied with a discussion of the
preferred answer (indicated with a "•") for environmental compliance.
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Spill Prevention, Control, and Countermeasures Program
In 1973, EPA issued the Oil Pollution
regulation (40 CFR Part 112) to address the
oil spill prevention provisions contained in
the Clean Water Act of 1972. The
regulation forms the basis of EPA's oil spill
prevention, control, and countermeasures
(SPCC) program, which seeks to prevent oil
spills from certain ASTs and USTs. In
particular, the regulation applies to facilities
that:
Have an aboveground storage capacity
of more than 660 gallons in a single AST
or more than 1,320 gallons in multiple
ASTs, or a total underground storage
capacity of 42,000 gallons; and
On December 2,1997, EPA proposed a rule
called the Oil Pollution Prevention and
Response; Non-Transportation Related
Onshore and Offshore Facilities - Proposed
Rule. It eliminates the requirement of
preparing an SPCC plan for those non-
transportation related facilities having an
aboveground capacity in excess of 660 gallons,
as long as the facility stores 1,320 gallons or
less of oil. This rule is expected to become
final in September 2000. For more information,
call EPA's RCRA/UST, Superfund, and
EPCRA Hotline at 1-800-424-9346.
Has physical potential to discharge oil in harmful quantities into navigable waters of the
United States.
4.3a Does the facility's total tank storage capacity make it subject to the
Oil Pollution regulation?
If the facility has total gasoline, fuel oil, or lubricating oil storage capacity greater than
1,320 gallons (or greater than 660 gallons in any one tank) in aboveground storage
tanks or total underground tank storage capacity greater than 42,000 gallons, then it is
subject to the Oil Pollution regulation and is required to have an SPCC plan.
Note that the limits are different for above and below ground tanks. When adding
totals, the capacity:
• Includes amount of oil that could be contained (e.g., 1,500-gallon tank with 350
gallons of oil would still count as 1,500 gallons toward the total).
• Includes oil stored in drums, buckets, etc. (e.g., 1,600-gallon aboveground tank,
plus a 1,500-gallon aboveground tank, plus five 55-gallon drums would equal
3,375 gallons total storage).
Q Yes Facility exceeds capacity limits indicated above.
Q No Facility storage capacity is less than limits above.
Q NA Facility does not have storage tanks.
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4.3b Could spilled oil reach navigable waters or adjoining shorelines?
The term "navigable waters" generally means any body of water. The word eventually
is the key here. If a spill could get to groundwater, storm water, a creek etc it is
considered to be able to "eventually" reach navigable waters or potential drinking water
sources. Spills are considered able to eventually reach navigable waters even if man-
made structures (e.g., dikes, berms, storage containers) are present.
Q Ves A spill could reach navigable waters or adjoining shorelines.
Q No A spill could not reach navigable waters or adjoining shorelines.
Q NA Facility does not have storage tanks.
4.3c Does the facility have a Spill Prevention, Control, and
Countermeasures (SPCC) plan signed by a Professional Engineer?
If the answer to 4.3a and 4.3b was "yes", then the facility must to have an SPCC plan
The SPCC plan must be on site if the facility is normally manned for at least eight hours
per day. Otherwise, it must be kept at the nearest field office. An SPCC plan is a
written description of how a facility's operations comply with the prevention guidelines
under the Oil Pollution Prevention regulation. Each SPCC plan, while unique to the
facility it covers, must include certain elements to ensure compliance with the
regulations. These elements include:
• Written descriptions of any spills occurring within the past year, corrective actions
taken, and plans for preventing their recurrence.
• A prediction of the direction, rate of flow, and total quantity of oil that could be
discharged where experience indicates a potential equipment failure.
A description of secondary containment
and/or diversionary structures or
equipment to prevent discharged oil from
reaching navigable waters.
If containment and/or diversionary
equipment or structures are not practical,
a strong oil spill contingency plan and a
written commitment of manpower,
equipment, and materials to quickly
control and remove spilled oil.
Secondary Containment
Under SPCC guidelines, all storage tank
installations should be constructed so
that secondary containment is provided
for the entire contents of the largest
single tank plus sufficient freeboard to
allow for precipitation. Diked areas
should be sufficiently impervious to
contain spilled oil. If dikes are not
appropriate, an alternative system may
be used.
• A complete discussion of the spill
prevention and control measures applicable to the facility and/or its operations.
Facilities must have an SPCC plan that has been signed by a professional engineer
This is not the same as a "hazardous materials plan," or an "emergency response plan "
However, some facilities may combine the SPCC plan with another plan If this is done
the plan should include wording such as "spill control and emergency response plan " '
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Storage Tanks, SPCC, and Emergency Response
For more information refer to EPA's website at
http://www.epa.gov/oerrpage/oilspill/spccplan.htm.
Q Vies Facility has an SPCC that has been signed by a professional engineer. •
Q No Facility does not have an SPCC plan, or the plan is not signed by a
Professional Engineer.
Q NA Facility is not required to have an SPCC plan.
4.3d Is the phone number for the National Response Center posted on site
for immediate reporting of oil spills?
In addition to an SPCC plan, EPA requires that if a facility has an accidental release of
an oil 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 Ves NRC phone number is available on site. •
Q No NRC phone number is not available.
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Recordkeeping
SECTION 5.0 RECORDKEEPING
5.1 NPDES Recordkeeping
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 NPDES
necordkeepmg for compliance with environmental requirements:
a. Does the facility keep accurate records of monitoring information for the
minimum requirement of 3 years? (p. W-71)
b. As part of the SWPPP, does the facility maintain records of incidents (e q
spills or other discharges) and other information describing the quality and
quantity of storm water discharges? (p. W-72)
5.1 a
c.
As part of the SWPPP, does the facility maintain records documentinq
inspections and maintenance activities? (p. W-72)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
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.
Monitoring results for wastewater discharges must be reported on a Discharge
Monitoring Report (DMR) form to the NPDES permitting agency. The permit will
specify the monitoring and reporting schedule. Such requirements are determined on
a facility-specific basis. Records of monitoring information generated under the
NPDES program must include:
• The date, exact place, method, and time of sampling and the names of the
person or persons taking the samples;
• The dates analyses were performed;
• Who performed the analyses;
• The analytical techniques or methods used;
• The results of such analyses.
NPDES permits require that all records related to monitoring 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
Facility maintains monitoring records as described above. •
Facility does not maintain monitoring records listed above and/or for a
minimum of 3 years.
Q NA Facility does not have wastewater discharges.
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Recordkeeping
5.1b As part of the SWPPP, does the facility maintain records of incidents
(e.g., spills or other discharges) and other information describing the
quality and quantity of storm water discharges?
Q Yes Facility maintains these records as described above. •
Q No Facility does not maintain these records.
Q NA Facility is not required to have an SWPPP.
5.1 c As part of the SWPPP, does the facility maintain records
documenting inspections and maintenance activities?
Q Yes Facility maintains these records as required. •
Q No Facility does not maintain records as required.
Q NA Facility is not required to have an SWPPP.
5.2 Recordkeeping for Air Emissions
NOTE: The following questions, all of which are included in the accompanying checklist
(highlighted in bold), will help the facility examine its operations relating to air
emissions recordkeeping for compliance with environmental requirements:
a. Does the facility meet the recordkeeping requirements of its air permit(s) ?
(p. W-72)
b. If the facility owns/operates appliances that contain ozone-depleting
refrigerants, does the facility maintain all required records? (p. W-72)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
5.2a Does the facility meet the recordkeeping requirements of its air
permit(s)?
Facilities that conducts certain operations (e.g., parts cleaning, painting/paint removal,
burning of fuel, etc.) may be required to obtain an air permit. Many air permits require
recordkeeping to verify permit compliance. Contact the state or local air pollution
control agency for more information.
Q Yes Facility meets the recordkeeping requirements of its air permit(s). •
Q No Facility does not meet the recordkeeping requirements of its air permit(s).
Q NA Facility is not required to have an air permit.
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Recordk>
5.2b If the facility owns/operates appliances that contain ozone-depleting
refrigerants, does the facility maintain all required records?
air-
EPA has established recordkeeping requirements for servicing and disposal of „,
conditioning and refrigeration equipment that contains regulated ozone-depleting
refrigerants. If the facility owns/operates appliances (e.g., motor vehicle air
conditioners, refrigerators, etc.) containing ozone-depleting refrigerants it must
maintain the following records:
• Records documenting the date and type of servicing performed on the
appliances;
• Records of refrigerant purchased and added; and
• If the facility employs technicians to service and maintain refrigerant-containing
appliances, records demonstrating compliance with the certification
requirement (40 CFR Part 82).
Q Ves Facility maintains records described above. •
Q No Facility does not maintain records described above.
Q NA Facility does not own/operate these appliances.
5.3 RCRA Recordkeeping
NOTE:
The following question, which is included in the accompanying checklist will helo
relatin9 to RCRA
°* ** ma"ifests f°rthe 3
minimum
5.3a
I!SLTi<;ftion app£a!? in fle foll°wing text, accompanied with a discussion of the
preferred answer (md.cated with a V") for environmental compliance
Does the facility keep copies of its manifests for the 3 year minimum
requirement?
The facility must meet various recordkeeping requirements as part of its hazardous
waste management obligations. The Uniform Hazardous Waste Manifest Form is a
multi-copy shipping document that reports the contents of the shipment the transport
company used, and the treatment/disposal facility receiving the wastes The
hazardous waste generator, the transporter, and the treatment/disposal facility must
each sign this document and keep a copy. The waste disposal/treatment facility also
must send a copy back to the generating facility, so that it can be sure that its
shipment was received. A copy of the manifest must be kept at the facility for 3 years
or until a signed copy of the manifest is received from the waste disposal/treatment
facility. The signed copy of the manifest must be kept on file for 3 years Generators
may have other recordkeeping and reporting requirements. Contact your State or
EPA Region for more information.
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Recordkeeping
Q 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.
5.4 Recordkeeping for Underground 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
recordkeeping for underground storage tanks for compliance with environmental
requirements:
a. Does the facility maintain leak detection records? (p. W-75)
b. Does the facility maintain corrosion protection records? (p. W-75)
c. Does the facility maintain records showing that a repaired or upgraded system
was properly repaired or upgraded? (p. W-75)
d. Does the facility maintain records of the site assessment results required for
permanent closure for at least 3 years after closing a UST? (p. W-76)
e. Does the facility maintain records that document its financial responsibility?
(p. W-76)
These questions appear in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
UST Recordkeeping Requirements
Facilities can use underground storage tanks (USTs) to store product or waste. Facilities with
USTs are responsible for assuring that there are not leaks or spills from USTs. For example, a
facility must assure that USTs maintain their integrity and are protected from spills, overfills,
and corrosion. A facility should regularly review areas around the tanks to observe any signs
of tank spills, overflows, and leaks. In addition, facilities must maintain all records including
permits, registrations, and installation or closure records, and submit appropriate notification
information to EPA or the state implementing agency. A facility will have to keep records that
can be provided to an inspector during an on-site visit that prove the facility meets certain
requirements. Facilities must keep these records long enough to show the facility's recent
compliance status in five major areas: (1) leak detection; (2) overflow, spill, and corrosion
protection; (3) corrective actions; (4) closure; and (5) financial responsibility.
Facilities should check their regulatory authority about specific recordkeeping requirements.
Generally, a facility should follow this useful rule of thumb for recordkeeping: When in doubt,
keep it.
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Recordk
5.4a Does the facility maintain leak detection records?
The facility will have to keep records of leak detection performance and maintenance
information including the following:
• The last year's monitoring results and the most recent tightness test;
• Copies of performance claims provided by leak detection manufacturers; and
• Records of recent maintenance, repair, and calibration of on-site leak detection
equipment.
Facility maintains records listed above on site. •
Facility does not maintain all records listed above on site.
Facility does not have a UST.
a
QAto
a N'A
5.4b Does the facility maintain corrosion protection records?
Corrosion protection records include results of last two tests proving the cathodic
protection system is working and the last three inspections proving that impressed
current systems are operating properly.
Facility maintains corrosion protection records on site. •
Facility does not maintain corrosion protection records on site.
Facility does not have a UST.
5Ac Does the facility maintain records showing that a repaired or
upgraded system was properly repaired or upgraded?
a/vo
UNA
a yes
a/vo
Facility maintains records as described above. •
Facility does not maintain records as described above.
Facility does not have a UST.
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Recordkeeping
5.4d Does the facility maintain records of the site assessment results
required for permanent closure for at least 3 years after closing a
UST?
These results are important because they show the impact of a facility's UST on the
surrounding area.
Q Ves Facility maintains records for at least 3 years after closing a UST
as required. •
Q A/o Facility does not maintain records for at least 3 years after closing a UST as
required.
Q NA Facility has not closed any USTs.
5.4e Does the facility maintain records that document its financial
responsibility?
Financial responsibility documentation shows one of the following. The facility:
Participates in a state financial assurance fund;
Has insurance coverage;
Has a guarantee from another firm;
• Has a surety bond;
Has a letter of credit;
Has passed a financial test;
Has set up a trust fund; or
Uses another financial method(s) of coverage approved by the state.
Q Yes Facility maintains records that document financial responsibility. •
Q No Facility does not maintain records that document financial responsibility.
Q NA Facility does not have a UST.
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Recorcfkeeping
5.5 Records of Pesticide Application
NOTE: The following question, which is not included in the accompanying checklist will help
the facility examine its operations relating to records of pesticide application for
compliance with environmental requirements:
a. Does the facility maintain accurate records of use and storage of pesticides?
(p. W-77)
This question appears in the following text, accompanied with a discussion of the
preferred answer (indicated with a V") for environmental compliance.
5.5a Does the facility maintain accurate records of use and storage of
pesticides?
Federal law requires that facilities keep accurate records of use and storage of
restricted use pesticides (RUPs). Records of use are necessary to track when the next
application should occur to control pest problems. Frequency of application is
determined by label directions. Records of stored (RUP) pesticides allow management
to do the inventory, so that oldest pesticides can be used first, and excess pesticides
are not purchased and stored. In addition, accurate recordkeeping for pesticide
storage can be crucial in the event of an accidental spill or fire, so that emergency
responders can know exactly the hazards posed.
Q Yes Facility maintains accurate records of use and storage of RUP pesticides. •
Q Afo Facility does not maintain accurate records of use and storage of RUP
pesticides.
Q NA Facility does not use pesticides.
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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
propeliants for aerosol containers. These chemicals have been determined to be partially
responsible for depletion of ozone levels in the upper atmosphere.
Civil Penalties: Monetary penalties which can be imposed on companies and individuals for
violations of civil laws and regulations.
Clean Air Act (CAA): The federal law designed to improve air quality by regulating air pollution
emission from stationary and non-stationary sources. The Act includes National Ambient Air
Quality Standards (NAAQS) for specific pollutants.
Cleanup: Actions taken to deal with a release or threat of a hazardous substances release
that could affect people or the environment. The term "cleanup" is sometimes used
interchangeably with the terms "remedial action," "removal action," "response action " "remedy"
"remediation," or "correction action."
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Glossary of Terms
Cleanup Operation: An operation in which hazardous substances are removed, contained,
incinerated, neutralized, stabilized, cleaned up, or in any other manner processed or handled
with the ultimate goal of making the site safer for people or the environment.
Clean Water Act (CWA): The purpose of this federal law is to restore and maintain the water
quality of lakes, streams and rivers. This goal is being pursued by controlling both point
sources and non-point sources of discharge into surface water.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
The federal law established in 1980 to identify, investigate, and clean up sites that might
release hazardous substances into the environment. It also established funding for these
cleanup projects (commonly called Superfund) and procedures for recovering any fund money
expended. CERCLA also requires the reporting of spills and releases of hazardous
substances.
Conditionally Exempt Small Quantity Generators: Hazardous waste generators who are
basically exempt from the majority of RCRA regulations due to the small amounts generated
and the low frequency of production. One must generate less than 100 kilograms of
hazardous waste per month, or less than 1 kg of acute hazardous waste to qualify as a
conditionally exempt small quantity generator.
Container: Any portable device in which a material is stored, transported, treated, disposed of,
or otherwise handled, including drums, pails, buckets, and inner liners.
Corrosive: Material with a pH of less than 2.0 or greater than 12.5 or a material capable of
dissolving or wearing away steel at a rate greater than 0.25 inch per year.
Cradle-to-Grave: The Resource Conservation and Recovery Act requirement for management
and tracking of hazardous waste is documented from the source of the waste (i.e., generator)
through its transportation, to treatment, storage and eventually acceptance by a disposal
facility.
Criminal Penalties: Penalties imposed for a willful and/or knowing violation of a criminal law.
They include monetary fines for companies and individuals and jail time for individuals.
Department of Transportation (DOT): The federal agency that regulates the transport of
hazardous materials under the Hazardous Materials Transportation Act. These materials
include CERCLA hazardous substances and RCRA hazardous wastes.
Direct Discharge: Clean Water Act defines direct discharge as any addition of any pollutant or
combination of pollutants to (a) U.S. waters from any "point source", or (b) waters of the
"contiguous zone" or the ocean from any point source other than a vessel or other floating
craft which is being used as a means of transportation.
This definition includes additions of pollutants into waters of the U.S. from: surface runoff
which is collected or channeled by man; discharges through pipes, sewers, or other
conveyances owned by a State, municipality, or other person which do not lead to a treatment
works; and discharges through pipes, sewers, or other conveyances, leading into privately
owned treatment works.
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. Glossary of Terms
Discharge: The accidental or intentional spilling, leaking, pumping, pouring, emitting
emptying, or dumping of waste into or on any land or water.
Disposal: The discharge deposit, injection, dumping, spilling, leaking, or placing of any solid
waste or hazardous waste into any land or water so that such solid waste or hazardous waste
or any constituent thereof, enters the environment, is emitted into the air, or is discharged into'
any waters, including groundwater.
Disposal Facility: A facility or part of facility at which solid or hazardous waste is intentionally
placed into or on any land or water, and at which waste will remain after closure.
Effluent: Any gaseous, liquid, or solid waste material that is released into the environment.
Emergency Response: A response effort by employees from outside the immediate release
area or by other designated responders (i.e., mutual-aid groups, local fire departments etc ) to
an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous
substance. Responses to incidental releases of hazardous substances which can be
absorbed, neutralized, or otherwise controlled at the time of release by employees in the
immediate release area, or by maintenance personnel, are not considered to be emergency
responses within the scope of the OSHA HAZWOPER standard. Responses to releases of
hazardous substances 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.
DOO JHaZar?°US WaSte C°de: The code ass'9ned by EPA to each hazardous waste listed in
RCRA regulations and to each hazardous waste characteristic identified in RCRA regulations.
EPA ID Number: The identification number assigned by EPA to each hazardous waste
generator, transporter and treatment, storage, and disposal facility.
EPA Region: The states and territories found in any one often EPA regions, such as Region
4-Tennessee, Kentucky, North Carolina, South Carolina, Georgia, Florida, Alabama and
Mississippi.
Erosion: The process of being worn away or deteriorated by wind or water.
Evacuation: A personnel or population protection strategy that provides for the orderly
movement of people away from an actual or potential hazard.
Facility: All buildings, structures, equipment, and other stationary items that are located on a
single site or on continuous or adjacent sites and that are owned or operated by the same
person (or by any person which controls, is controlled by, or under common control with such
person). Under certain circumstances, a facility can include rolling stock and other transport
vehicles.
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Glossary of Terms
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): The federal law which
regulates the sale, distribution, and use of pesticides and establishes requirements for
registration, labeling, use, and disposal of these products.
Fire Hazards: Hazardous chemicals, including flammable chemicals, that are liable to cause
fire through friction, absorption, spontaneous chemical changes, retained heat, or which can
be ignited readily and burn vigorously and persistently; combustible liquids having flashpoints
at or above 90°F but below 100°F; flammable liquids with flash points below 100°F; pyrophoric
chemicals that ignite spontaneously in air at temperatures of 130° F or below; and oxidizers
that can promote combustion in other materials, causing fire either by themselves or through
the release of oxygen or other gases.
Freeboard: The vertical distance from the normal water surface to the top of the confining
wall.
Friable Asbestos Material: Any material that contains more than one percent asbestos by
weight, and can be crumbled, pulverized, or reduced to powder by hand pressure.
Fugitive Emissions: Air emissions not normally vented through a stack, chimney, vent, or
equivalent opening. Fugitive emissions includes emissions from ponds, lagoons, landfills, and
piles of stored materials.
Generator of Hazardous Waste: Entity that produces hazardous waste. Generators are
classified by how much hazardous waste they produce in a given time period. In general,
there are three classes of waste generators: conditionally exempt small quantity generators,
small quantity generators, and large quantity generators. The generator is required to
determine if a waste is hazardous. If the waste is hazardous, the generator must apply for and
obtain an EPA ID number before transporting the waste to an approved treatment, storage,
and disposal facility. The generator must also use a hazardous waste manifest to track the
hazardous waste, must package and label the hazardous waste, and must keep records of its
shipments for 3 years.
Groundwater: Water below the land surface in a zone of saturation.
Hazard: A circumstance or condition that can do harm. Hazards are categorized into four
groups: biological, chemical, radiation, and physical.
Hazard Classes: These are descriptive terms prescribed by the Department of Transportation
to categorize the nature of DOT regulated materials. There are nine numeric classes and two
word classes as follows: Class 1 (explosives), Class 2 (gases), Class 3 (flammable liquids),
Class 4 (flammable solids and substances), Class 5 (oxidizing substances), Class 6
(poisonous and infectious substances), Class 7 (radioactive), Class 8 (corrosive), and Class 9
[miscellaneous substances, and Combustible Liquids, ORM-D (consumer commodities)].
Hazardous Material: A substance designated by the Department of Transportation as posing
a potential hazard when transported. See 49 CFR 171.101 for a list of DOT hazardous
materials. Hazardous wastes requiring a manifest are considered hazardous materials.
Hazardous Substance: CERCLA Section 101(14), as amended, defines "hazardous
substance" by referencing other environmental statutes, including: CWA Sections 311 and
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Glossary of Terms
307(a); CAA section 112; RCRA Section 3001; and TSCA Section 7. A list of over 600
CERCLA hazardous substances is provided in 40 CFR 302.4. EPA has the authority to
designate additional hazardous substances not listed under the statutory provisions cited
above.
Hazardous Waste: A solid waste material that may cause or significantly contribute to serious
illness or death or that may pose a substantial threat to human health or the environment if not
managed properly, and which includes liquids, semisolids, and contained gases. Hazardous
wastes are subject to manifest reporting requirements. A material is considered a hazardous
waste under RCRA if it meets one of the following conditions:
• The material has been listed as a hazardous waste by regulations.
• It is ignitable, corrosive, reactive, or toxic.
• It is a mixture of a listed hazardous waste and a non-hazardous waste.
Hazmat: A contraction of Hazardous Materials.
Ignitable: Material that has a flashpoint less than 140°F, is combustible through friction, is
combustible through absorption of moisture, or can spontaneously combust.
Incident: A release or potential release of a hazardous material, substance, or waste into the
environment.
Indirect Discharge: A discharge which goes to a publicly-owned treatment works (POTW).
Indirect discharges do not need a National Pollutant Discharge Elimination System (NPDES)
permit but must comply with the POTW pretreatment standards.
Influent: Wastewater or other raw or partially treated liquid flowing into a basin, treatment
process, or treatment plant.
Land Disposal: Includes, but is not limited to placement of hazardous waste in a landfill
surface impoundment, waste pile, injection well, land treatment facility, salt dome formation/salt
bed formation, underground mine or cave, or concrete vault or bunker intended for disposal
purposes. Land disposal facilities are a subset of treatment, storage, and disposal facilities
(TSDFs). Groundwater monitoring is required at all land disposal facilities. Waste material can
only be disposed of at a permitted facility.
Land Disposal Restrictions: Regulations prohibiting the disposal of hazardous waste on land
without prior treatment of the waste. Land disposal restriction notifications ensure proper
treatment of the waste prior to disposal.
Landfill: A disposal facility or part of a facility where waste is placed in or on land and which is
not a land treatment facility, a surface impoundment, or an injection well.
Large Quantity Generators: One of three classes of hazardous waste generators under
RCRA producing 1,000 kilograms or more of hazardous waste in one calendar month at a given
location.
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Glossary of Terms
Listed Waste: Waste listed as hazardous under 40 CFR Part 261. A waste is listed as a
hazardous waste based on the process from which the waste was generated and/or the
constituents found in the waste.
Local Emergency Planning Committee (LEPC): A local community group, including police
and fire departments, which must be notified in the event of an accidental release that exceeds
the reportabie quantity of the following substances (1) EHSs (listed in 40 CFR Part 355,
Appendices A and B); or (2) hazardous substances subject to emergency notification
requirements under CERCLA Section 103(a) (listed in 40 CFR 302.4).
Major Stationary Source: Any stationary source that emits or has the potential to emit 100
tons per year or more of any air pollutant.
Manifest: The "cradle-to-grave" paperwork recording hazardous waste movement from its
generation through final storage or disposal. All parties must keep records for 3 years.
Material Safety Data Sheets (MSDS): Information sheets which provide workers with details
on the health and physical hazards of chemicals to which they may be exposed in the
workplace.
Maximum Achievable Control Technology (MACT): Generally, the best available control
technology, taking into account cost and technical feasibility.
Milligrams per Kilogram (mg/kg): Weight of a substance, measured in milligrams, contained
in a weight of the total material, measured in kilograms. A concentration used to measure
solid materials such as contamination in soil.
Milligrams per Liter (mg/l): Weight of a substance, measured in milligrams, contained in a
volume of solution measured in liters. A concentration used for liquid substances.
Monitoring: The process of measuring certain environmental parameters on a real-time basis
for spatial and time variations. For example, air monitoring may be conducted with direct
reading instruments to indicate relative changes in air contaminant concentration at various
times.
National Ambient Air Quality Standards (NAAQS): Standards established by the Clean Air
Act for air quality of an area in terms of allowable levels of specific pollutants.
National Emission Standards for Hazardous Air Pollutants (NESHAP): The EPA regulations
which govern specific processes which could possibly emit certain hazardous pollutants such
as asbestos into the air.
National Pollutant Discharge Elimination System (NPDES): A permitting system under the
CWA established for regulating direct discharges of wastewater from industries and
municipalities into surface waters of the United States.
National Priority List (NPL): The prioritized list required by CERCLA of abandoned or
uncontrolled hazardous waste sites.
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Glossary of Terms
National Response Center: The center (1-800-424-8802) which must be notified immediately
of releases of hazardous substances in excess of their reportable quantities and hazardous
materials (under certain circumstances).
New Source Performance Standards (NSPS): Standards established by the EPA under the
CAA for new, modified, or reconstructed operations which emit air pollutants.
Nonattainment: The status of an area that is determined to exceed any national ambient air
quality standard for a particular pollutant.
Oil: Oil of any kind or in any form, including but not limited to petroleum, fuel oil, oil sludge oil
refuse, and oil mixed with wastes.
On site: The same or geographically contiguous property which may be divided by public or
private right-of-way, provided the entrance and exit between the properties are at a crossroads
intersection and access is by crossing, as opposed to going along, the right-of-way. However,
non-contiguous properties owned by the same person but connected by a right-of-way which he
or she controls and to which the public does not have access are also considered on-site
properties.
Operator: The person responsible for the overall operation of a facility or process.
Occupational Safety and Health Administration (OSHA): A federal agency which protects
worker health and safety under the Occupational Safety and Health Act and plays an important
role in environmental issues such as chemical exposure in the workplace.
Outfall: The mouth of a drain or sewer which flows directly into surface water.
Owner: The person who owns a facility or part of a facility.
Parts per Million (ppm): A standard or measurement for concentrations of pollutants. A ratio
(volume/volume or weight/weight) usually used for airborne concentration of gases or vapors,
for concentrations of chemicals in water, or concentrations of chemicals in soil.
Permit: A written document issued by the government that establishes standards and/or
pollutant limits for water discharges, air emissions, or for the handling, treating, storing or
disposing of hazardous waste.
Pesticide: Any substance or mixture of substances intended for preventing, destroying,
repelling or mitigating any pest; any substance/mixture of substances intended as a plant
regulator, defoliant or desiccant.
pH: A measure of alkalinity or acidity on a scale whose values range from 0 to 14 with 7
representing neutral. Numbers less than 7 correspond to increasing acidity. Numbers greater
than 7 correspond to increasing alkalinity.
Point Source Discharges: Any discernible, confined, and discrete conveyance, including but
not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling
stock, concentrated animal feeding operation, landfill leachate collection system, vessel or other
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Glossary of Terms
floating craft from which pollutants are or may be discharged. This term does not include return
flows from irrigated agriculture or agricultural storm water runoff.
Pollutant or Contaminant: Any element, substance, compound, or mixture which after release
into the environment and upon exposure, ingestion, inhalation, or assimilation into any
organism, either directly from the environment or indirectly by ingesting through food chains, will
or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer,
genetic mutation, physiological malfunctions, or physical deformation in such organisms or their
offspring. It presents an imminent and substantial danger to public health or welfare.
Pollution Prevention: Any source reduction activity that results in the reduction of total volume
of waste, reduction of toxicity of waste, or both, as long as the reduction is consistent with the
goal of minimizing present and future risks to public health and the environment. Transfer of
hazardous constituents from one environmental medium to another does not constitute waste
minimization (see waste minimization).
Polychlorinated biphenyls (PCBs): A hazardous chemical once widely used in electrical
transformer oil and now subject to a manufacturing ban and use restrictions under TSCA.
Potentially Responsible Party: See PRP.
Preliminary Assessment/Site Investigation (PA/SI): The first phase of a site investigation for
possible chemical contamination. It consists of a record search, investigation of prior site uses,
on-site inspections, and possible site sampling to determine if a potential threat exists.
Publicly-Owned Treatment Works (POTW): Any device or system used in the treatment
(including recycling and reclamation) of municipal sewage or industrial wastes of a liquid nature
which is owned by a "State" or "municipality." This definition includes sewers, pipes, or other
conveyances only if they convey wastewater to a POTW providing treatment.
Reasonably Available Control Technology (RACT): Control technology that is reasonably
available and both technologically and economically feasible. Usually applied to existing
sources in nonattainment areas; in most cases is less stringent than new source performance
standards.
Regulated Material: A substance or material that is subject to regulations set forth by the EPA,
Department of Transportation, or any other federal and/or state agency.
Releases: Defined by federal and most state laws as any spilling, leaking, pouring, dumping,
emitting, discharging, injecting, escaping, leaching, or disposing of hazardous wastes or
hazardous substances into the environment. This includes the abandonment of barrels,
containers, and other closed receptacles containing any hazardous substance or pollutant.
Under environmental laws, the term "release" does not include releases which result in
exposure to persons solely within a workplace, with respect to a claim which such persons may
assert against the employer of such persons.
Reportable Quantity (RQ): The minimum quantity of a CERCLA hazardous substance or
EPCRA extremely hazardous substance which is reportable. A release equal to or greater than
the RQ within a 24-hour period must be reported to the appropriate authorities (i.e., National
Response Center).
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than the RQ within a 24-hour period must be reported to the appropriate authorities (i e
National Response Center).
Resource Conservation and Recovery Act (RCRA): The federal act which regulates the
management of hazardous waste from the point of generation through transport, storage, and
disposal. It also regulates underground storage tanks and nonhazardous waste disposal
under separate subtitles.
SARA Title III: The part of SARA, now known as EPCRA (Emergency Planning and
Community Right-to-Know Act) which regulates emergency response plans, community right-
to-know issues, and chemical release reporting.
Safe Drinking Water Act (SDWA): The federal act which deals with the quality of treated
drinking water. Regulations developed by EPA under authority of this act include drinking
water standards.
Sedimentation: The act or process of depositing sediment.
Site Inspection: The collection of information from a Superfund site to determine the extent
and severity of hazards posed by the site. It follows and is more extensive than a preliminary
assessment.
Sludge: A solid, semi-solid, or liquid material produced by the process of settling or sinking
caused by gravity. Sludges are generally waste products and are commonly generated by
municipal and industrial water treatment processes and air pollution control processes.
Sludges also occur in process tanks where liquids are stored. Sludges must be tested to
determine if they are hazardous wastes.
Small Quantity Generators (SQGs): One of the three classes of hazardous waste generators
under RCRA. SQGs produce between 100 and 1,000 kilograms of hazardous waste at a
given location.
Soil and Groundwater Analysis: Tests used to determine the presence of substance
contamination and concentration levels. The analysis may involve soil borings and the
installation of test pits and/or monitoring wells.
Solid Waste: Any garbage, refuse, sludge, or other waste materials not excluded by definition
Exclusions include domestic sewage and any mixture of other wastes that pass through a
sewer system to a publicly-owned treatment works (POTW); industrial wastewater discharges
that are point source discharges subject to regulation under the Clean Water Act irrigation
return flows; nuclear materials defined by the Atomic Energy Act; and "in situ" or "in position-
mining materials. Note that wastewaters being collected, stored, or treated before discharge
and sludges generated by wastewater treatment are not excluded. EPA defines hazardous
waste as a subset of solid waste.
Solvent: Any substance that can dissolve another substance. The term is most often used to
mean petroleum-based solvents, capable of dissolving greases, oils, tars, and asphalts Many
petroleum-based solvents are volatile, flammable, may be hazardous, and may be regulated
as an air pollutant. Used solvents being disposed of (even if recycled) must be manifested as
hazardous waste unless exempted.
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Source Standards: Standards for emission levels at the source or point of emission.
Special Waste: A type of waste which is not a hazardous waste but requires more care than a
regular solid waste and may require special disposal procedures. Examples include: certain
sludges, asbestos containing waste materials, and oil waste.
Spill Prevention, Control, and Countermeasure (SPCC) Plan: Plan designed to ensure that
a facility puts in place containment and other control measures that will prevent oil spills from
reaching navigable U.S. waters.
State Emergency Response Commission (SERC): The state agency which must be notified
in the event of an accidental release of an extremely hazardous substance, a CERCLA
hazardous substance, or a chemical with an MSDS above the chemical's threshold planning
quantity (TPQ) or its reportable quantity (RQ).
Stationary Source: Any building, structure, facility, or installation that emits or may emit any air
pollutant.
Storage: The holding of hazardous waste for a temporary period, at the end of which the
hazardous waste is treated, disposed of, or stored elsewhere. Generators are required to have
a RCRA permit for storage of hazardous waste for more than 90 days or 180 days, depending
on the generator's status. Treatment or disposal facilities must be permitted.
Superfund Amendments and Reauthorization Act (SARA): The amendments to CERCLA
which increased available funds for site cleanups, added cleanup standards, and required
hazardous waste operations training for site workers and emergency response personnel.
Superfund: The common name for CERCLA. It also refers to the fund that is to be used for
cleaning up hazardous substance sites.
Toxic Substances Control Act (TSCA): The federal law designed to evaluate the human
health and environmental effects of all chemical substances entering the U.S. market, to
establish an inventory of existing chemicals, and to regulate the use and disposal of toxic
substances. PCBs are regulated under TSCA.
Toxicity Characteristic Leaching Procedure (TCLP): A physical/chemical analytical
procedure used to determine if a substance is classified as a toxic hazardous waste. If the test
results show that a solid waste exceeds any of the limits prescribed for 39 specific
contaminants, the waste is deemed to be a characteristically toxic hazardous waste. (The other
three characteristics are corrosivity, ignitability and reactivity.)
Transporter of Hazardous Waste: Entity that moves or transports hazardous waste by truck,
rail, boat, or plane and has received an EPA hazardous waste transporter ID number. Some
states also require proper permits. (On-site movement of hazardous waste does not apply.)
Transporters of hazardous waste must properly manifest and record movement as part of
"cradle-to-grave" tracking required by RCRA. In addition, transporters must follow Department
of Transportation (DOT) Hazardous Materials regulations and must immediately notify the
appropriate officials if a release or incident occurs. Transporters are responsible for
undertaking emergency response to any accident that occurs during transportation.
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Treatment: Any method, technique, or process, including neutralization, designed to change
the physical, chemical, or biological character or composition of any hazardous waste to
neutralize such waste, to recover energy or material resources from the waste, or to render
such waste non-hazardous, safer to transport, store or dispose of, or amenable to recovery
storage, or reduction in volume.
Treatment, Storage, and Disposal Facilities (TSDFs): Usually refers to off-site facilities
where untreated hazardous waste can be taken for treatment, storage, and/or disposal.
TSDFs are subject to RCRA requirements and permits. TSDFs complete the "cradle-to-grave"
cycle by continuing record keeping requirements. There are many complex rules for facility
operations and training of employees.
Underground Injection Control (UIC): The program under the Safe Drinking Water Act that
regulates the use of wells to pump fluids into the ground.
Underground Storage Tank (UST): USTs are regulated under RCRA, Subtitle I by the federal
government and by individual states under state programs. A UST is a tank, including any
underground pipes, which contains or used to contain regulated hazardous substances or
petroleum and has at least 10% of its volume beneath the surface of the ground.
United States Environmental Protection Agency (EPA): The federal regulatory agency in
charge of administering and enforcing various federal environmental laws.
Used Oil: Any oil that has been refined from crude oil or any synthetic oil that has been used
and as a result of that use is contaminated by physical or chemical impurities.
Waste Minimization: This is the reduction in volume ortoxicity of wastes generated by source
reduction or recycling. Generators and TSDFs operating under RCRA permits are required to
certify annually that they have waste minimization plans in place and that the plans are being
implemented at their facilities. Generators must also sign a waste minimization statement
when signing the manifest.
Waste Pile: Any non-containerized accumulation of solid, non-flowing hazardous waste that is
used for treatment or storage.
Waters of the United States: (1) Navigable waters, waters subject to tidal action shoreward to
the mean high water mark and currently used or may be used to transport goods moving in
interstate or foreign commerce, including oceans, coastal and inland waters, lakes, rivers and
streams that are navigable; (2) Tributaries of navigable waters; (3) Wetlands, including those
adjacent to waters of the United States as defined above; and (4) Surface waters
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