United States
Environmental Protection
Agency	
Enforcement and    EPA305-B-01-003
Compliance Assurance  June 2001
(2224-A)	
Protocol for Conducting
Environmental Compliance
Audits for Hazardous
Waste Generators under
RCRA
         EPA Office of Compliance

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Notice

U.S. EPA's Office of Compliance prepared this document to aid regulated entities in developing programs at
individual facilities to evaluate their compliance with environmental requirements arising under federal law. The
statements in this document are intended solely as guidance to you in this effort.  Among other things, the
information provided in this document describes existing requirements for regulated entities under the Resource
Conservation and Recovery Act (RCRA) and their implementing regulations at 40 CFR 260 through 268.  While  the
Agency has made every effort to ensure the accuracy of the statements in this document, the regulated entity's legal
obligations are determined by the terms of its applicable environmental facility-specific permits, and underlying
statutes and applicable state and local law. Nothing in this document alters any statutory, regulatory or permit
requirement. In the event of a conflict between statements in this document and either the permit or the regulations,
the document would not be controlling. U.S.  EPA may decide to revise this document without notice to reflect
changes in EPA's regulations or to clarify and update the text. To determine whether U.S. EPA has revised this
document and/or to obtain additional copies, contact EPA's National Center for Environmental Publications at (1-
800-490-9198). The contents of this document reflect regulations issued as of April 30,2001.

Acknowledgment!

U.S. EPA would like to gratefully acknowledge the support of the U.S. Army Corps of Engineers Construction
Engineering Research Laboratory (CERL) for providing suggestions for overall format of this document. The Office
of Compliance at U.S. EPA gratefully acknowledges the contribution of U.S. EPA's program offices and the U.S.
EPA's Office of Counsel in reviewing and providing comment on this document.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Table of Contents

Notice	inside cover
Acknowledgment	inside cover

Section 1: Introduction
Background	ii
Who Should Use These Protocols?	ii
U.S. EPA's Public Policies that Support Environmental Auditing	iii
How To Use the Protocols	iv
The Relationship of Auditing to Environmental Management Systems	vi

Section II: Audit Protocol
Applicability	1
Review of Federal Legislation	1
State and Local Regulations	2
Key Compliance Requirements	2
Key Terms and Definitions 	6
Typical Records to Review	 16
Typical Physical Features to Inspect	 17
List of Acronyms and Abbreviations	 17
Index for Checklist Users	 19
Checklist	21

Appendices
Appendix A: Hazardous Waste from Non-Specific Sources and From Specific Sources	Al
Appendix B: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified
             as Toxic Wastes	Bl
Appendix C: Toxicity Characteristics Constituents and Regulatory Levels	Cl
Appendix D: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified
             as Acute Hazardous Wastes	Dl
Appendix E: Hazardous Waste Storage Incompatibility Chart	El
Appendix F: User Satisfaction Questionnaire and Comment Form	Fl
   This document is intended solely for guidance.
   No statutory or regulatory requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


                                                  Section I
                                               Introduction


Background

The Environmental Protection Agency (EPA) is responsible for ensuring that businesses and organizations comply with
federal laws that protect the public health and the environment. EPA's Office of Enforcement and Compliance Assurance
(OECA) has begun combining traditional enforcement activities with more innovative compliance approaches including the
provision of compliance assistance to the general public. EPA's Office of Compliance Assistance was established in 1994 to
focus on compliance assistance-related activities. EPA is also encouraging the development of serf-assessment programs at
individual facilities. Voluntary audit programs play an important role in helping companies meet their obligation to comply
with environmental requirements. Such assessments can be a critical link, not only to improved compliance, but also to
improvements in other aspects of an organization's performance. For example, environmental audits may identify pollution
prevention opportunities that can substantially reduce an organization's operating costs.  Environmental audits can also serve
as an important diagnostic tool in evaluating a facility's overall environmental management system or EMS.

EPA is developing 13 multi-media Environmental Audit Protocols to assist and encourage businesses and organizations to
perform environmental audits and disclose violations in accordance with OECA's Audit and Small Business Policies. The
audit protocols are also intended to promote consistency among regulated entities when conducting environmental audits and
to ensure that audits are conducted in a thorough and comprehensive manner. The protocols provide detailed regulatory
checklists  that can be customized to  meet specific needs  under the following primary environmental management areas:

     •   Generation of RCRA             •   Treatment Storage and           •   EPCRA
         Hazardous Waste                   Disposal of RCRA
                                            Hazardous Waste

     •   CERCLA                      •   Clean Air Act                   •   Clean Water Act

     •   Safe Drinking Water Act         •   TSCA                          •   Universal Waste and Used Oil

     •   Managing Nonhazardous         •   Pesticides Management           •   Management of Toxic
         Solid Waste                         (FIFRA)                            Substances (e.g., PCBs, lead-
                                                                               based paint, and asbestos)
                                        •   RCRA Regulated Storage
                                            Tanks
Who Should Use These Protocols?

EPA has developed these audit protocols to provide regulated entities with specific guidance in periodically evaluating their
compliance with federal environmental requirements. The specific application of this particular protocol, in terms of which
media or functional area it applies to, is described in Section II under "Applicability".

The Audit Protocols are designed for use by individuals who are already familiar with the federal regulations but require an
updated comprehensive regulatory checklist to conduct environmental compliance audits at regulated facilities.  Typically,
compliance audits are performed by persons who are not necessarily media or legal experts but instead possess a working
knowledge of the regulations and a familiarity with the operations and practices of the facility to be audited.  These two basic
skills are a prerequisite for adequately identifying areas at the facility subject to environmental regulations and potential
regulatory violations that subtract from the organizations environmental performance. With these basic skills, audits can be
successfully conducted by persons with various educational backgrounds (e.g., engineers, scientists, lawyers, business owners
or operators). These protocols are not intended to be a substitute for the regulations nor are they intended to be instructional
   This document is intended solely for guidance.
   No statutory or regulatory requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


to an audience seeking a primer on the requirements under Title 40, however, they are designed to be sufficiently detailed to
support the auditor's efforts.

The term "Protocol" has evolved over the years as a term of art among the professional practices of auditing and refers to the
actual working document used by auditors to evaluate facility conditions against a given set of criteria (in this case the federal
regulations). Therefore these documents describe "what" to audit a facility for rather than "how" to conduct an audit. To
optimize the effective use of these documents, you should become familiar with basic environmental auditing practices. For
more guidance on how to conduct environmental audits, EPA refers interested parties to two well known organizations: The
Environmental Auditing Roundtable (EAR) and the Institute for Environmental Auditing (IEA).

Environmental Health and Safety Auditing Roundtable       The Institute for Environmental Auditing
35888 Mildred Avenue                                   Box 23686
North Ridgeville, Ohio 44039                             L'Enfant Plaza Station
(216) 327-6605                                          Washington, DC 20026-3686

U.S. EPA's Public Policies that Support Environmental Auditing

In 1986, in an effort to encourage the use of environmental auditing, EPA published its "Environmental Auditing Policy
Statement" (see 51 FR 25004).  The 1986 audit policy states that "it is EPA policy to encourage the use of environmental
auditing by regulated industries to help achieve and maintain compliance with environmental laws and regulation, as well as
to help identify and correct unregulated environmental hazards."  In addition, EPA defined environmental auditing as "a
systematic, documented, periodic, and objective review of facility operations and practices related to meeting environmental
requirements." The policy also identified several objectives for environmental audits:
          •   verifying compliance with environmental requirements,
          •   evaluating the effectiveness of in-place environmental management systems, and
          •   assessing risks from regulated and unregulated materials and practices.

In 1995, EPA published "Incentives for Serf-Policing: Discovery, Disclosure, Correction and Prevention of Violations" -
commonly known as the EPA Audit Policy - which both reaffirmed and expanded the Agency's  1986  audit policy (see 60 FR
66706 December 22, 1995). The 1995  audit policy offered major incentives for entities to discover, disclose and correct
environmental violations.  On April 11, 2000, EPA issued a revised final Audit Policy that replaces the 1995 Audit Policy (65
FR 19,617). The April 11, 2000 revision maintains the basic structure and terms of the 1995 Audit Policy while lengthening
the prompt disclosure period to 21 days, clarifying some of its language (including the applicability of the Policy in the
acquisitions context), and conforming its provisions to actual EPA practices.  The revised audit policy continues the Agency's
general practice of waiving or substantially mitigating gravity-based civil penalties for violations discovered through an
environmental audit or through a compliance management system, provided the violations are promptly disclosed and
corrected and that all of the Policy conditions are met. On the criminal  side, the revised policy continues the Agency's
general practice of not recommending that criminal charges be brought against entities that disclose violations that are
potentially criminal in nature, provided the entity meets all of the policy's conditions.  The policy safeguards human health
and the environment by precluding relief for violations that cause serious environmental harm or may have presented  an
imminent and substantial endangerment. The audit policy is available on the Internet at www.epa.gov/auditpol.html.

In 1996, EPA issued its "Policy on Compliance Incentives for Small Businesses" which is commonly called the "Small
Business Policy" (see 61 FR 27984 June 3,  1996). The Small Business Policy was intended to promote environmental
compliance among small businesses by providing them with special incentives to participate in government sponsored on-site
compliance assistance programs or conduct environmental audits. EPA will eliminate or reduce penalties for small businesses
that voluntarily discover, promptly disclose, and correct violations in a timely manner.

On April 11, 2000, EPA issued its revised final Small Business Policy (see 65 FR 19630) to expand the options allowed
under the 1996 policy for discovering violations and to establish a time  period for disclosure. The major changes contained in
the April 11, 2000 Small Business Policy revision include lengthening the prompt disclosure period from 10 to 21 calendar
days and broadening the applicability of the Policy to violations uncovered by small businesses through any means of
voluntary discovery. This broadening of the Policy takes advantage of the wide range of training, checklists, mentoring, and
other activities now available to small businesses through regulatory agencies, private organizations, and the Internet.
   This document is intended solely for guidance.                                                                   m
   No statutory or regulatory requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
More information on EPA's Small Business and Audit/Self-Disclosure Policies are available by contacting EPA's
Enforcement and Compliance Docket and Information Center at (202) 564-2614 or visiting the EPA web site at:
http://es.epa.gov/oeca/main/strategy/crossp.html
How to Use The Protocols

Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the federal laws
affecting a particular environmental management area. They also include a checklist containing detailed procedures for
conducting a review of facility conditions. The audit protocols are designed to support a wide range of environmental
auditing needs; therefore several of the protocols in this set or sections of an individual protocol may not be applicable to a
particular facility. To provide greater flexibility, each audit protocol can be obtained electronically from the EPA Website
(www.epa.gov/oeca/ccsmd/profile.html). The EPA Website offers the protocols in a word processing format which allows
the user to custom-tailor the checklists to more specific environmental aspects associated with the facility to be audited.

The protocols are not intended to be an exhaustive set of procedures; rather they are meant to inform the auditor, about the
degree and quality of evaluation essential to a thorough environmental audit.  EPA is aware that other audit approaches may
also provide an effective means of identifying and assessing facility environmental status and in developing corrective actions.

It is important to understand that there can be significant overlap within the realm of the federal regulations.  For example,
the Department of Transportation (DOT) has established regulations governing the transportation of hazardous materials.
Similarly,  the Occupational Safety and Health Administration (OSHA) under the U.S. Department of Labor has promulgated
regulations governing the protection of workers who are exposed to hazardous chemicals. There can also be significant
overlap between federal and state environmental regulations.  In fact, state programs that implement federally mandated
programs may contain more stringent requirements that are not included in these protocols.  There can also be multiple state
agencies regulating the areas covered in these protocols. The auditor also should determine which regulatory agency has
authority for implementing an environmental program so that the proper set of regulations is consulted. Prior to conducting
the audit, the auditor should review federal, state and local environmental requirements and expand the protocol, as required,
to  include other applicable requirements not included in these documents.


 Review of Federal Legislation and Key Compliance Requirements:

These sections are intended to provide only supplementary information or a "thumbnail sketch" of the regulations and
statutes.  These sections are not intended to function as the main tool of the protocol (this is the purpose of the checklist).
Instead, they serve to remind the auditor of the general thrust of the regulation and to scope  out facility requirements covered
by that particular regulation. For example, a brief paragraph describing record keeping and reporting requirements and the
associated subpart citations will identify and remind the auditor of a specific area of focus at the facility. This allows the
auditor to plan the audit properly and to identify key areas and documents requiring review and analysis.


State and Local Regulations:

Each EPA Audit Protocols contains a  section alerting the auditor to typical issues addressed in state and local regulations
concerning a given topic area (e.g., RCRA and used oil). From a practical  standpoint, EPA cannot present individual state
and local requirements in the protocols.  However, this section does provide general guidance to the auditor regarding the
division of statutory authority between EPA and the states over a specific media. This section also  describes circumstances
where states and local governments may enact more stringent requirements that go beyond the federal requirements.
   This document is intended solely for guidance.
   No statutory or regulatory requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


EPA cannot overemphasize how important it is for the auditor to take under consideration the impact of state and local
regulations on facility compliance.  EPA has delegated various levels of authority to a majority of the states for most of the
federal regulatory programs including enforcement.  For example, most facilities regulated under RCRA,  and/or CWA have
been issued permits written by the states to ensure compliance with federal and state regulations. In turn, many states may
have delegated various levels of authority to local jurisdictions. Similarly, local governments (e.g., counties, townships) may
issue permits for air emissions from the facility. Therefore, auditors are advised to review local and state regulations in
addition to the federal regulations in order to perform a comprehensive audit.


Key Terms and Definitions:

This section of the protocol identifies terms of art used in the regulations and the checklists that are listed in the "Definitions"
sections of the Code of Federal Regulations (CFR).  It is important to note that not alldefmitions from the CFR may be
contained in this section, however; those definitions which are commonly repeated in the checklists or are otherwise critical to
an audit process are included.  Wherever possible, we have attempted to list these definitions as they are written in the  CFR
and not to interpret their meaning outside of the regulations.


The Checklists:

The checklists delineate what should be evaluated during an audit. The left column states either a requirement mandated by
regulation or a good management practice that exceeds the requirements of the federal regulations.  The right column gives
instructions to help conduct the evaluation. These instructions are performance objectives that should be  accomplished by the
auditor. Some of the performance objectives may be simple documentation checks that take only a few minutes; others may
require a time-intensive physical inspection of a facility. The checklists contained in these protocols are (and must be)
sufficiently detailed to identify any area of the  company or organization that would potentially receive a notice of violation if
compliance is not achieved. For this reason, the checklists often get to a level of detail such that a specific paragraph of the
subpart (e.g., 40 CFR 262.34(a)(l)(i)) contained in the CFR is identified for verification by the auditor. The checklists
contain the following components:


    •       "Regulatory Requirement or Management Practice Column"
            The "Regulatory Requirement or Management Practice Column" states either a requirement mandated by regulation
            or a good management practice that exceeds the requirements of the federal regulations.  The regulatory citation is
            given in parentheses after the stated requirement. Good management practices are  distinguished from regulatory
            requirements in the  checklist by the acronym (MP) and are printed in italics.

    •       "Reviewer Checks" Column:
            The items under the "Reviewer Checks:" column identify requirements that must be verified to accomplish the
            auditor's performance objectives. (The key to successful compliance auditing is to verify and document site
            observations and other data.) The checklists  follow very closely with the text in the CFR in order to provide the
            service they are intended to fulfill (i.e., to be used for compliance auditing). However, they are not a direct recitation
            of the CFR. Instead they are organized into more of a functional arrangement (e.g., record keeping and reporting
            requirements vs. technical controls) to accommodate an auditor's likely sequence of review  during the site visit.
            Wherever possible,  the statements or items under the "Reviewer Checks" column, will follow the same sequence or
            order of the citations listed at the end of the statement in the "Regulatory Requirement" column.

    •       "NOTE:" Statements
            "Note:" statements contained in the checklists serve several purposes. They usually are distinguished from "Verify"
            statements to alert the auditor to exceptions or conditions that may affect requirements or to referenced standards that
            are not part of Title 40 (e.g., American Society for Testing and Materials (ASTM) standards). They also  may be used
            to identify options that the regulatory agency may choose in interacting with the facility (e.g., permit reviews) or
            options the facility may employ to comply with a given requirement.
   This document is intended solely for guidance.
   No statutory or regulatory requirements are in any way altered by any statement(s) contained herein.

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 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA

 •       Checklist Numbering System:
         The checklists also have a unique numbering system that allows the protocols to be more easily updated by topic area
         (e.g., RCRA Small Quantity Generator). Each topic area in turn is divided into control breaks to allow the protocol to
         be divided and assigned to different teams during the audit. This is why blank pages may appear in the middle of the
         checklists. Because of these control breaks, there  is intentional repetition of text (particularly "Note" Statements)
         under the "Reviewer Checks" column to prevent oversight of key items by the audit team members who may be using
         only a portion of the checklist for their assigned area.
 Environmental regulations are continually changing both at the federal and state level. For this reason, it is important for
 environmental auditors to determine if any new regulations have been issued since the publication of each protocol document
 and, if so, amend the checklists to reflect the new regulations. Auditors may become aware of new federal regulations through
 periodic review of Federal Register notices as well as public information bulletins from trade associations and other
 compliance assistance providers.  In addition, EPA offers information on new regulations, policies and compliance incentives
 through several Agency Websites. Each protocol provides specific information regarding EPA program office websites and
 hotlines that can be accessed for regulatory and policy updates.

                      of           to

 An environmental auditing program is an integral part of any organization's environmental management system (EMS). Audit
 findings generated from the use of these protocols can be used as a basis to implement, upgrade, or benchmark environmental
 management systems.  Regular environmental auditing can be the key element to a high quality environmental management
 program and will function best when an organization identifies the "root causes" of each audit finding. Root causes are the
 primary factors  that lead to noncompliance events. For example a violation of a facility's wastewater discharge permit may be
 traced back to breakdowns in management oversight, information exchange, or inadequate evaluations by untrained facility
 personnel.

 As shown in Figure 1, a typical approach to auditing involves three basic steps: conducting the audit, identifying problems
 (audit findings), and fixing identified deficiencies. When the audit process is expanded, to identify and correct root causes to
 noncompliance, the organization's corrective action part of its EMS becomes more effective.  In the expanded model, audit
 findings (exceptions) undergo a root cause analysis to identify underlying causes to noncompliance events.  Management
 actions are then taken to  correct the underlying causes behind the audit findings and improvements are made to the
 organizations overall EMS before another audit is conducted on the facility. Expanding the audit process allows the
 organization to successfully correct problems, sustain compliance, and prevent discovery of the same findings again during
 subsequent audits.

 Furthermore, identifying the root cause of an audit finding can mean identifying not only the failures that require correction but
 also successful practices that promote compliance and prevent violations.   In each case a root cause analysis should uncover
 the failures while promoting the successes so that an organization can make continual progress toward environmental
 excellence.
This document is intended solely for guidance.
No statutory or regulatory requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                             Figure 1 - Expanded Corrective Action Model
                           Improve
                           Environmental
                           Mgmt. System
                           Effectiveness
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                   vn

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                  This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                                  vui
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


                                                 Section II
                                             Audit Protocols


Applicability

This protocol is intended to help inform facilities that generate hazardous waste, and it includes requirements for waste
minimization and export of hazardous waste. There is a separate booklet that applies to treatment, storage, and disposal
facilities (TSDFs).

The following pages and checklist items contained in the December 1998 document (Protocol for Conducting
Environmental Compliance Audits of Hazardous Waste Generators under the Resource Conservation and Recovery
Act (EPA 300-B-98-005)) have been added/revised in this edition:

    -   Definitions for the terms Aquifer, Battery, Closure Device, Cover, Dike, Equipment, Exempted Hazardous Waste
        Containers and Surface Impoundments, Exempted Hazardous Waste Management Unit, Hazardous Debris, New
        Hazardous Waste Management Facility, On-site, Open-end Valve or Line, Qualified Groundwater Scientist,  Soil,
        Treatment, and Used Oil (see pages 6 through 16 of this document)
    -   HW.10.1
    -   HW.80.2
    -   HW. 130.7 through HW. 130.12
    -   HW.200.2
    -   Appendix A

Not all checklist items will be applicable to a particular facility. Guidance is provided on the  checklists to direct the auditor to
the regulations typically applicable to the type of hazardous waste activities/facilities on the site.

There are numerous environmental regulatory requirements administered by federal, state, and local governments.  Each level
of government may have a major impact on areas at the facility that are subject to the audit. Therefore, auditors are advised to
review federal, state, and location regulations in order to perform a comprehensive audit.

Review of Federal Legislation

The Resource Conservation and Recovery Act, Subtitle C (1976)
The Resource,  Conservation and Recovery Act (RCRA) of 1976, which amended the Solid Waste Disposal Act of  1965,
addresses hazardous (Subtitle C) and solid (Subtitle D) waste management activities. Subtitle C of RCRA, 42 U.S. Code
(USC) sections 6921-693 9b, establishes standards and procedures for the handling, storage, treatment, and disposal of
hazardous waste.  For example, RCRA prohibits the placement of bulk or noncontainerized liquid hazardous waste or free
liquids containing hazardous waste into a landfill.  It also prohibits the "land disposal" of specified wastes and disposal of
hazardous waste through underground injection within 1/4 mile (0.40 km) of an underground source of drinking water.
Pursuant to Subtitle C of RCRA, the United States  Environmental Protection Agency (U.S. EPA) promulgated regulations at
40 CFR Parts 260-299, establishing a "cradle-to-grave" system that governs hazardous waste  from the point of generation to
its treatment or disposal.

The 1984 Hazardous and Solid Wastes Amendments (HSWA) greatly expanded the requirements and coverage of RCRA.
Perhaps the most significant provision of HSWA is the prohibition on the land disposal of hazardous waste. The land disposal
restrictions (LDRs) promulgated by U.S. EPA essentially ban the disposal of untreated liquid hazardous waste or hazardous
waste containing free liquids in landfills and establish treatment standards for these wastes. In addition to the new statutory
and regulatory  requirements imposed by HSWA, a new subtitle to the act was created to govern underground storage  tanks
(USTs). This document does not provide audit guidance for underground or above ground storage tanks regulated
under RCRA. Audit guidance and technical information on above and underground storage tanks is provided by U.S. EPA in
a separate  protocol titled Protocol for Conducting Environmental Compliance Audits of Storage Tanks under the Resource
Conservation and Recovery Act, EPA Document Number 300-B-00-006.


This document is intended solely for guidance. No statutory or regulatory                                        \
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
After assessing air emissions at TSDFs, the U.S. EPA ascertained that volatile organic chemicals (VOCs) adversely affect
human health and welfare.  In response, U.S. EPA promulgated three subparts of RCRA rules designed to control VOCs. In
1990, U.S. EPA issued Subparts AA and BB, which amended 40 CFR Parts 264 and 265. Subpart AA governs organic
chemical emissions from certain hazardous waste treatment processes, while Subpart BB governs equipment that contains or
contacts hazardous waste with at least 10% organic  chemicals by weight. Subpart CC includes requirements for controlling
VOC emissions from tanks, surface impoundments,  containers, and certain miscellaneous "Subpart X" units. The Subpart CC
Final Rule was signed  on December 6, 1994, and the Final Rule Amendments were signed on October 4, 1996.

State/Local Regulations

RCRA encourages states to develop their own parallel regulatory programs for hazardous waste management.  This includes
enacting statutory authority and operating hazardous waste regulatory programs. Many states have met the requirements
established by U.S. EPA in 40 CFR 271 (Requirements for Authorization of state Hazardous Waste Programs) and have been
approved to manage their own state programs. Many  states have adopted the U.S. EPA regulations by reference or have
promulgated regulations that are identical to the U.S. EPA regulations, while other states have promulgated regulations
stricter than the federal RCRA. These differences between individual state regulations and the federal program require that
auditors check the status of their state's authorization and then determine which regulations apply. For example, some states
have listed additional waste as hazardous waste (used oil, PCBs, asbestos). Since the section checklists are based exclusively
on the requirements of the federal RCRA program, the auditor should determine in what ways the applicable state program
differs from the federal program.

Key Compliance Requirements

Identification of Hazardous Waste
Proper identification of hazardous wastes is a complex task that is fundamental to determining which materials at a facility are
subject to RCRA Subtitle C requirements. To determine whether or not a material is a hazardous waste, a facility must answer
four questions about each waste stream. First, is the material a "solid waste," as defined by the RCRA regulations? The
regulatory framework for distinguishing solid and hazardous wastes can be found at 40 CFR งง261.2 and 261.3. Second, does
it fit one of the exclusions from the definition of solid or hazardous waste? Materials that have been excluded are listed in 40
CFR ง261.4. Third, is  it a listed or characteristic hazardous waste? Listed and characteristic wastes are defined in 40 CFR
ง261, Subparts B, C, and D. And finally, has the waste been delisted?

Waste Analysis
A solid waste is a hazardous waste if it is a listed hazardous waste (defined at 40 CFR ง261, Subpart D) or if it exhibits any of
the characteristics defined in 40 CFR ง261, Subpart C.  In order to determine whether the waste exhibits any of the
characteristics, the generator generally must use analytical methods capable of quantitatively identifying the contaminants in
question. Unlike  characteristic wastes, listed wastes are generally determined based on the generator's knowledge of its
manufacturing process or the chemicals used.

A generator can meet waste analysis requirements using several methods or combinations of methods. Wherever feasible, the
preferred method is to  conduct sampling and laboratory analysis because it is more accurate than other options. However,
generators can also apply "acceptable knowledge," which includes (1) process knowledge; (2) waste analysis data obtained
from facilities that send their waste off-site for treatment, storage, or disposal; or (3) records of analysis performed before the
effective date of RCRA regulations, assuming the information is current and accurate.

Process knowledge involves obtaining detailed information on a waste from existing published or documented waste analysis
data or studies conducted on hazardous waste generated by processes similar to that which generated the waste.

When using process descriptions and existing data, a facility must carefully scrutinize whether (1) there are any differences
between the processes  documented and the actual processes and (2) the data used are  accurate and current, including (a)
whether any wastes are newly regulated as hazardous wastes, (b) whether existing data are sufficient to identify any  new
constituent concentration limits, and (c) the information is based on currently valid analytical techniques.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Generator Requirements
The responsibilities of any particular facility are based on the amount of hazardous waste being generated in one calendar
month. Typical hazardous wastes include solvents, paint, contaminated antifreeze or oil, and sludges. In some states, waste oil
and other substances have been classified as a hazardous waste and therefore need to be included in the total amount of waste
generated. Under federal regulations there are three classifications of generators:


1.   A Conditionally Exempt Small Quantity Generator (CESQG) generates no more than 100 kg (220.46 Ib.) of hazardous
    waste or 1 kg (2.20 Ib.) of acutely hazardous waste in a calendar month. A CESQG also may not accumulate on-site more
    than 1,000 kg (2,204.62 Ib.) of hazardous waste at any one time. When either the volume of hazardous waste produced in
    one calendar month exceeds 100 kg (220.46 Ib.) or more than 1,000 kg (2,204.62 Ib.) of hazardous waste have
    accumulated on-site, the facility is required to comply with the more stringent standards applicable to a Small Quantity
    Generator (SQG). When the volume of acutely hazardous waste exceeds 1 kg of spill residue, contaminated soil, waste
    or other debris exceeds 100 kg, then the waste is subject to standards applicable to  large quantity generators (LQGs);

2.   An SQG generates between 100 kg (220.46 Ib.) and 1,000 kg (2,204.62 Ib.) of hazardous waste in a calendar month. The
    hazardous waste cannot accumulate on-site for more than 180 days unless the waste is transported more than 200 miles
    (321.87 km) to a treatment, storage and disposal facility (TSDF). If the hazardous  waste must be transported more than
    200 miles, it can accumulate for up to 270 days. At no time is there to be more than 6,000 kg (13,227.73 Ib.) of
    hazardous waste accumulated at the facility. When the volume of hazardous waste generated in 1 mo exceeds 1,000 kg
    (2,204.62 Ib.) of nonacutely hazardous  waste or 1 kg (2.20 Ib.) of acutely hazardous waste or the accumulation time limit
    is exceeded, the facility is required to comply with the standards for an LQG. When more than 6,000 kg (13,227.73 Ib.)
    of hazardous waste is stored on-site, the SQG is required to obtain a storage permit and comply with the requirements of
    40 CFR 264 and 40 CFR 265;

3.   An LQG generates more than 1,000 kg (2,204.62 Ib.) of hazardous waste in a calendar month. (NOTE: Usingwater,
    which weighs approximately 8.34 Ibs./gal (3.78 kg/gal or 1 kg/L) as a basis of measurement, 100 kg (220.46 Ib.) would
    equal about 26.4 gallons (100 L) (almost one-half of a 55-gal. (208.2 L) drum); 1,000 kg (2,204.62 Ib.) would equal
    about 264 gallons (1000 L) (almost five 55-gal. drums)).

Whether the facility is a CESQG, SQG, or a LQG determines whether and how the RCRA regulations apply to that facility.
Storage areas connected with generation points are often referred to as 90 day storage areas. Regardless of the amount of
hazardous waste generated, the regulations require every facility to test or use knowledge of materials or processes used to
determine if its waste is a listed hazardous waste or exhibits one of four hazardous characteristics (ignitability, corrosivity,
toxicity, reactivity).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                          Comparison of RCRA Generator Requirements
Requirement
Determine Whether Solid
Waste is Hazardous
Quantity Limits
Acute Waste Limits
Facility Receiving Waste
EPA ID Number
RCRA Personnel Training
Exception Report
Biennial Report
On-site Accumulation
Limits (without permit)
Accumulation Time Limits
(without permit)
Storage Requirements for
Accumulated Hazardous
Waste
Use Manifests
Contingency Plan
CESQG
Yes
<100 kg/mo (220.46
Ib./mo)
<1 kg/mo (2.20 Ib./mo)
State approved, RCRA
permitted, interim status,
or exempt recycling
facility
Not required
Not required
Not required
Not required
1,000 kg (2,204.62 Ib.)
None
None
No
No
SQG
Yes
100 kg/mo (220.46 Ib.) to
1,000 kg/mo (2,204.62
Ib.)
<1 kg/mo (2.20 Ib./mo)
RCRA permitted, interim
status, or exempt
recycling facility
Required
Basic training required
Required within 60 days
of hazardous waste being
accepted by initial
transporter
Not required
6,000 kg (13,227.73 Ib.)
180 days [or 270 days if
transported more than 200
mi. (321. 87 km)] U.S. EPA
may grant 30 days for
unforeseen, temporary, and
uncontrollable
circumstances.
Basic requirements with
technical standards for
containers or tanks
Yes, unless the waste is
reclaimed under
contractual agreement in
accordance with the
requirements of 40 CFR
262.20 (e).
No
LQG
Yes
>1,000 kg/mo (2,204.62
Ib./mo)
None
RCRA permitted, interim
status, or exempt
recycling facility
Required
Required
Required within 45 days
of hazardous waste being
accepted by initial
transporter
Required
Any quantity
90 days +
U.S. EPA may grant 30 days
for unforeseen, temporary,
and uncontrollable
circumstances.
Full compliance with
management of containers
or tanks
Yes, unless the waste is
reclaimed under
contractual agreement in
accordance with the
requirements of 40 CFR
262.20 (e).
Required
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Pre-Transport Requirements
Hazardous waste shipped off-site must be packaged, labeled and marked.  The vehicles used to transport the waste must be
placarded in accordance with DOT regulations.

90 Day Storage
90 day storage is an area in or near the place where hazardous waste is accumulated or stored before being sent off-site for
disposal.  Storage in these areas is temporary, and the permissible length of time for accumulation depends on whether the
facility is classified as anLQG, SQG, or CESQG.

Satellite Accumulation Point Management
A satellite accumulation point is an area at or near the point of generation where no more than 55 gal. (208.20 L) of a
hazardous waste or one qt. (0.95 L) of acutely hazardous waste is accumulated. The satellite accumulation point is to remain
under the control of a single operator. When the 55 gal. (208.20 L) limit is reached, the operator has three days to move the
waste to a 90 day storage area or a permitted TSDF. These standards apply to SQGs and LQGs only.

Waste Minimization/Pollution Prevention
Waste minimization and pollution prevention programs are being increasingly discussed and implemented by both
environmental managers and environmental policy makers. Usually defined as a reduction in the volume and toxicity of waste,
waste minimization often pays for itself through reduced disposal costs, operating costs, and liability. While these cost savings
are often enough to justify a program, there are an increasing number of voluntary and mandatory programs that drive waste
minimization/pollution prevention.

Under RCRA, LQGs are required to  sign a certification on each manifest stating that they have a program in place to reduce
waste to the degree that is economically feasible and to select a disposal method that minimizes threats to human health and
the environment. SQGs must show a "good faith effort" to minimize waste and to select the best waste management method
available.

U.S. EPA has also developed guidelines on a waste minimization program for generators. Issued in 58 Federal Register (FR)
31114 on May 28, 1993, the Interim Final Guidance to Hazardous Waste Generators on the Elements of a Waste
Minimization Program is intended to provide guidance to generators of regulated hazardous wastes. The program includes:
•   Provisions for top management assurance that waste minimization is a company-wide effort;
•   Characterization of waste generation and waste management costs;
•   Periodic waste minimization assessments;
•   A cost allocation system;
•   Encouragement of technology transfer; and
•   Program implementation and evaluation.
For further information regarding the RCRA regulations, contact U.S. EPA's RCRA/UST, Superfund and EPCRA Hotline at
800-424-9346 (or 703-412-9810 in the D.C. area) from 9 a.m. to 6 p.m., Monday through Friday.

This U.S. EPA hotline provides up-to-date information on regulations developed under RCRA, CERCLA (Superfund), and
the Oil Pollution Act. The hotline can assist with Section 112(r) of the Clean Air Act (CAA) and Spill Prevention, Control
and Countermeasures (SPCC) regulations. The hotline also responds to  requests for relevant documents and can direct the
caller to additional tools that provide a more detailed discussion of specific regulatory requirements.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Key Terms and Definitions

Acknowledgement of Consent
The cable sent to the U.S. EPA from the U.S. Embassy in a receiving country that acknowledges the written consent of the
receiving country to accept the hazardous waste and describes the terms and conditions of the receiving country's consent to
the shipment (40 CFR 262.51).

Acute Hazardous Waste
Any waste listed under 40 CFR 261.31 through 261.33(c) with a hazard code of H. These also include U.S. EPA hazardous
waste numbers F020, F021, F022, F023, F026, and F027 (40 CFR 261.31) and the P listed wastes in 40 CFR 261.3 3 (e) (40
CFR 261.31 through 261.33).

Approved State Program
A RCRA program administered by a state that has been approved by U.S. EPA according to 40 CFR 271.

Aquifer
A geologic formation or group of formations, or part of a formation capable of yielding a significant amount of groundwater
to wells or springs (40 CFR 260.10).

Average Volatile Organic (VO) Concentration
The mass-weighted average VO concentration of a hazardous waste (40 CFR 265.1081).

Battery
A device consisting of one or more electrically connected electrochemical cells which is designed to receive, store, and
deliver electric energy.  An electrochemical cell is a system consisting of an anode, cathode, and an electrolyte, plus such
connections (electrical and mechanical) as may be needed to allow the cell to deliver or receive electrical energy.  The term
battery also includes an intact, unbroken battery from which the electrolyte has been removed (40 CFR 260.10 and 273.9).

Boiler
An enclosed device using controlled flame combustion and having the following characteristics (40 CFR 260.10):
1.  The unit has physical provisions for recovering and exporting thermal energy in the form of steam, heated fluids, or
    heated gases; and
2.  The unit's combustion chamber and primary energy recovery section(s) must be of integral design; and
3.  While in operation the unit maintains a thermal energy recovery efficiency of at least 60 percent;  and
4.  The unit has been approved by the Administrator of U.S. EPA; and
5.  The unit must export and utilize at least 75% of the recovered energy (40 CFR 260.10).
U.S. EPA may also decide on a case-by-case basis that certain enclosed devices using controlled flame combustion are boilers
even though they may not otherwise meet the definition of boiler.

Certification
A statement of professional opinion based upon knowledge and belief (40 CFR 260.10).

Characteristics of Hazardous Waste
The characteristics of ignitibility, corrosivity, reactivity, and toxicity that identify hazardous waste (40 CFR 261.20 through
261.24).

Closure Device
A cap, hatch, lid, plug, seal, valve, or other type of fitting that blocks an opening in a cover such that when the device is
secured in the closed position it prevents or reduces air pollutant emissions to the atmosphere. Closure devices include
devices that are detachable from the cover (e.g., a sampling port cap), manually operated (e.g., hinged access lid or hatch), or
automatically operated (e.g., a spring loaded pressure relief valve) (40 CFR 265.1081).
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Competent Authorities
The regulatory authorities of concerned countries having jurisdiction over transfrontier movements of wastes destined for
recovery operations (40 CFR 262.81).

Consignee
The ultimate treatment, storage, or disposal facility in a receiving country to which the hazardous waste will be sent (40 CFR
262.51).

Container
Any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled (40 CFR 260.10).

Containment Building
A hazardous waste management unit that is used to store or treat hazardous waste under 40 CFR 264.1100 through 264.1102
and 40 CFR 265.1100 through 265.1102 (40 CFR 260.10).

Contingency Plan
A document setting out an organized, planned, and coordinated course of action to be followed in case of a fire, explosion, or
release of hazardous waste or hazardous waste constituents which could threaten human health or the environment (40 CFR
260.10).

Cover
A device that provides a continuous barrier over the hazardous waste managed in a unit to prevent or reduce air pollutant
emissions to the atmosphere. A cover may have openings (such as access hatches, sampling ports, gauge wells) that are
necessary for operation, inspection, maintenance, and repair of the unit on which the cover is used. A cover may be a separate
piece of equipment which can be detached and removed from the unit or a cover may be formed by structural features
permanently integrated into the design of the unit (40 CFR 265.1081).

Debris
Solid material exceeding a 60 mm particle size that is intended for disposal and that is a manufactured object, plant or animal
matter, or natural geologic material. The following materials are not debris: any material for which a specific treatment
standard is provided; process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludges, or
air emissions residues; and intact containers of hazardous waste that are not ruptured and retain at least 75 percent of their
original volume (40 CFR 268.2).

Dike
An embankment or ridge of either natural or man-made materials used to prevent the movement of liquids, sludges, solids, or
other materials (40 CFR 260.10).

Discharge or Hazardous Waste Discharge
The accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous waste into  or
on any land or water (40 CFR 260.10).

 Disposal
The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or on any
land or water so that such solid waste or hazardous waste or any constituent thereof may enter the environment or be emitted
into the air or discharged into any waters, including groundwaters (40 CFR 260.10).

Disposal Facility
A facility or part of a facility at which hazardous waste  is intentionally placed into or on any land or water, and at which waste
will remain after closure. The term disposal facility does not include a corrective action management unit into which
remediation wastes are placed (40 CFR 260.10).
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Elementary Neutralization Unit
A device which is used for neutralizing hazardous wastes that are hazardous only because they exhibit corrosivity (as defined
in 40 CFR 261.22) or are listed in Subpart D of 40 CFR 261 and that meets the definition of tank, tank system container,
transport vehicle, or vessel (40 CFR 260.10).

Enclosure
A structure that surrounds a tank or container, captures organic vapors emitted from the tank or container, and vents the
captured vapors through a closed-vent system to a control device (40 CFR 265.1081).

EPA Hazardous Waste Number
The number assigned by U.S. EPA to each listed hazardous waste under Subpart D and to each characteristic waste under
Subpart C (40 CFR 260.10).

EPA Identification Number
The number assigned by U.S. EPA to each generator, transporter, and treatment, storage, or disposal facility (40 CFR
260.10).

Equipment
Each valve, pump, compressor, pressure relief device, sampling connection system, open-ended valve or line, or flange or
other connector, and any control devices or systems required by this subpart (40  CFR 264.1031) [Added April 1999].

Exempted Hazardous Waste Containers and Surface Impoundments
Containers and surface impoundments are exempt from these air emission control requirements (specified under 40 CFR
264.1084 through 264.1087 or under 40 CFR 265.1085 through 265.1088) if the waste management unit is one of the
following (40 CFR 264.1082(c) and 265.1083(b)):
1.  containers and surface impoundments for which all hazardous wastes entering the unit have an average VO concentration
    at the point of waste origination of less than 500 ppmw as determined by using the procedures specified under 40 CFR
    264.1083(a) and 40 CFR 265.1084(a). This determination is updated at least every  12 months
2.  containers and surface impoundments for which the organic content of all hazardous wastes entering the unit has been
    reduced by an organic destruction or removal process that achieves any of the following conditions:
        a.   a process that removes or destroys the organics to a level such that the average VO concentration of the
            hazardous waste at the point of waste treatment is less than the exit concentration limit established for the
            process as determined by using the procedures specified under 40 CFR 264.1083(a) and 265.1084(b)
        b.   a process that removes or destroys the organics contained in the hazardous  waste to such a level that the organic
            reduction efficiency for the process is equal to or greater than 95 percent, and the average VO concentration of
            the hazardous waste at the point of waste treatment is less than 100 ppmw as determined by using the procedures
            specified under 40 CFR 264.1083(a) and 265.1084(b)
        c.   a process that removes or destroys the organics contained in the hazardous  waste to such a level that the actual
            organic mass removal rate for the process  is greater than the required organic mass removal rate established for
            the process as determined by using the procedures specified under 40 CFR 264.1083(a) and 265.1084(b)
        d.   a biological process that destroys or degrades the organics contained in the hazardous waste such that either of
            the following is met:
               (i)  the organic reduction efficiency for the process is equal to or greater than 95 percent and the organic
                   biodegradation efficiency for the process is equal to or greater than 95 percent as determined by using
                   the procedures specified under 40 CFR 264.1083(a) and 265.1084(b)
               (ii) the total actual organic mass biodegradation rate for all hazardous waste treated by the process is equal
                   to or greater than the  required organic mass removal rate as determined by using the procedures
                   specified under 40 CFR 264.1083(a) and 265.1084(b)
        e.   a process that removes or destroys the organics contained in the hazardous  waste and meets all the following
            conditions:
               (i)  from the point of waste origination through the point where the hazardous waste enters the treatment
                   process, the hazardous waste is continuously managed in waste management units which use air
                   emissions controls as specified in  40 CFR 264.1084 through 264.2087 or in 40 CFR 265.1085 through
                   265.1088, as applicable to the waste management unit

This document is intended solely for guidance. No statutory or regulatory                                       8
requirements are in any  way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


               (ii) from the point of waste origination through the point where the hazardous waste enters the process, any
                   transfer of the hazardous waste is accomplished through continuous hard-piping or other closed system
                   transfer that does not allow exposure of the waste to the atmosphere
               (iii) the average VO concentration of the hazardous waste at the point of waste treatment is less than the
                   lowest average VO concentration at the point of waste origination determined for each of the individual
                   hazardous waste streams entering the process or 500 ppmw, whichever value is lower (The average VO
                   concentration of each individual waste stream at the point of waste origination shall be determined using
                   the procedures specified under 40 CFR 264.1083(a) and 265.1084(b))
        f.   a process that removes or destroys the organics contained in the hazardous waste to a level such that the organic
            reduction efficiency for the process is equal to or greater than 95 percent and the owner/operator certifies that
            the average VO concentration at the point of waste origination for each of the individual waste streams entering
            the process is less than 10,000 ppmw, as determined by using the procedures specified under 40 CFR
            264.1083(a)  and 265.1084(b))
        g.   a hazardous waste incinerator for which the owner/operator has been issued a final permit under 40 CFR Part
            270, or has designed and operated the incinerator in compliance with 40 CFR 264, Subpart O
        h.   a boiler or industrial furnace for which the owner or operator has been issued a final permit under 40 CFR 270,
            or has designed and operated the unit in compliance with 40 CFR 266, Subpart H.
3.   a tank, container, or surface impoundment for which all hazardous waste placed in the unit either:
        a.   meets the numerical concentrations limits for organic hazardous constituents as specified in 40 CFR 268, or
        b.   the organic hazardous constituents in the waste have been treated by the treatment technology established by the
            U.S. EPA for the waste listed under 40 CFR 268.42(a) or have been removed or destroyed by an equivalent
            method of treatment approved by the U.S. EPA.

Exempted Hazardous Waste Management Unit
The air emission standards specified under Subpart CC of 40 CFR 264 and 265 do not apply to the following waste
management units (40 CFR 264.1080(b) and 265.1080(b)):
1.   a waste management unit that holds hazardous waste placed in the unit before December 6, 1996, and in which no
    hazardous waste is added to the unit on or after December 6, 1996
2.   a container that has a design capacity less than or equal to 0.1 m3
3.   a tank in which an owner/operator has stopped adding hazardous waste and the owner/operator has begun implementing
    or completed closure pursuant to an approved closure plan
4.   a surface impoundment in which an owner/operator has stopped adding hazardous waste (except to implement an
    approved closure plan) and the owner/operator has begun implementing or completed closure pursuant to an approved
    closure plan
5.   a waste management unit that is used solely for on-site treatment or storage of hazardous waste that is placed in the unit
    as a result of implementing remedial activities required under the corrective action authorities of RCRA Sect 3004(u),
    3004(v), or 3008(h); CERCLA authorities; or similar federal or state authorities
6.   a waste management unit that is used solely for the management of radioactive mixed waste in accordance with all
    applicable regulations under the Atomic Energy Act and the Nuclear Waste Policy Act
7.   a waste management unit that the owner or operator certifies is equipped with and operating air emissions controls in
    accordance with the requirements of an applicable Clean Air Act (CAA) regulation codified under 40 CFR 60, 61, and 63
8.   a tank that has a process vent as defined in 40 CFR 264.1031.

Existing Hazardous Waste Management Facility or Existing Facility
A facility which was in operation or for which construction commenced on or before November 19,  1980 (40 CFR 260.10).

Facility
All contiguous land and structures, other appurtenances, and improvements on the land, used for treating, storing, or disposing
of hazardous waste. A facility may consist of several treatment, storage or disposal operational units (e.g., one or more
landfills, surface impoundments, or combination of them) (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Fixed Roof
A cover that is mounted on a unit in a stationary position and does not move with fluctuations in the level of the material
managed in the unit (40 CFR 265.1081).

Food-Chain Crops
Tobacco, crops grown for human consumption, and crops grown for feed for animals whose products are consumed by
humans (40 CFR 260.10).

Free Liquids
Liquids which readily separate from the solid portion of a waste under ambient temperature and pressure (40 CFR 260.10).

Generator
Any person, by site, whose act or process produces hazardous waste identified or listed in 40 CFR Part 261, or whose act first
causes a hazardous waste to become subject to regulation (40 CFR 260.10).

Groundwater
Water below the land surface in a zone of saturation (40 CFR 260.10).

Halogenated Organic Compounds (HOC)
Those compounds having a carbon-halogen bond which are listed in Appendix III (40 CFR 268.2).

Hazardous Debris
Debris that contains a hazardous waste listed in subpart D of 40 CFR 261, or that exhibits a characteristic of hazardous waste
identified in subpart C of 40 CFR 26. Any deliberate mixing of prohibited hazardous waste with debris that changes its
treatment classification (i.e., from waste to hazardous debris) is not allowed under the dilution prohibition in 40 CFR 268.3
(40 CFR 268.2)

Hazardous Waste
A solid waste identified as a characteristic or listed hazardous waste in 40 CFR 261.3 (40 CFR 260.10).

Hazardous Waste Constituent
A constituent that caused the hazardous waste to be listed in 40 CFR Part 261, Subpart D (lists of hazardous wastes from non-
specific and specific sources, and listed hazardous wastes), or a constituent listed in the table of maximum concentrations of
contaminants  for the toxicity characteristic) (40 CFR 260.10).

Hazardous Waste Management Unit
A contiguous area of land on or in which hazardous waste is placed, or the largest area in which there is significant likelihood
of mixing hazardous waste constituents in the same area. Examples are a surface impoundment, a waste pile, a treatment area,
a landfill cell, an incinerator, a tank and its associated piping and underlying containment system, and a container storage
area. A container alone does not constitute a unit; the unit includes containers and the land or pad upon which they are placed
(40 CFR 260.10).

In Light Liquid Service
The piece of equipment  contains or contacts a waste  stream where the  vapor  pressure of one or more of the organic
components in the stream is greater than 0.3 kPa at 20 degrees Celsius, the total concentration of the pure organic components
having a vapor pressure greater than 0.3 kPa at 20 degrees Celsius is equal to or greater than 20 percent by weight, and the
fluid is a liquid at operating conditions (40 CFR 264.1031).

In Light Material Service
The container is used to manage material for which both of the following conditions apply:
1.  The vapor pressure of one or more of the organic constituents in the material is  greater than 0.3 kPa at 20 ฐ C , and
This document is intended solely for guidance.  No statutory or regulatory                                         19
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


2.  The total concentration of the pure organic constituents having a vapor pressure greater than 0.3 kPa at 20 ฐC is equal to
    or greater than 20 percent by weight (40 CFR 265.1081).

Incompatible Waste
A hazardous waste that is unsuitable for:
1.  Placement in a particular device or facility because it may cause corrosion or decay of containment materials (e.g.,
    container liners or tank walls); or
2.  Commingling with another waste or material under uncontrolled conditions because the commingling conditions produce
    heat or pressure, fire or explosion, violent reaction, toxic dusts, mist, fumes, or gases, or flammable fumes or gases (40
    CFR 260.10).

Individual Generation Site
The contiguous site at or on which one or more hazardous wastes are generated. An individual generation site, such as a large
manufacturing plant, may have one or more sources of hazardous waste, but is considered a single or individual generation
site if the site or property is contiguous (40 CFR 260.10).

Industrial Furnace
Any of the following enclosed devices that are integral components of manufacturing processes and that use thermal treatment
to accomplish recovery of materials or energy:
1.   cement kilns
2.   lime kilns
3.   aggregate kilns
4.   phosphate kilns
5.   coke ovens
6.   blast furnaces;
7.   smelting, melting and refining furnaces;
8.   titanium dioxide  chloride process oxidation reactors
9.   methane reforming furnaces
10.   pulping liquor recovery furnaces
11.   combustion devices used in the recovery of sulfur values from spent sulfuric acid; certain halogen acid furnaces, and
12.   other devices designated by the Administrator of U. S. EPA (40 CFR 260.10).

Injection Wells
A well into which fluids  are injected (40 CFR 260.10).

Inner Liner
A continuous layer of material placed inside  a tank or container which protects the construction materials of the tank or
container from the contained waste or reagents used to treat the waste (40 CFR 260.10).

International Shipment
The transportation of hazardous waste into or out of the jurisdiction of the United States (40 CFR 260.10).

Land Disposal
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 placement in a concrete vault or bunker intended for disposal
purposes (40 CFR 268.2).

Land Treatment Facility
A facility or part of a facility at which hazardous waste is applied onto or incorporated into the soil surface; such facilities are
disposal facilities if the waste will remain after closure (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Landfill
A disposal facility or part of a facility where hazardous waste is placed in or on land and which is not a pile, a land treatment
facility, a surface impoundment, an underground injection well, a salt dome formation, a salt bed formation, an underground
mine, a cave, or a corrective action management unit (40 CFR 260.10).

Large Quantity Generator
A facility generating hazardous waste in quantities greater than 1000 kg (2,204.62 Ibs.) per calendar month or greater than 1
kg of acutely hazardous waste per calendar month (40  CFR 260.10).

Leachate
Any liquid, including any suspended components in the liquid, that has percolated through or drained from hazardous waste
(40 CFR 260.10).

Leak Detection System
A system capable of detecting the failure of either the primary or secondary containment structure or the presence of a release
of hazardous waste or accumulated liquid in the secondary  structure. Such a system must employ operational controls (e.g.,
daily visible containment for releases into the secondary containment system of aboveground tanks) or consist of an interstitial
monitoring device designed to detect continuously and automatically the failure of the primary or secondary containment
structure or the presence of a release of hazardous waste into the secondary containment structure (40 CFR 260.10).

Malfunction
Any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment,  process equipment, or a
process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operations
are not malfunctions (40 CFR 265.1081).

Management or Hazardous Waste Management
The systematic control of the collection, source separation, storage, transportation, processing, treatment, recovery, and
disposal of hazardous waste (40 CFR 260.10).

Management Practice (MP)
Practices which, although not mandated by law, are encouraged to promote safe operating procedures.

Manifest
The shipping document originated and signed by the generator containing the information required by 40 CFR 262, Subpart B
(40 CFR 260.10).

Manifest Document Number
The U.S. EPA 12-digit identification number assigned to the generator plus a unique 5-digit number assigned to the manifest
by the generator for recording and reporting purposes (40 CFR 260.10).

Movement
That hazardous waste transported to a facility in an individual vehicle  (40 CFR 260.10).

New Hazardous Waste Management Facility
A facility that began operation, or for which construction commenced  after October 21, 1976 (40 CFR 260.10).

No Detectable Organic Emissions
No escape of organics to the atmosphere as determined by using the procedures specified in 40 CFR 265.1084(d)    (40 CFR
265.1081).

Nonwastewaters
Wastes that do not meet the criteria for wastewaters (40 CFR 268.2). (See definition of wastewater.)

This document is intended solely for guidance.  No statutory or regulatory                                        12
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Notifier
The person under jurisdiction of the exporting country who has, or will have at the time the planned transfrontier movement
commences, possession or other forms of legal control of the wastes and who proposes their transfrontier movement for the
ultimate purpose of submitting them to recovery operations. When the United States (U.S.) is the exporting country, notifier
is interpreted to mean a person domiciled in the United States (40 CFR 262.81).

OECD Country
Designated member countries of the Organization for Economic Coordination and Development (OECD) consisting of
Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Japan, Luxembourg, Netherlands,
New Zealand, Norway, Portugal, Spain, Sweden, Switzerland, Turkey, United Kingdom, and the United States. Canada and
Mexico are considered OECD member countries under the RCRA regulations only for the purpose of transit (40 CFR
262.58).

On-site
The same or geographically contiguous property which may be divided by a public or private right-of-way, provided the
entrance and exit between the properties is at a crossroads intersection, and  access is by crossing as opposed to going along
the right-of-way. Non-contiguous properties owned by the same person but connected by a right-of-way which he controls
and to which the public does not have access is also considered onsite property (40 CFR 260.10)

Open Burning
The combustion of any material without the following characteristics:
1.   Control of combustion air to maintain adequate temperature for efficient combustion,
2.   Containment of the combustion-reaction in an enclosed device to provide sufficient residence  time and mixing for
    complete combustion,
3.   Control of emission of the gaseous combustion products (40 CFR 260.10).

Open-ended Valve or Line
Any valve, except pressure relief valves, having one side of the valve seat in contact with hazardous waste and one side open
to the atmosphere, either directly or through open piping (40 CFR 264.1031)

Pile
Any non-containerized accumulation of solid, nonflowing hazardous waste that is used for treatment or storage that is not a
containment building (40 CFR 260.10).

Point Source
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, vessel or floating craft, from which
pollutants are or may be discharged. This term does not include return flows from irrigated agriculture (40 CFR 260.10).

Point of Waste Treatment
The point where a hazardous waste exits a waste management unit used to destroy, degrade, or remove organics in the
hazardous waste (40 CFR 265.1081).

Pollution Prevention
The use of materials, processes, or practices that reduce or eliminate the creation of pollutants or waste at the source.  It
includes practices that reduce the use of hazardous materials, energy, water  or other resources and practices that protect
natural resources through conservation and more efficient use.

Primary Exporter
Any person who is required to originate the manifest for a shipment of hazardous waste in accordance with 40 CFR 262,
Subpart B or an equivalent state provision, that specifies a treatment, storage, or disposal facility in a receiving country as the
facility to which the hazardous waste will be sent and any intermediate arranging for the export (40 CFR 262.51).
This document is intended solely for guidance.  No statutory or regulatory                                        13
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Prohibited Wastes
A subset of restricted wastes (under the land disposal restriction (LDR) regulations) that have established treatment standards,
are not subject to variances or waiver, and do not meet the respective treatment standard.

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 (as defined by section 502(4) of the CWA). This definition includes
sewers, pipes, or other conveyances only if they convey wastewater to a POTW providing treatment (40 CFR 260.10).

Qualified Groundwater Scientist
A scientist or engineer who has received a baccalaureate  or post- graduate degree in the natural sciences or engineering and
has sufficient training and experience in groundwater hydrology and related fields as may be demonstrated by state
registration, professional certification, or completion of accredited university courses that enable the individual to make sound
professional judgments regarding groundwater monitoring and contaminant fate and transport (40 CFR 260.10).

Receiving Country
A foreign country to which a hazardous waste is sent for the purpose of treatment, storage, or disposal (except short-term
storage incidental to transportation) (40 CFR 262.51).

Representative Sample
A sample  of a universe  or whole (e.g., waste pile, lagoon, groundwater) which can be expected to exhibit the average
properties of the universe or whole (40 CFR 260.10).

Restricted Wastes
The RCRA hazardous wastes that are subject to the LDR program. A waste is restricted if U.S. EPA has established a
treatment  standard for it, or if it has been specifically designated by Congress as ineligible for land disposal.

Runoff
Any rainwater, leachate, or other liquid that drains over land from any part of a facility (40 CFR 260.10).

Run-on
Any rainwater, leachate, or other liquid that drains over land onto any part of a facility (40 CFR 260.10).

Sludge
Any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water
supply treatment plant,  or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant (40
CFR 260.10).

Small Quantity Generator
A generator who generates less than 1,000 kg (2,204.62 Ib.) of hazardous waste but more than 100 kg (220.46 Ib.) in a
calendar month (40 CFR 260.10).

Soil
Unconsolidated earth material composing the superficial geologic strata (material overlying bedrock), consisting of clay, silt,
sand, or gravel size particles as classified by the U.S. Natural Resources Conservation Service, or a mixture of such materials
with liquids, sludges or solids which is inseparable by simple mechanical removal processes and is made up primarily of soil
by volume based on visual inspection. Any deliberate mixing of prohibited hazardous waste with soil that changes its
treatment classification (i.e., from waste to contaminated soil) is not allowed under the dilution prohibition in 40 CFR 268.3
(40 CFR 268.2)
This document is intended solely for guidance. No statutory or regulatory                                        14
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Storage
The holding of hazardous wastes for a temporary period, at the end of which the hazardous wastes are treated, disposed of, or
stored elsewhere (40 CFR 260.10).

Sump
Any pit or reservoir that meets the definition of tank and those troughs/trenches connected to it that serve to collect hazardous
waste for transport to hazardous waste TSDF except that as used in the landfill, surface impoundment, and waste pile rules,
sump means any lined pit or reservoir that serves to collect liquids drained from a leachate collection and removal system or
leak detection system for subsequent removal from the system (40 CFR 260.10).

Transfer Facility
Any transportation-related facility including loading docks, parking areas, storage areas and other similar areas where
shipments of hazardous wastes are kept during the normal course of transportation (40 CFR 260.10). (NOTE: Transfer
facilities are regulated under 40 CFR 263.12.)

Transfrontier Movement
Any shipment of hazardous wastes destined for recovery operations from an area under the national jurisdiction of one OECD
member country to an area under the national jurisdiction of another OECD country (40 CFR 262.81).

Transit Country
Any foreign country, other than a receiving country, through which a hazardous waste is transported (40 CFR 260.10).

Transport Vehicle
A motor vehicle or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, railroad
freight car, etc.) is a separate transport vehicle (40 CFR 260.10).

Transporter
A person engaged in the off-site transportation of hazardous wastes by air, rail, highway, or water (40 CFR 260.10).

Treatability Study
A study in which a hazardous waste is subjected to a treatment process to determine:
1.  Whether the waste is amenable to the treatment process,
2.  What pretreatment (if any) is required,
3.  The optimal process conditions needed to achieve the desired treatment,
4.  The efficiency of a treatment process for a specific waste or wastes, or
5.  The characteristics and volumes of residuals from a particular treatment process (40 CFR 260.10).

Also included in this definition for the purpose of the 40 CFR 261.4(e) and (f) exemptions are liner compatibility,  corrosion,
and other material compatibility studies and lexicological and health effects studies. A treatability study is not a means to
commercially treat or dispose of hazardous waste.

Treatment
Any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological
character or composition of any hazardous waste so as to neutralize the waste, or so as to recover energy or material resources
from the waste,  or so as to render the waste nonhazardous or less hazardous; safer to transport, store, or dispose of; or
amenable for recovery, amenable for storage, or reduced in volume (40 CFR 260.10).

Unsaturated Zone or Zone of Aeration
The zone between the land surface and the water table (40 CFR 260.10).
This document is intended solely for guidance. No statutory or regulatory                                         15
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


United States
The 50 states, the District of Columbia, the Commonwealth of Puerto Rico, the US Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern Mariana Islands (40 CFR 260.10).

Uppermost Aquifer
The geologic formation nearest the natural ground surface that is an aquifer, as well as lower aquifers that are hydraulically
interconnected with this aquifer within the facility's property boundary (40 CFR 260.10).

Used Oil
Any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is
contaminated by physical or chemical impurities (40 CFR 260.10).

Volatile Organic (VO) Concentration
The fraction by weight of the volatile organic compounds in a hazardous waste expressed in terms of ppmw as determined by
direct measurement or by knowledge of the waste (40 CFR 265.1081)

Waste Stabilization Process
Any physical or chemical process used to  either reduce the mobility of hazardous constituents in a hazardous waste or
eliminate free liquids (40 CFR 265.1081).

Wastewater Treatment Unit
A device that (1) is part of a wastewater treatment facility  subj ect to regulation under section 402 or 3 07 of the CWA; and (2)
receives and treats or stores an influent wastewater that is a hazardous waste (as defined in 40 CFR 261.3), or that generates
and accumulates a wastewater treatment sludge that is a hazardous waste, or treats or stores a wastewater treatment sludge;
and (3) meets the definition of tank or tank system (40 CFR 260.10).

Wastewaters
Wastes that contain less than one percent by weight total organic compounds and one percent by weight total suspended solids
(40 CFR 268.2).

Zone of Engineering Control
An area under the control of the owner/operator that upon detection of a hazardous waste  release, can be readily cleaned up
before the release of hazardous waste or hazardous constituents to groundwater or surface water (40 CFR 260.10).

Typical Records to Review

•   Notification of Hazardous Waste Activity (EPA ID No.);
•   Hazardous waste manifests;
•   Manifest exception reports;
•   Biennial reports;
•   Inspection logs;
•   Delistings;
•   Speculative accumulation records;
•   Land disposal restriction certifications;
•   Employee training documentation;
•   Hazardous substance spill control and contingency plan;
•   Notifications of hazardous waste oil fuel marketing or blending activity;
.   Material Safety Data Sheets (MSDSs);
•   Inventory records;
•   Shipping papers;
•   Hazardous Communication Plan;
•   Chemical Hygiene Plan (labs); and
•   Spill records.


This document is intended solely for guidance. No statutory or regulatory                                         15
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Typical Physical Features to Inspect

•   Hazardous waste generations sites (e.g., production and manufacturing areas);
•   Waste storage areas;
•   Satellite accumulation points;
•   Vehicles used for transport;
•   Container storage areas;
•   Generation points;
•   Shipping and receiving areas; and
•   Shop activities.

List of Acronyms and Abbreviations

AST       Aboveground storage tank
BTU       British thermal unit
CAA       Clean Air Act
CAMU     Corrective action management unit
CERCLA   Comprehensive Environmental Response, Compensation, and Liability Act (or Superfund)
CESQG    Conditionally exempt small quantity generator
CFC       Chlorofluorocarbon
CFR       Code of Federal Regulations
CSD       Contaminated soil and debris
CWA      Clean Water Act
DOT       Department of Transportation
EPA       Environmental Protection Agency
FR        Federal Register
ft.         Feet
gal.        Gallon
h          Hour
HOC       Halogenated organic compound
hp         Horsepower
HSWA     Hazardous and Solid Waste Amendments
HWM      Hazardous waste management
ID         Identification
kg         Kilogram
km        Kilometer
L          Liter
Ib.         Pound
LDR       Land disposal restriction
LQG       Large quantity generator
OECD      Organization for Economic Coordination and Development
m         Meter
Mg        Megagram
MJ        Megajoule
mm       Millimeter
mo        Month
MP        Management practice
MSDS      Material Data Safety Sheet
MW       Megawatt
NOV       Notice of violation
NRC       National Response Center
PCB       Polychlorinated biphenyl
PL        Public Law
POTW     Publicly owned treatment works
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
17

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
ppm        Part per million
ppmw       Part per million by weight
qt.          Quart
RCRA      Resource Conservation and Recovery Act
scf         Standard cubic foot
scm        Standard cubic meter
SDWA      Safe Drinking Water Act
SPCC       Spill prevention, control, and countermeasure
SQG        Small quantity generator
TSCA       Toxic Substances Control Act
TSDF       Treatment, storage, and disposal facility
UIC        Underground injection control
U.S.        United States
U.S. EPA    United States Environmental Protection Agency
USC        United States Code
UST        Underground storage tank
VO         Volatile organic
VOC        Volatile organic compound
yr          Year
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
18

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Index for Checklist Users


Category
All Facilities
All Sizes of Generators
Conditionally Exempt Small Quantity Generators (CESQG)
Small Quantity Generators (SQG)
General
Personnel Training
Containers
Satellite Accumulation Points
Container Storage Areas
Disposal of Restricted Wastes
Large Quantity Generators (LQG)
General
Personnel Training
Contingency Plans and Emergency Coordinators
Containers
Emissions from Process Vents
Air Emissions Standards for Equipment Leaks
Satellite Accumulation Points
Container Storage Areas
Containment Buildings
Disposal of Restricted Waste
Transportation of Hazardous Waste
Export/Import of Hazardous Waste
Exports of Hazardous Waste for Recovery Within the
OECD Member Countries
Exports of Hazardous Waste (Except to the OECD
Member Countries) for Recovery
Imports of Hazardous Waste for Recovery Within the
OECD Member Countries
Imports of Hazardous Waste (Except from the OECD
Member Countries) for Recovery
Waste Minimization/Pollution Prevention
Refer To:

Checklist Items:
HW. 1.1 through HW. 1.4
HW.10.1 through HW. 10.4
HW.20.1 through HW.20.6

HW.30.1 through HW.30.6
HW.40.1andHW.40.2
HW.50.1 through HW.50.6
HW.60.1
HW.70.1 through HW.70.3
HW.80.1 through HW.80.5

HW. 100.1 through HW. 100.7
HW. 1 10.1 and HW. 110.2
HW. 120.1 through HW. 120.4
HW. 130.1 through HW. 130. 12
HW. 140.1 through HW. 140.6
HW. 150.1 through HW. 150. 10
HW. 160.1
HW. 170.1 through HW. 170.3
HW. 190.1 through HW. 190.7
HW.200.1 through HW.200.6
HW.300.1 through HW.300.5

HW.400.1 through HW.400.7

HW.420.1 through HW.420.8

HW.440.1 through HW.440.6

HW.460.1andHW.460.2

HW.500.1
Page
Numbers:
21
23
27

31
35
37
39
41
43

47
51
53
57
69
77
85
87
89
93
97

101

107

111

115

117
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
19

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                                       20
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Checklist
                                         COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     ALL FACILITIES

     HW.l
     HW.1.1.  The current status
     of any ongoing or unresolved
     Consent Orders,  Compliance
     Agreements,   Notices   of
     Violation     (NOV),     or
     equivalent state enforcement
     actions pertaining to RCRA
     or   corresponding    state
     regulations     should    be
     examined.
Determine if noncompliance issues have been resolved by reviewing a copy of the
previous report, Consent Orders, Compliance Agreements, NOVs, Interagency
agreements or equivalent state enforcement actions.

Determine and indicate, for those open items, what corrective action is planned
and milestones established to correct problems.
     HW.1.2.    Facilities    are
     required to comply with state
     and    local     regulations
     concerning  hazardous  waste
     management.
Determine  state authorization status.   In authorized  states,  compare  state
regulations to federal requirements outlined in this document and annotate this
checklist accordingly.

Verify that the facility is abiding by state and local hazardous waste requirements.

Verify that the facility is operating according to hazardous waste permits issued
by the state or local agencies where approved.

(NOTE: Issues typically regulated by state and local agencies include:
   - additional manifesting requirements
   - more frequent reporting requirements
   - transportation
   - identification of special waste or waste  categories
   -regulation  of specific  substances as  hazardous waste such  as: medical,
     pathological, and infectious waste; used oil; explosives; used batteries
   - small and conditionally exempt small quantity generator requirements
   - RCRA permitting of oil/water separators
   - disposal requirements
   - construction and operation of storage and disposal facilities
   - satellite accumulation point requirements
   - container marking and labeling requirements.)

Verify that the  actions detailed in  compliance  agreements  are  being  taken
according to the schedule established in the agreements.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      21

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.1.3.    Facilities    are
     required to comply with all
     applicable federal regulatory
     requirements not identified in
     this checklist
Determine if any new hazardous waste regulations have been issued since the
finalization of the guide. If so, annotate checklist to include new standards.

Determine if the facility has hazardous waste activities or facilities that are
federally regulated, but not addressed in this checklist.

Verify that the facility is in compliance with all applicable and newly issued
hazardous waste regulations.
     HW.1.4.   Specific  persons
     should    be    designated
     responsible  for  hazardous
     waste storage areas, and the
     precise   nature  of   their
     responsibilities   should  be
     specified (MP).
Verify that specific individuals have been designated responsible for hazardous
waste storage areas.

Verify that the individuals designated responsible for hazardous waste storage
areas are aware of the precise nature of their responsibilities.

Verify that required training for hazardous waste handling is in personnel file.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      22

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     ALL SIZES OF
     GENERATORS

     HW.10
     HW.10.1.   Facilities   that
     generate solid wastes must
     determine  if the wastes  are
     hazardous  wastes (40 CFR
     262.11, 261.3, 261.4(b), and
     261.21   through   261.24)
     [Revised January 2001].
(NOTE:  Determination of whether or not a waste is a hazardous waste can be
done through one of the following:

   -knowledge of all the constituents of the waste (MSDSs) and whether it is
     listed in 40 CFR 261
   - laboratory analysis
   -knowledge of materials and processes used.)

(NOTE:  Unidentified waste materials and spilled hazardous materials may have
to be  disposed  of as hazardous waste depending  on their  constituents or
characteristics.)

(NOTE:  Some batteries, pesticides, thermostats, and mercury lamps may be
considered universal wastes instead of hazardous wastes and need to be handled
according to the requirements in 40 CFR 273.)

Discuss with staff how wastes generated on the facility were  identified and
classified.

Determine  if  the  facility  followed U.S.  EPA  criteria for  identifying the
characteristics of hazardous waste and U.S. EPA's listed wastes in 40 CFR 261
(see Appendices A, B, C, and D of this document).

Determine whether the facility  generates, transports, treats, stores, or disposes of
any hazardous waste and the quantity (see Appendices A, B, C, and D of this
document for guidance, note that the listings reflected in these appendices are
frequently revised in the Federal Register).

(NOTE:  When making quantity determinations, all hazardous waste generated
must be included except hazardous waste that is:
   -exempt  from  regulation under  40  CFR  261.4(c)  through 261.4(f),
     261.6(a)(3), 261.7(a)(l), or 261.8
   -managed   immediately  upon  generation  only  in  on-site  elementary
     neutralization  units,  wastewater  treatment  units, or  totally enclosed
     treatment facilities
   - recycled, without prior storage or accumulation, only in an on-site process
     subject to regulation under 40 CRR 261.6(c)(2)
   -used oil managed under 40 CFR 261.6(a)(4) and 40 CFR 279
   - spent lead-acid batteries managed under the requirements of 40  CFR 266,
     Subpart G	
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      23

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                     -universal waste managed under 40 CFR 261.9 and 40 CFR 273.)

                                  (NOTE:  The following are examples of solid wastes which are not considered
                                  hazardous wastes (40 CFR 261.3 and 261.4(b)):
                                     - household waste
                                     - solid wastes that are generated by any of the following and are returned to
                                       the soils as fertilizers:
                                          - growing and harvesting of agricultural crops
                                          - raising of animals, including animal manures
                                          - mining overburden returned to  the mine site
                                     - fly ash waste,  bottom ash waste, slag waste, and flue gas emission control
                                       waste generated primarily from the  combustion of coal or other fossil fuels
                                       except for facilities that burn hazardous waste
                                     -drilling  fluids, produced  waters   and  other  wastes affiliated  with the
                                       explorations,  development, or  production of  crude oil,  natural gas, or
                                       geothermal energy
                                     - wastes that fail the test for the toxicity characteristic because chromium is
                                       present or are listed in Subpart D because of the presence of chromium, that
                                       do not fail the test for toxicity characteristics for any other constituent or are
                                       not listed due to the presence of any other constituent, and that do not fail
                                       the test for other characteristics  (see 40 CFR 261.4(b)(6)(i) for a listing of
                                       types of industries generating this type of waste that receive exclusions)
                                     - solid waste from the extraction, beneficiation, and processing of ores and
                                       minerals (including coal, phosphate rock, and overburden) from the mining
                                       of uranium ore (NOTE:  There is an exception to this for facilities that burn
                                       or process hazardous waste, see 40 CFR 266.112.)
                                     - cement kiln dust waste, except for facilities that burn or process hazardous
                                       waste
                                     -solid  waste which  consists of  discarded arsenic-treated wood  or wood
                                       products which fails the test for Toxicity Characteristics for hazardous waste
                                       codes D004 through DO 17 and which is not a hazardous waste for any other
                                       reason if the waste  is generated by persons  who utilize the arsenic-treated
                                       wood and wood products for those materials intended end use
                                     -petroleum contaminated media  and debris that fail the  test for  Toxicity
                                       Characteristic  of 40 CFR 261.24 (Hazardous Waste Codes DO 18 through
                                       D043 only) and are required to meet the corrective action regulations under
                                       40 CFR280
                                     -injected groundwater that is hazardous only because it exhibits the  Toxicity
                                       Characteristic  (Hazardous  Waste Codes DO 18  through D043  only) in 40
                                       CFR  261.24 that  is reinjected through  an underground injection well
                                       pursuant to free  phase hydrocarbon  recovery operations undertaken at
                                       petroleum refineries, petroleum marketing terminals, petroleum bulk plants,
                                       petroleum pipelines, and petroleum transportation spill sites until January
                                       25,  1993. This extension applies to  recovery operations in existence, or for
                                       which contracts have been issued, on or  before March 25, 1991. For
                                       groundwater returned through infiltration galleries  from such operations at
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                              24

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                       petroleum refineries, marketing terminals, and bulk plants. New operations
                                       involving injection wells (beginning after March 25, 1991) will qualify for
                                       this compliance date extension (until January 25, 1993) only if:
                                          - operations are performed pursuant to a written state agreement that
                                            includes a provision to assess the groundwater and the need for further
                                            remediation once the free phase recovery is completed; and
                                          - a copy of the written agreement has been submitted to: Characteristics
                                            Section  (OS-333),  U.S.  Environmental Protection Agency,  401 M
                                            Street, SW., Washington, DC 20460
                                     -used chlorofluorocarbon refrigerants  from totally enclosed  heat  transfer
                                       equipment, including mobile air conditioning systems, mobile refrigeration
                                       and commercial and  industrial air conditioning and refrigeration  systems
                                       that use chlorofluorocarbons as the heat transfer fluid in a refrigeration
                                       cycle, provided that the refrigerant is reclaimed for further use
                                     - non-terne plated used oil filters that are not mixed with a listed hazardous
                                       waste if these oil filters have been gravity  hot-drained using one of the
                                       following methods:
                                          - puncturing the filter anti-drain back valve or the filter dome end and
                                            hot-draining
                                          - hot-draining and crushing
                                          - dismantling and hot-draining, or
                                          - any other equivalent hot-draining method that will remove used oil
                                     -used oil  re-refining  distillation  bottoms  that  are used  as  feedstock to
                                       manufacture asphalt products
                                     -leachate or gas condensate collected from landfills where  certain solid
                                       wastes have been disposed, provided that:
                                          -the solid wastes disposed would meet one or more of the listing
                                            descriptions  for Hazardous Waste Codes K169,  K170, K171, and
                                            K172 if these wastes had been generated after February 8, 1999
                                          - the solid wastes were disposed prior to the effective date of the listing
                                          -the leachate  or  gas  condensate  do not exhibit any  characteristic of
                                            hazardous waste nor are derived from any other listed hazardous waste
                                          - discharge of the leachate or gas condensate, including leachate or gas
                                            condensate transferred from the landfill to a POTW by truck, rail, or
                                            dedicated pipe, is subject to regulation under sections 307(b) or 402 of
                                            the CWA.

                                  (NOTE:  After  February 13, 2001, leachate or gas condensate will no longer be
                                  exempt if it is stored or managed in a surface impoundment prior to discharge.
                                  There is one exception: if the surface impoundment is used to temporarily store
                                  leachate or gas condensate in response to an emergency  situation (e.g., shutdown
                                  of wastewater treatment system), provided the impoundment has a double liner,
                                  and provided the leachate or gas condensate is removed from the impoundment
                                  and continues  to be managed in compliance with  40  CFR 261.4(b) after the
                                  emergency ends.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                             25

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  Verify that wastes are tested  for  toxicity  characteristics  or are previously
                                  identified as toxic.

                                  Verify that all data used for determination, including quality assurance data, is
                                  maintained and kept available for reference or inspection.
     HW.10.2.  Facilities  which
     claim  that   a   particular
     material is not a solid waste
     or is conditionally exempt
     from   regulation    as    a
     hazardous waste should  be
     prepared  to provide specific
     documentation in the event of
     an enforcement action  (40
     CFR261.2(f)).
Determine if the facility has any wastes that are typically handled as hazardous
wastes that it claims are exempt.

Verify that for these  wastes, the facility can demonstrate that there  is  a known
market or distribution for the material (if relevant) and that they meet the terms of
the exclusion or exemption.

Verify that documentation is provided that indicates the material is not a waste or
is exempt from regulation.

(NOTE:  One example of documentation is  contracts showing that a second
person uses the material as an ingredient in a production process.)

Verify that if the facility is claiming to recycle material, the equipment for the
recycling is actually at the facility and in working order.
     HW.10.3.   Areas    where
     containers   of   hazardous
     waste are stored should have
     secondary      containment
     (MP).
Verify  that the areas where  containers of hazardous waste are  stored have
secondary containment.
     HW.10.4.  Generators  must
     not  offer  their  waste  to
     transporters  or TSDFs  that
     have not  received an  EPA
     identification  number   (40
     CFR262.12(c)).
Verify that all transporters of hazardous wastes and TSDFs used by the generator
have an EPA identification number by examining facility records pertaining to
these  services.  Examples of such records could include sales  agreements  or
vendor contracts.  Auditors could also contact the state regulatory agency or local
U.S. EPA regional office to confirm that these vendors have the appropriate EPA
identification number.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       26

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     CONDITIONALLY
     EXEMPT SMALL
     QUANTITY
     GENERATORS (CESQG)

     HW.20
     HW.20.1.  Generators of no
     more   than   100   kg/mo
     (220.46 Ib/mo) of hazardous
     waste  or  1  kg  of acutely
     hazardous waste may qualify
     as CESQGs when they meet
     specific   requirements  (40
     CFR    261.5)     [Revised
     January 2001].
Verify that the following quantity and storage limitations are met:

   -no more than 100 kg (220.46 Ib.) of hazardous  waste is generated in a
     calendar month
   -total  on-site  accumulation does  not  exceed 1,000 kg (2,204.62 Ib.) of
     hazardous waste
   -no more than 1 kg (2.2 Ib.) of acute hazardous waste (see Appendix D) is
     generated in a calendar month
   -no more than a total of 100 kg (220.46 Ib.) of any residue or contaminated
     soil, waste, or other debris resulting from the cleanup of any acute wastes in
     a calendar month is generated.

Verify that wastes are either  treated  or disposed of in an on-site facility or
delivered to an off-site TSDF, which is one of the following:

   - permitted under 40 CFR 270
   - operating under interim status
   -authorized  to manage hazardous waste  by a  state with an  approved
     hazardous waste management program under 40 CFR 271
   - permitted, licensed, or registered by a state to manage solid waste
   - a facility which does one of the following:
        -beneficially uses or  reuses, or legitimately  recycles  or  reclaims its
         waste
        - treats it waste prior to beneficial use  or reuse, or legitimate recycling
         or reclamation
   - a universal waste handler or destination facility for universal  waste if the
     waste is to be disposed of is universal waste regulated under 40 CFR 273.

(NOTE:  If a hazardous waste generator  meets the requirements  for being a
CESQG, it is not required to meet any of the standards outlined in 40 CFR 262
through 266, (except 262.11), 268, and 270.)

(NOTE: If a facility mixes its waste with used  oil, the  mixture is subject to the
requirements in Subpart G of 40 CFR 279 if it is destined to be burned for energy
recovery.)

(NOTE:  Quantities of hazardous  and  acutely hazardous waste greater than the
threshold quantities listed above become subject to the standards for LQGs.)	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     27

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  (NOTE:  Even though a CESQG is not legally required to use  a manifest or
                                  obtain a hazardous waste identification number, many hazardous  waste haulers
                                  will not transport hazardous  waste from a facility without a manifest or ID
                                  number.)
     HW.20.2.    Environmental
     management at the facility
     may be enhanced if CESQG
     personnel    who    handle
     hazardous  waste   receive
     training in certain key areas
     of waste management (MP).
Verify that the facility personnel complete classroom instruction or on-the-job
training as set forth below:

Verify that the training program is directed by a person trained in hazardous
waste management procedures and that the program includes instruction which
teaches facility personnel hazardous waste management procedures relevant to
positions in which they are employed.

(NOTE: Although not specified by the regulations, examples of training topics for
hazardous  waste management procedures could include (but would not be
limited to) the following:
   - waste turn in procedures
   — identification of hazardous wastes
   — container use, marking, labeling and on-site transportation
   - manifesting and off-site transportation
   - 90 day storage area management
   —personal health and safety and fire safety.)

Verify that the training program includes contingency plan implementation and
is designed to ensure that facility personnel are able to respond to  emergencies
including (where applicable):

   — key parameters for automatic waste feed cut-off systems
   -procedures for using, inspecting, repairing, and replacing emergency and
     monitoring equipment
   — operation of communications and alarm systems
   -response to fire or explosion
   - response to  groundwater contamination incidents
   - response to  leaks or spills
   — shutdown of operations.

Verify that new employee training is completed within six months of employment/
assignment.

Verify that an annual review of initial training is provided.

Verify that employees do not work unsupervised until training is completed.

Verify specifically that  waste  storage area  managers  and hazardous waste
handlers have been trained.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      28

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.20.3.  Training records
     should be maintained for all
     CESQG  staff who  manage
     hazardous waste (MP).
 Verify that training records include the following:

   —job title and description for each employee by name
   - written description of how much training each position will obtain
   - documentation of training received by name.

 Determine if training records are  retained for  3  yr after employment at the
facility.
     HW.20.4.  Empty  containers
     at    CESQGs    previously
     holding   hazardous   wastes
     must  meet  the  regulatory
     definition  of empty  before
     they   are   exempted  from
     hazardous             waste
     requirements    (40    CFR
     261.7).
Verify that for containers or inner liners holding hazardous wastes:

   -wastes are  removed that can  be removed using practices  commonly
     employed  to remove materials from that type of container (e.g., pouring,
     pumping, and aspirating) and,
   - no more than 2.5 cm (1 in.) of residue remains, or
   -if the container is less than or equal to 110 gal. (416.40 L), no more than 3
     percent by weight of total container capacity remains, or
   -when the container is greater than 110 gal. (416.40 L), no more than 0.3
     percent by weight of the total container capacity remains.

Verify that  for containers that hold  a compressed gas,  the  pressure in the
container approaches atmosphere.

Verify that for a container or inner liner that held an acute hazardous waste listed
in Appendix D,  one of the following is done:

   - it is triple rinsed
   - it is cleaned by another method identified through the literature or testing as
     achieving equivalent removal
   - the inner liner is removed.
     HW.20.5.   Containers   at
     CESQGs should be managed
     in  accordance with specific
     management practices (MP).
 Verify the following by inspecting storage areas:

   — containers are not stored more than two high  and have pallets between
     them
   — containers of highly flammable wastes are electrically grounded (check for
     clips and wires and make sure wires lead to ground rod or system)
   - at least 3ft. (0.91 m) of aisle space is provided between rows of containers.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      29

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      COMPLIANCE CATEGORY;
                                 HAZARDOUS WASTE MANAGEMENT
         REGULATORY
       REQUIREMENT OR
         MANAGEMENT
           PRACTICE
                       REVIEWER CHECKS
    HW.20.6.   Containers  of
    hazardous waste should be
    kept in  designated  storage
    areas at CESQGs (UP).
Verify  that all  hazardous  waste containers are identified  and stored  in
appropriate areas.

(NOTE: Any unidentified contents of solid waste containers and/or containers
not in designated storage areas must be tested to determine if solid or hazardous
waste requirements apply.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                  30

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     SMALL QUANTITY
     GENERATORS (SQGs)

     HW.30

     General
     HW.30.1.     SQGs    that
     generate, transport, or handle
     hazardous wastes must obtain
     an    EPA    identification
     number (40  CFR  262.12(a)
     and  262.12(b);   40  CFR
     265.11).
Determine  the  facility's  generator  identification  number  by  examining
documentation from U.S. EPA.

Verify that correct identification number is used on all appropriate documentation
(i.e., manifests).
     HW.30.2.   Generators   of
     more than  100 kg  (220.46
     Ib.)  but less than 1,000 kg
     (2,204.62 Ib.)  of  hazardous
     waste per month may qualify
     as   an  SQG   which  can
     accumulate  hazardous waste
     on-site  for 180 days  (or 270
     days)  without  a  permit  if
     specific conditions are  met
     (40     CFR    262.34(d)(l),
     262.34(d)(4), 262.34(e)  and
     262.34(f)).
Verify that containers, storage, and records have been inspected.

Verify that no more than 1,000 kg (2,204.62 Ib.) of hazardous waste is generated
in any calendar month.

Verify that the on-site accumulation time does not exceed 180 days.

(NOTE:  For an SQG the accumulation start date begins when the first waste is
poured/placed into the waste container, except at satellite accumulation points.)

(NOTE:  The 180 day time period is extended to 270 days if the waste must be
transported more than 200 miles to a TSDF. This extension does not apply if a
TSDF is available within 200 miles and the facility chooses to transport the waste
to a more distant TSDF.)

Verify that no more than 6,000 kg (13,227.73 Ib.) is allowed to accumulate at the
facility.

Verify that containers are marked with the date that accumulation began and the
words HAZARDOUS WASTE.

Verify that the containers and the areas where containers are  stored meet the
requirements outlined in the subsections pertaining to SQG.

(NOTE:  Quantities  of hazardous and acutely hazardous waste  greater than the
threshold quantities listed above become subject to the standards for LQGs.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     31

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.30.3. An SQG must not
     offer its  hazardous waste to
     transporters or to TSDFs that
     have not  received an EPA
     identification  number  (40
     CFR262.12(c)).
Verify that all transporters of hazardous waste and TSDFs utilized by the facility
have an EPA identification number by examining facility records pertaining to
these services. Examples of such records could include vendor contracts or sales
agreements.  Auditors could also  contact the state regulatory agency or the local
U.S. EPA regional office to  confirm that these vendors have the appropriate EPA
identification number.
     HW.30.4.     SQGs     of
     hazardous waste are required
     to  use manifests and  keep
     records of  hazardous waste
     activity   (40  CFR  262.20,
     262.42(b) and 262.44).
Verify that signed copies of returned manifests are kept for three years from the
date the waste was accepted by the initial transporter.

Verify that exception reports were submitted to the regulatory agency when a
signed manifest copy was not received within 60 days of the waste being accepted
by the initial transporter.

Verify that exception reports are kept for at least three years.

(NOTE: The requirement to prepare a manifest does  not apply if:
   - the waste is reclaimed under contractual agreement and:
        -the  type of waste and frequency of shipments are specified in the
          agreement;
        - the vehicle used to transport the waste to  the recycling facility and to
          deliver regenerated  material back  to  the  generator is owned and
          operated by the reclaimer; and
        - the  generator maintains a copy of the reclamation agreement for at
          least three years after termination of the agreement.)

(NOTE:   Period of retention of records is extended automatically during the
course of  any  unresolved enforcement action or as  requested by the regulatory
agency.)
     HW.30.5. SQGs are required
     to  keep  records   of  waste
     analyses,  tests,  and  waste
     determinations   (40   CFR
     262.40(c)).
Verify that appropriate records are kept for at least three years from the date the
waste was last sent to an on-site or off-site TSDF.

(NOTE:   Period of retention of records  is extended automatically during the
course of any unresolved enforcement action or as requested by the regulatory
agency.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       32

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY;
                                  HAZARDOUS WASTE MANAGEMENT
         REGULATORY
       REQUIREMENT OR
         MANAGEMENT
           PRACTICE
                        REVIEWER CHECKS
     HW.30.6. SQGs are required
     to   have   an   emergency
     coordinator  and  emergency
     response planning (40 CFR
     262.34(d)(5)).
Verify that the facility has at least one emergency coordinator who is either on the
premises or on call.

Verify that the following emergency information is posted next to the telephone:

   - name and telephone number of emergency coordinator
   - location of fire extinguishers and spill control materials
   - location of fire alarms (if present)
   -telephone number of fire department.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   33

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                                       34
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY:
                                  HAZARDOUS WASTE MANAGEMENT
         REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                        REVIEWER CHECKS
     SMALL QUANTITY
     GENERATORS

     HW.40

     Personnel Training
     HW.40.1.   SQG personnel
     are required to be thoroughly
     familiar  with  proper  waste
     handling   and  emergency
     procedures    (40     CFR
     262.34(d)(5)(iii)).
Verify that personnel are thoroughly familiar with waste handling and emergency
procedures relevant to their responsibilities during normal facility operation and
emergencies.
     HW.40.2.  Training records
     should be maintained for all
     SQG  staff  who   manage
     hazardous waste (MP).
Verify that training records include the following:

   -job title and description for each employee by name
   — written description of how much training each position will obtain
   — documentation of training received by name.

Determine if training records are retained for three years after employment at
the facility.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   35

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                                       35
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     SMALL QUANTITY
     GENERATORS

     HW.50

     Containers
     HW.50.1.  Empty  containers
     at SQGs previously holding
     hazardous  wastes must meet
     the  regulatory  definition  of
     empty   before   they   are
     exempted  from   hazardous
     waste requirements (40 CFR
     261.7).
Verify that for containers or inner liners holding hazardous wastes:

   -wastes  are  removed  that  can be removed using practices  commonly
     employed to remove materials from that type of container (e.g., pouring,
     pumping, and aspirating), and
   - no more than 2.5 cm (1 in.) of residue remains, or
   -if the container is less than or  equal to 110 gal. (416.40 L), no more than 3
     percent by weight of total container capacity remains, or
   -when the container is greater  than 110 gal. (416.40 L), no more than 0.3
     percent by weight of the total container capacity remains.

Verify that for containers that held a compressed gas, the pressure in the container
approaches atmosphere.

Verify that for a container or inner liner that held an acute hazardous waste listed
in Appendix D, one of the following is done:

   - it is triple rinsed
   - it is cleaned by another method identified through the literature or testing as
     achieving equivalent removal
   - the inner liner is removed.
     HW.50.2. Containers used to
     store  hazardous  waste  at
     SQGs  must  be  in  good
     condition and not leaking (40
     CFR 262.34 (d)(2)  and 40
     CFR 265.171).
Verify that containers are not leaking, bulging, rusting, damaged or dented.

Verify  that waste in leaking containers is transferred to a new  container or
managed in another appropriate manner when necessary.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     37

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.50.3. Containers used at
     SQGs must be made  of or
     lined     with     materials
     compatible  with the  waste
     stored  in them  (40   CFR
     262.34(d)(2)  and  40   CFR
     265.172).
Verify that containers are compatible with waste; for example, check that strong
caustics and acids are not stored in metal drums.
     HW.50.4.    Containers   of
     hazardous  waste  at  SQGs
     must   be    closed   during
     storage and handled in a safe
     manner       (40      CFR
     262.34(d)(2)   and 40 CFR
     265.173).
Verify that containers are closed except when it is necessary to add or remove
waste (check bungs on drums, look for funnels).

Verify that handling and storage practices do not cause damage to the containers
or cause them to leak.
     HW.50.5.  The  handling  of
     incompatible    wastes    or
     incompatible   wastes  and
     materials  in  containers  at
     SQGs must comply with safe
     management  practices   (40
     CFR  262.34(d)(2)  and  40
     CFR 265.177).
Verify that incompatible wastes or incompatible wastes and materials are not
placed in the same containers unless it is done so that it does not:

   - generate extreme heat or pressure, fire, explosion, or violent reaction
   -produce uncontrolled  toxic  mists,  fumes,  dusts, or gases in sufficient
     quantities to threaten human health
   -produce uncontrolled flammable fumes or gases in sufficient quantities to
     pose a risk of fire or explosions
   - damage the structural integrity of the device or facility
   - threaten human health by any other like means.

(NOTE:  Incompatible wastes as listed in Appendix E of  this document should
not be placed in the same drum.)

Verify that hazardous wastes are not placed in an unwashed container that
previously held an incompatible waste or material.

Verify that containers holding hazardous wastes incompatible with wastes stored
nearby in other containers,  open tanks,  piles, or  surface  impoundments are
separated or protected from each  other by a dike, berm, wall or other device.
     HW.50.6.   Containers   of
     hazardous  waste  at  SQGs
     should  be  managed   in
     accordance   with   specific
     management practices (MP).
Determine the following by inspecting containers and storage areas:

   — containers are not stored more than two high and have pallets between
     them
   -containers of highly flammable wastes are electrically grounded (check for
     clips and wires and make sure wires lead to ground rod or system)
   - at least 3ft. (0.91 m) of aisle space is provided between rows of containers.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      38

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     SMALL QUANTITY
     GENERATORS

     HW.60

     Satellite Accumulation
     Points
     HW.60.1.  All  SQGs  may
     accumulate  as much as 55
     gal. of hazardous waste or 1
     qt.  of  acutely   hazardous
     waste in containers at or near
     any point of initial generation
     without complying with the
     requirements   for   on-site
     storage if specific standards
     are met (40 CFR 262.34(c)).
(NOTE: This type of storage area is often referred to as a satellite accumulation
point.)

Verify that the satellite accumulation point is at or near any point of generation
where wastes initially accumulate and is under the control of the operator of the
waste generating process.

Verify that the containers are in good condition and are compatible with the waste
stored in them and that the containers are kept closed except when waste is being
added or removed.

Verify that  the  containers  are  marked  HAZARDOUS  WASTE  or other
appropriate identification.

(NOTE:  See ices A, B, C, and D for a  guidance list of hazardous and acute
wastes.  Note that the listings reflected in these appendices are frequently revised
in the Federal Register)

Verify that shop  managers are interviewed, in order to identify when waste is
accumulated in excess of quantity limitations, and when such findings are made
the following actions are taken:

   -the excess container is marked with the date  the excess amount began
     accumulating
   - the waste is transferred to a storage area within three days where it will be
     stored for 180 days or less.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     39

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                                       40
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     SMALL QUANTITY
     GENERATORS

     HW.70

     Container Storage Areas
     HW.70.1.    Containers   of
     hazardous  waste  at  SQGs
     should be  kept in storage
     areas   designated   in  the
     management plan (MP).
Verify that all containers are identified and stored in appropriate areas.

(NOTE:  Any unidentified contents of solid waste containers and/or containers
not in designated storage areas must be tested to determine if solid or hazardous
waste requirements apply.)
     HW.70.2. SQG storage areas
     must     be     designed,
     constructed,  maintained,  and
     operated  to  minimize  the
     possibility   of   a   fire,
     explosion, or any unplanned
     release of hazardous waste or
     constituents   which   could
     threaten human health or the
     environment    (40    CFR
     262.34(d)(4)  and 40 CFR
     265.30 through 265.37).
Determine if the following required equipment is easily accessible and in working
condition by inspecting the SQG storage areas (unless none of the hazards posed
by  the waste  managed  at  the  facility would  require the particular kind of
equipment):

   - internal communications or alarm system capable of providing immediate
     emergency instruction to facility personnel
   - a telephone or hand-held two way radio capable of contacting local and
     emergency responders
   -portable fire extinguishers and fire control  equipment, including  special
     extinguishing equipment (foam, inert gas, or dry chemicals)
   - spill control equipment
   - decontamination equipment
   -fire  hydrants or other  source of water (reservoir, storage  tank, etc.) with
     adequate  volume and  pressure, foam producing  equipment, or automatic
     sprinklers, or water spray systems.

Determine if equipment is tested and maintained as necessary to insure proper
operation in an emergency.

Verify that sufficient aisle space is maintained to allow unobstructed movement
of  personnel,  fire  protection  equipment,  spill control equipment,  and
decontamination equipment to any area of the operation.

Verify that police, fire departments, and emergency response teams  are familiar
with the layout of the facility, properties of the waste being handled,  and general
operations as appropriate for the type of waste  and potential need for such
services,  by reviewing  with  them  the  procedures employed  by   facility
management.

Verify that local hospitals are familiar with the site and types of injuries that
could result in an emergency as appropriate for the type of waste and potential
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      41

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY;
                                  HAZARDOUS WASTE MANAGEMENT
         REGULATORY
       REQUIREMENT OR
         MANAGEMENT
           PRACTICE
                        REVIEWER CHECKS
                                need for such services by  reviewing with them the procedures  employed by
                                facility management.

                                (NOTE: Where state or local authorities decline to enter into arrangements, the
                                facility must document this refusal in the operating record.)
     HW.70.3.    SQGs   must
     conduct  weekly  inspections
     of container storage areas (40
     CFR    262.34(d)(2)    and
     265.174).
Verify  that inspections  are  conducted  at least weekly  to  look  for leaking
containers and signs of deterioration of containers.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   42

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     SMALL QUANTITY
     GENERATORS

     HW.80

     Disposal of Restricted
     Waste
     HW.80.1.  SQGs  must  test
     their wastes  or use process
     knowledge to  determine if
     they are restricted from land
     disposal      (40       CFR
     268.7(a)(l)).
Determine whether the generator determines if wastes have to be treated prior to
disposal.

Determine if the facility generates restricted wastes (see Appendix VII to 40 CFR
Part 268) by reviewing test results or reviewing procedures employed by facility
management  where  process knowledge was applied in  making the  waste
determinations.
     HW.80.2.  When an SQG is
     managing a restricted waste,
     a  written notice  must be
     issued to the TSDF of the
     appropriate        treatment
     standards  and   prohibition
     levels (40 CFR  268.7(a)(2)
     through         268.7(a)(4),
     268.7(a)(10))       [Revised
     January 2001].
(NOTE: The notification requirement under 40 CFR 268.7 has changed to a one-
time notification and certification if the composition of the wastes, the process
generating the wastes, and  the treatment facility receiving the  wastes do not
change (See FR Vol 62, No. 91, May 12, 1997, pg 26004).)

Verify that, for waste or contaminated soil which does not meet the  applicable
treatment standards or exceeds the applicable prohibition levels, the notice is
issued and includes:

   -U.S. EPA hazardous waste numbers and manifest number of first shipment
   -the waste is subject  to the  LDRs (NOTE:  The notice must also include
     constituents of concern for F001-F005, and F039, and underlying hazardous
     constituents in characteristic wastes, unless the waste will be treated and
     monitored for all constituents.  If all constituents will be treated  and
     monitored, there is no need to put them all on the LDR notice.)
   -the applicable wastewater/nonwastewater category  (see 40  CFR 268.2(d)
     and 268.2(f)) and subdivisions made within a waste code based on waste-
     specific criteria (such as D003 reactive cyanide)
   - waste analysis data (when available)
   -for  hazardous  debris,  when  treating  with  the  alternative  treatment
     technologies provided by 40 CFR 268.45:
        -the  contaminants subject to  treatment, as  described in 40  CFR
          268.45(b)
        - an indication that these contaminants are being treated to comply with
          40 CFR 268.45
   -for contaminated soil subject to LDRs as provided in 40 CFR 268.49(a), the
     constituents subject to treatment as described in 40 CFR 268.49(d), and the
     following statement:  'This contaminated  soil [does/does not] contain listed
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      43

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                       hazardous waste  and [does/does not] exhibit a characteristic of hazardous
                                       waste and  [is  subject to/complies  with] the soil  treatment standards as
                                       provided by 40 CFR 268.49(c) or the universal treatment standards."

                                  Verify that, for waste or contaminated soil which meets the treatment standard at
                                  the original point of generation, the notice includes:

                                     -U.S. EPA hazardous waste numbers and manifest number of first shipment
                                     -the  waste is subject to the LDRs (NOTE:  The notice must also include
                                       constituents of concern for F001-F005, and F039, and underlying hazardous
                                       constituents in characteristic  wastes, unless the waste will be treated and
                                       monitored  for all  constituents. If all  constituents  will be treated and
                                       monitored, there is no need to put them all on the LDR notice.)
                                     -the  applicable wastewater/nonwastewater category  (see 40  CFR  268.2(d)
                                       and 268.2(f)) and subdivisions made within a waste code based on waste-
                                       specific criteria (such as D003 reactive cyanide)
                                     - waste analysis data
                                     -for contaminated soil subject to LDRs as provided in 40 CFR 268.49(a), the
                                       constituents subject to treatment as described in 40 CFR 268.49(d), and the
                                       following statement: "This contaminated soil [does/does not]  contain listed
                                       hazardous waste  and [does/does not] exhibit a characteristic of hazardous
                                       waste and  [is  subject to/complies  with the  soil  treatment standards as
                                       provided by 40 CFR 268.49(c) or the universal treatment standards"
                                     -the  signature of an authorized representative certifying that the  waste
                                       complies with the  treatment standards  of 40 CFR 268  (the text of the
                                       required certification statement can be found in 40 CFR 268.7(a)(3)(i).)

                                  Verify that, for waste or contaminated soil that meets the treatment standard at the
                                  original point  of generation, if the  waste changes, the  generator sends a new
                                  notice and certification to the receiving facility and placed a copy in their files.

                                  (NOTE:   Generators  of  hazardous debris  excluded from the  definition of
                                  hazardous waste under 40 CFR 261.3(f)  are not subject  to the requirements for
                                  waste or contaminated soil which meets the  treatment standard at the original
                                  point of generation.)

                                  Verify that, for restricted waste subject to  an exemption from a prohibition of the
                                  type of land disposal used, the notice states that the waste is not prohibited from
                                  land disposal and includes:

                                     -U.S. EPA hazardous waste numbers and manifest number of first shipment
                                     - statement: this waste is not prohibited from land disposal
                                     - waste analysis data, when available
                                     - date the waste is subject to the prohibition
                                     -for  hazardous  debris,  when treating  with the  alternative  treatment
                                       technologies provided by 40  CFR 268.45: the contaminants subject to
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                             44

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                          COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                          REVIEWER CHECKS
                                       treatment, as described in 40 CFR 268.45(b); and an indication that these
                                       contaminants are being treated to comply with 40 CFR 268.45.

                                   (NOTE: SQGs with tolling agreements are required to comply with notification
                                   and certification  requirements for the initial shipment of waste subject to the
                                   agreement.  The  SQG  will  retain an on-site  copy  of  the  notification  and
                                   certification along with the tolling agreement for at least three years after the
                                   termination or expiration of the agreement.)
     HW.80.3.  SQGs  that  are
     managing prohibited  wastes
     in  tanks,   containers,   or
     containment  buildings  and
     treating the waste  to meet
     applicable         treatment
     standards, must develop and
     follow   a   written   waste
     analysis   plan  (40   CFR
     268.7(a)(5)             and
     268.7(a)(10)).
Verify that the plan describes the procedures that the generator will follow in
order to comply with treatment standards.

(NOTE:    SQGs treating  hazardous debris under  the  alternative  treatment
standards are not required to conduct waste analysis.)

Verify that the plan is kept on-site and:

   -the plan  is based on a  detailed chemical  and  physical  analysis  of
     representative sample of the prohibited waste being treated
   - the plan contains all information necessary to treat the wastes in accordance
     with regulatory requirements including the selected testing frequency
   -the plan must  be kept in the facility's on-site files and made available to
     regulatory inspectors.

(NOTE:  SQGs with tolling agreements are required to comply with notification
and certification requirements for the initial shipment of waste subject to the
agreement.   The SQG will retain  an on-site  copy of the notification and
certification along with the tolling agreement for at  least three years after the
termination or expiration of the agreement.)
     HW.80.4. SQGs are required
     to  keep  specific documents
     pertaining    to    restricted
     wastes  on-site   (40  CFR
     268.7(a)(4)          through
     268.7(a)(7)             and
     268.7(a)(10)).
Verify that if the facility is using generator knowledge to determine whether a
waste or contaminated  soil meets land disposal restriction requirements,  the
supporting  data  used in making this determination  is retained  on-site  in  the
facility operating files.

Verify that if the  facility has determined whether a waste  is restricted using
appropriate test methods, the waste analysis data is retained on-site in the files.

Verify that if the facility has determined that it is managing a restricted waste that
is excluded from the definition of a hazardous waste or solid waste or exempt
from RCRA Subtitle C,  a one-time notice is placed in the facility's files  stating
that the generated waste is excluded.

Verify that a copy of all notices, certifications, waste analysis data and other
documentation is kept for at least three years from the date that the waste was last
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                        45

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  sent to on-site or off-site treatment, storage, or disposal.

                                  Verify that SQGs with tolling agreement  retain the agreement and copies of
                                  notification and certification for at least three years after the agreement expires.
     HW.80.5.  The  storage  of
     hazardous   waste  that  is
     restricted from land disposal
     is not allowed unless specific
     conditions are  met (40  CFR
     268.50).
Verify that land disposal restricted waste is not stored at the facility unless the
SQG is storing the wastes in tanks, containers, or containment buildings on-site
only for the purpose of accumulating enough quantity of hazardous  waste to
facilitate proper recovery, treatment, or disposal and all appropriate standards for
containers, tanks, and containment buildings are met.

(NOTE: The prohibition on storage does not apply to hazardous wastes  that have
met treatment standards.)

Verify that liquid hazardous  wastes containing PCBs  at concentrations greater
than 50 ppm are stored at a site that meets the requirements of 40 CFR 761.65(b)
(see Toxic Substances Control Act (TSCA)) and is removed from storage within
one year of the date it was first placed into storage.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      46

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS (LQGs)

     HW.100

     General
     HW.100.1.  A generator that
     generates,   transports,    or
     handles   hazardous   wastes
     must   obtain   an   EPA
     identification   number  (40
     CFR     262.12(a)     and
     262.12(b)).
Determine  the  facility's   generator  identification  number  by  examining
documentation from U.S. EPA.

Verify that  the correct  identification number  is  used  on all  appropriate
documentation (i.e., manifests).
     HW. 100.2.  Generators  may
     accumulate  hazardous waste
     on-site  for  90 days or less
     without a permit or interim
     status  provided  they  meet
     certain  conditions (40 CFR
     262.34(a)(2),   262.34(a)(3)
     and 262.34(b)).
Verify that each 90 day storage area is inspected and the storage manager is
interviewed so as to verify the following:

   - the date upon which accumulation begins is clearly marked and visible for
     inspection
   - the recorded start date indicates no container or tank has been accumulating
     a hazardous waste longer than 90 days (unless granted a 30 day extension)
   -each container and tank  is labeled or marked clearly with  the  words
     HAZARDOUS WASTE.

(NOTE:  For a generator the accumulation start date begins when the first waste
is poured/placed into the waste container, except at satellite accumulation points.)

(NOTE:  A generator who meets these standards is exempt from meeting the
closure requirements outlined in 40 CFR 265.110 through 265.156, except for
265.Ill and 265.114.)

(NOTE:  A generator who  accumulates hazardous waste for more than 90 days
(without an extension), is subject to all TSDF and permitting requirements.)
     HW. 100.3.  Generators must
     not  offer  their  waste   to
     transporters or  TSDFs that
     have not received an EPA
     identification   number  (40
     CFR262.12(c)).
Verify that all transporters of hazardous wastes and TSDFs used by the generator
have an EPA identification number by examining facility records pertaining to
these  services.  Examples of such records could include sales agreements or
vendor contracts. Auditors could also contact the state regulatory agency or local
U.S. EPA regional office to confirm that these vendors have the appropriate EPA
identification number.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     47

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW. 100.4. Generators who
     shipped hazardous waste off-
     site to a TSDF must submit a
     biennial   report    to   the
     regulatory  agency  by   1
     March of even   numbered
     years (40 CFR 262.40(b) and
     262.41(a)).
Verify that the biennial  report (EPA Form 8700-13 A)  is complete  and was
submitted in a timely manner.

Verify that copies are kept for three years.

(NOTE:   Reporting for exports of hazardous  waste is  covered under  the
import/export section of this protocol.)

(NOTE:  Periods of retention of records may be extended automatically during
the course  of any  unresolved enforcement action  or at  the  request  of  the
regulatory agency.)
     HW. 100.5.  Generators  are
     required to use manifests, file
     manifest  exception reports,
     and  maintain  records  (40
     CFR   262.20,   262.40(a),
     262.40(b),  262.40(d),   and
     262.42(a)).
Verify that manifests are used when shipping the waste off-site.

Verify that exception reports were filed with the regulatory agency when a copy
of the manifest was not received within 45 days of the waste being accepted by
the initial transporter.

Verify that manifests and exception reports are kept for three years.

(NOTE:  Periods of retention for reports may be extended automatically during
the course of any unresolved enforcement action.)
     HW. 100.6.  Generators  are
     required to keep  records of
     waste   analyses,   tests,  and
     waste   determinations   (40
     CFR 262.40(c)).
Verify that the appropriate records are kept for three years from the date the
waste was last sent to the on-site or off-site TSDF.

(NOTE:  Periods  of retention for reports may be extended automatically during
the course  of  any  unresolved  enforcement action  or  at  the  request  of the
regulatory agency.)
     HW. 100.7.       Generator
     storage   areas   must   be
     designed,       constructed,
     maintained, and operated to
     minimize the possibility of a
     fire,   explosion,   or   any
     unplanned     release    of
     hazardous     waste     or
     constituents   which   could
     threaten human health or the
     environment    (40    CFR
     262.34(a)(4)  and  40  CFR
     265.30 through 265.37).
Determine if the following required equipment is easily accessible and in working
condition at the  storage area (unless none of the hazards posed by the waste
managed at the facility would require the particular kind of equipment):

   - internal communications or alarm system capable of providing immediate
     emergency instruction to facility personnel
   - a telephone or hand-held two way radio capable of summoning emergency
     assistance
   -portable fire extinguishers and fire  control equipment, including special
     extinguishing equipment (foam, inert gas, or dry chemicals)
   - spill control equipment
   - decontamination equipment
   -fire hydrants or other source  of water (reservoir, storage tank, etc.) with
     adequate volume and  pressure, foam producing equipment,  or automatic
     sprinklers, or water spray systems.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       48

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                 Determine if equipment is tested and maintained as necessary to insure proper
                                 operation in an emergency.

                                 Verify that sufficient aisle space is maintained to allow unobstructed movement
                                 of  personnel,  fire  protection  equipment,  spill  control  equipment,  and
                                 decontamination equipment to any area of the operation.

                                 Verify that police, fire departments, and emergency response teams are familiar
                                 with the layout of the facility, properties of the waste being handled, and general
                                 operations  as appropriate  for the type of  waste and potential need for such
                                 services, by reviewing  with them  the  procedures  employed  by  facility
                                 management.

                                 Verify that local hospitals are familiar with the site and types of injuries that
                                 could result in an emergency as appropriate for the type of waste and potential
                                 need  for such services by reviewing with them the procedures employed by
                                 facility management.

                                 (NOTE: Where state or local authorities decline to enter into arrangements, the
                                 facility must document this refusal in the operating record.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                            49

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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This document is intended solely for guidance. No statutory or regulatory                                       50
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.110

     Personnel Training
     HW.110.1.    All   facility
     personnel    who    handle
     hazardous waste  must meet
     certain training requirements
     (40  CFR  262.34(a)(4);  40
     CFR   265.16(a)   through
     265.16 (c)).
Verify that the facility personnel has completed classroom instruction or on-the-
job training as set forth below.

Verify that the training program is directed by a person trained in hazardous
waste management procedures and that the program includes instruction which
teaches facility personnel hazardous waste management procedures relevant to
positions in which they are employed.

(NOTE: Although not specified by the regulations, examples of training topics for
hazardous waste management procedures could include (but would not be limited
to) the following:
   - waste turn in procedures
   - identification of hazardous wastes
   - container use, marking, labeling and on-site transportation
   - manifesting and off-site transportation
   - 90 day storage area management
   - personal health and safety and fire safety.)

Verify that the training program includes contingency plan implementation and is
designed to  ensure that facility personnel are able to respond to  emergencies
including (where applicable):

   - key parameters for automatic waste feed cut-off systems
   -procedures for using, inspecting, repairing,  and replacing emergency and
     monitoring equipment
   - operation of communications and alarm systems
   - response to fire or explosion
   - response to groundwater contamination incidents
   - response to leaks or spills
   - shutdown of operations.

Verify that  new  employee  training  is completed  within  six  months of
employment/ assignment.
                                  Verify that an annual review of initial training is provided.

                                  Verify that employees do not work unsupervised until training is completed.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      51

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY;
                                  HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                                                    REVIEWER CHECKS
                                 Verify  specifically  that waste  storage  area  managers and  hazardous waste
                                 handlers have been trained.
                                 Verify that training records include the following by examination:

                                    -job title and description for each employee by name
                                    - written description of how much training each position will obtain
                                    - documentation of training received by name.

                                 Determine if training records are retained for three years for former employees.

                                 Determine if training  records on current employees are  maintained.  (NOTE:
                                 Training records on current employees must be  maintained until the closure of the
                                 facility.)
HW. 110.2.  Training records
must be  maintained for all
facility  staff who  manage
hazardous waste  (40  CFR
262.34(a)(4);    40    CFR
265.16(d) and 265.16(e)).
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                52

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.120

     Contingency Plans and
     Emergency Coordinators
     HW.120.1.  Generators  must
     have a contingency plan (40
     CFR  262.34(a)(4) and 40
     CFR 265.50 through 265.54).
(NOTE:  Generating activities may be addressed in the facility's SPCC plan or
other emergency plan, or if none exists, in a separate contingency plan.)

Verify that the contingency plan is designed to minimize hazards to human health
or the environment from fires, explosions, or any unplanned sudden or  non-
sudden release of hazardous waste or hazardous waste constituents.

Verify that the plan includes the following:

   - a description of actions to be taken during an emergency
   -a description of arrangements  made with  local  police departments, fire
     departments, hospitals, contractors,  and state and local emergency response
     teams as appropriate
   -names,  addresses, and phone numbers  of all persons qualified to act  as
     emergency coordinator  (if  more than one  name is listed,  the plan must
     identify  one person as  the  primary emergency coordinator with other
     persons listed in the order in which they will assume responsibility as  an
     alternate)
   - a list of all emergency equipment at the facility and where this equipment is
     required, located, and what it looks like
   -an evacuation plan  for facility personnel where there is a possibility
     evacuation would be needed.

Verify that copies of the contingency plan and all revisions are maintained at the
facility and also have been submitted to organizations which may be called upon
to provide emergency services.

Verify that the contingency plan is routinely  reviewed and updated, especially
when:

   - the applicable regulations are revised
   - the plan fails in an emergency
   -the facility changes (e.g., in its design, construction, operation, maintenance)
     in a  way that materially increases the potential for  fires,  explosions,  or
     releases of hazardous constituents or changes the response necessary in  an
     emergency	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      53

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                          COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                          REVIEWER CHECKS
                                      - the list of emergency coordinators changes
                                      - the list of emergency equipment changes.
     HW. 120.2.  Each  generator
     must  have   an  emergency
     coordinator  on  the  facility
     premises or  on call at all
     times  (40 CFR 262.34(a)(4)
     and 40 CFR 265.55).
Verify that, at all times, there is at least one employee at the facility or on call
with responsibility for coordinating all emergency response measures.

Verify that the emergency  coordinator is thoroughly familiar with the facility,
including all operations and activities  at the facility, the location of all records
within the facility, the facility layout, the characteristics of the waste handled, and
the provisions of the contingency plan.  In  addition,  verify  the  emergency
coordinator has the authority to commit the resources needed to carry out  the
contingency plan.
     HW. 120.3.      Emergency
     coordinators  at  generators
     must     follow     certain
     emergency       procedures
     whenever    there    is   an
     imminent      or     actual
     emergency situation (40 CFR
     262.34(a)(4)  and  40  CFR
     265.56(a) through 265.56(1)).
Verify that the emergency coordinator is required to follow these  emergency
procedures:

   -immediately activate facility alarms  or communication systems and notify
     appropriate facility, state, and local response parties
   -identify the character, exact source,  amount, and  a real extent of any
     released materials
   - assess possible hazards to human health or the environment, including direct
     and indirect effects (e.g.,  release of gases, surface  runoff from water  or
     chemicals used to control fire or explosions, etc.)
   - take all reasonable measures necessary to ensure that fires, explosions and
     releases do not  occur, recur, or spread to other  hazardous  waste at the
     facility. These measures must include where applicable:
        - stop processes and operations at the facility when necessary to prevent
          fires, explosions, or further releases
        - collect and contain the released waste
        - remove or isolate containers when necessary
   - monitor for leaks, pressure buildup,  gas generation,  or ruptures in valves,
     pipes, or other equipment whenever appropriate
   - provide for treatment, storage, or disposal of recovered waste, contaminated
     soil, or surface water, or other material  immediately after emergency
   - ensure that no waste that may be incompatible with the released material is
     treated, stored, or disposed of until cleanup is completed
   - ensure that all emergency equipment is cleaned and fit for its intended use
     before operations are resumed
   -notify U.S. EPA, and appropriate state and local authorities that the facility
     is in compliance with 40 CFR 265.56(h) before operation resumes.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                        54

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY;
                                  HAZARDOUS WASTE MANAGEMENT
         REGULATORY
       REQUIREMENT OR
         MANAGEMENT
           PRACTICE
                        REVIEWER CHECKS
     HW. 120.4.       Generator
     operators  must  record  the
     time, date, and details of any
     incident    that     requires
     implementing           the
     contingency  plan (40  CFR
     262.34(a)(4)  and 40  CFR
     265.560)).
Determine if incidents have been recorded  and corrective actions taken by
reviewing facility operating records.

Verify that written reports have been submitted to the regulatory agency within 15
days after the incident.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                   55

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory                                       55
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.130

     Containers
     HW.130.1. Empty containers
     at   generators    previously
     holding   hazardous   wastes
     must  meet  the  regulatory
     definition of empty  before
     they   are   exempted  from
     hazardous             waste
     requirements    (40    CFR
     261.7).
Verify that for containers or inner liners holding hazardous wastes:

   -wastes  are  removed  that  can be  removed  using  practices  commonly
     employed to remove materials from that type of container (e.g., pouring,
     pumping, and aspirating), and
   - no more than 2.5 cm (1 in.) of residue remains, or
   -if the container is less than or equal to 110 gal. (416.40 L), no more than 3
     percent by weight of total container capacity remains, or
   -when the container is greater than 110 gal. (416.40 L), no more than 0.3
     percent by weight of the total container capacity remains.

Verify that for containers that held a compressed gas, the pressure in the container
approaches atmosphere.

Verify that for a container or inner liner that held an acute hazardous waste listed
in Appendix D, one of the following is done:

   - it is triple rinsed
   - it is cleaned by another method identified through the literature or testing as
     achieving equivalent removal
   - the inner liner is removed.

Verify that the rinse water has been tested.
     HW. 130.2.  Containers used
     to  store hazardous waste at
     generators must be in good
     condition and not leaking (40
     CFR   262.34(a)(l)(i)    and
     265.171).
Verify that containers are not leaking, bulging, rusting, damaged or dented.

Verify  that waste is transferred  to a  new container  or  managed  in  another
appropriate manner when necessary
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     57

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW. 130.3. Containers  used
     at generators  must be made
     of or  lined  with  materials
     compatible with the  waste
     stored  in  them  (40  CFR
     262.34(a)(l)(i)and265.172).
Verify that containers are compatible with waste.  For example, check that strong
caustics and acids are not stored in metal drums.
     HW. 130.4. Containers  must
     be closed during storage and
     handled in a safe manner at
     generators     (40     CFR
     262.34(a)(l)(i)and265.173).
Verify that containers are closed except when it is necessary to add or remove
waste (check bungs on drums, look for funnels).

Verify that handling and storage practices do not cause damage to the containers
or cause them to leak.
     HW. 130.5. The handling of
     incompatible   wastes,   or
     incompatible   wastes   and
     materials  in  containers  at
     generators must comply with
     safe  management  practices
     (40 CFR 262.34(a)(l)(i) and
     265.177).
Verify that incompatible wastes or incompatible  wastes and  materials are not
placed in the same containers unless it is done so that it does not:

   - generate extreme heat or pressure, fire, or explosion, or violent reaction
   -produce uncontrolled  toxic  mists,  fumes,  dusts, or  gases in  sufficient
     quantities to threaten human health
   -produce uncontrolled  flammable fumes or gases in sufficient quantities to
     pose a risk of fire or explosions
   - damage the structural integrity of the device or facility
   -by any other like means threaten human health or the environment.

(NOTE: Incompatible wastes, as listed in Appendix E, should not be placed in
the same drum.)

Verify that hazardous wastes are not placed in an unwashed container that
previously held an incompatible waste or material.

Verify that containers holding hazardous wastes incompatible with wastes stored
nearby in other containers, open tanks,  piles, or  surface impoundments are
separated or protected from each other by a dike, berm, wall, or other device.
     HW. 130.6. Containers used
     to  store hazardous waste at
     generators     should    be
     managed in accordance with
     specific        management
     practices (MP).
Verify the following by inspecting container storage areas:

   - containers are not stored more than 2 high and have pallets between them
   -containers of highly flammable wastes are electrically grounded (check for
     clips and wires and make sure wires lead to ground rod or system)
   - at least 3ft. (0.91 m) of aisle space is provided between rows of containers.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      58

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                          REVIEWER CHECKS
     HW. 130.7.  Containers with
     design capacities greater than
     0.1  m3  [-26 gal.]  and less
     than or  equal  to  0.46  m3
     [-122   gal.]   into   which
     hazardous waste is placed are
     required   to  meet   specific
     design    and     operating
     standards      (40     CFR
     262.34(a)(l)(i),     265.178,
     265.1087(a)         through
     265.1087(b)(l)(i),       and
     265.1087(c)).
 (NOTE:  These requirements  do not apply to a container that has a design
 capacity less than or equal to 0.1 m3 [-26 gal.] (40 CFR 265.1080(b)(2)) or to
 containers of any size  at satellite accumulation points.  See the definition of
 Exempted Hazardous  Waste  Containers  and  Surface Impoundments  and
 Exempted Hazardous Waste Management Units as listed on page 8 and 9 of this
 document.)

 (NOTE:  Standards for  containers used in waste stabilization processes (40 CFR
 265.1087(b)(2)) are in checklist item HW.HW. 130.9.)

 Verify that, for containers with a design capacity greater than 0.1 m3 [-26 gal.]
 and less  than or equal to  0.46  m3  [-122 gal.], air emissions are controlled
 according to the following Container Level 1 standards:

    - a container that meets applicable U.S. DOT regulations on the packaging of
     hazardous materials for transportation
    - a container that is equipped with a cover and closure devices  that form a
     continuous barrier over the container openings so that when the cover  and
     closure devices are secured in the closed position there are not visible holes,
     gaps or other open spaces into the interior of the container
    -an open-top container in which an organic vapor suppressing barrier is
     placed on or over the hazardous waste in the container so that no hazardous
     waste is exposed to the atmosphere.

 Verify that when a container using Level 1 standards, other than DOT approved
 containers, is  used, it is equipped with covers  and closure devices composed of
 suitable materials to  minimize exposure of the hazardous waste to the atmosphere
 and to maintain the equipment integrity for as long as it is in service.

 Verify that, whenever waste is in a container using Level 1 controls, covers  and
 closure devices are installed and closure devices are secured and maintained in
 the closed position except as follows:

    - opening  of a closure device or  cover is allowed for adding waste or other
     material to the container as follows:
         -when  the  container is filled  to the  intended  final  level in  one
          continuous operation,  the  closure  device is secured in the closed
          position and the  cover is  installed at the conclusion of the filling
          operation
         - when discrete batches or quantities of material are added intermittently
          to the container over a period of time, the closure devices are secured
          in the closed position and covers installed upon either the container
          being  filled to  the intended  final level,  the completion of a batch
          loading after which no  additional material will  be  added  to  the
          container  within  15  minutes, the  person  performing the loading
	operation  leaving the  immediate vicinity of the  container,  or  the
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                        59

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                            shutdown of the process  generating the material being  added to the
                                            container, whichever condition occurs first.
                                      - opening of a closure device or cover is allowed for removing the hazardous
                                       waste as follows:
                                          - in order to meet the requirements for an empty container
                                          - when discrete quantities or batches of material are removed from the
                                            container but the container  is not empty, the  closure devices will
                                            promptly be returned to the  closed position and the covers  installed
                                            upon completion of batch removal after which no additional material
                                            will  be  removed within  15  minutes or the person performing the
                                            unloading leaves the  immediate vicinity, whichever condition occurs
                                            first
                                      -opening of a closure device or cover is allowed  when access inside the
                                       container  is needed  to  perform routine activities other than transfer of
                                       hazardous waste
                                      - opening of a spring loaded, pressure vacuum relief valve, conservation vent,
                                       or similar type of pressure  relief device which vents  to the  atmosphere is
                                       allowed during normal operations for the purpose of maintaining  internal
                                       container pressure
                                      - opening of a safety device to avoid unsafe conditions.
     HW. 130.8.  Containers with
     design capacities greater than
     0.46  m3  [-122  gal.]  into
     which  hazardous  waste  is
     placed are  required to meet
     specific design and operating
     standards      (40      CFR
     262.34(a)(l)(i), 265.178, and
     265.1087(a)        through
     265.1087(b)(l)(ii),
     265.1087(b)(l)(iii),
     265.1087(c),            and
     265.1087(d)).
(NOTE:   These requirements do not apply to a container that has a design
capacity less than or equal to 0.1  m3 [-26 gal.] (40 CFR 265.1080(b)(2)) or to
containers of any size at satellite accumulation points.  See  the definition of
Exempted Hazardous Waste Containers  and Surface  Impoundments  and
Exempted Hazardous  Waste Management Units as listed on page 8 and 9 of this
document.)

(NOTE:  Standards for containers used in waste stabilization processes (40 CFR
265.1087(b)(2)) are in checklist item HW.HW. 130.9.)

Verify that, for containers with a design capacity greater than 0.46 m3 [-122 gal.]
that are not in light material service, air emissions are controlled according to the
following Container Level 1 standards:

   - a container that meets applicable U.S. DOT regulations on the packaging of
     hazardous materials for transportation
   - a container that is equipped with a cover and closure devices that form a
     continuous barrier over the container openings so that when the cover  and
     closure devices are secured in the closed position there  are not visible holes,
     gaps or other open spaces into the interior of the container
   -an open-top container in which an organic vapor suppressing barrier is
     placed on or over the hazardous waste in the container  so that no hazardous
     waste is exposed to the atmosphere.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       60

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                          COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                   Verify that, for containers with a design capacity greater than 0.46 m3 [-122 gal.]
                                   that are  in light material service, air emissions are controlled according to the
                                   following Container Level 2 standards:

                                      -a container is used that meets applicable U.S. DOT regulations on the
                                       packaging of hazardous materials for transportation
                                      - a container is used that operates with no detectable organic emissions
                                      -a container is  used that has been demonstrated within the preceding 12 mo
                                       to be air tight.

                                   (NOTE:   Level 2 standards apply only to containers that are in light material
                                   service.  For the containers that are not in light material service, Level 1 standards
                                   apply. (See 40 CFR 265.1087(b)(ii) and (iii).)

                                   Verify that when a  container using Level 1 standards, other than DOT approved
                                   containers, is used  it is equipped with covers and closure devices composed of
                                   suitable materials to minimize exposure of the hazardous waste to the atmosphere
                                   and to maintain the equipment integrity for as long as it is in service.

                                   Verify that whenever waste is in a container using Level  1  or Level 2 controls,
                                   covers and closure devices are  installed and closure devices are  secured and
                                   maintained in a closed position except as follows:

                                      - opening of a closure device or cover is allowed for adding waste or other
                                       material to the container as follows:
                                           -when the  container is filled to  the  intended  final level in  one
                                            continuous operation, the closure devices are  secured in the closed
                                            position  and the covers  installed at the conclusion of the filling
                                            operation
                                           - when discrete batches or quantities of material are added intermittently
                                            to the container over a period of time, the closure devices are promptly
                                            secured in the closed position and covers installed upon either:
                                               - the  container being filled to the intended final level
                                               -the  completion of a batch  loading  after which no additional
                                                 material will be added to the container within 15 minutes
                                               -the   person performing  the  loading operation  leaving  the
                                                 immediate vicinity of the container
                                               - the  shutdown of the process generating the material being added
                                                 to the container, whichever condition occurs first
                                      - opening of a closure device or cover is  allowed for removing the hazardous
                                       waste as follows:
                                           - in order to meet the requirements for an empty container
                                           - when discreet quantities or batches of material are removed from the
                                            container but  the  container is not empty, the  closure  devices are
                                            promptly secured in the closed position and the covers installed either:
                                  	-upon completion of batch removal  after which no additional
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                              61

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                                material will be removed within 15 min
                                               -the  person performing the  unloading  leaves  the immediate
                                                vicinity, whichever condition occurs first
                                     -opening of a closure device or cover is allowed when access inside the
                                       container is needed  to perform  routine activities other than transfer of
                                       hazardous waste
                                     - opening of a spring loaded, pressure vacuum relief valve, conservation vent,
                                       or similar type of pressure relief device which vents to the atmosphere and is
                                       allowed during normal  operations for the purpose  of maintaining internal
                                       container pressure
                                     - opening of a safety device to avoid unsafe conditions.

                                  Verify that  the transfer of hazardous waste  in or out of containers  meeting
                                  Container Level 2 controls is  done in a  manner to minimize exposure of the
                                  hazardous waste to the atmosphere (i.e., a submerged fill pipe, a vapor balancing
                                  system, a vapor recovery  system, a fitted opening  in the top of the container
                                  through which the hazardous waste is filled and subsequently purge the transfer
                                  line before removing it).
     HW. 130.9.  Containers with
     design capacities greater than
     0.1 m3 [-26 gal.] used for the
     treatment  of  a  hazardous
     waste  by a waste stabilization
     process are required to meet
     specific design and operating
     standards      (40      CFR
     262.34(a)(l)(i),    265.178,
     265.1087(a)         through
     265.1087(b)(2),         and
     265.1087(e)(l)      through
     265.1087(e)(3)).
(NOTE:   These requirements  do not apply to a container that  has  a design
capacity less than or equal to 0.1 m3 [-26 gal.] (40 CFR 265.1080(b)(2)) or to
containers of any size at satellite accumulation points.  See the definition of
Exempted Hazardous  Waste  Containers  and  Surface  Impoundments  and
Exempted Hazardous Waste Management  Units as listed on page 8 and 9 of this
document.)

(NOTE: Safety devices may be installed and operated as necessary.)

Verify that containers with design capacities greater than 0.1  m3 [-26 gal.] used
for the  treatment of a hazardous waste  by a stabilization process meet  the
following Container  Level  3  standards  at  those  times  during  the waste
stabilization process when the hazardous waste in the container is exposed to the
atmosphere:

   -a container is  vented directly  through a closed-vent system to a control
     device
   -a container is  vented  inside an enclosure which is  exhausted through a
     closed-vent system to a control device
   -the  container closure  is  designed and operated  in  accordance  with  the
     criteria for a permanent total enclosure under 40 CFR 52.741
   -the  closed-vent system and control device is designed and operated in
     accordance with 265.1088 (see checklist item HW. 130.12).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       62

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.130.10.   Facilities are
     required  to  have  a  written
     plan   and   schedule   for
     inspection  and  monitoring
     requirements  for containers
     and meet specific inspection
     requirements    (40    CFR
     262.34(a)(l)(i),    265.178,
     265.1087(c)(4),
     265.1087(d)(4),         and
     265.1089).
(NOTE:   These requirements  do not apply to a container that has a design
capacity less than or equal to 0.1 m3 [-26 gal.] (40 CFR 265.1080(b)(2)) or to
containers of any size at satellite accumulation points.  See the definition of
Exempted Hazardous Waste  Containers  and  Surface Impoundments   and
Exempted Hazardous  Waste Management Units as listed on page 8 and 9 of this
document.)

Verify that the facility has a written plan and schedule for performing inspections
and monitoring.

Verify that the plan and schedule are being met.

Verify that inspections of the containers and their covers and closure devices for
containers using Container Level 1 or Level 2 controls are done as follows:

   - when a hazardous waste is already in the container when it is first accepted
     and the container is not emptied within 24 hours after  it is accepted, it is
     visually inspected within 24 hours after acceptance for cracks, holes, gaps,
     or other open spaces
   - when a container is used for managing hazardous waste  for 1 yr or more, it
     is visually inspected at least once every  12 mo for visible  cracks, holes,
     gaps, or other open spaces when the cover and closure devices  are secured
     in the closed position.

Verify that when a  defect is detected, the first efforts at repairs are within 24
hours after detection, and repair is completed as  soon as possible but no later than
5 calendar days after detection.

(NOTE:   If repair cannot be completed  within 5 calendar days, the hazardous
waste must be removed from the container.)
     HW.130.11.   Facilities are
     required       to       meet
     documentation  requirements
     for   containers   (40   CFR
     262.34(a)(l)(i),    265.178,
     265.1087(c)(5), 265.1090(a),
     and   265.1090(d)  through
     265.1090(1).
(NOTE:   These requirements  do not apply to a container that has a design
capacity less than or equal to 0.1 m3 [-26 gal.] (40 CFR 265.1080(b)(2)) or to
containers of any size at satellite accumulation points.  See the definition of
Exempted Hazardous Waste  Containers  and  Surface Impoundments   and
Exempted Hazardous  Waste Management Units as listed on page 8 and 9 of this
document.)

Verify that a copy is available of the procedure used to determine that containers
with a capacity of  0.46  m3 [-122  gal.] or greater which do  not  meet DOT
standards are not managing hazardous waste in light material service.

Verify that if using Container Level 3 air emissions controls, the facility prepares
and maintains records that:

   - include the most recent set of calculations and measurements performed by
     the  owner/operator to verify  that  the  enclosure  meets the criteria  of  a
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       63

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                       permanent total enclosure as specified in 40 CFR 52.741, Appendix B
                                     - The same records as required for closed-vent systems.

                                  Verify that if using a closed-vent system and control device, the following records
                                  are maintained:

                                     - certification that is signed and dated by the owner/operator stating that the
                                       control device is designed to operate at the performance level documented
                                       by a design analysis or by performance tests when the container is operating
                                       at capacity or the highest level reasonably expected to occur
                                     - design documents  if design analysis is used, including certification that the
                                       equipment meets the applicable specification
                                     - a performance test plan if performance tests are used and all test results
                                     - description and date of each modification, as applicable
                                     - identification of operating  parameters, description  of monitoring devices,
                                       and diagrams of monitoring sensor locations, as applicable
                                     - semiannual records of the following for those planned routine maintenance
                                       operations that would require the control device to exceed limitations:
                                          - a description of the planned  routine maintenance that is anticipated to
                                            be performed for the  control device during  the  next 6-mo period,
                                            including the type of maintenance  needed, planned frequency, and
                                            lengths of maintenance periods.
                                          - a  description of the planned routine maintenance that was performed
                                            for the  control device during the previous 6-mo period, including the
                                            type of maintenance performed and  the total number of hours during
                                            those  6-mo  that  the  control  device did  not meet applicable
                                            requirements
                                     -records  of the  following  for  those unexpected  control device system
                                       malfunctions that would cause the  control device to not meet specifications:
                                          - the occurrence and duration  of each  malfunction of the control device
                                            system
                                          - the duration of each period during a malfunction when gases, vapors,
                                            or fumes are vented  from the waste management unit  through the
                                            closed-vent system to the control device while the control device is not
                                            properly functioning
                                          - actions taken during periods of malfunction to restore a malfunctioning
                                            control device to its normal or usual manner of  operation
                                          -records of the management of the  carbon removed from a carbon
                                            adsorption system.

                                  Verify that,  for exempted containers,  the following records are prepared and
                                  maintained as applicable:

                                     -if  exempted  under  the   hazardous  waste concentration  conditions,
                                       information used for  the waste determination in the facility operating log
                                       and/or the date, time, and location of each waste sample if analysis results
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                             64

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                       for samples are used
                                     -if  exempted under  incinerator use  or  process  destruction  use,  the
                                       identification number for the incinerator, boiler, or industrial furnace in
                                       which the hazardous waste is treated.

                                  Verify that covers designated as unsafe to monitor are listed in a log kept in the
                                  facility operating record with an explanation of why they are unsafe to inspect and
                                  monitor and a plan and schedule of inspection and monitoring is recorded.

                                  Verify that, for containers not using the air emissions controls specified in 40
                                  CFR  265.1085  through 265.1088  (see  checklist  items  HW. 130.7 through
                                  HW.130.12), the following information is maintained:

                                     - a list of the individual organic peroxide compounds  manufactured at the
                                       facility if it produces more than one functional family of organic peroxides
                                       or multiple organic peroxides within one functional family, and one or more
                                       of these  organic  peroxides could  potentially undergo serf-accelerating
                                       thermal decomposition at or below ambient temperatures
                                     - a description of how the hazardous waste containing the organic peroxide
                                       compounds identified in the above list are managed, including:
                                          - a facility identification number for the container or group of containers
                                          - the purpose and placement of this container or group of containers in
                                            the management train of this hazardous waste
                                          -the procedures used  to ultimately  dispose  of the hazardous waste
                                            handled in the containers
                                     -explanations why managing these containers  would  be an  undue safety
                                       hazard.

                                  Verify that all records, except design information records, are kept for at least 3
                                  years.

                                  Verify that design information records  are  maintained in the operating record
                                  until the air emissions control equipment  is replaced or otherwise no longer in
                                  service.

                                  (NOTE: See also the recordkeeping  requirements for carbon adsorption units in
                                  checklist item HW. 130.)
     HW.130.12.   Facilities are
     required  to  meet  specific
     requirements for closed-vent
     systems and control devices
     used to achieve compliance
     (40  CFR   262.34(a)(l)(i),
     265.178, and 265.1088).
(NOTE:   These requirements  do not apply to a container that  has  a design
capacity less than or equal to 0.1 m3 [-26 gal.] (40 CFR 265.1080(b)(2)) or to
containers of any size at satellite accumulation points.  See the definition of
Exempted Hazardous  Waste  Containers  and  Surface  Impoundments  and
Exempted Hazardous Waste Management Units as listed on page 8 and 9 of this
document.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                  Verify that closed-vent systems meet the following:

                                     - it routes the gases, vapors  and fumes emitted from the hazardous waste in
                                       the waste management unit to a control device
                                     -it is  designed and operated in accordance with 40  CFR 265.1033(j) (see
                                       checklist item HW. 140.2)
                                     - if it includes bypass devices that could be used to divert the gas or vapor
                                       stream to  the atmosphere  before entering the  control device, one of the
                                       following  equipment requirements is met for each  type of bypass device
                                       (NOTE: low leg drains, high point bleeds, analyzer vents, open-ended valve
                                       or lines,  spring loaded pressure relief valves,  and  other fittings used for
                                       safety purposes are not considered bypass devices):
                                          - a flow indicator is installed, calibrated, maintained, and operated at the
                                            inlet to the bypass line used to divert gases and vapors from the closed-
                                            vent system to the atmosphere at a point upstream of the control device
                                            inlet
                                          -a seal or locking device is placed on the mechanism by which the
                                            bypass device position is controlled when the  bypass  valve is in the
                                            closed position so that the bypass device cannot be opened without
                                            breaking the  seal or removing the lock.

                                  Verify that the seal or closure mechanism is visually inspected at least once every
                                  month.

                                  Verify that one of the following control devices are used:

                                     - a device designed and operated to reduce the total  organic content of the
                                       inlet vapor stream vented  to the control device by  at least 95 percent by
                                       weight
                                     - an enclosed combustion  device designed and operated in accordance with
                                       265.1033(c) (see checklist item HW. 140.2)
                                     -a flare designed and operated in accordance with 40 CFR 265.1033(d) (see
                                       checklist item HW. 140.2).

                                  Verify that, when a closed-vent  system and control device is used, the following
                                  are met:

                                     - periods of planned routine  maintenance of the control  device during which
                                       the device does not meet specifications do not exceed 240 hours per year
                                     - control device system malfunctions are corrected as soon as practicable
                                     - it is operated such that gases, vapors, and/or fumes are not actively vented to
                                       the control device during periods of planned maintenance  or control device
                                       system malfunction, except in cases where it is necessary to do so in order to
                                       avoid an unsafe condition or to implement malfunction corrective actions or
                                       planned maintenance actions.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                              66

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                  Verify that, if a carbon absorption system is used, the following requirements are
                                  met:

                                     -all  activated  carbon is replaced with fresh  carbon on a regular basis as
                                      outlined in 40 CFR  265.1033(g)  and 265.1033(h)  (see  checklist item
                                      HW. 140.2)
                                     - all carbon removed from the devices is managed in a correct manner.

                                  Verify that, if a control device  other than a thermal vapor incinerator, flare,
                                  boiler, process  heater,  condenser,  or carbon absorption  system is  used, the
                                  requirements in 40 CFR 265.1033(i) are met (see checklist item HW. 140.2).

                                  Verify that, for control  devices, it is demonstrated by either a performance test or
                                  a design analysis that the device achieves compliance except for the following:

                                     - a flare
                                     -boiler or process  heater with  a design heat input capacity of 44 MW or
                                      greater
                                     - a boiler or  process heater into  which the vent stream is introduced with the
                                      primary fuel
                                     - a boiler or  process heater burning hazardous waste for which the owner or
                                      operator has been issued a final permit under 40 CFR 270 and has designed
                                      and operates the unit in accordance with the requirements of 40  CFR 266,
                                      subpart H
                                     -a boiler or industrial  furnace burning hazardous waste for the  owner or
                                      operator has certified compliance with the interim status requirements of 40
                                      CFR 266, subpart  H.

                                  Verify that the readings from each control device are inspected at least once each
                                  operating day to  check control device operation.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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This document is intended solely for guidance. No statutory or regulatory                                       68
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.140

     Emissions from Process
     Vents
     HW.140.1.  Generators with
     process vents associated with
     distillation,    fractionation,
     thin-film evaporation, solvent
     extraction,  or  air  or steam
     stripping   operations,   that
     manage   hazardous  wastes
     with organic concentrations
     of at least 10  ppmw,  are
     required  to  meet  specific
     standards      (40      CFR
     262.34(a)(l)(  i),  265.178,
     265.1030(b),    265.1030(e)
     and 265.1032).
(NOTE:   This applies  only  if the operations  are  conducted in one of the
following:
   - a unit that is subject to the permitting requirements of 40 CFR 270
   - a unit (including a hazardous waste recycling unit) that is not exempt from
     permitting under the provisions of 40 CFR 262.34(a) (i.e., a hazardous
     waste recycling unit that is  not a 90-day  tank or container) and that  is
     located at a hazardous waste management facility that is otherwise subject to
     the permitting requirements of 40 CFR 270
   -a unit that is exempt from  permitting under the provisions of 40 CFR
     262.34(a) (i.e., a 90-day tank or container).)

Verify that one of the following is met:

   -total organic emissions from the process  vents do not exceed 1.4 kg/h (3
     Ib/h) and 2.8 Mg/yr (3.1 tons/yr)
   -total organic emissions are reduced  by use of  a  control device from all
     process vents by 95 weight percent.

(NOTE:   A  process vent  is  not subject  to  these standards if the facility
owner/operator certifies  that all the regulated  process vents at the facility are
equipped  with and operating  air  emission controls in  accordance with the
requirements of the Clean Air Act (CAA) 40 CFR Parts 60, 61, and 63.)
     HW. 140.2.      When   a
     generator uses a closed-vent
     system and control device to
     meet the standards for total
     organic    emissions,    the
     closed-vent   system    and
     control  device   must  meet
     certain            minimum
     requirements    (40    CFR
     262.34(a)(l)(i),     265.178,
     265.1033(b)        through
     265.1033(k)).
(NOTE:   This  applies  to  generators  with process vents  associated with
distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam
stripping operations, that manage hazardous wastes with organic concentrations
of at least 10 ppmw, if the operations are conducted in one of the following:
   - a unit that is subject to the permitting requirements of 40 CFR 270
   - a unit (including a hazardous waste  recycling unit) that is not exempt from
     permitting under the  provisions of 40 CFR 262.34(a) (i.e., a hazardous
     waste recycling unit that is not a  90-day tank  or container) and that is
     located at a hazardous waste management facility that is otherwise subject to
     the permitting requirements of 40 CFR 270
   -a unit that is exempt from permitting under  the provisions of 40 CFR
     262.34(a) (i.e., a 90-day tank or container).)

Verify that control devices involving vapor recovery are designed and operated to
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      69

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                  recover organic vapors vented to the air with an efficiency of 95 weight percent
                                  or greater, unless the total organic emission limit can be attained at an efficiency
                                  of less than 95 weight percent.

                                  Verify that, if an enclosed combustion device is used (i.e., vapor incinerator,
                                  boiler, or process heater), it is designed and operated to reduce the  organic
                                  emissions vented to it by 95 weight percent or greater, to achieve a total organic
                                  compound concentration  of  20 ppmv expressed as  the  sum of the actual
                                  compounds, not carbon equivalents, on a dry basis corrected to 3 percent  oxygen,
                                  or  to  provide a  minimum residence  time of  0.50 seconds at  a  minimum
                                  temperature of 760 degrees Celsius  [1400 degrees Fahrenheit].

                                  Verify that, if a boiler or process heater is used as the control device, the vent
                                  stream is introduced into the flame zone of the boiler or process heater.

                                  Verify that, if flares are used:

                                      - they are designed and operated with no visible emissions except for periods
                                       not in excess of 5 minutes during any 2 consecutive hours
                                      - they are operated with a flame present at all times
                                      - they are  used only if the net  heating value of the gas being combusted is
                                       11.2 MJ/scm (300 Btu/scf) or greater if the flare is  steam assisted or air
                                       assisted
                                      -if nonassisted, the net heating value of the  gas being combusted is 7.45
                                       MJ/scm (200 Btu/scf) or greater
                                      - if nonassisted or steam assisted, have an exit velocity less than 18.3  m/s (60
                                       ft/s) except when the net heating value of the gas being combusted is greater
                                       than 37.3 MJ/scm (1000 Btu/scf) and the exit velocity is equal to or greater
                                       than 18.3 m/s (60 ft/s) but less than 122 m/s (400 ft/s).

                                  Verify that each monitor and control device is inspected on a routine basis.

                                  Verify that each  required control device is installed, calibrated, monitored and
                                  inspected as follows:

                                      - a flow indicator is installed in the vent stream at the nearest feasible  point to
                                       the control device inlet, but before being combined with other streams, and
                                       provides a record of vent stream flow from each affected process vent to the
                                       control device at least once every hour
                                      -a control device to continuously monitor control  device  operations  as
                                       specified:
                                          - a temperature monitoring device equipped with a continuous recorder
                                            for a thermal vapor incinerator
                                          - a temperature monitoring device equipped with a continuous recorder
                                            for a catalytic vapor incinerator
                                  	- a heat sensing monitor with a continuous recorder for flares	
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                              70

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                          - a temperature monitoring device equipped with a continuous recorder
                                           to  measure  parameters  that  indicate  good  combustion  operating
                                           practices are being used for a boiler or process heater having a design
                                           heat input capacity less than 44 MW
                                          -for a condenser, one of the following:
                                               - a monitoring device with a continuous recorder to measure the
                                                concentration level of the organic compound in the exhaust vent
                                                stream from the condenser
                                               -a temperature monitoring device  equipped with a continuous
                                                recorder capable of monitoring temperature in the exhaust vent
                                                stream from the condenser with an accuracy of +/- 1 percent of
                                                the temperature being monitored in Celsius  or  in  +/-0.5 ฐC,
                                                whichever is greater
                                          - for a carbon absorption system such as a fixed carbon bed absorber
                                           that regenerates the carbon bed directly in the control device, one of
                                           the following:
                                               -a monitoring device equipped  with  a  continuous  recorder to
                                                measure the concentration levels of the organic compounds in the
                                                exhaust vent stream from the carbon bed
                                               -a monitoring device equipped  with  a  continuous  recorder to
                                                measure a parameter that  indicates the carbon bed is regenerated
                                                on a regular, predetermined time cycle.

                                  Verify that readings from monitoring devices are checked at least once a day.

                                  Verify that,  if a carbon absorption system is being used that regenerates the
                                  carbon bed directly on-site, the existing carbon in the control device is replaced
                                  with fresh carbon at a regular, predetermined time interval.

                                  (NOTE:  The predetermined time interval  is based on the design analysis required
                                  under 40 CFR 265.1035(b)(4)(iii)(F).)

                                  Verify that if a carbon absorption system is being used that does not regenerate
                                  the carbon bed directly on-site in the control device, the existing carbon in the
                                  control device is replaced on a regular basis.

                                  (NOTE:  When to replace the carbon is determined by one of the  following
                                  procedures:
                                     - monitoring the concentration level of the organic compound  in the exhaust
                                       vent stream from  the carbon absorption system daily or at an interval no
                                       greater than 20 percent of the time required to consume the total carbon
                                       working capacity, whichever is longer
                                     - replace the carbon at a regular predetermined time interval that is less than
                                       the design carbon replacement interval.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                             71

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  Verify that closed-vent systems meet one of the following:

                                     - are designed and operated with no detectable emissions as indicated by an
                                       instrument reading of less than 500 ppm above background as determined
                                       by the procedures in 40 CFR 265.1034(b) and by visual inspection
                                     - are designed to operate at a pressure below atmospheric pressure and are
                                       equipped with at least one pressure  gauge or other pressure measurement
                                       device that can be read from a readily accessible location.
     HW. 140.3.  Generators are
     required to maintain specific
     records pertaining to process
     vent  emissions   (40   CFR
     262.34(a)(l)(i), 265.178, and
     265.1035).
Verify that the following information is kept in the operating record:

   - an implementation schedule
   - up-to-date documentation of compliance with process vents and with closed-
     vent systems and control devices
   - the test plan if test data is used to determine the organic removal efficiency
     or total organic compound concentration achieved by a control device
   - documentation of compliance with 40 CFR 265.1033, including:
        - a list of all information, references and sources used in preparing the
          documentation
        - records, including the dates  of required compliance tests
        -design  analysis, specifications,  drawing,  schematics, and piping and
          instrumentation diagrams if engineering calculations are used
   - a statement signed and dated by the operator or owner certifying that the
     operating parameters used in the design analysis reasonably represent the
     conditions which exist when the hazardous waste  management unit is or
     would be operating at the highest load or capacity level reasonably expected
   - a statement signed and dated by the owner or operator certifying that the
     control device is  designed to operate at  an efficiency of 95 percent or
     greater unless the total  organic concentration limit is achieved at  an
     efficiency of less  than 95 weight percent, or  the total organic emissions
     limits for affected process vents can be  attained by  a control device
     involving vapor recovery at an efficiency less than 95 weight percent
   - all performance test results if used to demonstrate compliance
   - design documentation
   - monitoring and  inspection results for each closed-vent system and control
     device
   - notations of exceedance of control device parameter design value
   - explanation for each period of exceedance
   - for carbon absorption systems:
        - when the carbon is replaced in carbon absorption systems
        -date  and  time  when  a control device  is  monitored for carbon
          breakthrough
   - the date of each control device  startup and shutdown.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  Verify that records of monitoring operations and inspection information are kept
                                  for 3 years.
     HW. 140.4.     Closed-vent
     systems are required  to  be
     monitored,   inspected,   and
     leaks   repaired   (40   CFR
     262.34(a)(l)(i),     265.178,
     265.1033(k)            and
     265.1033(n)).
(NOTE:    This  applies  to  generators  with process vents  associated with
distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam
stripping operations, that manage hazardous wastes with organic concentrations
of at least 10 ppmw, if the operations are conducted in one of the following:
   - a unit that is subject to the permitting requirements of 40 CFR 270
   - a unit (including a hazardous waste  recycling unit) that is not exempt from
     permitting under the  provisions of 40 CFR 262.34(a) (i.e., a hazardous
     waste recycling unit  that is not a  90-day tank  or container) and  that is
     located at a hazardous waste management facility that is otherwise subject to
     the permitting requirements of 40 CFR 270
   -a unit that is exempt from permitting under  the provisions of 40 CFR
     262.34(a) (i.e., a 90-day tank or container).)

Verify that closed-vent systems  designed and  operated with no detectable
emissions,  as indicated by an instrument reading of less than 500 ppm above
background, are monitored  as follows:

   -an initial leak detection monitoring of the  closed-vent system using  the
     procedures  specified  in 40 CFR 265.1034(b)  on or before  the date  the
     system became subject to this section of the CFR
   - after initial leak detection monitoring:
        -visual inspection at least once a year for closed-vent system joints,
          seams, or other connections that are permanently or semi-permanently
          sealed (e.g., a welded joint between two sections of hard piping or a
         bolted and gasketed ducting flange)
        - whenever a component is repaired or replaced, monitor according to
         40CFR265.1034(b)
        - annually and at  times required by the regulatory agency for all other
         parts of the  system using the  procedures  specified  in 40 CFR
         265.1034(b).

Verify that closed-vent systems designed to operate at no detectable emissions, as
indicated by an instrument  reading of less than 500 ppmv above background,  are
monitored as follows:

   - annual visual inspection to check for defects that could result in air pollutant
     emissions
   -initial inspection on or before the date the system becomes subject to this
     section of the CFR.

(NOTE:  For closed-vent systems designed to operate at no detectable emissions,
as indicated by an instrument reading  of less than 500 ppmv above background,
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       73

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                          REVIEWER CHECKS
                                  portions of the system designated as unsafe to monitor are exempt from the visual
                                  monitoring if:
                                     - the components are unsafe to monitor because monitoring personnel would
                                       be exposed to an immediate danger
                                     - a written plan that requires monitoring as practicable during safe to monitor
                                       periods is in place and followed.)

                                  Verify that detectable  emissions,  as indicated by visual  inspection or by an
                                  instrument reading of greater than 500 ppmv above background, are controlled as
                                  soon as practicable but not later than 15 days after the emissions are detected.

                                  Verify that a first attempt at repair is made no later than 5 calendar days after the
                                  emission is detected.

                                  (NOTE:   Delay of repair of  a closed-vent  system for which leaks have been
                                  detected is allowed if the repair is  technically infeasible without a process unit
                                  shutdown, or if it is determined that the emissions resulting from the immediate
                                  repair would be greater than the fugitive emissions likely to result from delay of
                                  repair.)
     HW. 140.5.     Closed-vent
     systems and control devices
     used  to  comply   with  the
     provisions   of   40   CFR
     265.1030  through  265.1035
     are required to be operated at
     all times when emissions may
     be vented to  them (40 CFR
     262.34(a)(l)(i), 265.178, and
     265.1033(1)).
 (NOTE:   This  applies to  generators  with  process  vents associated  with
 distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam
 stripping operations, that manage hazardous wastes with organic concentrations
 of at least 10 ppmw, if the operations are conducted in one of the following:
    - a unit that is subject to the permitting requirements of 40 CFR 270
    - a unit (including a hazardous waste recycling unit) that is not exempt from
     permitting under the  provisions of 40 CFR 262.34(a) (i.e.,  a hazardous
     waste recycling unit that is not a 90-day tank or container)  and that is
     located at a hazardous waste management facility that is otherwise subject to
     the permitting requirements  of 40 CFR 270
    -a  unit that is exempt from permitting under the provisions  of 40  CFR
     262.34(a) (i.e., a 90-day tank or container).)

 Verify that closed-vent systems and control devices are operated at all times when
 emissions may be vented to  them.
     HW. 140.6.   When  carbon
     absorption systems are used,
     operators  are  required  to
     manage  all carbon that is a
     hazardous waste according to
     specific  parameters (40 CFR
     262.34(a)(l)(i), 265.178, and
     265.1033(m)).
 (NOTE:   This  applies to  generators  with  process  vents associated  with
 distillation, fractionation, thin-film evaporation, solvent extraction, or air or steam
 stripping operations, that manage hazardous wastes with organic concentrations
 of at least 10 ppmw, if the operations are conducted in one of the following:
    - a unit that is subject to the permitting requirements of 40 CFR 270
    - a unit (including a hazardous waste recycling unit) that is not exempt from
     permitting under the  provisions of 40 CFR 262.34(a) (i.e.,  a hazardous
     waste recycling unit that is not a 90-day tank or container)  and that is
     located at a hazardous waste management facility that is otherwise subject to
	the permitting requirements  of 40 CFR 270	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       74

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY;
                                  HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                    -a unit that is  exempt from permitting under the provisions of 40 CFR
                                     262.34(a) (i.e., a 90-day tank or container).)

                                 Verify that carbon removed from control devices  that is a hazardous waste is
                                 managed  in  one  of the following  manners,  regardless of the average VOC
                                 concentration of the carbon:

                                    - regenerated or reactivated in a thermal treatment unit that meets one of the
                                     following:
                                        - the unit has a final permit under 40 CFR 270 which implements the
                                          requirements of 40 CFR 264, subpart X
                                        -the unit is equipped  with and  operating  air emission  controls  in
                                          accordance with applicable requirements
                                    - incinerated in a hazardous waste incinerator for which the operator either:
                                        -has a  final permit under  40  CFR 270  which implements  the
                                          requirements of 40 CFR 264, subpart O
                                        -has designed  and operates the incinerator in accordance with  the
                                          interim status required in 40 CFR 265, subpart O
                                    -burned in a boiler or industrial furnace for which the operator either:
                                        -has been issued a final permit under 40 CFR 270 implementing 40
                                          CFR 266
                                        -has designed and  operates  the boiler  or industrial  furnace  in
                                          accordance with the interim status requirements of 40  CFR 266,
                                          subpart H.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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This document is intended solely for guidance. No statutory or regulatory                                       75
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.150

     Air Emission Standards for
     Equipment Leaks
(NOTE:  This section applies to equipment that contains or contacts hazardous
waste with organic concentrations of at least  10 percent by weight that are
managed in one of the following (40 CFR 265.1050(b):
   - a unit that is subject to the permitting requirements of 40 CFR 270
   - a unit (including a hazardous waste recycling unit) that is not exempt from
     permitting under the provisions of 40 CFR 262.34(a)  (i.e., a hazardous
     waste recycling unit that is  not a 90-day tank or container) and that  is
     located at a hazardous waste management facility that is otherwise subject to
     the permitting requirements of 40 CFR 270
   -a unit that  is exempt from  permitting under  the  provisions of 40 CFR
     262.34(a) (i.e., a 90-day tank or container) and is not a recycling unit under
     the provisions of 40 CFR 261.6.)

(NOTE: This section does not apply to (40 CFR 265.1050(d) and 265.1050(e)):
   - equipment that is in vacuum service and is identified as such on the required
     list
   -equipment that  contains  or  contacts hazardous waste  with an organic
     concentration of at least 10 percent by weight for less than 300  hours per
     calendar year and is identified as such.)
     HW.150.1.  Generators with
     pumps in light liquid service,
     that   contain   or  contact
     hazardous   wastes    with
     organic concentrations of at
     least 10  percent by weight,
     are required to meet specific
     standards     (40      CFR
     262.34(a)(l)(i),     265.178,
     265.1052).
Verify that pumps in light  liquid service are monitored monthly according to
designated reference methods and inspected visually weekly.

(NOTE:  A leak is detected if there is an instrument reading of 10,000 ppm or
greater or if there is an indication of liquid dripping from the pump seal.)

Verify that, when a leak is detected, the first attempt at repair is made within 5
calendar days and repair is completed within 15 calendar days.

(NOTE:   Pumps equipped with dual mechanical  seal  systems  and pumps
designated for no detectable emissions that meet standards outlined here do not
have to be monitored monthly or visually checked weekly.)

Verify that pumps equipped with a dual mechanical seal system which do not
have to be  monitored monthly or visually checked weekly, meet the following
design and operation requirements:

   - the dual mechanical seal system is operated with barrier fluid at a pressure
     that is at all times greater than the pump stuffing box, or equipped with a
     barrier fluid degassing reservoir that is connected by a closed-vent system to
     a control device, or equipped with a system that purges the barrier fluid into
     a hazardous waste stream with no detectable emission to the atmosphere
   - the barrier fluid system has no hazardous waste with organic concentrations
     10 percent or greater by weight
   - the barrier fluid system is equipped with a sensor that will detect failure if
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      77

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                       the seal is broken
                                     - pumps are checked by visual inspection weekly
                                     - sensors are checked daily or equipped with an audible alarm that is checked
                                       monthly.

                                  (NOTE:  Each owner or operator must determine, based on design considerations
                                  and  operating  experience,  criteria that indicate failure of the seal system, the
                                  barrier fluid system, or both.)

                                  Verify that pumps designated for no detectable emissions meet the following:

                                     -they are   operated with  no detectable  emissions,  as  indicated  by an
                                       instrument reading of 500 ppm above background or less
                                     - they are tested for compliance as indicated by an instrument reading of 500
                                       ppm above background or less  initially upon designation, annually, and at
                                       other times as requested by the regulatory agency
                                     - no externally actuated shaft penetrates the pump housing.

                                  (NOTE:   Any  pump that is equipped with a closed-vent system capable  of
                                  capturing and transporting any leakage from the seal or seals to a control device is
                                  exempt from all above requirements.)
     HW. 150.2.  Generators with
     compressors that  contain or
     contact   hazardous  wastes
     with organic concentrations
     of at least 10  percent  by
     weight are required to  meet
     specific  standards  (40  CFR
     262.34(a)(l)(i), 265.178, and
     265.1053).
Verify that each compressor is equipped with a seal system which includes a
barrier fluid  system and prevents leakage of total organic emissions  to  the
atmosphere except if:

   -it  is  equipped with  a  closed-vent system  capable  of capturing and
     transporting any leakage from the seal to a control device, and
   - it is designated for no detectable emissions as indicated by an instrument
     reading of less than 500 ppm above background, and
   - it is tested for compliance initially upon designation, annually, and at times
     as requested by the regulatory agency.

Verify that the compressor seal systems meet one of the following:

   - it is operated  with the barrier fluid at a pressure that is at all times greater
     than the compressor stuffing box pressure
   - it is equipped with a barrier fluid system that is connected to  a closed-vent
     system or a control device
   - it is equipped with a system that purges the barrier fluid into a hazardous
     waste stream with no detectable emissions to the atmosphere.

Verify that the barrier fluid is not a hazardous waste with organic concentrations
10 percent or greater by weight.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       78

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  Verify that each barrier system is equipped with a sensor which will detect failure
                                  of the seal system, barrier fluid system, or both.

                                  Verify that each sensor is checked daily or it is equipped with an audible alarm
                                  that is checked monthly.

                                  (NOTE:  Sensors on compressors located within the boundary of an unmanned
                                  site must be checked daily.)

                                  (NOTE:  Each owner or operator must determine, based on design considerations
                                  and operating experience, criteria that  indicate failure of the seal  system, the
                                  barrier fluid system, or both.)

                                  Verify that, when a leak is detected, the first attempt at repair is made within 5
                                  calendar days and the repair is made within 15 calendar days.
     HW. 150.3.  Generators with
     pressure  relief  devices  in
     gas/vapor service that contain
     or contact  hazardous waste
     with organic concentrations
     of at least 10  percent  by
     weight are  required to meet
     specific  standards  (40 CFR
     262.34(a)(l)(i), 265.178, and
     265.1054).
Verify that, except during pressure releases,  each pressure  relief device  in
gas/vapor service is operated with no detectable emissions  as indicated by  an
instrument reading of less than 500 ppm above background.

Verify that if there is a pressure release, the device is returned to a no detectable
emission status within 5 calendar days and the device is monitored to ensure
compliance.

(NOTE:  Any  pressure relief device that is equipped with a closed-vent system
capable of capturing and transporting leakage from the pressure  relief device to a
control device is exempt from these requirements.)
     HW. 150.4.  Generators with
     sampling connecting systems
     that   contain   or   contact
     hazardous   wastes    with
     organic  concentrations of at
     least  10 percent  by weight
     are required to meet specific
     standards      (40     CFR
     262.34(a)(l)(i), 265.178, and
     265.1055).
Verify that each sampling connection system is equipped with a closed-purge,
closed loop system or closed-vent system.

Verify that each system collects the sample purge for return to the processing or
for routing to the appropriate treatment system.

(NOTE:  Gases displaced through filling of the sample container are not required
to be collected or captured.)

Verify that each closed-purge, closed-loop system or closed-vent system does one
of the following:

   - returns the purged process fluid directly to the process line
   - collects and recycles the purged process fluid
   -is designed and operated to capture and transport all the purged process
     fluid to a waste management unit that is in compliance or a control device
     that is in compliance,	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       79

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  (NOTE:  In-situ sampling systems are exempt from these requirements.)
     HW. 150.5.  Generators with
     open-ended  valves  or  lines
     that   contain   or   contact
     hazardous   wastes    with
     organic  concentrations of at
     least 10 percent  by weight
     are required to meet specific
     standards     (40     CFR
     262.34(a)(l)(i), 265.178, and
     265.1056).
Verify that each open-ended valve or line is equipped with a cap, blind flange,
plug or second valve.

Verify that the cap, blind flange, plug, or second valve seals the open end at all
times,  except during operations requiring hazardous waste stream flow through
the open-ended valve or line.

Verify that each open-ended valve or line equipped with a second valve  is
operated so the valve on the hazardous waste stream end is closed before the
second valve is closed.

Verify that, when a double block and bleed system is being used, the bleed valve
is shut or plugged except during operations that require venting the line between
the block valves.
     HW. 150.6.  Generators with
     valves in gas/vapor service or
     light  liquid   service,   that
     contain or contact hazardous
     wastes      with     organic
     concentrations of at least 10
     percent   by   weight,    are
     required  to  meet  specific
     monitoring    and    repair
     standards      (40      CFR
     262.34(a)(l)(i),    265.178,
     265.1057, and 265.1062).
Verify that valves in gas/vapor  service or light liquid service  are monitored
monthly to detect leaks.

(NOTE:  A leak is detected if an  instrument reading of 10,000 ppm or greater is
measured. If a leak is not detected for 2 consecutive months, monitoring may be
cut back to quarterly until a leak is detected.)

(NOTE:  Valves that  are designated for no detectable emissions, as indicated by
an instrument reading of less than 500 ppm above background, do not have to be
monitored monthly if:
   - the valve has no external actuating mechanism in contact with the hazardous
     waste stream
   - the valve is operated with emissions less than 500 ppm above background
   - the valve is tested initially upon designation, annually, and at the request of
     the regulatory agency.)

(NOTE:  Valves that are designated as unsafe to monitor are exempt  from the
requirement for monthly monitoring if:
   -the  valve  is unsafe to monitor because monitoring personnel would be
     exposed to an immediate  danger
   - a written monitoring plan is  followed that requires monitoring as often as is
     reasonably practicable during safe to monitor times.)

(NOTE:  The generator may elect to have all valves within a hazardous waste
management unit comply with an alternative standard of no greater than 2 percent
of the valves to leak; see checklist item HW. 150.10.)

(NOTE: Valves that  are designated as difficult to monitor are exempt  from the
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                   requirement for monthly monitoring if:
                                      - the valve cannot be monitored without elevating the monitoring personnel
                                       more than 2 m above a support surface
                                      - the hazardous waste management unit within which the valve is located was
                                       in operation before 21 June 1990
                                      - a written monitoring plan is  followed that requires the monitoring of the
                                       valve at least once per calendar year.)

                                   (NOTE:  The following are alternatives  to the prescribed monitoring schedule
                                   which can be used until the percentage of valves leaking is greater than 2 percent:
                                      - after 2 consecutive quarterly  leak detection periods with the percentage of
                                       valves leaking equal to or less  than 2 percent, an owner or operator may
                                       begin to skip one of the quarterly leak detection periods for the valves
                                       subject to 40  CFR 265.1057
                                      - after 5 consecutive quarterly  leak detection periods with the percentage of
                                       valves leaking equal to or less  than 2 percent, an owner or operator may
                                       begin to skip three of the  quarterly leak detection periods for the valves
                                       subject to 40  CFR 265.1057.)

                                   Verify that the first attempt at repairing a leak is done within 5 calendar days after
                                   detection and leak  repair is completed within 15 calendar days after detection.

                                   (NOTE: First attempts at repair include but are not limited to:
                                      - tightening of bonnet bolts
                                      - replacement of bonnet bolts
                                      -tightening of packing gland nuts
                                      - injection of lubricant into lubricated packaging.)
     HW. 150.7. Generators with
     pumps and valves in heavy
     liquid service, pressure relief
     devices in light liquid service
     or heavy liquid service, and
     other connectors that contain
     or contact hazardous wastes
     with organic concentrations
     of at least   10  percent  by
     weight are required to meet
     specific    monitoring   and
     repair  standards  (40  CFR
     262.34(a)(l)(i),  265.178, and
     265.1058).
Verify that pumps and valves in heavy liquid service, pressure relief devices in
light liquid service or heavy liquid service, and other connectors are monitored
within 5 days if evidence of a potential leak is found by visual, olfactory, audible,
or other detection method.

(NOTE:  Any connector that is inaccessible  or is ceramic  or ceramic-lined is
exempt from the monitoring requirements.)

(NOTE:  A leak is detected if an instrument reading of 10,000 ppm or greater is
measured.)

Verify that, when a leak is detected, the first attempt at repair occurs within 5
days and repair is done within 15 days after discovery.

(NOTE:  First attempts at repair include, but are not limited to:
   - tightening of bonnet bolts
   - replacement of bonnet bolts	
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                     -tightening of packing gland nuts
                                     - injection of lubricant into lubricated packaging.)
     HW. 150.8.   Generators are
     required  to  keep  specific
     records  pertaining  to  the
     valves, pumps, pressure relief
     devices,    and   connecting
     systems being monitored for
     leaks  and  to  submit certain
     reports      (40       CFR
     262.34(a)(l)(i),     265.178,
     265.1058(e) and 265.1064).
 Verify that the following information is maintained in the generator's operating
 record:

    -equipment  identification  number  and   hazardous   management   unit
     identification
    - approximate locations
    - type of equipment
    - percent-by-weight total  organics in the hazardous waste  stream at the
     equipment
    - hazardous waste state at the equipment (gas, liquid, vapor)
    - method of compliance
    - implementation schedule if needed
    - a performance plan for control devices if needed
    - documentation of compliance
    - documentation of repair, including:
        - the  instrument and operator identification numbers and the equipment
          identification number
        - the  date evidence of a potential leak was found
        - the  date the leak was detected and the date of each attempt to repair the
          leak
        - repair methods applied in each attempt
        - "Above 10,000" if the maximum instrument reading after each repair
          attempt is greater than 10,000 ppm
        - "Repair Delayed" and the reason for delay if the leak is not repaired
          within 15 calendar days after discovery
        - documentation supporting the delay of repair of a valve
        - signature of the  owner or operator whose decision it was that the repair
          could not be effected without a hazardous waste management unit
          shutdown
        -the  expected date  of successful repair of the  leak when it is not
          repaired within 15 calendar days
        -the  date of the successful repair of the leak
    - design documentation and monitoring, operating, and inspection information
     for each closed-vent system control device required  to comply with the
     provisions of 40 CFR 265.1060
    -monitoring and  inspection  information indicating proper operation and
     maintenance of the control device for a control device other than a thermal
     vapor incinerator, catalytic vapor incinerator, flare, boiler, process heater,
     condenser, or carbon  absorption system
    -the following information for all equipment subject to 40 CFR 265.1052
     through 40 CFR 265.1060:
	- a list of identification numbers for equipment (except welded fittings)
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                          -a  list  of identification  numbers for equipment  that the owner or
                                           operator elects to designate for no detectable emissions
                                          - a list of equipment identification numbers for pressure relief devices
                                          -the  dates  of required  compliance  tests, background  levels,  and
                                           maximum instrument reading measured during the compliance test
                                          - a list of identification numbers for equipment in vacuum service
                                          - identification either by list or location (area or group) of equipment
                                           that  contains  or  contacts  hazardous  waste  with  an  organic
                                           concentration of at least 10 percent by weight for less than 300 hours
                                           per calendar year.

                                  Verify that the following information is kept for all valves subject to  40 CFR
                                  265.1057(g)and(h):

                                     - a list of identification  numbers for valves listed as unsafe to  monitor, an
                                       explanation for each valve stating why it is difficult to monitor, and the plan
                                       for monitoring each valve
                                     - a list of identification numbers for valves that are designated as difficult to
                                       monitor, an explanation for each valve stating why it is  difficult to  monitor,
                                       and the plan for monitoring each valve
                                     - the following for all valves complying with 40 CFR 265.1062:
                                          - a schedule of monitoring
                                          - the percent of valves found leaking in each monitoring period.

                                  Verify that the following information is kept for use in determining exemptions:

                                     - an analysis determining the design  capacity of the unit
                                     - a statement listing the  hazardous  waste influent to and effluent from each
                                       unit subject to 40  CFR 265.1052  through 265.1060  and  an  analysis
                                       determining whether these hazardous wastes are heavy liquids
                                     -an  up-to-date analysis and the supporting information and data used to
                                       determine if equipment is subject to the requirements.

                                  (NOTE:  Any connector that  is inaccessible  or is ceramic  or ceramic lined is
                                  exempt from the recordkeeping requirements.)
     HW. 150.9.  Each piece of
     equipment  subject  to  the
     requirements  in  40   CFR
     265.1050  through 265.1064
     is required to be marked so
     that it  can be distinguished
     from other  equipment  (40
     CFR        262.34(a)(l)(i),
     265.178, and 265.1050(c)).
Verify that each piece of equipment subject to the requirements  in 40  CFR
265.1050 through 265.1064 (see checklist items HW. 150.1 through HW.150.10)
is marked so that it can be distinguished from other equipment.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.150.10.      When   a
     generator  has  elected  to
     comply   with   alternative
     standards,  specific  actions
     are   required  (40    CFR
     262.34(a)(l)(i)         and
     265.1061).
Determine if the owner/operator subject to 40 CFR 265.1057 (see checklist item
HW. 150.6) has elected to have all valves within a hazardous waste management
unit comply with an alternative standard of allowing 2 percent of the valves to
leak.

Verify that the  following actions  have been taken if the owner/operator has
decided to comply with the 2 percent alternative:

   - the regulatory agency has been notified of the choice to comply with the
    alternative standards
   - a performance test was conducted initially upon designation, annually, and
    at other times as required by the regulatory agency
   - if a valve leak is detected, first attempt at repair is within five calendar days
    and leak repair is completed within 15 days after detection.

Verify that if the owner/operator has decided to no longer comply with  the 2
percent rule, the regulatory agency has been notified.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                        REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.160

     Satellite Accumulation
     Points
     HW.160.1.  Generators may
     accumulate  as  much as  55
     gal. of hazardous waste or 1
     qt.  of  acutely  hazardous
     waste in containers at or near
     any point of initial generation
     without complying with the
     requirements   for   on-site
     storage if specific standards
     are met (40 CFR 262.34(c)).
(NOTE: This type of storage area is often referred to as a satellite accumulation
point.)

Verify that the satellite accumulation point is at or near the point of generation
and is under the control of the operator of the waste generating process.

Verify that the containers are in good condition and are compatible with the waste
stored in them and the containers are kept closed  except when waste is being
added or removed.

Verify that  the  containers are  marked HAZARDOUS  WASTE or  other
appropriate identification.

(NOTE: See Appendices A, B, C, and D for a guidance list of hazardous and
acutely hazardous wastes.)

Verify by interviewing the  shop  managers that when waste is accumulated in
excess of quantity limitations, the following actions are taken:

   -the excess container is marked with the date the excess  amount began
     accumulating
   - the waste is transferred to a 90 day or permitted  storage area within three
     days.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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This document is intended solely for guidance. No statutory or regulatory                                       86
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                        REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.170

     Container Storage Areas
     HW.170.1.  At  generators,
     containers   of   hazardous
     waste  should  be  kept  in
     designated   storage  areas
     (UP).
Verify that all containers are identified and stored in appropriate areas.

(NOTE: Any unidentified contents of solid waste containers and/or containers
not in designated storage areas must be tested to determine if solid or hazardous
waste requirements apply.)
     HW.170.2.       Containers
     holding ignitable  or reactive
     waste must be located  15 m
     (50 ft.) from the property line
     of the  facility  (40  CFR
     262.34(a)(l)(i)and265.176).
Determine the distance from storage containers holding ignitable or reactive
waste to the property line.
     HW.170.3.        Generator
     personnel   must   conduct
     weekly    inspections    of
     container storage  areas (40
     CFR  262.34(a)(l)(i)   and
     265.174).
Verify  that inspections are conducted at least weekly  to  look for  leaking
containers and signs of deterioration of containers.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      This Page Intentionally Left Blank
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                                REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.190

     Containment Buildings
      (NOTE: According to the 'Background Information' published on page 37221 of
      the  August  18,  1992,  edition  of the Federal Register,  a  hazardous waste
      containment building involves "the management of a hazardous waste inside a
      unit designed and operated to contain the hazardous waste within the unit". This
      is not a building that holds drums or tanks filled  with hazardous waste, but a
      building that holds the hazardous waste itself.)
     HW.190.1. Generators with
     containment  buildings  that
     are  in compliance are not
     subject to  the  definition of
     land  disposal   if  specific
     requirements  are  met  (40
     CFR  262.34(a)(l)(iv)  and
     265.1100).
      Verify that the containment building meets the following:

          -it is a completely enclosed, serf-supporting structure that is designed and
           constructed of man-made materials of sufficient strength and thickness to
           support themselves,  the  waste contents,  and any  personnel  and heavy
           equipment that operate within the unit
          -it is  designed  to prevent  failure due to pressure  gradients,  settlement,
           compression, or uplift, physical contact with the hazardous wastes, climatic
           conditions, and the stress of daily operations
          -it has a primary barrier that is  designed to be sufficiently  durable  to
           withstand the movement of personnel, wastes, and handling of equipment
           within the unit
          - if the unit is used to manage liquids:
              -there is a primary barrier designed and constructed of materials to
                prevent migration of hazardous constituents into  the barrier
              -there is  a liquid  collection system designed and  constructed  of
                materials to minimize the accumulation of liquid on the primary barrier
              - there is a secondary containment system designed and constructed of
                materials  to prevent  migration of  hazardous  constituents  into  the
                barrier, with a leak detection and liquid collection system capable of
                detecting, collecting, and removing leaks of hazardous constituents at
                the earliest practicable  time
          - it has controls sufficient to prevent fugitive dust emissions
          - it is designed and operated  to ensure containment and prevent the tracking
           of materials from the unit by personnel and equipment.
     HW. 190.2.     Containment
     buildings are required to be
     designed    according    to
     specific standards  (40  CFR
     262.34(a)(l)(iv),
and
     265.1101(a)(2),
     265.1 10 l(a)(4),
     265.1101(b)).
Verify that containment buildings meet the following design standards:

   - it is completely enclosed with a floor, walls, and a roof to prevent exposure
     to the elements and to assure containment of wastes
   -the  floor and containment  walls,  including  any  required  secondary
     containment system, are designed and constructed of man-made materials of
     sufficient strength and thickness to support themselves, the waste contents,
     and any personnel and heavy equipment that operate within the unit
   -it is designed to prevent failure due  to  pressure gradients, settlement,
     compression, or uplift, physical contact with the hazardous wastes, climatic
     conditions, and the stress of daily operations
   - it has sufficient structural strength to prevent collapse or other failure	
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                      - all surfaces in contact with hazardous wastes are compatible with the wastes
                                      -it has a primary barrier that is designed to be  sufficiently durable  to
                                       withstand the movement of personnel, wastes, and handling of equipment
                                       within  the  unit and  is  appropriate  for  the chemical  and  physical
                                       characteristics of the waste.

                                   Verify that if the containment building is going to manage hazardous wastes with
                                   free liquids or treated with free liquids, the following design requirements are also
                                   met:

                                      - there is a primary barrier designed and constructed of materials to prevent
                                       migration of hazardous constituents into the barrier (e.g., a geomembrane
                                       covered by a concrete wear surface)
                                      - there is a liquid collection and removal system designed and constructed of
                                       materials to minimize the accumulation of liquid on the primary barrier
                                          -the primary barrier is  sloped to  drain  liquids to the associated
                                            collection system
                                          - liquids and wastes are collected and removed to minimized hydraulic
                                            head on the containment system at the earliest practicable time
                                      -there is a secondary containment system, including a secondary barrier,
                                       designed and constructed of materials  to prevent migration of hazardous
                                       constituents  into the barrier,  with a leak detection and  liquid collection
                                       system  capable of detecting, collecting, and removing leaks of hazardous
                                       constituents  at the earliest practicable time
                                      - the leak detection component of the secondary  containment system meets
                                       the following:
                                          - it is constructed with a bottom slope of 1 percent or more
                                          -it  is constructed of granular drainage materials with a hydraulic
                                            conductivity of 1 x  10~2 cm/sec or more and a thickness of 12 in (30.5
                                            cm) or more, or constructed of synthetic or geonet drainage  materials
                                            with a transmissivity of 3 x 10~5 m2/sec or more
                                      - if treatment is to be  conducted in the building, the treatment area is designed
                                       to prevent the release of liquids, wet materials,  or liquid aerosols to other
                                       portions of the building
                                      -the  secondary  containment system is  constructed  of materials that are
                                       chemically resistant to the waste and liquids managed in the building and of
                                       sufficient strength and thickness to prevent collapse under pressure exerted
                                       by overlaying materials and by any equipment used.

                                   (NOTE: An  exception to the  structural strength requirement may be made for
                                   lightweight doors  and windows based  on the nature of the waste  management
                                   operations if the following criteria are met:
                                      -the doors and  windows provide  an effective barrier again fugitive dust
                                       emissions
                                      - the unit is designed  and operated in a manner that ensures that the waste will
                                       not come in contact  with the doors or windows.)	
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  (NOTE: A containment building can serve as secondary containment systems for
                                  tanks within the building if it meets the requirements of 40 CFR 264.193(b),
                                  264.193(c)(l) and (2), and 264.193(d).)
     HW. 190.3.     Containment
     buildings are required to be
     operated     according    to
     specific standards  (40  CFR
     262.34(a)(l)(iv),
     265.1101(a)(3),
     265.1101(c)(l),         and
     265.1101(c)(4)).
Verify that incompatible wastes or treatment  reagents are not placed in the
building or its secondary containment system if they could cause the unit or the
secondary containment system to leak, corrode, or otherwise fail.

Verify that the following operational procedures are done:

   - controls and practices are used to ensure the containment of the waste within
     the building
   - the primary barrier is maintained so that it is free of significant cracks, gaps,
     corrosion, or  other deterioration that could cause hazardous waste  to be
     released from the primary barrier
   - the  level of the stored/treated hazardous waste is maintained so  that the
     height of any containment wall is not exceeded
   - measures are implemented to prevent the tracking of hazardous waste out of
     the unit by personnel or equipment used in the handling of the waste
   -there  is  a  designated area for  the  decontamination  of  equipment and
     collection of rinsate
   - any collected rinsate is managed as needed according to its constituents
   -measures are  implemented to control fugitive dust emissions  so that no
     openings exhibit visible emissions
   -paniculate  collection devices  are maintained  and operated according to
     sound air pollution control practices.

Verify that data is gathered from monitoring equipment and  leak detection
equipment and the site is inspected at least once every seven days and the results
recorded in the operating record.

Verify that there is a written description of procedures to ensure that waste does
not remain in the building for more than 90 days.

Verify that there is documentation that the waste does not remain for more than
90 days.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW. 190.4.     Containment
     buildings are required to be
     certified   by  a  registered
     professional  engineer  (40
     CFR  262.34(a)(l)(iv)  and
     265.1101(c)(2)).
Verify by reviewing the documentation that the building has been certified.
     HW. 190.5.    Leaks    in
     containment buildings  must
     be repaired and reported (40
     CFR  262.34(a)(l)(iv)   and
     265.1101(c)(3)).
Verify that if a condition is detected that could lead to a leak or has already
caused a leak, it is repaired promptly.

Verify that when a leak is discovered:

   - the discovery is recorded in the facility operating record
   - the portion of the  containment building that  is affected is removed from
     service
   - a cleanup and repair schedule is established
   -within seven days the regulatory agency is notified and within 14 working
     days written notice is provided to the regulatory agency
   -the regulatory agency is notified upon the completion of all repairs, and
     certification from a registered professional engineer is also submitted.
     HW. 190.6.     Containment
     buildings  that contain both
     areas   with   and  without
     secondary containment must
     meet  specific  requirements
     (40  CFR  262.34(a)(l)(iv),
     264.1101(d),            and
     265.1101(d)).
Verify that each  area is designed and operated according to the appropriate
requirements.

Verify that measures are taken to prevent the release of liquids or wet materials
into areas without secondary containment.

Verify that a written description is maintained in the facilities operating log of
operating procedures used to  maintain the  integrity of areas without  secondary
containment.
     HW. 190.7.     When     a
     containment   building    is
     closed, specific requirements
     must  be   met   (40   CFR
     262.34(a)(l)(iv),  264.1102,
     and 265.1102).
Determine if the facility has closed a containment building recently.

Verify that  at closure,  all waste residues, contaminated containment system
components, contaminated subsoils, and structures and equipment contaminated
with waste and leachate were removed or decontaminated.

Verify that the containment building is closed in accordance with closure and
post-closure requirements for TSDFs.

Verify that if it is found that not all contaminated subsoils  can be practicably
removed or  decontaminated,  the  site  is closed  and  landfill  post-closure
requirements are implemented.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     LARGE QUANTITY
     GENERATORS

     HW.200

     Disposal of Restricted
     Waste
     HW.200.1.  Facilities  that
     generate  hazardous  wastes
     must test their wastes or use
     process    knowledge    to
     determine   if   they   are
     restricted from land disposal
     (40CFR268.7(a)(l)).
Determine whether the generator tests for restricted wastes.

Determine if the facility generates restricted wastes (see Appendix VII of 40 CFR
Part 268) by reviewing test results or reviewing procedures employed by facility
management  where process  knowledge  was applied  in  making the  waste
determination.
     HW.200.2.     When     a
     generator  is  managing  a
     waste or  contaminated  soil
     that does not meet treatment
     standards,  a written notice
     must be issued to the TSDF
     stating    the    appropriate
     treatment   standards    and
     prohibition levels  (40  CFR
     268.7(a)(2), and 268.7(a)(3))
     [Revised January 2001].
(NOTE: The notification requirement under 40 CFR 268.7 has changed to a one-
time notification and certification if the composition of the wastes, the process
generating the wastes, and the treatment facility receiving the wastes  do not
change (See FR Vol 62, No. 91, May 12, 1997, pg 26004).)

Verify that, for waste or contaminated soil which does not meet the applicable
treatment standards or exceeds the applicable prohibition levels, the notice is
issued and includes:

   -U.S. EPA hazardous waste numbers and manifest number of first shipment
   -the waste is subject to the LDRs (NOTE:  The  notice must also include
     constituents of concern for F001-F005, and F039, and underlying hazardous
     constituents in characteristic wastes, unless the waste will be treated and
     monitored for all  constituents.  If all constituents will  be  treated  and
     monitored, there is no need to put them all on the LDR notice.)
   -the applicable wastewater/nonwastewater category  (see 40 CFR 268.2(d)
     and 268.2(f)) and subdivisions made within a waste code  based on waste-
     specific criteria (such as D003 reactive cyanide)
   - waste analysis data (when available)
   -for  hazardous  debris, when  treating  with  the  alternative treatment
     technologies provided by 40 CFR 268.45:
        -the  contaminants subject to  treatment, as described  in 40  CFR
          268.45(b)
        - an indication that these contaminants are being treated to comply with
          40 CFR 268.45
   -for contaminated soil subject to LDRs as provided in 40 CFR 268.49(a), the
     constituents subject to treatment as described in 40 CFR 268.49(d), and the
     following statement: "This contaminated soil [does/does not] contain listed
     hazardous waste and  [does/does not] exhibit a characteristic of hazardous
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
REVIEWER CHECKS
                                       waste and  [is subject to/complies with]  the  soil treatment standards as
                                       provided by 40 CFR 268.49(c) or the universal treatment standards."

                                  Verify that, for waste or contaminated soil which meets the treatment standard at
                                  the original point of generation, the notice includes:

                                      -U.S. EPA hazardous waste numbers and manifest number of first shipment
                                      -the waste is subject to the  LDRs (NOTE:  The notice must also include
                                       constituents of concern for F001-F005, and F039, and underlying hazardous
                                       constituents in characteristic wastes, unless  the waste will be treated and
                                       monitored  for all constituents.  If all  constituents  will be treated  and
                                       monitored, there is no need to put them all on the LDR notice.)
                                      -the applicable wastewater/nonwastewater  category (see 40 CFR 268.2(d)
                                       and 268.2(f)) and subdivisions made within a  waste code based on waste-
                                       specific criteria (such as D003 reactive cyanide)
                                      - waste analysis data
                                      -for contaminated soil subject to LDRs as provided in 40 CFR 268.49(a), the
                                       constituents subject to treatment as described in 40 CFR 268.49(d), and the
                                       following statement: "This contaminated soil [does/does not]  contain listed
                                       hazardous waste  and [does/does not]  exhibit a characteristic of hazardous
                                       waste and  [is subject to/complies with  the  soil treatment standards as
                                       provided by 40 CFR 268.49(c) or the universal treatment standards"
                                      -the signature of  an authorized  representative certifying that  the  waste
                                       complies with the treatment  standards  of 40 CFR  268  (the text of the
                                       required certification statement can be found in 40 CFR 268.7(a)(3)(i).)

                                  Verify that, for waste or contaminated soil that meets the treatment standard at the
                                  original point of generation, if the waste  changes, the generator sends a new
                                  notice and certification to the receiving facility and placed a copy in their files.

                                  (NOTE:   Generators  of  hazardous debris  excluded from the  definition of
                                  hazardous waste under 40 CFR 261.3(f) are not subject to the requirements for
                                  waste or contaminated soil which  meets the treatment standard at the original
                                  point of generation.)

                                  Verify that, for restricted waste  subject to an exemption from a prohibition of the
                                  type of land disposal used, the notice states that the waste is not prohibited from
                                  land disposal and includes:

                                      -U.S. EPA hazardous waste numbers and manifest number of first shipment
                                      - statement: this waste is not prohibited from land disposal
                                      - waste analysis data, when available
                                      - date the waste is subject to the prohibition
                                      -for  hazardous  debris,  when  treating  with  the  alternative  treatment
                                       technologies  provided by 40  CFR 268.45: the  contaminants  subject to
                                       treatment, as  described in 40  CFR 268.45(b);  and an indication that these
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                          COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                          REVIEWER CHECKS
                                        contaminants are being treated to comply with 40 CFR 268.45.
     HW.200.3.  Generators  that
     are   managing   prohibited
     wastes in tanks,  containers,
     or containment buildings and
     treating the waste  to  meet
     applicable         treatment
     standards, must develop and
     follow   a  written  waste
     analysis   plan   (40    CFR
     268.7(a)(5)             and
     268.7(a)(10)).
Verify that the plan describes the procedures that the generator will carry out to
comply with treatment standards.

(NOTE:   Generators treating hazardous debris under the alternative treatment
standards are not required to conduct waste analysis.)

Verify that the plan is kept on-site and:

   -the  plan  is  based  on a detailed chemical and  physical  analysis  of
     representative sample of the prohibited waste being treated
   -contains all information necessary to  treat the waste in accordance  with
     regulatory requirements including the selected testing frequency
   -the  plan is kept in the on-site files  and made available to regulatory
     inspectors.
     HW.200.4.  Generators  are
     required  to  keep   specific
     documents    pertaining   to
     restricted wastes on-site  (40
     CFR   268.7(a)(6)   through
     268.7(a)(8)).
Verify that if the facility is using generator knowledge to determine whether a
waste or contaminated soil is restricted from land disposal, the supporting data
used in making this determination is retained on-site in the generator's files.

Verify that if the facility has determined whether a waste or contaminated soil is
restricted using appropriate test methods,  the waste analysis data is retained on-
site.

Verify that if the facility has determined that they are managing a restricted waste
that is excluded from the definition of a hazardous waste or solid waste or exempt
from RCRA Subtitle C, a one-time notice is placed in the facility's files stating
that the generated waste is excluded.

Verify that a copy  of all notices, certifications, waste analysis data and other
documentation is kept for at least three years from the date that the waste was last
sent to an on-site or off-site TSDF.
     HW.200.5.  Generators  who
     first  claim  that  hazardous
     debris  is excluded from the
     definition of hazardous waste
     are required to meet specific
     notification and  certification
     requirements     (40     CFR
     268.7(d)).
Verify that a one-time notification is submitted to the regulatory agency including
the following:

   -the name and address of the facility receiving the treated waste
   - a description of the hazardous debris as  initially generated,  including the
     applicable EPA hazardous waste codes, treatability groups, and underlying
     hazardous constituents
   - for excluded debris, the technology used to treat the debris.

Verify that the notification  is updated if the  debris is shipped to a different
facility.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                  Verify that for debris that is excluded, if a different type of debris is treated or if a
                                  different technology is used to treat the debris, the notification is updated.
     HW.200.6.  The  storage  of
     hazardous   waste  that  is
     restricted from land disposal
     is not allowed unless specific
     conditions are met (40  CFR
     268.50).
Verify that land disposal restricted waste is not stored at the facility unless the
generator is storing the wastes in tanks, containers, or containment buildings on-
site only for the purpose of accumulating enough quantity of hazardous waste to
facilitate proper recovery, treatment, or disposal and all appropriate standards for
containers, tanks, and containment buildings are met.

(NOTE: If the 90 day storage period is exceeded, the generator is required to be
permitted as a TSDF.)

(NOTE: The prohibition on storage does not apply to hazardous wastes that have
met treatment standards.)

Verify that liquid hazardous  wastes containing PCBs  at concentrations greater
than 50 ppm are stored at a site that meets the requirements of 40 CFR 761.65(b)
(see the Toxic Substances Control Act  (TSCA)) and is removed from storage
within one year of the date it was first placed into storage.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY:
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     TRANSPORTATION OF
     HAZARDOUS WASTE

     HW.300
     HW.300.1. Transporters  of
     hazardous  waste   that  is
     required  to be  manifested
     must    have    an    EPA
     identification   number   and
     must comply with  manifest
     management   requirements
     (40     CFR     263.10(a),
     263.10(b), 263.11, 263.20(a)
     through  263.20(d),   263.21
     and263.22(a)).
(NOTE:   These requirements do  not  apply  to  the  on-site  transportation of
hazardous waste.)

Determine if the facility transports  hazardous waste off-site by using their own
vehicles or a contractor.

Verify that the transporter has an EPA identification number.

Verify that  all waste  accepted,  transported,  or  offered  for  transport is
accompanied by a manifest.

Verify that prior to transport, the transporter signs and dates the  manifest and
returns a copy to the generator prior  to leaving the facility.

Verify that the transporter retains a copy of the manifest after delivery.

Verify that all wastes accepted by the transporter are delivered to the designated
facility listed on the manifest, or the alternate designated facility if an emergency
prevents delivery,  or the next designated transporter or the place outside the
United States designated by the generator.

(NOTE: If the transporter cannot deliver the hazardous waste to the facilities or
transporters designated on the manifest, the transporter must contact the generator
for further directions and  revise  the  manifest according to  the  generator's
instructions.)

Verify that manifests are kept on file for three years.

(NOTE:  Special issues involved in the transportation of hazardous waste by air,
rail or water are not addressed in this guide.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.300.2.          Before
     transporting hazardous waste
     or offering hazardous waste
     for transportation off-site in
     the United States, the facility
     must package and label the
     waste  in  accordance  with
     DOT regulations contained in
     49 CFR 172, 173, 178, and
     179 (40 CFR 262.30 through
     262.33).
Determine what pretransport procedures for hazardous waste are used.

Verify that containers are properly constructed and exhibit no leaks, corrosion, or
bulges by inspecting a sample of containers awaiting transport.

Verify that there are no indications of drum failure  by examining end-seams for
minor weeping.

Verify that labeling and marking on each container is compatible with the
manifests.

Verify that the  following information  is  displayed on a  random  sample  of
containers of 110 gal. (416.40 L) or less in accordance with 49 CFR  172.304:

   - "HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If
     found, contact the  nearest police  or  public safety authority or the U.S.
     Environmental Protection Agency."
   - generator's name and address
   - Manifest Document Number.

Verify that proper DOT placarding is available for the transporter.
     HW.300.3. Transporters  of
     waste  off-site   must  take
     immediate  notification and
     clean-up action if a discharge
     occurs  during  transport  (40
     CFR 263.30 and 263.31).
Verify that transport operators have instructions to notify local authorities and
take clean-up action so that the discharge does not present a hazard.

Verify that transporters give notice to the NRC and report in writing as required
by 49 CFR 171.15 and 49 CFR 171.16.
     HW.300.4.   The   facility
     should     ensure     that
     transportation  of hazardous
     wastes between buildings is
     accomplished in  accordance
     with    good   management
     practices  to  help  prevent
     spills,     releases,     and
     accidents (MP).
Determine  if procedures  exist to manage  movement of hazardous  wastes
throughout the facility.

Determine if drivers are trained in spill control procedures.

Determine if provisions have been made for securing wastes in vehicles during
transport.
     HW.300.5.     Transporters
     must  not  store manifested
     shipments    in   containers
     meeting   DOT   packaging
     requirements for more than
     10 days at a transfer facility
     (40 CFR 263.12).
Determine if the facility has a transfer facility.

Verify the following:

   - transfer facility storage is for 10 days or less
   - DOT packaging requirements are met
   - shipments are manifested and manifests accompany shipments
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                      COMPLIANCE CATEGORY;
                                 HAZARDOUS WASTE MANAGEMENT
         REGULATORY
       REQUIREMENT OR
         MANAGEMENT
           PRACTICE
REVIEWER CHECKS
                                  - storage is consistent with good management practices.

                                (NOTE: Storage for more than 10 days will require a TSDF permit.)

                                Verify that transporters  do not  store  manifested  shipments of land disposal
                                restricted wastes for more than 10 days (40 CFR 268.50(a)(3)).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
    EXPORT/IMPORT OF
    HAZARDOUS WASTE

    HW.400

    Exports of Hazardous
    Waste for Recovery Within
    the OECD Member
    Countries
    HW.400.1.  A U.S. Notifier
    that exports amber list or red
    list hazardous waste (see 40
    CFR  262.89   and 262.82)
    destined     for    recovery
    operations   (see   40   CFR
    262.81(k))   in  an  OECD
    member  country  (40  CFR
    262.58(a))  must comply with
    notification requirements  (40
    CFR 262.83).
Determine whether the importing country  is an  Organization for Economic
Coordination and Development (OECD)  member  country  [Australia,  Austria,
Belgium, Denmark, Finland, France,  Germany, Greece,  Iceland, Ireland, Italy,
Japan,  Luxembourg,  Netherlands, New  Zealand,  Norway,  Portugal,  Spain,
Sweden, Switzerland, Turkey, United Kingdom, and United States].

(NOTE: The following countries have become OECD member countries since
U.S. EPA promulgated its OECD regulations in  1996: South Korea, Czech
Republic, Poland, and Hungary.   U.S. EPA plans to amend its regulations to
reflect these new OECD countries.  In the interim, U.S. EPA strongly recommends
that U.S. exports to these new OECD countries comply with the applicable OECD
regulations,  since  these  countries  would  expect  compliance  with  OECD
requirements for shipments they receive from the U.S.)

Determine whether the waste is  destined for recovery operations, including
resource recovery, recycling, reclamation, direct re-use or alternative uses.

Verify that 45 days prior to shipment of hazardous waste, the facility has notified
U.S. EPA (in writing) of the following:

   - serial number or other accepted identifier of the notification form
   - name, address, telephone and telefax numbers, and  EPA ID number of the
     notifier
   - name, address, telephone and telefax numbers of any consignee (other than
     the owner or operator of the recovery facility) and whether the consignee
     will exchange or store the waste before delivery to the final recovery facility
   - Intended transporters  and any agents
   - country of export and point of departure
   - countries of transit, relevant  competent authority, and point of entry and
     departure
   - country of import, relevant competent authority, and point of entry
   - statement of whether the notification is  for a single or multiple shipments
     and, for multiple shipments, period of validity requested
   - date foreseen for shipments to begin
   - designation of waste types from the appropriate list (amber or red and waste
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                       list code), descriptions of each waste type, estimated total quantity of each,
                                       RCRA waste code, and United Nations number for each waste type
                                     - signed certification that states the following:
                                          - "I certify that the above information is complete and correct to the best
                                           of my knowledge.   I also certify that  legally-enforceable  written
                                           contractual obligations have been entered into, and that any applicable
                                           insurance or other financial guarantees are or shall be in force covering
                                           the transfrontier movement."

                                  (NOTE: The U.S. does not currently require financial assurance; however, U.S.
                                  exporters may  be asked by other  governments to provide and  certify to such
                                  assurance as a condition of obtaining consent to a proposed movement.)

                                  (NOTE: If wastes with similar physical and chemical characteristics, the same
                                  United Nations classification, and the same RCRA waste codes are to be sent to
                                  the  same recovery  facility by the same  notifier, the notifier may submit one
                                  notification of intent to export these wastes in multiple shipments  during a period
                                  of up to one year.)

                                  (NOTE: For amber list wastes to be shipped to a recovery facility pre-approved by
                                  the  competent authority of the receiving  country, the notifier must provide  the
                                  above information to U.S. EPA at least 10 days prior to shipment.  Waste may be
                                  shipped as soon as the notification has been received by the competent authorities
                                  in the  exporting, importing,  and transit  countries unless  the notifier receives
                                  information indicating that any country objects to the shipment.)

                                  Verify  that, for amber list wastes, either (1) no objection was  lodged by any
                                  exporting, importing, or transit countries within 30  days after issuance  of  the
                                  Acknowledgment of Receipt  of notification by the  competent authority  of  the
                                  importing country or (2) the  competent authorities of all importing and transit
                                  countries provided written consent within 30 days.

                                  Verify that, for red list wastes, written consent was received from the  importing
                                  country and any transit countries prior to export.
     HW.400.2.   A  U.S.  notifier
     must execute  a  valid written
     contract or chain of contracts
     with the recovery facility that
     specifies  the  responsibilities
     of each (40 CFR 262.85).
Verify that contracts specify the name and EPA ID number, where available, of:

   - the generator of each type of waste
   - each person who will have physical custody of the waste
   - each person who will have legal control of the waste
   - the recovery facility.

Verify that contracts specify:

   -which party will assume responsibility for  alternate management  of the
     wastes if it cannot be carried out as described in the notification of intent to
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       102

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                       export
                                      - that the person with actual possession or physical control over the waste will
                                       immediately notify the notifier and the competent authorities of the exporting
                                       and importing countries and transit country if wastes are located in a country
                                       of transit
                                      - the person specified in the contract who will assume responsibility for the
                                       adequate management  of the wastes including, if necessary, arranging for
                                       their return to the original country of export
                                      - notification prior to re-export to a third country
                                      - provisions for financial guarantees.
     HW.400.3.   A U.S. notifier
     must ensure that  a tracking
     document accompanies each
     shipment of amber or red list
     wastes  until it reaches  the
     final recovery  facility   (40
     CFR 262.84).
Verify that a copy of the tracking document is attached to the shipment.

Verify that  the tracking document  includes all  information contained in the
notification and the following:

   - the date shipment commenced
   -name,  address,  telephone  and telefax  numbers of primary exporter, if
     different than the notifier
   - name and EPA ID number of all transporters
   - any special precautions to be taken by transporters
   - signed certification that states the following:
        - "I certify that the above information is complete and correct to the best
         of my knowledge.   I also  certify  that legally-enforceable written
         contractual obligations have been entered into, and that any applicable
         insurance or other financial guarantees are or shall be in force covering
         the transfrontier movement, and that:
             - 1. All necessary consents have been received; OR
             - 2. The shipment is directed at a recovery facility within the OECD
              area and no  objection  has  been received from any of the
              concerned countries within the 30 day tacit consent period; OR
             -3. The shipment is directed at a recovery facility pre-authorized
              for  that  type  of waste within  the  OECD  area;  such  an
              authorization has not been revoked, and no  objection  has been
              received from any of the concerned countries."
             -(NOTE:  The  notifier  may delete  sentences  that  are  not
              applicable.)
   - appropriate signatures for each custody transfer.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                       103

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
     HW.400.4.   A  U.S.  notifier
     must  comply  with  special
     manifest  requirements  (40
     CFR 262.84(c) and 262.54(a),
Verify that the tracking documents contain the following:

   - the name and address of the foreign consignee (and any alternate consignee)
     in place of the designated facility's name, address, and EPA ID number
   -the  point of departure from the United  States indicated in the Special
     Handling Instructions and Additional Information section.

Verify that  a copy of the manifest is provided for delivery to  the U.S. Customs
official at the point of departure from the U.S.
     HW.400.5.      A   primary
     exporter must file an annual
     report  with  U.S.  EPA  by
     March   1  of   each  year
     regarding  hazardous  waste
     exported for recovery during
     the  previous year  (40  CFR
     262.87(a)).
Verify that an annual report has been submitted by March 1 of every year for
hazardous waste exported for recovery during the previous calendar year.

Determine  whether annual reports contain the following information for all
hazardous waste exported for recovery during the previous year by randomly
checking several of them:

   - the EPA ID number, name, mailing and site address of the notifier filing the
     report
   - calendar year covered by the report
   - the name and address of each final recovery facility
   - for each final recovery facility and each waste exported: a description of the
     waste, the EPA hazardous waste number, the OECD  waste type and code,
     the  DOT hazard class, the EPA ID number  for each transporter used, the
     total amount of waste shipped, and the number of shipments
   -under certain circumstances,  the efforts  used  to reduce the volume and
     toxicity of the waste and the change achieved during the previous year in
     comparison to earlier years
   - certification signed by the primary exporter that states the following:
        - "I certify under penalty of law that I  have personally examined and am
         familiar  with the information submitted  in this  and all attached
         documents,  and  that based on  my  inquiry  of  those  individuals
         immediately responsible for obtaining the  information, I believe that
         the submitted information is true, accurate,  and complete.  I am aware
         that there are  significant  penalties  for submitting false information
         including the possibility of fine and imprisonment."
     HW.400.6.      A   primary
     exporter   must    file   an
     exception  report with U.S.
     EPA     under      certain
     circumstances    (40    CFR
     262.87(b)).
Verify that an exception report is  filed with U.S. EPA each time  any of the
folio wing occurs:

   - the notifier does not receive a  copy of the tracking document signed by the
     transporter stating  point of departure  from the U.S. within  45  days  of
     acceptance by the initial transporter
   -within  90 days  from the date the waste  was accepted  by the initial
     transporter,  the notifier  does  not  receive written  confirmation from the
     recovery facility that the waste was received or	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


COMPLIANCE CATEGORY;
HAZARDOUS WASTE MANAGEMENT
REGULATORY
REQUIREMENT OR
MANAGEMENT
PRACTICE

HW.400.7. A primary
exporter must maintain
records that relate to export
activities (40 CFR 262.87(c)).
REVIEWER CHECKS
-the waste is returned to the U.S.
Verify that the following records are kept for the appropriate period of time:
- each notification of intent to export and all written consents obtained (at
least three years from the date the hazardous waste was accepted by the
initial transporter)
- each annual report (at least three years from the due date of the report)
- any exception reports and each confirmation of delivery received from the
recovery facility (at least three years from the date the initial waste was
received from the recovery facility).

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
105

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                  HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                        REVIEWER CHECKS
    EXPORT/IMPORT OF
    HAZARDOUS WASTE

    HW.420

    Exports of Hazardous
    Waste (Except to the OECD
    Member Countries) for
    Recovery
    HW.420.1.     A  primary
    exporter of hazardous waste
    must comply with notification
    requirements    (40    CFR
    262.53(a) and 262.53(b)).
Determine if the facility imports/exports hazardous waste.

Verify  that  60 days prior to the  initial  shipment of hazardous waste  to each
country in each calendar year, the facility has notified the U.S. EPA (in writing) of
the following:

   - name, mailing address, telephone number, and EPA identification number of
     the primary exporter
   -by consignee, for each hazardous waste type:
        - identification of the hazardous waste shipped  by EPA identification
         number
        - DOT shipping name, hazard class, and importer for the waste
        - estimated frequency/rate at which such wastes(s) is to be exported
        - estimated total quantity (in units)
        - all points of entry to and departure from each foreign country the waste
         will pass through
        - a description of the approximate length of time the waste will remain in
         each country, and how it will be handled there
        - the mode of transportation used to  transport the waste and type(s) of
         containers used
        - description of the treatment, storage, or disposal method to be used in
         the receiving country
        - name and address of the foreign consignee.
    HW.420.2.   The   primary
    exporter must attach a copy of
    an        U.S.        EPA
    Acknowledgment of Consent
    (that confirms the consent of
    the foreign country to receive
    the waste) to the shipment of
    hazardous waste to a foreign
    country (40 CFR 262.52(c),
    262.53(f) and 262.54(h)).
Verify that a copy of the U.S. EPA Acknowledgment of Consent is on file by
checking the records.

Verify that a copy of this document was attached to the shipment.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     107

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                    HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                          REVIEWER CHECKS
     HW.420.3. Primary exporters
     of  hazardous   waste  must
     require confirmation of the
     delivery  of the  hazardous
     waste and a description of any
     significant     discrepancies
     between the manifest and the
     shipment (40 CFR 262.54(f)).
 Verify that the facility has been receiving confirmation of delivery.

 Determine if there are any notations of discrepancies.
     HW.420.4. Primary exporters
     of  hazardous   waste  are
     required  to  comply  with
     general manifest requirements
     with certain modifications (40
     CFR    262.54(a)   through
     262.54(e) and 262.54(1)).
 Verify that the manifest copies comply with the general manifest requirements of
 40 CFR 262.20 through 262.23.

 Determine if the following modifications  are made by reviewing the  manifest
 copies:

   - the name and address of the foreign consignee (and any alternate consignee)
     is put in the place of the designated facility's name, address, and EPA
     number.
   -the point of departure from the United  States is indicated in the Special
     Instructions and Additional Information sections.
   -this  statement,  "and conform to  the terms  of the  attached  U.S.  EPA
     Acknowledgment of Consent," is added to the end of the first sentence of the
     certification in Item 16.

 Verify that a copy of the manifest is provided for delivery to the U.S.  Customs
 official at the U.S. point of departure.
     HW.420.5. Primary exporters
     of  hazardous   waste  are
     required  to  follow  specific
     procedures when a shipment
     cannot  be delivered to the
     designated    or    alternate
     consignee      (40      CFR
     262.54(g)).
 Verify that when a shipment cannot be delivered, the primary exporter does one of
 the following:

    -notifies the U.S.  EPA of a  change in the conditions of the original
     notification to allow shipment to a new consignee and obtains an U.S. EPA
     Acknowledgment of Consent prior to delivery, or
    - instructs the transporter to return the waste  to the primary exporter in the
     United States or designates another facility within the United States.

 Verify that the facility instructs the transporter to revise the  manifest to  reflect
 changes made.
     HW.420.6. Primary exporters
     of  hazardous   waste  are
     required to file  an exception
     report     under     certain
     conditions (40 CFR 262.55).
 Verify that an exception report was filed if:

    - a signed copy of the manifest from the transporter containing the following
     information was not received within 45 days from the day it was accepted by
     the initial transporter:
         -date of departure of the waste from the United States
	-place of departure of the waste from the United States	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
        REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                     -within 90  days from the date the waste was accepted by  the  initial
                                      transporter, the facility has not received a written confirmation from the
                                      foreign consignee stating that the hazardous waste was received
                                     - the waste is returned to the United States.
     HW.420.7.    The   primary
     exporter must file an Annual
     Report with  the  regulatory
     agency by March 1 of each
     year   regarding   hazardous
     waste  exported  during  the
     previous   year  (40   CFR
     262.56).
Verify that an Annual Report has been submitted by March 1 of every calendar
year.

Verify that the Annual Reports contain the following information for all hazardous
waste exported during the previous calendar year:

   -type, EPA hazardous waste number, DOT hazard class and name for each
     hazardous waste(s) exported
   - EPA identification number for each transporter (where applicable)
   - quantity of hazardous waste(s) exported
   - frequency (dates) of hazardous waste(s) exported
   - ultimate destination for all hazardous waste(s) exported
   - efforts used to reduce the volume and toxicity of the waste (and the changes
     achieved during the year in comparison to previous years)
   - a certification signed by the primary exporter that states:
        - "I certify under penalty of law that I  have personally examined and am
          familiar  with the information submitted  in this and all attached
          documents, and  that based  on my inquiry  of  those  individuals
          immediately responsible for obtaining the information, I believe that
          the submitted information is true, accurate, and complete.  I am aware
          that there  are  significant penalties  for submitting false information
          including the possibility of fine and imprisonment."
     HW.420.8. Primary exporters
     of hazardous  wastes  must
     maintain  additional  records
     that  relate  to  their export
     activities (40 CFR 262.57).
Verify that the following are kept for at least three years:

   - a copy of each notification of intent to export
   - a copy of each U.S. EPA Acknowledgment of Consent
   - a copy of each confirmation of delivery (signed manifests) of the waste
   - annual reports.

(NOTE: Periods of retention are automatically extended during the course of any
unresolved enforcement action.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY:
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
    EXPORT/IMPORT OF
    HAZARDOUS WASTE

    HW.440

    Imports of Hazardous
    Waste for Recovery Within
    the OECD Member
    Countries
    HW.440.1.  A U.S. importer
    of  amber  list  or red  list
    hazardous waste  (see 40 CFR
    262.89 and  262.82) destined
    for recovery operations (see
    40  CFR  262.81(k)) from an
    OECD member  country  (40
    CFR 262.58(a)) must execute
    a  valid  written  contract or
    chain of contracts  with  the
    recovery  facility that specifies
    the responsibilities of each
    (40 CFR  262.85).
Determine whether the exporting country is an OECD member country [Australia,
Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Ireland,
Italy, Japan, Luxembourg, Netherlands, New Zealand, Norway, Portugal,  Spain,
Sweden, Switzerland, Turkey, United Kingdom, and United States].

(NOTE: The following  countries have become OECD  member countries since
U.S. EPA promulgated  its regulations in 1996:  South Korea, Czech Republic,
Poland, and Hungary. U.S. EPA plans to amend its regulations to reflect these
new OECD countries.  In the interim, U.S. EPA strongly recommends that exports
to these new OECD countries  comply with applicable OECD regulations, since
these countries would  expect compliance with OECD requirements for shipments
they receive from the U.S.)

Determine  whether the waste is for recovery  operations, including resource
recovery, recycling, reclamation, direct re-use or alternative uses.

Verify that contracts specify the name and EPA ID number, where available, of:

   - the generator of each type  of waste
   - each person who  will have physical custody of the waste
   - each person who  will have legal control of the waste
   - the recovery facility.

Verify that contracts specify:

   -which party will assume responsibility for alternate management  of the
     wastes if it cannot be carried out as described in the notification of intent to
     export
   - that the person with actual possession or physical control over the waste will
     immediately notify the notifier and the competent authorities of the exporting
     and importing countries and transit country if wastes are located in a country
     of transit
   - that the person specified  in the  contract will assume responsibility for the
     adequate management of the wastes including, if necessary, arranging their
     return to the original country of export	
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     Ill

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
          MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
                                     - notification prior to re-export to a third country
                                     - provisions for financial guarantees.
     HW.440.2.  A U.S. importer
     must ensure that  a  tracking
     document accompanies  each
     shipment of amber or red list
     wastes  until  it reaches the
     final recovery  facility  (40
     CFR 262.84).
Verify that a copy of the tracking document was attached to the shipment.

Verify that  the tracking  document included all information contained in the
notification and the following:
   - the date shipment commenced
   -name, address,  telephone  and telefax numbers of primary exporter,
     different than the notifier
   - name and EPA ID number of all transporters
   - identification of means of transport, including types of packaging
   - any special precautions to be taken by transporters
   - signed certification required by 40 CFR 262.84(b)(6)
   - appropriate signatures for each custody transfer.
if
     HW.440.3.     A  consignee
     must  comply  with  general
     manifest  requirements  with
     certain  modifications   (40
     CFR 262.84(c) and 262.60).
Verify that the manifest copies comply with the general manifest requirements of
40 CFR 262.20.

Determine if the following modifications  are made by reviewing the manifest
copies:

   -the name and address of the foreign generator and the  importer's name,
     address and EPA identification number are put in place of the generator's
     name, address and EPA identification number
   -the U.S. importer (or his agent) must sign and date the certification statement
     in place of the generator's signature and obtain the signature of the initial
     transporter.
     HW.440.4.   Each person in
     the  U.S.  that has  physical
     custody of the waste until it
     arrives at the recovery facility
     must   sign   the   tracking
     document      (40      CFR
     262.84(d)).
Verify that the U.S. transporter, consignee, and owner or operator of the recovery
facility have signed the manifest.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                      112

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        COMPLIANCE CATEGORY;
                                   HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                         REVIEWER CHECKS
    HW.440.5.              An
    owner/operator  of a   U.S.
    recovery facility  must  send
    signed copies of the tracking
    document to the  notifier,  to
    U.S.   EPA,   and  to   the
    competent  authorities  of the
    exporting    and     transit
    countries within three days of
    receipt  of  imports (40  CFR
    262.84(e)).
Verify  that the facility sends signed copies of the  tracking document to the
notifier, to U.S. EPA, and to the competent authorities  of the exporting and transit
countries within the three days.
    HW.440.6.   A  facility that
    has   arranged   to   receive
    hazardous   waste   from  a
    foreign source  must notify
    U.S.    EPA    (40   CFR
    264.12(a)(l)            and
    265.12(a)(l)).
Verify that the facility notifies the appropriate U.S. EPA Regional Administrator
in writing at least four weeks prior to the date the waste is expected to arrive at the
facility.

(NOTE: Notice of subsequent shipments of the same waste from the same foreign
source is not required.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                     113

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY:
                                  HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                        REVIEWER CHECKS
    EXPORT/IMPORT OF
    HAZARDOUS WASTE

    HW.460

    Imports of Hazardous
    Waste (Except from the
    OECD Member Countries)
    for Recovery
    HW.460.1.  Any person who
    imports hazardous waste must
    comply with general manifest
    requirements   with  certain
    modifications    (40    CFR
    262.60).
Verify that the manifest copies comply with the general manifest requirements of
40 CFR 262.20.

Determine if the following modifications  are made  by reviewing the  manifest
copies:

   -the name  and address of the foreign generator and the importer's name,
     address and EPA identification number are put in place of the generator's
     name, address and EPA identification number
   -the U.S. importer (or his agent) must sign and date the certification statement
     in place of the generator's signature and obtain the signature of the initial
     transporter.
    HW.460.2.   A  facility  that
    has   arranged   to   receive
    hazardous  waste   from  a
    foreign  source   must  notify
    U.S.    EPA    (40    CFR
    264.12(a)(l)            and
    265.12(a)(l)).
Verify that the facility notifies the appropriate U.S. EPA Regional Administrator
in writing at least four weeks prior to the date the waste is expected to arrive at the
facility.

(NOTE: Notice of subsequent shipments of the same waste from the same foreign
source is not required.)
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    115

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                       COMPLIANCE CATEGORY:
                                  HAZARDOUS WASTE MANAGEMENT
          REGULATORY
       REQUIREMENT OR
         MANAGEMENT
            PRACTICE
                        REVIEWER CHECKS
     WASTE MINIMIZATION/
     POLLUTION
     PREVENTION

     HW.500
     HW.500.1.  The  generator
     should have in place a waste
     minimization  program   to
     reduce   the  volume   and
     toxicity of hazardous wastes
     generated.   The generator is
     required    to   sign   the
     Generator's    Certification
     statement on each manifest,
     attesting   to    its   waste
     minimization program (MP).
Determine if the generator's waste minimization program  includes practical
methods for  reducing the  volume of hazardous wastes generated.   Determine
whether any or  all of the following methods  suggested by  U.S.  EPA  are
incorporated into the program:

   — the generator retains  information  that  documents waste minimization
     activities.
   — the program includes:
        —provisions for top management assurance that waste minimization is a
         company-wide effort
        — characterization of waste generation and waste management costs
        —periodic waste minimization assessments
        - a cost allocation system
        - encourages technology transfer
        —program implementation and evaluation
        — waste minimization employee awareness plans
        - adequate funding
        -clearly delineated roles both within the company  and among  each
         facility generating waste.
   -conclude if facility actions are resulting in the reduction of hazardous
     wastes.

(NOTE: Refer to Interim Final Guidance to Hazardous Waste Generators on the
Elements of a Waste Minimization Program, 58 FR 31114, May 28, 1993.)
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                    117

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
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This document is intended solely for guidance. No statutory or regulatory                                       118
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous
                  Waste Generators under RCRA

                          Appendix A:
  Hazardous Waste from Nonspecific Sources and from Specific Sources
                    (40 CFR 261.31 and 261.32)

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                       Hazardous Waste from Nonspecific Sources and from Specific Sources
        Industry and
            EPA
         hazardous
         waste No.
                                 Table 1
               Hazardous Waste From Nonspecific Sources
                            (40 CFR 261,31)
Hazard
Code
                                                         Generic
       F001
The following spent halogenated solvents used in degreasing:
Tetrachloroethylene, trichloroethylene,  methylene chloride, 1,1,1 -
trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent
solvent mixtures/blends used in degreasing containing, before use, a total often
percent or more (by volume) of one or more of the above halogenated solvents
or those solvents listed in F002, F004, and F005; and still bottoms from the
recovery of these spent solvents and spent solvent mixtures.
  (T)
       F002
The following spent halogenated solvents: Tetrachloroethylene, methylene
chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-
trichloro-l,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane,
and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before
use, a total of ten percent or more (by volume) of one or more of the above
halogenated solvents or those listed in F001, F004, or F005; and still bottoms
from the recovery of these spent solvents and spent solvent mixtures.
  (T)
       F003
The following spent non- halogenated solvents: Xylene, acetone, ethyl acetate,
ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol,
cyclohexanone, and methanol; all spent solvent mixtures/blends containing,
before use, only the above spent non- halogenated solvents; and all spent solvent
mixtures/blends containing, before use, one or more of the above non-
halogenated solvents, and, a total of ten percent or more (by volume) of one or
more of those solvents listed in F001, F002, F004, and F005; and still bottoms
from the recovery of these spent solvents and spent solvent mixtures.
  (I)*
       F004
The following spent non-halogenated solvents: Cresols and cresylic acid, and
nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of
ten percent or more (by volume) of one or more of the above non-halogenated
solvents or those solvents listed in F001, F002, and F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
  (T)
       F005
The following spent non-halogenated solvents: Toluene, methyl ethyl ketone,
carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-
nitropropane; all spent solvent mixtures^lends containing, before use, a total of
ten percent or more (by volume) of one or more of the above non-halogenated
solvents or those solvents listed in F001, F002, or F004; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
       F006
Wastewater treatment sludges from electroplating operations except from the
following processes: (1) Sulfuric acid anodizing of aluminum; (2) tin plating on
carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with
tin, zinc and aluminum plating on carbon steel; and (6) chemical etching and
milling of aluminum.
  (T)
       F007
Spent cyanide plating bath solutions from electroplating operations.
 (R,T)
                                                                                                              Al

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
        Industry and
            EPA
         hazardous
         waste No.
       F008
       F009
       F010
       F011
       F012
       F019
       F020
       F021
       F022
       F023
       F024
                                 Table 1
               Hazardous Waste From Nonspecific Sources
                            (40 CFR 261.31)
Plating bath residues from the bottom of plating baths from electroplating
operations where cyanides are used in the process.
Spent stripping and cleaning bath solutions from electroplating operations where
cyanides are used in the process.
Quenching bath residues from oil baths from metal heat treating operations
where cyanides are used in the process.
Spent cyanide solutions from salt bath pot cleaning from metal heat treating
operations.
Quenching wastewater treatment sludges from metal heat treating operations
where cyanides are used in the process.
Wastewater treatment sludges from the chemical conversion coating of
aluminum except from zirconium phosphating in aluminum can washing when
such phosphating is an exclusive conversion coating process.
Wastes (except wastewater and spent carbon from hydrogen chloride
purification) from the production or manufacturing use (as a reactant, chemical
intermediate, or component in a formulating process) of tri- or
tetrachlorophenol, or of intermediates used to produce their pesticide
derivatives. (This listing does not include wastes from the production of
Hexachlorophene from highly purified 2,4,5-trichlorophenol.).
Wastes (except wastewater and spent carbon from hydrogen chloride
purification) from the production or manufacturing use (as a reactant, chemical
intermediate, or component in a formulating process) of pentachlorophenol, or
of intermediates used to produce its derivatives.
Wastes (except wastewater and spent carbon from hydrogen chloride
purification) from the manufacturing use (as a reactant, chemical intermediate,
or component in a formulating process) of terra-, penta-, or hexachlorobenzenes
under alkaline conditions.
Wastes (except wastewater and spent carbon from hydrogen chloride
purification) from the production of materials on equipment previously used for
the production or manufacturing use (as a reactant, chemical intermediate, or
component in a formulating process) of tri- and tetrachlorophenols. (This listing
does not include wastes from equipment used only for the production or use of
Hexachlorophene from highly purified 2,4,5- trichlorophenol.).
Process wastes, including but not limited to, distillation residues, heavy ends,
tars, and reactor clean-out wastes, from the production of certain chlorinated
aliphatic hydrocarbons by free radical catalyzed processes. These chlorinated
aliphatic hydrocarbons are those having carbon chain lengths ranging from one
to and including five, with varying amounts and positions of chlorine
substitution. (This listing does not include wastewaters, wastewater treatment
sludges, spent catalysts, and wastes listed in Sec.  261.31 or Sec.  261.32.).
Hazard
Code
 (R,T)
 (R,T)
 (R,T)
 (R,T)
  (T)
  (T)
  (H)
  (H)
  (H)
  (H)
  (T)
                                                                                                              A2

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
        Industry and
            EPA
         hazardous
         waste No.
       F025
       F026
       F027
       F028
       F032
       F034
       F035
                                 Table 1
               Hazardous Waste From Nonspecific Sources
                            (40 CFR 261.31)
Condensed light ends, spent filters and filter aids, and spent desiccant wastes
from the production of certain chlorinated aliphatic hydrocarbons, by free
radical catalyzed processes. These chlorinated aliphatic hydrocarbons are those
having carbon chain lengths ranging from one to and including five, with
varying amounts and positions of chlorine substitution.
Wastes (except wastewater and spent carbon from hydrogen chloride
purification) from the production of materials on equipment previously used for
the manufacturing use (as a reactant, chemical intermediate, or component in a
formulating process) of tetra-, penta-, or hexachlorobenzene under alkaline
conditions.
Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or
discarded unused formulations containing compounds derived from these
chlorophenols. (This listing does not include formulations containing
Hexachlorophene sythesized from prepurified 2,4,5- trichlorophenol as the sole
component.).
Residues resulting from the incineration or thermal treatment of soil
contaminated with EPA Hazardous Waste Nos. F020, F021, F022, F023, F026,
andF027.
Wastewaters (except those that have not come into contact with process
contaminants), process residuals, preservative drippage, and spent formulations
from wood preserving processes generated at plants that currently use or have
previously used chlorophenolic formulations (except potentially cross-
contaminated wastes that have had the F032 waste code deleted in accordance
with 40 CFR 261.35 or potentially cross-contaminated wastes that are otherwise
currently regulated as hazardous wastes (i.e., F034 or F035), and  where the
generator does not resume or initiate use of chlorophenolic formulations). This
listing does not include K001 bottom sediment sludge from the treatment of
wastewater from wood preserving processes that use creosote and/or
pentachlorophenol.
Wastewaters (except those that have not come into contact with process
contaminants), process residuals, preservative drippage, and spent formulations
from wood preserving processes generated at plants that use creosote
formulations. This listing does not include K001 bottom sediment sludge from
the treatment of wastewater from wood preserving processes that use creosote
and/or pentachlorophenol.
Wastewaters (except those that have not come into contact with process
contaminants), process residuals, preservative drippage, and spent formulations
from wood preserving processes generated at plants that use inorganic
preservatives containing arsenic or chromium. This listing does not include
K001 bottom sediment sludge from the treatment of wastewater from wood
preserving processes that use creosote and/or pentachlorophenol.
Hazard
Code
  (T)
  (H)
  (H)
  (T)
  (T)
  (T)
  (T)
                                                                                                              A3

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
        Industry and
            EPA
         hazardous
         waste No.
       F037
       F038
       F039
                                 Table 1
               Hazardous Waste From Nonspecific Sources
                            (40 CFR 261.31)
Petroleum refinery primary oil/water/solids separation sludge-Any sludge
generated from the gravitational separation of oil/water/ solids during the
storage or treatment of process wastewaters and oil cooling wastewaters from
petroleum refineries. Such sludges include, but are not limited to, those
generated in oil/water/ solids separators; tanks and impoundments; ditches and
other conveyances; sumps; and stormwater units receiving dry weather flow.
Sludge generated in stormwater units that do not receive dry weather flow,
sludges generated from non-contact once-through cooling waters segregated for
treatment from other process or oily cooling waters, sludges generated in
aggressive biological treatment units as defined in Sec. 261.3 l(b)(2) (including
sludges generated in one or more additional units after wastewaters have been
treated in aggressive biological treatment units) and K051 wastes are not
included in this listing. This listing does include residuals generated from
processing or recycling oil-bearing hazardous secondary materials excluded
under Sec. 261.4(a)(12)(i), if those residuals are to be disposed of.
Petroleum refinery secondary (emulsified) oil/water/solids separation sludge--
Any sludge and/or float generated from the physical and/or chemical separation
of oil/water/ solids in process wastewaters and oily cooling wastewaters from
petroleum refineries. Such wastes include, but are not limited to, all sludges and
floats generated in: induced air flotation (IAF) units, tanks and impoundments,
and all sludges generated in DAF units. Sludges generated in stormwater units
that do not receive dry weather flow, sludges generated from non-contact once-
through cooling waters segregated for treatment from other process or oily
cooling waters, sludges and floats generated in aggressive biological treatment
units as defined in Sec. 261.3 l(b)(2) (including sludges and floats generated in
one or more additional units after wastewaters have been treated in aggressive
biological treatment units) and F037, K048, and K051 wastes are not included
in this listing.	
Leachate (liquids that have percolated through land disposed wastes) resulting
from the disposal of more than one restricted waste classified as hazardous
under subpart D of this part. (Leachate resulting from the disposal of one or
more of the following EPA Hazardous Wastes and no other Hazardous Wastes
retains its EPA Hazardous Waste Number(s):  F020, F021, F022, F026, F027,
and/or F028.).
Hazard
Code
  (T)
  (T)
  (T)
                                                                                                               A4

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.

K001

K002
K003
K004
K005
K006
K007
K008

K009
K010
K011
K013
K014
K015
K016
K017
K018
K019
K020
K021
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261.32, Revised January 2001)
Wood Preservation
Bottom sediment sludge from the treatment of wastewaters from wood
preserving processes that use creosote and/or pentachlorophenol.
Inorganic Pigments
Wastewater treatment sludge from the production of chrome yellow and orange
pigments.
Wastewater treatment sludge from the production of molybdate orange
pigments.
Wastewater treatment sludge from the production of zinc yellow pigments.
Wastewater treatment sludge from the production of chrome green pigments.
Wastewater treatment sludge from the production of chrome oxide green
pigments(anhydrous and hydrated).
Wastewater treatment sludge from the production of iron blue pigments.
Oven residue from the production of chrome oxide green pigments.
Organic Chemicals
Distillation bottoms from the production of acetaldehyde from ethylene.
Distillation side cuts from the production of acetaldehyde from ethylene.
Bottom stream from the wastewater stripper in the production of acrylonitrile.
Bottom stream from the acetonitrile column in the production of acrylonitrile.
Bottoms from the acetonitrile purification column in the production of
acrylonitrile.
Still bottoms from the distillation of benzyl chloride.
Heavy ends or distillation residues from the production of carbon tetrachloride.
Heavy ends (still bottoms) from the purification column in the production of
epichlorohydrin.
Heavy ends from the fractionation column in ethyl chloride production.
Heavy ends from the distillation of ethylene dichloride in ethylene dichloride
production.
Heavy ends from the distillation of vinyl chloride in vinyl chloride monomer
production.
Aqueous spent antimony catalyst waste from fluoromethanes production.
Hazard
Code

(T)

(T)
(T)
(T)
(T)
(T)
(T)
(T)

(T)
(T)
(R,T)
(R,T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
                                                                                                 A5

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.
K022
K023
K024
K025
K026
K027
K028
K029
K030
K083
K085
K093
K094
K095
K096
K103
K104
K105
K107
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261,32, Revised January 2001)
Distillation bottom tars from the production of phenol/acetone from cumene.
Distillation light ends from the production of phthalic anhydride from
naphthalene.
Distillation bottoms from the production of phthalic anhydride from
naphthalene.
Distillation bottoms from the production of nitrobenzene by the nitration of
benzene.
Stripping still tails from the production of methy ethyl pyridines.
Centrifuge and distillation residues from toluene diisocyanate production.
Spent catalyst from the hydrochlorinator reactor in the production of 1 , 1 , 1 -
trichloroethane.
Waste from the product steam stripper in the production of 1 , 1 , 1 -
trichloroethane.
Column bottoms or heavy ends from the combined production of
trichloroethylene and perchloroethylene.
Distillation bottoms from aniline production.
Distillation or fractionation column bottoms from the production of
chlorobenzenes.
Distillation light ends from the production of phthalic anhydride from ortho-
xylene.
Distillation bottoms from the production of phthalic anhydride from ortho-
xylene.
Distillation bottoms from the production of 1 , 1 , 1 -trichloroethane .
Heavy ends from the heavy ends column from the production of 1 , 1 , 1 -
trichloroethane.
Process residues from aniline extraction from the production of aniline.
Combined wastewater streams generated from nitrobenzene/aniline production.
Separated aqueous stream from the reactor product washing step in the
production of chlorobenzenes.
Column bottoms from product separation from the production of 1, 1- dimethyl-
hydrazine (UDMH) from carboxylic acid hydrazines.
Hazard
Code
(T)
(T)
(T)
(T)
(T)
(R,T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(C,T)
                                                                                                 A6

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.
K108
K109
K110
Kill
K112
K113
K114
K115
K116
K117
K118
K136
K149
K150
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261,32, Revised January 2001)
Condensed column overheads from product separation and condensed reactor
vent gases from the production of 1,1-dimethylhydrazine (UDMH) from
carboxylic acid hydrazides.
Spent filter cartridges from product purification from the production of 1,1-
dimethylhydrazine (UDMH) from carboxylic acid hydrazides.
Condensed column overheads from intermediate separation from the production
of 1,1-dimethylhydrazine (UDMH) from carboxylic acid hydrazides.
Product washwaters from the production of dinitrotoluene via nitration of
toluene.
Reaction by-product water from the drying column in the production of
toluenediamine via hydrogenation of dinitrotoluene.
Condensed liquid light ends from the purification of toluenediamine in the
production of toluenediamine via hydrogenation of dinitrotoluene.
Vicinals from the purification of toluenediamine in the production of
toluenediamine via hydrogenation of dinitrotoluene.
Heavy ends from the purification of toluenediamine in the production of
toluenediamine via hydrogenation of dinitrotoluene.
Organic condensate from the solvent recovery column in the production of
toluene diisocyanate via phosgenation of toluenediamine.
Wastewater from the reactor vent gas scrubber in the production of ethylene
dibromide via bromination of ethene.
Spent adsorbent solids from purification of ethylene dibromide in the production
of ethylene dibromide via bromination of ethene.
Still bottoms from the purification of ethylene dibromide in the production of
ethylene dibromide via bromination of ethene.
Distillation bottoms from the production of alpha-(or methyl-) chlorinated
toluenes, ring-chlorinated toluenes, benzoyl chlorides, and compounds with
mixtures of these functional groups, (This waste does not include still bottoms
from the distillation of benzyl chloride.).
Organic residuals, excluding spent carbon adsorbent, from the spent chlorine gas
and hydrochloric acid recovery processes associated with the production of
alpha-(or methyl-) chlorinated toluenes, ring- chlorinated toluenes, benzoyl
chlorides, and compounds with mixtures of these functional groups.
Hazard
Code
(I,T)
(T)
(T)
(C,T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
                                                                                                 A7

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
        Industry and
            EPA
         hazardous
         waste No.
       K151
       K156
       K157
       K158
       K159
       K161
       K174
       K175
                                 Table 2
                 Hazardous Waste From Specific Sources
                 (40 CFR 261,32, Revised January 2001)
Wastewater treatment sludges, excluding neutralization and biological sludges,
generated during the treatment of wastewaters from the production of alpha- (or
methyl-) chlorinated toluenes, ring-chlorinated toluenes, benzoyl chlorides, and
compounds with mixtures of these functional groups.
Organic waste (including heavy ends, still bottoms, light ends, spent solvents,
filtrates, and decantates) from the production of carbamates and carbamoyl
oximes (This listing does not apply to wastes generated from the manufacture of
3-iodo-2-propynyln-butylcarbamate.).
Wastewaters (including scrubber waters, condenser waters, washwaters, and
separation waters) from the production of carbamates and carbamoyl oximes.
(This listing does not apply to wastes generated from the manufacture of 3-iodo-
2-propynyl n-butylcarbamate.).
Bag house dusts and filter/separation solids from the production of carbamates
and carbamoyl oximes. (This listing does not apply to wastes generated from the
manufacture of 3-iodo-2-propynyl n-butylcarbamate.).
Organics from the treatment of thiocarbamate wastes.
Purification solids (including filtration, evaporation, and centrifugation solids),
bag house dust and floor sweepings from the production of dithiocarbamate
acids and their salts. (This listing does not include K125 or K126.).
Wastewater treatment sludges from the production of ethylene dichloride or
vinyl chloride monomer (including sludges that result from commingled
ethylene dichloride or vinyl chloride monomer wastewater and other
wastewater), unless the sludges meet the following conditions: (i) they are
disposed of in a subtitle C or non- hazardous landfill licensed or permitted by
the state or federal government; (ii) they are not otherwise placed on the land
prior to final disposal; and  (iii) the generator maintains documentation
demonstrating that the waste was either disposed of in an on-site landfill or
consigned to a transporter or disposal facility that provided a written
commitment to dispose of the waste in an off-site landfill. Respondents in any
action brought to enforce the requirements of subtitle C must, upon a showing
by the government that the  respondent managed wastewater treatment sludges
from the production of vinyl chloride monomer or ethylene dichloride,
demonstrate that they meet the terms of the exclusion set forth above. In doing
so, they must provide appropriate documentation (e.g., contracts between the
generator and the landfill owner/operator, invoices documenting delivery of
waste to landfill, etc.) that the terms of the exclusion were met.
Wastewater treatment sludges from the production of vinyl chloride monomer
using mercuric chloride catalyst in an acetylene-based process.
Hazard
 Code
  (T)
  (T)
  (T)
  (T)
  (T)
 (R,T)
  (T)
  (T)
                                                                                                              A8

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.

K071
K073
K106

K031
K032
K033
K034
K035
K036
K037
K038
K039
K040
K041
K042
K043
K097
K098
K099
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261,32, Revised January 2001)
Inorganic Chemicals
Brine purification muds from the mercury cell process in chlorine production,
where separately prepurified brine is not used.
Chlorinated hydrocarbon waste from the purification step of the diaphragm cell
process using graphite anodes in chlorine production.
Wastewater treatment sludge from the mercury cell process in chlorine
production.
Pesticides
By-product salts generated in the production of MSMA and cacodylic acid.
Wastewater treatment sludge from the production of chlordane.
Wastewater and scrub water from the chlorination of cyclopentadiene in the
production of chlordane.
Filter solids from the filtration of hexachlorocyclopentadiene in the production
of chlordane.
Wastewater treatment sludges generated in the production of creosote.
Still bottoms from toluene reclamation distillation in the production of
disulfoton.
Wastewater treatment sludges from the production of disulfoton.
Wastewater from the washing and stripping of phorate production.
Filter cake from the filtration of diethylphosphorodithioic acid in the production
of phorate.
Wastewater treatment sludge from the production of phorate.
Wastewater treatment sludge from the production of toxaphene.
Heavy ends or distillation residues from the distillation of tetrachlorobenzene in
the production of 2,4,5- T.
2,6-Dichlorophenol waste from the production of 2,4-D.
Vacuum stripper discharge from the chlordane chlorinator in the production of
chlordane.
Untreated process wastewater from the production of toxaphene.
Untreated wastewater from the production of 2,4-D.
Hazard
Code

(T)
(T)
(T)

(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
                                                                                                 A9

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.
K123
K124
K125
K126
K131
K132

K044
K045
K046
K047

K048
K049
K050
K051
K052
K169
K170
K171
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261,32, Revised January 2001)
Process wastewater (including supernates, filtrates, and washwaters) from the
production of ethylenebisdithiocarbamic acid and its salt.
Reactor vent scrubber water from the production of ethylenebisdithiocarbamic
acid and its salts.
Filtration, evaporation, and centrifugation solids from the production of
ethylenebisdithiocarbamic acid and its salts.
Baghouse dust and floor sweepings in milling and packaging operations from
the production or formulation of ethylenebisdithiocarbamic acid and its salts.
Wastewater from the reactor and spent sulfuric acid from the acid dryer from the
production of methyl bromide.
Spent absorbent and wastewater separator solids from the production of methyl
bromide.
Explosives
Wastewater treatment sludges from the manufacturing and processing of
explosives.
Spent carbon from the treatment of wastewater containing explosives.
Wastewater treatment sludges from the manufacturing, formulation and loading
of lead-based initiating compounds.
Pink/red water from TNT operations.
Petroleum Refining
Dissolved air flotation (DAF) float from the petroleum refining industry.
Slop oil emulsion solids from the petroleum refining industry.
Heat exchanger bundle cleaning sludge from the petroleum refining industry.
API separator sludge from the petroleum refining industry.
Tank bottoms (leaded) from the petroleum refining industry.
Crude oil storage tank sediment from petroleum refining operations.
Clarified slurry oil tank sediment and/or in-line filter/separation solids from
petroleum refining operations.
Spent Hydrotreating catalyst from petroleum refining operations, including
guard beds used to desulfurize feeds to other catalytic reactors (this listing does
not include inert support media).
Hazard
Code
(T)
(C,T)
(T)
(T)
(C,T)
(T)

(R)
(R)
(T)
(R)

(T)
(T)
(T)
(T)
(T)
(T)
(T)
(I,T)
                                                                                                A10

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.
K172

K061
K062




K088


K069
K100

K084
K101
K102
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261,32, Revised January 2001)
Spent Hydrorefining catalyst from petroleum refining operations, including
guard beds used to desulfurize feeds to other catalytic reactors (this listing does
not include inert support media).
Iron and Steel
Emission control dust/ sludge from the primary production of steel in electric
furnaces.
Spent pickle liquor generated by steel finishing operations of facilities within the
iron and steel industry (SIC Codes 331 and 332).
Primary Copper
(No Entries)
Primary Lead
(No Entries)
Primary Zinc
(No Entries)
Primary Aluminum
(No Entries)
Spent pot liners from primary aluminum reduction.
Ferroalloys
(No Entries)
Secondary lead
Emission control dust/ sludge from secondary lead smelting. (Note: This listing
is stayed administratively for sludge generated from secondary acid scrubber
systems. The stay will remain in effect until further administrative action is
taken. If EPA takes further action effecting this stay, EPA will publish a notice
of the action in the Federal Register.
Waste leaching solution from acid leaching of emission control dust/ sludge
from secondary lead smelting.
Veterinary _Pharmaceuticals
Wastewater treatment sludges generated during the production of veterinary
Pharmaceuticals from arsenic or organo -arsenic compounds.
Distillation tar residues from the distillation of aniline-based compounds in the
production of veterinary Pharmaceuticals from arsenic or organo-arsenic
compounds.
Residue from the use of activated carbon for decolorization in the production of
veterinary Pharmaceuticals from arsenic or organo-arsenic compounds.
Hazard
Code
(I,T)

(T)
(C,T)




(T)


(T)
(T)

(T)
(T)
(T)
                                                                                                All

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Industry and
EPA
hazardous
waste No.

K086

K060
K087
K141
K142
K143
K144
K145
K147
K148
Table 2
Hazardous Waste From Specific Sources
(40 CFR 261,32, Revised January 2001)
Ink Formulation
Solvent washes and sludges, caustic washes and sludges, or water washes and
sludges from cleaning tubs and equipment used in the formulation of ink from
pigments, driers, soaps, and stabilizers containing chromium and lead.
Coking
Ammonia still lime sludge from coking operations.
Decanter tank tar sludge from coking operations.
Process residues from the recovery of coal tar, including, but not limited to,
collecting sump residues from the production of coke from coal or the recovery
of coke by-products produced from coal. This listing does not include K087
(decanter tank tar sludges from coking operations).
Tar storage tank residues from the production of coke from coal or from the
recovery of coke by- products produced from coal.
Process residues from the recovery of light oil, including, but not limited to,
those generated in stills, decanters, and wash oil recovery units from the
recovery of coke by-products produced from coal.
Wastewater sump residues from light oil refining, including, but not limited to,
intercepting or contamination sump sludges from the recovery of coke by-
products produced from coal.
Residues from naphthalene collection and recovery operations from the recovery
of coke by-products produced from coal.
Tar storage tank residues from coal tar refining.
Residues from coal tar distillation, including but not limited to, still bottoms.
Hazard
Code

(T)

(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
                                                                                                A12

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Protocol for Conducting Environmental Compliance Audits of Hazardous
                  Waste Generators under RCRA

                          Appendix B:
      Commercial Chemical Products or Manufacturing Chemical
              Intermediates Identified as Toxic Wastes
                        (40 CFR 261.33(f))

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This Page Intentionally Left Blank

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                           Commercial Chemical Products or Manufacturing Chemical
                                    Intermediates Identified as Toxic Wastes
                                               (40 CFR 261.33(f))

[Comment: For the convenience of the regulated community, the primary hazardous properties of these materials have been
indicated by the letters T (Toxicity), R (Reactivity), I (Ignitability) and C (Corrosivity). Absence of a letter indicates that the
compound is only listed for toxicity.]
Hazardous
Waste No.
U394
U001
U034
U187
U005
U240
U112
U144
U214
see F027
U002
U003
U004
U005
U006
U007
U008
U009
U011
U012
U136
U014
U015
U010
U280
U278
U364
U271
U157
U016
U017
U192
U018
U094
U012
U014
U049
U093
U328
U353
Chemical Abstracts
Number
30558-43-1
75-07-0
75-87-6
62-44-2
53-96-3
1 94-75-7
141-78-6
301-04-2
563-68-8
93-76-5
67-64-1
75-05-8
98-86-2
53-96-3
75-36-5
79-06-1
79-10-7
107-13-1
61-82-5
62-53-3
75-60-5
492-80-8
115-02-6
50-07-7
101-27-9
22781-23-3
22961-82-6
17804-35-2
56-49-5
225-51-4
98-87-3
23950-58-5
56-55-3
57-97-6
62-53-3
492-80-8
3165-93-3
60-11-7
95-53-4
106-49-0
Substance
A2213.
Acetaldehyde (I)
Acetaldehyde, trichloro-
Acetamide, N-(4-ethoxyphenyl)-
Acetamide, N-9H-fluoren-2-yl-
Acetic acid, (2,4-dichlorophenoxy)-, salts & esters
Acetic acid ethyl ester (I)
Acetic acid, lead(2+) salt
Acetic acid, thallium(l+) salt
Acetic acid, (2,4,5-trichlorophenoxy)-
Acetone (I)
Acetonitrile (I,T)
Acetophenone
2-Acetylaminofluorene
Acetyl chloride (C,R,T)
Acrylamide
Acrylic acid (I)
Acrylonitrile
Amitrole
Aniline (I,T)
Arsinic acid, dimethyl-
Auramine
Azaserine
Azirino[2,33,4]pyrrolo[l,2-a]indole-4,7-dione, 6-amino-8-
[[(aminocarbonyl)oxy] methyl]- l,la,2,8,8a,8b-hexahydro-8a-methoxy-5-methyl-
, [laS-(laalpha, 8beta,8aalpha,8balpha)]-
Barban
Bendiocarb
Bendiocarb phenol
Benomyl
Benz[j]aceanthrylene, l,2-dihydro-3-methyl-
Benz[c]acridine
Benzal chloride
Benzamide, 3,5-dichloro-N-(l,l- dimethyl-2-propynyl)-
Benz[a]anthracene
Benz[a]anthracene, 7,12-dimethyl-
Benzenamine (I,T)
Benzenamine, 4,4-carbonimidoylbis[N,N-dimethyl-
Benzenamine, 4-chloro-2 -methyl-, hydrochloride
Benzenamine, N,N-dimethyl-4-(phenylazo)-
Benzenamine, 2-methyl-
Benzenamine, 4-methyl-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
Bl

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U158
U222
U181
U019
U038
U030
U035
U037
U221
U028
U069
U088
U102
U107
U070
U071
U072
U060
U017
U223
U239
U201
U127
U056
U220
U105
U106
U055
U169
U183
U185
U020
U020
U207
U061
U247
U023
U234
U021
U202
U278
U364
U203
U141
U367
U090
U064
U248
U022
Chemical Abstracts
Number
101-14-4
636-21-5
99-55-8
71-43-2
510-15-6
101-55-3
305-03-3
108-90-7
25376-45-8
117-81-7
84-74-2
84-66-2
131-11-3
117-84-0
95-50-1
541-73-1
106-46-7
72-54-8
98-87-3
26471-62-5
1330-20-7
108-46-3
118-74-1
110-82-7
108-88-3
121-14-2
606-20-2
98-82-8
98-95-3
608-93-5
82-68-8
98-09-9
98-09-9
95-94-3
50-29-3
72-43-5
98-07-7
99-35-4
92-87-5
1 81-07-2
22781-23-3
22961-82-6
94-59-7
120-58-1
1563-38-8
94-58-6
189-55-9
'81-81-2
50-32-8
Substance
Benzenamine, 4,4-methylenebis[2-chloro-
Benzenamine, 2-methyl-, hydrochloride
Benzenamine, 2-methyl-5-nitro-
Benzene (I,T)
Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-alpha-hydroxy-, ethyl ester
Benzene, l-bromo-4-phenoxy-
Benzenebutanoic acid, 4-[bis(2-chloroethyl)amino]-
Benzene, chloro-
Benzenediamine, ar-methyl-
1,2-Benzenedicarboxylic acid, bis(2-ethylhexyl) ester
1,2-Benzenedicarboxylic acid, dibutyl ester
1,2-Benzenedicarboxylic acid, diethyl ester
1,2-Benzenedicarboxylic acid, dimethyl ester
1,2-Benzenedicarboxylic acid, dioctyl ester
Benzene, 1,2-dichloro-
Benzene, 1,3-dichloro-
Benzene, 1,4-dichloro-
Benzene, 1, l-(2,2-dichloroethylidene)bis[4-chloro-
Benzene, (dichloromethyl)-
Benzene, 1,3-diisocyanatomethyl- (R,T)
Benzene, dimethyl- (I,T)
1,3-Benzenediol
Benzene, hexachloro-
Benzene, hexahydro- (I)
Benzene, methyl-
Benzene, l-methyl-2,4-dinitro-
Benzene, 2-methyl-l,3-dinitro-
Benzene, (1-methylethyl)- (I)
Benzene, nitro-
Benzene, pentachloro-
Benzene, pentachloronitro-
Benzenesulfonic acid chloride (C,R)
Benzenesulfonyl chloride (C,R)
Benzene, 1,2,4,5-tetrachloro-
Benzene, l,l-(2,2,2-trichloroethylidene)bis[4-chloro-
Benzene, l,l-(2,2,2-trichloroethylidene)bis[4- methoxy-
Benzene, (trichloromethyl)-
Benzene, 1,3,5-trinitro-
Benzidine
l,2-Benzisothiazol-3(2H)-one, 1,1-dioxide, & salts
l,3-Benzodioxol-4-ol, 2,2-dimethyl-, methyl carbamate.
l,3-Benzodioxol-4-ol, 2,2-dimethyl-
1,3-Benzodioxole, 5-(2-propenyl)-
1,3-Benzodioxole, 5-(l-propenyl)-
7-Benzofuranol, 2,3 -dihydro-2,2-dimethyl-
1,3-Benzodioxole, 5-propyl-
Benzo [rst]pentaphene
2H-l-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-l-phenyl-butyl)-, & salts, when
present at concentrations of 0.3% or less
Benzo[a]pyrene
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B2

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U197
U023
U085
U021
U073
U091
U095
U225
U030
U128
U172
U031
U159
U160
U053
U074
U143
U031
U136
U032
U372
U271
U280
U238
U178
U373
U409
U097
U389
U387
U114
U062
U279
U372
U367
U215
U033
U156
U033
U211
U034
U035
U036
U026
U037
U038
U039
Chemical Abstracts
Number
106-51-4
98-07-7
1464-53-5
92-87-5
91-94-1
119-90-4
119-93-7
75-25-2
101-55-3
87-68-3
924-16-3
71-36-3
78-93-3
1338-23-4
4170-30-3
764-41-0
303-34-4
71-36-3
75-60-5
13765-19-0
10605-21-7
17804-35-2
101-27-9
51-79-6
615-53-2
122-42-9
23564-05-8
79-44-7
2303-17-5
52888-80-9
1 111-54-6
2303-16-4
63-25-2
10605-21-7
1563-38-8
6533-73-9
353-50-4
79-22-1
353-50-4
56-23-5
75-87-6
305-03-3
57-74-9
494-03-1
108-90-7
510-15-6
59-50-7
Substance
p-Benzoquinone
Benzotrichloride (C,R,T)
2,2-Bioxirane
[1,1 -Biphenyl] -4,4-diamine
[1, r-Biphenyl]-4,4'-diamine, 3,3'-dichloro-
[1,1 '-Biphenyl] -4,4'-diamine, 3 ,3 '-dimethoxy-
[1,1 '-Biphenyl] -4,4'-diamine, 3 ,3 '-dimethyl-
Bromoform
4-Bromophenyl phenyl ether
1,3 -Butadiene, 1,1,2,3,4,4-hexachloro-
1-Butanamine, N-butyl-N-nitroso-
1-Butanol (I)
2-Butanone (I,T)
2-Butanone, peroxide (R,T)
2-Butenal
2-Butene, 1,4-dichloro- (I,T)
2-Butenoic acid, 2-methyl-,7-[[2,3 -dihydroxy-2-( 1 -methoxyethyl)-3 -methyl- 1 -
oxobutoxy]methyl]-2,3,5,7a- pyrrolizin-1-tetrahydro-lH-yl ester, [1S-
[lalpha(Z),7(2S*,3R*),7aalpha]]-
n-Butyl alcohol (I)
Cacodylic acid
Calcium chromate
Carbamic acid, lH-benzimidazol-2-yl, methyl ester.
Carbamic acid, [l-[(butylamino)carbonyl]-lH-benzimidazol-2-yl]-, methyl
ester
Carbamic acid, (3-chlorophenyl)-, 4-chloro-2-butynyl ester.
Carbamic acid, ethyl ester
Carbamic acid, methylnitroso-, ethyl ester
Carbamic acid, phenyl-, 1-methylethyl ester
Carbamic acid, [1,2-phenylenebis (iminocarbonothioyl)]bis-, dimethyl ester
Carbamic chloride, dimethyl-
Carbamothioic acid, bis( 1-methylethyl)- , S-(2,3,3-trichloro-2-propenyl)
ester
Carbamothioic acid, dipropyl-, S(phenylmethyl) ester
Carbamodithioic acid, 1,2-ethanediylbis-, salts & esters
Carbamothioic acid, bis( 1-methylethyl)-, S-(2,3-dichloro-2-propenyl) ester
Carbaryl
Carbendazim
Carbofuran phenol
Carbonic acid, dithallium(l+) salt
Carbonic difluoride
Carbonochloridic acid, methyl ester(I,T)
Carbon oxyfluoride (R,T)
Carbon tetrachloride
Chloral
Chlorambucil
Chlordane, alpha & gamma isomers
Chlornaphazin
Chlorobenzene
Chlorobenzilate
p-Chloro-m-cresol
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B3

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U042
U044
U046
U047
U048
U049
U032
U050
U051
U052
U053
U055
U246
U197
U056
U129
U057
U130
U058
U240
U059
U060
U061
U062
U063
U064
U066
U069
U070
U071
U072
U073
U074
U075
U078
U079
U025
U027
U024
U081
U082
U084
U085
U108
U028
U395
U086
U087
U088
Chemical Abstracts
Number
110-75-8
67-66-3
107-30-2
91-58-7
95-57-8
3165-93-3
13765-19-0
218-01-9

1319-77-3
4170-30-3
98-82-8
506-68-3
106-51-4
110-82-7
58-89-9
108-94-1
77-47-4
50-18-0
1 94-75-7
20830-81-3
72-54-8
50-29-3
2303-16-4
53-70-3
189-55-9
96-12-8
84-74-2
95-50-1
541-73-1
106-46-7
91-94-1
764-41-0
75-71-8
75-35-4
156-60-5
111-44-4
108-60-1
111-91-1
120-83-2
87-65-0
542-75-6
1464-53-5
123-91-1
117-81-7
5952-26-1
1615-80-1
3288-58-2
84-66-2
Substance
2-Chloroethyl vinyl ether
Chloroform
Chloromethyl methyl ether
beta-Chloronaphthalene
o-Chlorophenol
4-Chloro-o-toluidine, hydrochloride
Chromic acid H2CrO4, calcium salt
Chrysene
Creosote
Cresol (Cresylic acid)
Crotonaldehyde
Cumene (I)
Cyanogen bromide (CN)Br
2,5-Cyclohexadiene- 1 ,4-dione
Cyclohexane (I)
Cyclohexane, 1,2,3,4,5,6-hexachloro-
,lalpha,2alpha,3beta,4alpha,5alpha,6(beta)-
Cyclohexanone (I)
1,3-Cyclopentadiene, 1,2,3,4,5,5-hexachloro-
Cyclophosphamide
2,4-D, salts & esters
Daunomycin
ODD
DDT
Diallate
Dibenz [a,h] anthracene
Dibenzo [a,i]pyrene
1 ,2-Dibromo-3 -chloropropane
Dibutyl phthalate
o-Dichlorobenzene
m-Dichlorobenzene
p-Dichlorobenzene
3 ,3 '-Dichlorobenzidine
l,4-Dichloro-2-butene (I,T)
Dichlorodifluoromethane
1 , 1 -Dichloroethylene
1 ,2-Dichloroethylene
Dichloroethyl ether
Dichloroisopropyl ether
Dichloromethoxy ethane
2,4-Dichlorophenol
2,6-Dichlorophenol
1 ,3 -Dichloropropene
l,2:3,4-Diepoxybutane (I,T)
1 ,4-Diethyleneoxide
Diethylhexyl phthalate
Diethylene glycol, dicarbamate
N,N'-Diethylhydrazine
O,O-Diethyl S-methyl dithiophosphate
Diethyl phthalate
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B4

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U089
U090
U091
U092
U093
U094
U095
U096
U097
U098
U099
U101
U102
U103
U105
U106
U107
U108
U109
U110
uni
U041
U001
U404
U174
U155
U067
U076
U077
U131
U024
U117
U025
U184
U208
U209
U218
U226
U227
U410
U394
U359
U173
U395
U004
U043
U042
U078
U079
Chemical Abstracts
Number
56-53-1
94-58-6
119-90-4
124-40-3
60-11-7
57-97-6
119-93-7
80-15-9
79-44-7
57-14-7
540-73-8
105-67-9
131-11-3
77-78-1
121-14-2
606-20-2
117-84-0
123-91-1
122-66-7
142-84-7
621-64-7
106-89-8
75-07-0
121-44-8
55-18-5
91-80-5
106-93-4
75-34-3
107-06-2
67-72-1
111-91-1
60-29-7
111-44-4
76-01-7
630-20-6
79-34-5
62-55-5
71-55-6
79-00-5
59669-26-0
30558-43-1
110-80-5
1116-54-7
5952-26-1
98-86-2
75-01-4
110-75-8
75-35-4
156-60-5
Substance
Diethylstilbesterol
Dihydrosafrole
3 ,3 '-Dimethoxybenzidine
Dimethylamine (I)
p-Dimethylaminoazobenzene
7, 12-Dimethylbenz[a]anthracene
3 ,3 '-Dimethylbenzidine
alpha,alpha-Dimethylbenzylhydroperoxide (R)
Dimethylcarbamoyl chloride
1 , 1 -Dimethylhydrazine
1 ,2-Dimethylhydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
1,4-Dioxane
1 ,2-Diphenylhydrazine
Dipropylamine (I)
Di-n-propylnitrosamine
Epichlorohydrin
Ethanal (I)
Ethanamine, N,N-diethyl-
Ethanamine, N-ethyl-N-nitroso-
1,2-Ethanediamine, N,N-dimethyl-N'-2-pyridinyl-N'-(2-thienylmethyl)-
Ethane, 1,2-dibromo-
Ethane, 1,1-dichloro-
Ethane, 1,2-dichloro-
Ethane, hexachloro-
Ethane, l,l'-[methylenebis(oxy)]bis[2-chloro-
Ethane, l,l'-oxybis-(I)
Ethane, l,l'-oxybis[2-chloro-
Ethane, pentachloro-
Ethane, 1,1,1,2-tetrachloro-
Ethane, 1,1,2,2-tetrachloro-
Ethanethioamide
Ethane, 1,1,1-trichloro-
Ethane, 1,1,2-trichloro-
Ethanimidothioic acid, N,N'-[thiobis [(methylimino) carbonyloxy]]bis-,
dimethyl ester
Ethanimidothioic acid, 2-(dimethylamino)-N-hydroxy-2-oxo-, methyl ester
Ethanol, 2-ethoxy-
Ethanol, 2,2'-(nitrosoimino)bis-
Ethanol, 2,2'-oxybis-, dicarbamate
Ethanone, 1-phenyl-
Ethene, chloro-
Ethene, (2-chloroethoxy)-
Ethene, 1,1-dichloro-
Ethene, 1,2-dichloro-, (E)-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B5

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U210
U228
U112
U113
U238
U117
U114
U067
U077
U359
U115
U116
U076
U118
U119
U120
U122
U123
U124
U125
U147
U213
U125
U124
U206
U206
U126
U163
U127
U128
U130
U131
U132
U243
U133
U086
U098
U099
U109
U134
U134
U135
U135
U096
U116
U137
U190
U140
U141
U142
Chemical Abstracts
Number
127-18-4
79-01-6
141-78-6
140-88-5
51-79-6
60-29-7
1 111-54-6
106-93-4
107-06-2
110-80-5
75-21-8
96-45-7
75-34-3
97-63-2
62-50-0
206-44-0
50-00-0
64-18-6
110-00-9
98-01-1
108-31-6
109-99-9
98-01-1
110-00-9
18883-66-4
18883-66-4
765-34-4
70-25-7
118-74-1
87-68-3
77-47-4
67-72-1
70-30-4
1888-71-7
302-01-2
1615-80-1
57-14-7
540-73-8
122-66-7
7664-39-3
7664-39-3
7783-06-4
7783-06-4
80-15-9
96-45-7
193-39-5
85-44-9
78-83-1
120-58-1
143-50-0
Substance
Ethene, tetrachloro-
Ethene, trichloro-
Ethyl acetate (I)
Ethyl acrylate (I)
Ethyl carbamate (urethane)
Ethyl ether (I)
Ethylenebisdithiocarbamic acid, salts & esters
Ethylene dibromide
Ethylene dichloride
Ethylene glycol monoethyl ether
Ethylene oxide (I,T)
Ethylenethiourea
Ethylidene dichloride
Ethyl methacrylate
Ethyl methanesulfonate
Fluoranthene
Formaldehyde
Formic acid (C,T)
Furan (I)
2-Furancarboxaldehyde (I)
2,5-Furandione
Furan, tetrahydro-(I)
Furfural (I)
Furfuran (I)
Glucopyranose, 2-deoxy-2-(3-methyl-3-nitrosoureido)-, D-
D-Glucose, 2-deoxy-2-[[(methylnitrosoamino)-carbonyl]amino]-
Glycidylaldehyde
Guanidine, N-methyl-N'-nitro-N-nitroso-
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Hydrazine (R,T)
Hydrazine, 1,2-diethyl-
Hydrazine, 1,1-dimethyl-
Hydrazine, 1,2-dimethyl-
Hydrazine, 1,2-diphenyl-
Hydrofluoric acid (C,T)
Hydrogen fluoride (C,T)
Hydrogen sulfide
Hydrogen sulfide H2S
Hydroperoxide, 1 -methyl- 1 -phenylethyl-(R)
2-Imidazolidinethione
Indeno [ 1 ,2,3 -cd]pyrene
1 ,3 -Isobenzofurandione
Isobutyl alcohol (I,T)
Isosafrole
Kepone
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B6

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U143
U144
U146
U145
U146
U129
U163
U147
U148
U149
U150
U151
U152
U092
U029
U045
U046
U068
U080
U075
U138
U119
U211
U153
U225
U044
U121
U036
U154
U155
U142
U247
U154
U029
U186
U045
U156
U226
U157
U158
U068
U080
U159
U160
U138
U161
U162
U161
U164
Chemical Abstracts
Number
303-34-4
301-04-2
1335-32-6
7446-27-7
1335-32-6
58-89-9
70-25-7
108-31-6
123-33-1
109-77-3
148-82-3
7439-97-6
126-98-7
124-40-3
74-83-9
74-87-3
107-30-2
74-95-3
75-09-2
75-71-8
74-88-4
62-50-0
56-23-5
74-93-1
75-25-2
67-66-3
75-69-4
57-74-9
67-56-1
91-80-5
143-50-0
72-43-5
67-56-1
74-83-9
504-60-9
74-87-3
79-22-1
71-55-6
56-49-5
101-14-4
74-95-3
75-09-2
78-93-3
1338-23-4
74-88-4
108-10-1
80-62-6
108-10-1
56-04-2
Substance
Lasiocarpine
Lead acetate
Lead, bis(acetato-O)tetrahydroxytri-
Lead phosphate
Lead subacetate
Lindane
MNNG
Maleic anhydride
Maleic hydrazide
Malononitrile
Melphalan
Mercury
Methacrylonitrile (I, T)
Methanamine, N-methyl- (I)
Methane, bromo-
Methane, chloro- (I, T)
Methane, chloromethoxy-
Methane, dibromo-
Methane, dichloro-
Methane, dichlorodifluoro-
Methane, iodo-
Methanesulfonic acid, ethyl ester
Methane, tetrachloro-
Methanethiol (I, T)
Methane, tribromo-
Methane, trichloro-
Methane, trichlorofluoro-
4,7-Methano-lH-indene, l,2,4,5,6,7,8,8-octachloro-2,3,3a,4,7,7a-hexahydro-
Methanol (I)
Methapyrilene
l,3,4-Metheno-2H-cyclobuta[cd]pentalen-2-one, l,la,3,3a,4,5,5,5a,5b,6-
decachlorooctahydro-
Methoxychlor
Methyl alcohol (I)
Methyl bromide
1-Methylbutadiene (I)
Methyl chloride (I,T)
Methyl chlorocarbonate (I,T)
Methyl chloroform
3 -Methylcholanthrene
4,4'-Methylenebis(2-chloroaniline)
Methylene bromide
Methylene chloride
Methyl ethyl ketone (MEK) (I,T)
Methyl ethyl ketone peroxide (R,T)
Methyl iodide
Methyl isobutyl ketone (I)
Methyl methacrylate (I,T)
4-Methyl-2-pentanone (I)
Methylthiouracil
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B7

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U010
U059
U167
U168
U026
U165
U047
U166
U236
U279
U166
U167
U168
U217
U169
U170
U171
U172
U173
U174
U176
U177
U178
U179
U180
U181
U193
U058
U115
U126
U041

U183
U184
U185
See F027
U161
U186
U187
U188
U048
U039
U081
U082
U089
U101
U052
Chemical Abstracts
Number
50-07-7
20830-81-3
134-32-7
91-59-8
494-03-1
91-20-3
91-58-7
130-15-4
72-57-1
63-25-2
130-15-4
134-32-7
91-59-8
10102-45-1
98-95-3
100-02-7
79-46-9
924-16-3
1116-54-7
55-18-5
759-73-9
684-93-5
615-53-2
100-75-4
930-55-2
99-55-8
1120-71-4
50-18-0
75-21-8
765-34-4
106-89-8
2
608-93-5
76-01-7
82-68-8
87-86-5
108-10-1
504-60-9
62-44-2
108-95-2
95-57-8
59-50-7
120-83-2
87-65-0
56-53-1
105-67-9
1319-77-3
Substance
Mitomycin C
5,12-Naphthacenedione, 8-acetyl-10-[(3-amino-2,3,6-trideoxy)-arpha-L-lyxo-
hexopyranosyl)oxy]-7,8,9,10-tetrahydro-6,8,ll-trihydroxy-l-methoxy-, (8S-
cis)-
1 -Naphthalenamine
2-Naphthalenamine
Naphthalenamine, N,N'-bis(2-chloroethyl)-
Naphthalene
Naphthalene, 2-chloro-
1 ,4-Naphthalenedione
2,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-dimethyl[l, l'-biphenyl]-4,4'-
diyl)bis(azo)bis[5-amino-4-hydroxy]-, tetrasodium salt
1-Naphthalenol, methylcarbamate
1 ,4-Naphthoquinone
alpha-Naphthylamine
beta-Naphthylamine
Nitric acid, thallium(l+) salt
Nitrobenzene (I,T)
p-Nitrophenol
2-Nitropropane (I,T)
N-Nitrosodi-n-butylamine
N-Nitrosodiethanolamine
N-Nitrosodiethylamine
N-Nitroso-N-ethylurea
N-Nitro so -N-methy lurea
N-Nitroso-N-methylurethane
N-Nitrosopiperidine
N-Nitrosopyrrolidine
5 -Nitro -o -toluidine
1,2-Oxathiolane, 2,2-dioxide
2H- 1 ,3 ,2-Oxazaphosphorin-2-amine, N,N-bis(2-chloroethyl)tetrahydro-,
2-oxide
Oxirane (I,T)
Oxiranecarboxy aldehyde
Oxirane, (chloromethyl)-
123-63-7 Paraldehyde
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene (PCNB)
Pentachlorophenol
Pentanol, 4-methyl-
1,3-Pentadiene (I)
Phenacetin
Phenol
Phenol, 2-chloro-
Phenol, 4-chloro-3 -methyl-
Phenol, 2,4-dichloro-
Phenol, 2,6-dichloro-
Phenol, 4,4'-(l,2-diethyl-l,2-ethenediyl)bis-, (E)-
Phenol, 2,4-dimethyl-
Phenol, methyl-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B8

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U132
U411
U170
See F027
See F027
See F027
See F027
U150
U145
U087
U189
U190
U191
U179
U192
U194
Ulll
U110
U066
U083
U149
U171
U027
U193
See F027
U235
U140
U002
U007
U084
U243
U009
U152
U008
U113
U118
U162
U373
U411
U387
U194
U083
U148
U196
U191
U237
U164
U180
U200
U201
Chemical Abstracts
Number
70-30-4
114-26-1
100-02-7
87-86-5
58-90-2
95-95-4
88-06-2
148-82-3
7446-27-7
3288-58-2
1314-80-3
85-44-9
109-06-8
100-75-4
23950-58-5
107-10-8
621-64-7
142-84-7
96-12-8
78-87-5
109-77-3
79-46-9
108-60-1
1120-71-4
93-72-1
126-72-7
78-83-1
67-64-1
79-06-1
542-75-6
1888-71-7
107-13-1
126-98-7
79-10-7
140-88-5
97-63-2
80-62-6
122-42-9
114-26-1
52888-80-9
107-10-8
78-87-5
123-33-1
110-86-1
109-06-8
66-75-1
56-04-2
930-55-2
50-55-5
108-46-3
Substance
Phenol, 2,2'-methylenebis[3,4,6-trichloro-
Phenol, 2-(l-methylethoxy)-, methylcarbamate
Phenol, 4-nitro-
Phenol, pentachloro-
Phenol, 2,3,4,6-tetrachloro-
Phenol, 2,4,5-trichloro-
Phenol, 2,4,6-trichloro-
L-Phenylalanine, 4-[bis(2-chloroethyl)amino] -
Phosphoric acid, lead(2+) salt (2:3)
Phosphorodithioic acid, O,O-diethyl S-methyl ester
Phosphorus sulfide (R)
Phthalic anhydride
2-Picoline
Piperidine, 1-nitroso-
Pronamide
1-Propanamine (I,T)
1-Propanamine, N-nitroso-N-propyl-
1-Propanamine, N-propyl- (I)
Propane, l,2-dibromo-3-chloro-
Propane, 1,2-dichloro-
Propanedinitrile
Propane, 2-nitro- (I,T)
Propane, 2,2'-oxybis[2-chloro-
1,3 -Propane sultone
Propanoic acid, 2-(2,4,5-trichlorophenoxy)-
1-Propanol, 2,3-dibromo-, phosphate(3:l)
1-Propanol, 2-methyl- (I,T)
2-Propanone (I)
2-Propenamide
1-Propene, 1,3-dichloro-
1-Propene, 1, 1,2,3,3, 3-hexachloro-
2-Propenenitrile
2-Propenenitrile, 2-methyl- (I,T)
2-Propenoic acid (I)
2-Propenoic acid, ethyl ester (I)
2-Propenoic acid, 2-methyl-, ethyl ester
2-Propenoic acid, 2-methyl-, methyl ester (I,T)
Propham
Propoxur
Prosulfocarb
n-Propylamine (I,T)
Propylene dichloride
3,6-Pyridazinedione, 1,2-dihydro-
Pyridine
Pyridine, 2-methyl-
2,4-(lH,3H)-Pyrimidinedione, 5-[bis(2-chloroethyl) amino]-
4( lH)-Pyrimidinone, 2,3 -dihydro-6-methyl-2-thioxo-
Pyrrolidine, 1-nitroso-
Reserpine
Resorcinol
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B9

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U202
U203
U204
U204
U205
U205
U015
See F027
U206
U103
U189
See F027
U207
U208
U209
U210
See F027
U213
U214
U215
U216
U216
U217
U218
U410
U153
U244
U409
U219
U244
U220
U221
U223
U328
U353
U222
U389
U011
U227
U228
U121
See F027
See F027
U404
U234
U182
U235
U236
U237
U176
Chemical Abstracts
Number
1 81-07-2
94-59-7
7783-00-8
7783-00-8
7488-56-4
7488-56-4
115-02-6
93-72-1
18883-66-4
77-78-1
1314-80-3
93-76-5
95-94-3
630-20-6
79-34-5
127-18-4
58-90-2
109-99-9
563-68-8
6533-73-9
7791-12-0
7791-12-0
10102-45-1
62-55-5
59669-26-0
74-93-1
137-26-8
23564-05-8
62-56-6
137-26-8
108-88-3
25376-45-8
26471-62-5
95-53-4
106-49-0
636-21-5
2303-17-5
61-82-5
79-00-5
79-01-6
75-69-4
95-95-4
88-06-2
121-44-8
99-35-4
123-63-7
126-72-7
72-57-1
66-75-1
759-73-9
Substance
Saccharin, & salts
Safrole
Selenious acid
Selenium dioxide
Selenium sulfide
Selenium sulfide SeS2 (R,T)
L-Serine, diazoacetate (ester)
Silvex (2,4,5-TP)
Streptozotocin
Sulfuric acid, dimethyl ester
Sulfur phosphide (R)
2,4,5-T
1,2,4,5-Tetrachlorobenzene
1,1,1 ,2-Tetrachloroethane
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
2,3 ,4,6-Tetrachlorophenol
Tetrahydrofuran (I)
Thallium(I) acetate
Thallium(I) carbonate
Thallium(I) chloride
Thallium chloride Tlcl
Thallium(I) nitrate
Thioacetamide
Thiodicarb
Thiomethanol (I,T)
Thioperoxydicarbonic diamide [(H2N)C(S)]2S2, tetramethyl-
Thiophanate-methyl
Thiourea
Thiram
Toluene
Toluenediamine
Toluene diisocyanate (R,T)
o-Toluidine
p-Toluidine
o-Toluidine hydrochloride
Triallate
lH-l,2,4-Triazol-3-amine
1 , 1 ,2-Trichloroethane
Trichloroethylene
Trichloromonofluoromethane
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
1,3,5-Trinitrobenzene (R,T)
1,3,5-Trioxane, 2,4,6-trimethyl-
Tris(2,3-dibromopropyl) phosphate
Trypan blue
Uracil mustard
Urea, N-ethyl-N-nitroso-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
BIO

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
U177
U043
U248
U239
U200
U249
Chemical Abstracts
Number
684-93-5
75-01-4
1 81-81-2
1330-20-7
50-55-5
1314-84-7
Substance
Urea, N-methyl-N-nitroso-
Vinyl chloride
Warfarin, & salts, when present at concentrations of 0.3% or less
Xylene (I)
Yohimban-16-carboxylic acid, ll,17-dimethoxy-18-[(3,4,5-
trimethoxybenzoyl)oxy]-, methyl ester, (3beta,16beta,17alpha,18beta,20alpha)-
Zinc phosphide Zn3P2, when present at concentrations of 10% or less
  CAS Number given for parent compound only.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
Bll

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This document is intended solely for guidance. No statutory or regulatory                                       B12
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous
                  Waste Generators under RCRA

                           Appendix C
      Toxicity Characteristics Constituents and Regulatory Levels
                         (40 CFR 261.24)

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                           Toxicity Characteristics Constituents and Regulatory Levels
                                                 (40 CFR 261.24)
U.S. EPA
HWNo.
D004
D005
D018
D006
D019
D020
D021
D022
D007
D023
D024
D025
D026
D016
D027
D028
D029
D030
D012
D031
D032
D033
D034
D008
D013
D009
D014
D035
D036
D037
D038
D010
D011
D039
D015
D040
D041
D042
D017
D043
Constituent
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Cresol
p-Cresol
Cresol
2,4-D
1 ,4-Dichlorobenzene
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its epoxide)
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
CAS No
7440-38-2
7440-39-3
71-43-2
7440-43-9
56-23-5
57-74-9
108-90-7
67-66-3
7440-47-3
95-48-7
108-39-4
106-44-5

94-75-7
106-46-7
107-06-2
75-35-4
121-14-2
72-20-8
76-44-8
118-74-1
87-68-3
67-72-1
7439-92-1
58-89-9
7439.97-6
72-43-5
78-93-3
98-95-3
87-86-5
110-86-1
7782-49-2
7440-22-4
127-18-4
8001-35-2
79-01-6
95-95-4
88-06-2
93-72-1
75-01-4
Regulatory
level (mg/L)
5.0
100.0
0.5
1.0
0.5
0.03
100.0
6.0
5.0
200.0 l
200.0 l
200.0 1
200.0 1
10.0
7.5
0.5
0.7
0.13 2
0.02
0.008
0.13 2
0.50
3.0
5.0
0.4
0.2
10.0
200.0
2.0
100.0
5.0 2
1.0
5.0
0.7
0.5
0.5
400.0
2.0
1.0
0.2
  If o-, m-, and p-cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used.
2 Quantitation limit is greater than the calculated regulatory level. Therefore, the quantitation limit becomes the regulatory
level.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
Cl

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This document is intended solely for guidance. No statutory or regulatory                                       C2
requirements are in any way altered by any statement(s) contained herein.

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Protocol for Conducting Environmental Compliance Audits of Hazardous
                  Waste Generators under RCRA

                          Appendix D
      Commercial Chemical Products or Manufacturing Chemical
          Intermediates Identified as Acute Hazardous Waste
                (40 CFR 261.33(a) through 261.33(e))

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                           Commercial Chemical Products or Manufacturing Chemical
                               Intermediates Identified as Acute Hazardous Waste
                                      (40 CFR 261.33(a) through 261.33(e))

(Comment: For the convenience of the regulated community the primary hazardous properties of these materials have been
indicated by the letters T (Toxicity), and R (Reactivity). Absence of a letter indicates that the compound only is listed for
acute toxicity.]
Hazardous
Waste No.
P023
P002
P057
P058
P002
POOS
P070
P203
P004
POOS
P006
P007
POOS
P009
P119
P099
P010
P012
P011
P011
P012
P038
P036
P054
P067
P013
P024
P077
P028
P042
P046
P014
P127
P188
P001
P028
P015
P017
P018
Chemical Abstracts
Number
107-20-0
591-08-2
640-19-7
62-74-8
591-08-2
107-02-8
116-06-3
1646-88-4
309-00-2
107-18-6
20859-73-8
2763-96-4
504-24-5
131-74-8
7803-55-6
506-61-6
7778-39-4
1327-53-3
1303-28-2
1303-28-2
1327-53-3
692-42-2
696-28-6
151-56-4
75-55-8
542-62-1
106-47-8
100-01-6
100-44-7
51-43-4
122-09-8
108-98-5
1563-66-2
57-64-7
1 81-81-2
100-44-7
7440-41-7
598-31-2
357-57-3
Substance
Acetaldehyde, chloro-
Acetamide, N-(aminothioxomethyl)-
Acetamide, 2-fluoro-
Acetic acid, fluoro-, sodium salt
1 -Acetyl-2-thiourea
Acrolein
Aldicarb
Aldicarb sulfone
Aldrin
Allyl alcohol
Aluminum phosphide (R,T)
5-(Aminomethyl)-3-isoxazolol
4 - Aminopy ridine
Ammonium picrate (R)
Ammonium vanadate
Argentate(l-), bis(cyano-C)-, potassium
Arsenic acid H3AsO4
Arsenic oxide As2O3
Arsenic oxide As2O5
Arsenic pentoxide
Arsenic trioxide
Arsine, diethyl-
Arsonous dichloride, phenyl-
Aziridine
Aziridine, 2-methyl-
Barium cyanide
Benzenamine, 4-chloro-
Benzenamine, 4-nitro-
Benzene, (chloromethyl)-
1,2-Benzenediol, 4-[l-hydroxy-2-(methylamino)ethyl]-, (R)-
Benzeneethanamine, alpha, alpha-dimethyl-
Benzenethiol
7-Benzofuranol, 2,3-dihydro-2,2-dimethyl-, methylcarbamate
Benzoic acid, 2-hydroxy-, compd. With(3aS-cis)-l,2,3,3a,8,8a-hexahydro-
l,3a,8-trimethylpyrrolo[2,3-b]indol-5-yl methylcarbamate ester (1:1)
2H-l-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-l-phenylbutyl)-, & salts, when
present at concentrations greater than 0.3%.
Benzyl chloride
Beryllium powder
Bromoacetone
Brucine
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
Dl

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
P045
P021
P021
P189
P191
P192
P190
P127
P022
P095
P189
P023
P024
P026
P027
P029
P029
P202
P030
P031
P033
P033
P034
P016
P036
P037
P038
P041
P040
P043
P004
P060

P037
P051
P044
P046
P191
P047
P048
P020
P085
Chemical Abstracts
Number
39196-18-4
592-01-8
592-01-8
55285-14-8
644-64-4
119-38-0
1129-41-5
1563-66-2
75-15-0
75-44-5
55285-14-8
107-20-0
106-47-8
5344-82-1
542-76-7
544-92-3
544-92-3
64-00-6

460-19-5
506-77-4
506-77-4
131-89-5
542-88-1
696-28-6
60-57-1
692-42-2
311-45-5
297-97-2
55-91-4
309-00-2
465-73-6

60-57-1
1 72-20-8
60-51-5
122-09-8
644-64-4
1 534-52-1
51-28-5
88-85-7
152-16-9
Substance
2-Butanone, 3,3-dimethyl-l-(methylthio)-, O-[methylamino)carbonyl] oxime
Calcium cyanide
Calcium cyanide Ca(CN)2
Carbamic acid, [(dibutylamino)-thio]methyl-, 2,3-dihydro-2,2- dimethyl- 7-
benzofuranyl ester
Carbamic acid, dimethyl-, l-[(dimethyl-amino)carbonyl]- 5-methyl-lH-pyrazol-
3-yl ester
Carbamic acid, dimethyl-, 3 -methyl- l-(l-methylethyl)-lH- pyrazol-5-yl ester
Carbamic acid, methyl-, 3-methylphenyl ester
Carbofuran
Carbon disulfide
Carbonic dichloride
Carbosulfan
Chloroacetaldehyde
p-Chloroaniline
1 -(o-Chlorophenyl)thiourea
3 -Chloropropionitrile
Copper cyanide
Copper cyanide Cu(CN)
m-Cumenyl methylcarbamate
Cyanides (soluble cyanide salts), not otherwise specified
Cyanogen
Cyanogen chloride
Cyanogen chloride (CN)C1
2-Cyclohexyl-4,6-dinitrophenol
Dichloromethyl ether
Dichlorophenylarsine
Dieldrin
Diethylarsine
Diethyl-p-nitrophenyl phosphate
O,O-Diethyl O-pyrazinyl phosphorothioate
Diisopropylfluorophosphate (DFP)
1,4,5,8-Dimethanonaphthalene, 1,2,3,4, 10, 10-hexa-chloro-l,4,4a,5,8,8a,-
hexahydro-,(lalpha,4alpha,4abeta,5alpha,8alpha,8 abeta)-
1,4,5,8-Dimethanonaphthalene, l,2,3,4,10,10-hexa-chloro-l,4,4a,5,8,8a-
hexahydro-,(lalpha,4alpha,4abeta,5beta,8beta,8abeta)-
2,7:3,6-Dimethanonaphth[2,3-b] oxirene, 3,4,5,6,9,9-hexachloro-
la,2,2a,3,6,6a,7,7a-octahydro-,(laalpha,2beta,2aalpha,3beta,6beta,6a
alpha, 7beta, 7aalpha)-
2,7:3,6-Dimethanonaphth [2,3-b] oxirene, 3,4,5,6,9,9-hexachloro-
la,2,2a,3,6,6a,7,7a-octahydro-,(laalpha,2beta,2abeta,3alpha,6alpha,6
abeta,7beta, 7aalpha)-, & metabolites
Dimethoate
alpha,alpha-Dimethylphenethylamine
Dimetilan
4,6-Dinitro-o-cresol, & salts
2,4-Dinitrophenol
Dinoseb
Diphosphoramide, octamethyl-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D2

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
Pill
P039
P049
P185
P050
P088
P051
P051
P042
P031
P194
P066
P101
P054
P097
P056
P057
P058
P198
P197
P065
P059
P062
P116
P068
P063
P063
P096
P060
P192
P202
P007
P196
P196
P092
P065
P082
P064
P016
P112
P118
P198
P197
P050
P059
Chemical Abstracts
Number
107-49-3
298-04-4
541-53-7
26419-73-8
115-29-7
145-73-3
72-20-8
72-20-8
51-43-4
460-19-5
23135-22-0
16752-77-5
107-12-0
151-56-4
52-85-7
7782-41-4
640-19-7
62-74-8
23422-53-9
17702-57-7
628-86-4
76-44-8
757-58-4
79-19-6
60-34-4
74-90-8
74-90-8
7803-51-2
465-73-6
119-38-0
64-00-6
2763-96-4
15339-36-3
15339-36-3
62-38-4
628-86-4
62-75-9
624-83-9
542-88-1
509-14-8
75-70-7
23422-53-9
17702-57-7
115-29-7
76-44-8
Substance
Diphosphoric acid, tetraethyl ester
Disulfoton
Dithiobiuret
l,3-Dithiolane-2-carboxaldehyde, 2,4-dimethyl-, O- [(methylamino)-
carbonyljoxime
Endosulfan
Endothall
Endrin
Endrin, & metabolites
Epinephrine
Ethanedinitrile
Ethanimidothioc acid, 2-(dimethylamino)-N-[[(methylamino) carbonyl]oxy]-2-
oxo-, methyl ester
Ethanimidothioic acid, N-[[(metriylamino)carbonyl]oxy]-,methyl ester
Ethyl cyanide
Ethyleneimine
Famphur
Fluorine
Fluoroacetamide
Fluoroacetic acid, sodium salt
Formetanate hydrochloride
Formparanate
Fulminic acid, mercury(2+) salt (R,T)
Heptachlor
Hexaethyl tetraphosphate
Hydrazinecarbothioamide
Hydrazine, methyl-
Hydrocyanic acid
Hydrogen cyanide
Hydrogen phosphide
Isodrin
Isolan
3 -Isopropylphenyl N-methylcarbamate
3(2H)-Isoxazolone, 5-(aminomethyl)-
Manganese, bis(dimethylcarbamodithioato-S,S')-
Manganese dimethyldithiocarbamate
Mercury, (acetato-O)phenyl-
Mercury fulminate (R,T)
Methanamine, N-methyl-N-nitroso-
Methane, isocyanato-
Methane, oxybis[chloro-
Methane, tetranitro- (R)
Methanethiol, trichloro-
Methanimidamide, N,N-dimethyl-N'-[3-[[(methylamino)-carbonyl]oxy]phenyl]-,
monohydrochloride
Methanimidamide, N,N-dimethyl-N'-[2-methyl-4-
[[(methylamino)carbonyl]oxy]phenyl]-
6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10, 10- hexachloro-l,5,5a,6
hexahydro-,3-oxide
9,9a-
4,7-Methano-lH-indene, 1,4,5,6,7,8,8- heptachloro-3a,4,7,7a-tetrahydro-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D3

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
P199
P066
P068
P064
P069
P071
P190
P128
P072
P073
P073
P074
P074
P075
P076
P077
P078
P076
P078
P081
P082
P084
P085
P087
P087
P088
P194
P089
P034
P048
P047
P020
P009
P128
P199
P202
P201
P092
P093
P094
P095
P096
P041
P039
P094
P044
P043
P089
P040
P097
Chemical Abstracts
Number
2032-65-7
16752-77-5
60-34-4
624-83-9
75-86-5
298-00-0
1129-41-5
315-8-4
86-88-4
13463-39-3
13463-39-3
557-19-7
557-19-7
1 54-1 1-5
10102-43-9
100-01-6
10102-44-0
10102-43-9
10102-44-0
55-63-0
62-75-9
4549-40-0
152-16-9
20816-12-0
20816-12-0
145-73-3
23135-22-0
56-38-2
131-89-5
51-28-5
1 534-52-1
88-85-7
131-74-8
315-18-4
2032-65-7
64-00-6
2631-37-0
62-38-4
103-85-5
298-02-2
75-44-5
7803-51-2
311-45-5
298-04-4
298-02-2
60-51-5
55-91-4
56-38-2
297-97-2
52-85-7
Substance
Methiocarb
Methomyl
Methyl hydrazine
Methyl isocyanate
2-Methyllactonitrile
Methyl parathion
Metolcarb
Mexacarbate
alpha-Naphthylthiourea
Nickel carbonyl
Nickel carbonyl Ni(CO)4, (T-4)-
Nickel cyanide
Nickel cynaide Ni(CN)2
Nicotine, & salts
Nitric oxide
p-Nitroaniline
Nitrogen dioxide
Nitrogen oxide NO
Nitrogen oxide NO2
Nitroglycerine (R)
N-Nitrosodimethylamine
N-Nitrosomethylvinylamine
Octamethylpyrophosphoramide
Osmium oxide OsO4, (T-4)-
Osmium tetroxide
7-Oxabicyclo[2.2. l]heptane-2,3-dicarboxylic acid
Oxamyl
Parathion
Phenol, 2-cyclohexyl-4,6-dinitro-
Phenol, 2,4-dinitro-
Phenol, 2-methyl-4,6-dinitro-, & salts
Phenol, 2-( 1 -methylpropyl)-4,6-dinitro-
Phenol, 2,4,6-trinitro-, ammonium salt(R)
Phenol, 4-(dimethylamino)-3,5-dimethyl-, methylcarbamate (ester)
Phenol, (3,5-dimethyl-4-(methylthio)-, methylcarbamate
Phenol, 3-(l-methylethyl)-, methyl carbamate
Phenol, 3-methyl-5-(l-methylethyl)-, methyl carbamate
Phenylmercury acetate
Phenylthiourea
Phorate
Phosgene
Phosphine
Phosphoric acid, diethyl 4-nitrophenyl ester
Phosphorodithioic acid, O,O-diethyl S-[2-(ethylthio)ethyl] ester
Phosphorodithioic acid, O,O-diethyl S-[(ethylthio)methyl] ester
Phosphorodithioic acid, O,O-dimethyl S-[2-(methylamino)-2-oxoethyl] ester
Phosphorofluoridic acid, bis(l-methylethyl) ester
Phosphorothioic acid, O,O-diethyl O-(4-nitrophenyl) ester
Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester
Phosphorothioic acid, O-[4-[(dimethylamino)sulfonyl]phenyl] O,O- dimethyl
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D4

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.

P071
P204
P188
P110
P098
P098
P099
P201
P070
P203
P101
P027
P069
P081
P017
P102
POOS
POOS
P067
P102
POOS
P075
P204

P114
P103
P104
P104
P105
P106
P106
P108
P018
P108
P115
P109
P110
Pill
P112
P062
P113
P113
P114
P115
P109
P045
P049
P014
P116
Chemical Abstracts
Number

298-00-0
57-47-6
57-64-7
78-00-2
151-50-8
151-50-8
506-61-6
2631-37-0
116-06-3
1646-88-4
107-12-0
542-76-7
75-86-5
55-63-0
598-31-2
107-19-7
107-02-8
107-18-6
75-55-8
107-19-7
504-24-5
1 54-11-5
57-47-6

12039-52-0
630-10-4
506-64-9
506-64-9
26628-22-8
143-33-9
143-33-9
1 57-24-9
357-57-3
1 57-24-9
7446-18-6
3689-24-5
78-00-2
107-49-3
509-14-8
757-58-4
1314-32-5
1314-32-5
12039-52-0
7446-18-6
3689-24-5
39196-18-4
541-53-7
108-98-5
79-19-6
Substance
ester
Phosphorothioic acid, O,O, -dimethyl O-(4-nitrophenyl) ester
Physostigmine
Physostigmine salicylate
Prumbane, tetraethyl-
Potassium cyanide
Potassium cyanide K(CN)
Potassium silver cyanide
Promecarb
Propanal, 2-methyl-2-(methylthio)-, O-[(methylamino)carbonyl]oxime
Propanal, 2-methyl-2-(methyl-surfonyl)-, O-[(methylamino)carbonyl] oxime
Propanenitrile
Propanenitrile, 3-chloro-
Propanenitrile, 2-hydroxy-2-methyl-
1,2,3-Propanetriol, trinitrate (R)
2-Propanone, 1-bromo-
Propargyl alcohol
2-Propenal
2-Propen-l-ol
1 ,2-Propylenimine
2-Propyn-l-ol
4-Pyridinamine
Pyridine, 3-(l-methyl-2-pyrrolidinyl)- , (S)-, & salts
Pyrrolo[2,3-b]indol-5-ol,l,2,3,3a,8,8a-hexahydro-l,3a,8-trimethyl-
,methylcarbamate (ester), (3aS-cis)-
Selenious acid, dithallium(l+) salt
Selenourea
Silver cyanide
Silver cyanide Ag(CN)
Sodium azide
Sodium cyanide
Sodium cyanide Na(CN)
Strychnidin-10-one, & salts
Strychnidin-10-one, 2,3-dimethoxy-
Strychnine, & salts
Sulfuric acid, dithallium(l+) salt
Tetraethyldithiopyrophosphate
Tetraethyl lead
Tetraethyl pyrophosphate
Tetranitromethane (R)
Tetraphosphoric acid, hexaethyl ester
Thallic oxide
Thallium oxide T12O3
Thallium(I) selenite
Thalliumฎ sulfate
Thiodiphosphoric acid, tetraethyl ester
Thiofanox
Thioimidodicarbonic diamide [(H2N)C(S)]2NH
Thiophenol
Thiosemicarbazide
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D5

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Hazardous
Waste No.
P026
P072
P093
P185
P123
P118
P119
P120
P120
P084
P001
P205
P121
P121
P122
P205
Chemical Abstracts
Number
5344-82-1
86-88-4
103-85-5
26419-73-8
8001-35-2
75-70-7
7803-55-6
1314-62-1
1314-62-1
4549-40-0
1 81-81-2
137-30-4
557-21-1
557-21-1
1314-84-7
137-30-4
Substance
Thiourea, (2-chlorophenyl)-
Thiourea, 1-naphthalenyl-
Thiourea, phenyl-
Tirpate.
Toxaphene
Trichloromethanethiol
Vanadic acid, ammonium salt
Vanadium oxide V2O5
Vanadium pentoxide
Vinylamine, N-methyl-N-nitroso-
Warfarin, & salts, when present at concentrations greater than 0.3%
Zinc, bis(dimethylcarbamodithioato- S,S')-
Zinc cyanide
Zinc cyanide Zn(CN)2
Zinc phosphide Zn3 P2, when present at concentrations greater than 10% (R,T)
Ziram.
1 CAS Number given for parent compound only.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D6

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Protocol for Conducting Environmental Compliance Audits of Hazardous
                  Waste Generators under RCRA

                          Appendix E
           Hazardous Waste Storage Incompatibility Chart

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                Hazardous Waste Storage Incompatibility Chart

                         Substances in bold have detailed example lists on the next page.
 If the material contains:
It may not be stored with any of the following:
Acid (pH below 2.0)
Caustics (pH above 12.5)
Reactive Metals
Alcohol
Water
Aldehydes
Halogenated, Nitrated, or Unsaturated Hydrocarbons
Reactive Organic Compounds and Solvents
Spent Cyanide and Sulfide Solutions
Oxidizers
 Caustic (pH above 12.5)
Acid (pH below 2.0)
Reactive Metals
Alcohol
Water
Aldehydes
Halogenated, Nitrated, or Unsaturated Hydrocarbons
Reactive Organic Compounds and Solvents	
 Reactive Metals
Caustics
Acids
Alcohol
Aldehydes
Halogenated, Nitrated, or Unsaturated Hydrocarbons
Reactive Organic Compounds and Solvents
Oxidizers
 Reactive Organic Compounds and Solvents
Caustics
Acids
Reactive Metals
 Spent Cyanide and Sulfide Solutions
Acids
 Oxidizers
Acetic or Other Organic Acids
Concentrated Mineral Acids
Reactive Metals
Reactive Organic Compounds and Solvents
Ignitable [Flammable/Combustible] Wastes*
* "Ignitable" in this context refers to substances with a flashpoint below 140 x ฐF, and includes:
Combustible substances, with a flashpoint below 140 x ฐF
Flammable substances, with a flashpoint below 100 x ฐF.

Some Deadly Combinations

Acids + Oil or Grease = Fire       Flammable Liquids + Hydrogen Peroxide = Fire/Explosion
Acids + Caustics = Heat/Spattering Aluminum Powder + Ammonium Nitrate = Explosion
Caustics + Epoxies = Extreme Heats        Sodium Cyanide + Sulfuric Acid = Lethal Hydrogen Cyanide
Chlorine Gas + Acetylene = Explosion      Ammonia + Bleach = Noxious Fumes

In general:   Reactives must be segregated from Ignitables
Acids must be segregated from Caustics
Corrosives should be segregated from Flammables
Oxidizers should be segregated from EVERYTHING
Many Corrosives are "Water Reactive"
Most Organic Reactives must be segregated from Inorganic Reactives (metals)

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                      El

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Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Ignitables
(Flammables/Combustibles)
Corrosives
Acids Caustics
1
Carburetor Cleaners
Engine Cleaners
Epoxy, Resins, Adhesives, and Rubber Cements
Finishes
Fuels
Lacquers
Paints
Paint Thinners
Paint Wastes
Pesticides that contain Solvents (such as Methyl Alcohol, Ethyl
Alcohol, Isopropyl Alcohol, Toluene, Xylene).
Petroleum Solvents (Drycleaning Fluid)
Solvents:
Acetone
Benzene
Carbon Tetrachloride (Carbon Tet)
Ethanol (Ethyl Alcohol)
Ethyl Benzene
Isopropanol (Isopropyl Alcohol)
Kerosene (Fuel Oil #1)
Methanol (Wood Alcohol)
Methyl Ethyl Ketone (MEK)
Petroleum Distillates
Tetrahydroruran (THF)
Toluene (Methacide, Methylbenzene, Methylbenzol,
Phenylmethane, Toluol, Antisal 1A)
White Spirits (White Spirits, Mineral Spirits, Naptha)
Xylene (Xylol)
Stains
Stripping Agents
Varsol
Waste Fuels
Waste Ink
Wax Removers
Wood Cleaners










Battery Acids
Degreasers and Engine
Cleaners
Etching Fluids
Hydrobromic Acid
Hydrochloric Acid (Muriatic
Acid)
Nitric Acid (<40%)
(Aquafortis)
Phosphoric Acid
Rust Removers
Sulfuric Acid (Oil of Vitriol)




Reactive Metals

Lithium (Batteries)
Aluminum
Beryllium
Calcium
Magnesium
Sodium
Zinc Powder










Oxidize rs
Chlorine Gas
Nitric Acid (>40%), aka Red
Fuming Nitric
Nitrates (Sodium Nitrate,
Ammonium Nitrate)
Perchlorates
Perchloric Acid
Perioxides
Calcium Hypochlorite (>60%)
Acetylene Sludge
Alkaline Battery Acids
Alkaline Cleaners
Alkaline Degreasers
Alkaline Etching Fluids
Lime and Water
Lime Wastewater
Potassium Hydroxide (Caustic
Potash)
Rust Removers
Sodium Hydroxide (Caustic
Soda, Soda Lye)


Reactive Organic
Compounds and Solutions


Alcohols
Aldehydes
Chromic Acids (from chrome
plating, copper stripping
and aluminum anodizing)
Cyanides (from electroplating
operations)
Hypochlorides (from water
treatment plants, swimming
pools, sanitizing
operations)
Organic Peroxides (including
Hydrogen Peroxide)
Perchlorates
Permanganates
Sulfides











This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E2

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Protocol for Conducting Environmental Compliance Audits of
        Hazardous Waste Generators under RCRA

                     Appendix F
    User Satisfaction Questionnaire and Comment Form

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                                             User Satisfaction Survey
                                           (OMB Approval No.  1860.01)
                                                Expires 9/30/2001

We would like to know if this Audit Protocol provides you with useful information. This information will be used by EPA to
measure the success of this tool in providing compliance assistance and to determine future applications and needs for
regulatory checklists and auditing materials.

1.   Please indicate which Protocol(s) this survey applies to:

    Title:
    EPA Document Number:
2.   Overall, did you find the Protocol helpful for conducting audits:

    Yes	   No	

    If not, what areas of the document are difficult to understand?

3.   How would you rate the usefulness of the Protocol(s) for conducting compliance audits on a scale of 1-5?

    1 = not useful or effective, 3 = somewhat useful/effective,  5 = very useful/effective

    Low                 Medium        High
    12345       Introduction Section
    12345       Key Compliance Requirements
    12345       Key Terms and Definitions
    12345       Checklist
4.   What actions do you intend to take as a result of using the protocol and/or conducting the audit? Please check all that
    apply.

    	 Contact a regulatory agency
    	 Contact a compliance assisstance provider (e.g., trade association, state agency, EPA)
    	 Contact a vendor
    	 Disclose violations discovered during the audit under EPA's audit Policy
    	 Disclose violations discovered under EPA's Small Business Policy
    	 Obtain a permit or certification
    	 Change the handling of a waste, emission or pollutant
    	 Change a process or practice
    	 Purchase new process equipment
    	 Install emission control equipment (e.g.,  scrubbers, wastewater treatment)
    	 Install waste treatment system (control technique)
    	 Implement or improve pollution prevention practices (e.g., source reduction, recycling)
    	 Improve organizational auditing program
    	 Institute an Environmental Management  System
    	 Improve the existing Environmental Management System (e.g., improve training, clarify standard operating
          procedures, etc.)
          Other

-------
5.    What, if any, environmental improvements will result from the actions to be taken (check all that apply)?

    	  reduced emissions
    	  waste reduction
    	  reduced risk to human health and the environment due to better management practices
    	  reduced quantity and toxicity of raw materials
    	  water conservation
    	  energy conservation
    	  conserved raw materials
    	  conservation of habitat or other environmental stewardship practice:	
          other:
          no environmental improvements are likely to result from the use of this document
6.   How did you hear about this document?
    	  trade association
    	  state technical assistance provider
    	  EPA internet homepage or website
    	  document catalog
    	  co-worker or business associate
    	  EPA, state, or local regulator
    	  other (please specify)	
7.   In order to understand your response, we would like to know what function you perform with respect to environmental
    compliance and the size of your organization.

	Company Personnel            	 Trade Association              	 Compliance Assistance
     	  Environmental Auditor          	  National                       Provider
     	  Corporate Level                	  Regional                       	 EPA
           Plant-level                           Local                               State
           Legal                         	 Manager                       	 State Small Business
           Environmental Manager         	 Information Specialist                 Assistance
           Operator - (e.g.,                                                    	Local
           Pollution Control                                                   	Other	
           Equipment                                                              	
           Other:
      Regulatory Personnel          	 Vendor/Consultant
      	  State                         	 Environmental Auditor
            Local                             Environmental
            EPA                               Engineer/Scientist
                                              Attorney
    How many employees are located at your facility (including full-time contractors?)

        0-9       10-49       50-100       101-500       More than 500

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Optional (Please Print)

Name:                                  Address:
Title:	City:	State:_

Zip code:	

Organization Name:	
Phone: (  1	E-mail:
Please return all pages (1 thru 3) of this survey by folding pages 1 and 2 into page 3 and using the preprinted, pre-stamped
address on the reverse side of page 3. If you have accessed this document electronically from one of EPA's web sites, simply
e-mail this questionnaire to: satterfield.richard(@,epa.gov.

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