-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
This document has been developed to assist in conducting environmental audits. The use of this document should
be restricted to environmental audits only. For example, areas such as safety, transportation, occupational health,
and fire protection are mentioned solely for clarification purposes. It is a summary of environmental regulations
under RCRA but it is not a substitute for a comprehensive knowledge of the regulations themselves. Any
variation between applicable regulations and the summaries contained in this guidance document are
unintentional, and, in the case of such variations, the requirements of the regulations govern.

This document is intended solely as guidance to explain performance objectives for environmental auditors.
Following the  steps set forth in this guidance generally should result in compliance with those aspects of the
regulations that it covers. The U.S. Environmental Protection Agency does not make any guarantee or assume any
liability with respect to the use of any information or recommendations contained in this document. Regulated
entities requiring additional information or advice should consult a qualified professional.

This guidance  does not constitute rulemaking by the EPA and may not be relied on to create a substantive or
procedural right or benefit enforceable, at law or in equity, by any person. EPA may take action at variance with
this guidance and its internal procedures.
Kknowledgements
EPA would like to gratefully acknowledge the support of the U.S. Army Corps of Engineers Construction
Engineering Research Laboratories (CERL) for their assistance in developing checklist items pertaining to the
RCRA Subpart CC and for providing suggestions for the overall format of this document.  In addition,
acknowledgment is given to the representatives of the  Synthetic Organic Chemical Manufacturing Association,
Inc. (SOCMA) and the Chemical Manufacturers Association (CMA) who contributed their comments.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Notice	inside cover
Acknowledgements	inside cover

Section I: Introduction
Background	ii
EPA's Policy on Environmental Audits	ii
Purpose of the Protocols for Conducting Environmental Compliance Audits	iii
How to Use This Protocol	iv
List of Acronyms and Abbreviations	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	13
Typical Physical Features to Inspect	13
Index for Checklist Users	14
Checklist	15

Appendices
Appendix A: Identification and Listing of Hazardous Waste	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: Identification of Hazardous Waste Hazardous Constituents	Dl
Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates
    Identified as  Toxic Wastes	El
Appendix F: Potentially Incompatible Hazardous Wastes	Fl
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates	Gl
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.

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

                                             Section I
                                           Introduction
                                                                    ปiL.
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. Recently, EPA has begun combining
traditional enforcement activities with more innovative compliance approaches. In its Strategic Plan, the Agency
recognizes the need to assist the regulated community by providing compliance assistance and guidance that will
promote improved compliance and overall environmental performance (see Exhibit 1). EPA encourages regulated
entities to recognize compliance as the floor, rather than the ceiling, of environmental performance by
internalizing and implementing sound environmental practices. As part of that effort, EPA is encouraging the
development of self-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.

Over the years, EPA has encouraged regulated entities to initiate environmental audit programs that support and
document compliance with environmental regulations. EPA has developed this audit protocol to provide regulated
entities with specific guidance in periodically evaluating their compliance with federal environmental
requirements.
                               Exhibit 1-EPA's Credible Deterrent Goal        ';  •  „,
•       • ,     .!    - ,'   ' • !=    "'.•."""'                     •*  - ,     f  ',      '•* /       "         -ซ••••—
Within its Strategic Plan, EPA has established a goal to ensure full compliance vtfith the laws Intended to protect'
human health and the environment.  Within the framework of this goal, EPA's objectives are-as follows:   """.r,
    Identify and reduce significant non-compliance in high priority program areas, while maintaining a strong
    enforcement presence in all regulatory program areas,                     '
    Promote the regulated communities' voluntary compliance with environmental requirements through „ ;
    compliance incentives and assistance programs.                      -           ' •-         *  ,'.

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,
ป•   evaluating the effectiveness of in-place environmental management systems, and
ป•   assessing risks from regulated and unregulated materials and practices.
This document is intended solely for guidance. No statutory or regulatory
requirements are in anyway altered by any statement(s) contained herein.

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
the
non
                             **
                                 '•ExWbft 1^-lEPA's 1995 Aulft^oliey
                                     ~"*     "    •>' f  (    x *"-ซ jP<
                                                                                     *,: •'ซ"
"seriousness" or puni:iveportion0penalties^oyer and ab^oy^,1^'pc>rtiottreptefetti^g1he:e^^
i-compliance. The^olic^r^uireS compan|fes;; ^'V/^   ซ"vr 4-  -    **  **-*./^^-'"''  ! --   ^I'J^^ '
-^*^ ^••>*pซซpซป4''Iwr x3*i-i*^l>^rt>v *^*i*4 *^r'ป*ปซป^>y%'4-1t)'*y%irtl^ซ^ซซlซ.^ซ -^r^     S     * *"            i--^"'1""    ^       .-  ^ ซ ™
                                                                                                  -
                                                                                                  from
*""  to promptly disclose aidcfrrectviolafiqflS,^"^   ' 4
                       "                          '
    to remedy Environmental harnt/
                     *    f
 ••*•
 •
 ซ,';  'violations Aat may present an imminent anjaf-afe|(rojBtptIy •^di^c'losed an
             -                  '--      --'         .ซ
 As afesult ofEPA*$ new ayt^|t jtoHcy, th^oiil^ht;IvJarcll 1998,-247gomjprjiie| have J&ciosjg*d enwpnrneiiitaii ^  ^;j ^
 violations a^moife ttiant^^facilities and EP1A ha| rfeduced or waived penaltiesfor' 89;companies^ftd 433' "   , V
 In 1995, EPA published "Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of
 Violations" which both reaffirmed and expanded its 1986 audit policy. The 1995 audit policy offers major
 incentives for entities to discover, disclose and correct environmental violations. Under the 1995 policy, EPA will
 not seek gravity-based penalties or recommend criminal charges be brought for violations that are discovered
 through an "environmental audit" (as defined in the 1986 audit policy) or a management system reflecting "due
 diligence" and that are promptly disclosed and corrected, provided that other important safeguards are met (see
 Exhibit 2). These safeguards protect health and the environment by precluding policy relief for violations that
 cause serious environmental harm or may have presented imminent and substantial endangerment, for example.
   urpose of the Protocols for
                                                  nviroi
                                                                                 ^^::!ฃS?:1^^J
 This protocol, which is part of a set containing other area or statutory specific audit protocols, is a tool to assist
 you in conducting environmental audits, which should inform you whether your facility is in compliance with
 federal regulations. EPA has developed these audit protocols to assist and encourage businesses and organizations
 to perform environmental audits and disclose violations in accordance with EPA's audit policy. The audit
 protocols are intended to promote consistency among regulated entities when conducting environmental audits
 and to ensure that audits are conducted in a thorough and comprehensive manner.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.

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


 Each protocol provides guidance on key requirements, defines regulatory terms, and gives an overview of the
 federal laws affecting a particular environmental management area. It also includes a checklist containing
 detailed procedures for conducting a review of facility conditions. In order to use these documents effectively,
 you should be familiar with basic environmental auditing practices and the relevant environmental regulations
 under Title 40 of the Code of Federal Regulations (CFR). The audit protocols are not intended to be exclusive or
 limiting with respect to procedures that may be followed. EPA recognizes that other audit approaches and
 techniques may be effective in identifying and evaluating a facility's environmental status and in formulating
 recommendations to correct observed deficiencies.

 These protocols can be used as a basis to implement, upgrade, or benchmark environmental management
 activities. The protocols are a management tool for measuring and improving environmental performance by
 correcting deficiencies uncovered by the audit (see Exhibit 3). This process is perhaps 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 those breakdowns in management oversight, information
 exchange, and evaluation that allow environmental problems to recur. Thus, while an organization may have
 developed an excellent record of dealing with a symptom, such as spill response, the underlying problem or "root
 cause" has not been addressed. Furthermore, identifying the root cause of an audit finding can mean identifying
 not only the failures that require correction but also the successes. 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.
i"! 	 ",.i • • ' •.-" f
-, ' i
i
!
.. i
' ' - - . : • -\.
1 	 : 	
Exhibit 3 - Corrective Action Model
Audit
i
^

N
Improve
Environmental
Mgmt. System
Effectiveness
-
_
I L i i
Identify
Problems
1
Fix
Problems
Develop Actions
to Correct
Underlying
Causes



ซ

Analyze
Exceptions
for
Cause/Effect
*
Group Findings
for Common
Causes
Examine each
Group for
Underlying
Causes
/ ' *
^ * -, "* "" * r. ^ ™
"~ *f '
t "* /"f* * * ?
ft / / -s x
*-&f * * it <
1 " '< x. - — ' ' '/* ^ \
/, ',
* •?



To conduct effective compliance audits, the auditor or audit team needs to possess sound working knowledge of
the operations and processes to be reviewed, the relevant regulations that apply to a given facility, and of
acceptable auditing practices. The audit protocol should be used as a planning tool to assist the auditor in
understanding the requirements for conducting a comprehensive audit. This document will provide the user with a
generic audit approach to regulatory issues that may require closer examination.  Once the general issues are
identified through the use of this protocol, the auditor should perform a more detailed investigation to determine
the specific area of noncomplianceto be corrected. The auditor should review federal, state and local
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
iv

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


environmental requirements and annotate the protocol, as required, to include other applicable requirements not
included in the protocol.

The auditor also should determine which regulatory agency has authority for implementing an environmental
program so that the proper set of regulations is consulted. State programs that implement federally mandated
programs may contain more stringent requirements. This protocol should not be used as a substitute for the
applicable regulations.

The collective set of the audit protocols developed by EPA is 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. Each protocol is not intended to be an exhaustive set of procedures; rather it is
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 provide an effective means of identifying and assessing
facility environmental status and in developing corrective actions.

Each protocol contains the following information:
•   List of acronyms and abbreviations used in the document,
•   Applicability - provides guidance on the major activities and operations included in the protocol and a brief
    description of how the protocol is applied,
•   Review of federal legislation - identifies key issues associated with the subject protocol area,
•   State and local regulations - identifies typical issues normally addressed in state and local regulations but does
    not present individual state/local requirements,
•   Key compliance requirements - summarizes the overall thrust of the regulations for that particular protocol,
•   Key compliance definitions - defines important terms,
•   Typical records to review - highlights documents, permits and other pertinent paperwork that should be
    reviewed by an auditor and reconciled against regulatory requirements,
•   Typical physical features to inspect - highlights pollution control equipment, manufacturing and process
    equipment and other areas that should be visited and evaluated during an audit,
•   Index for checklist users - outlines different areas of the checklist that may pertain to the facility being
    audited,
•   Checklist - matches the regulatory requirements with the tasks that should be accomplished by the auditor,
    and
•   Appendices - supporting  information for the checklist (e.g., regulatory deadlines, lists of contaminants,
    wastes, and required testing procedures). Note: information contained in the appendices is dated and should
    be verified with a current version of the applicable federal regulations.

The checklist delineates 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.
Good management practices are distinguished from regulatory requirements in the checklist by the acronym (MP)
and are printed in italics.  The regulatory citation is given in parentheses after the requirement. 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.

 EPA is presently is the process of developing a series of audit protocol application guides to serve as companion
 documents to the set of protocols. The application guides will provide the auditor with a matrix that identifies and
 cross-references certain site-specific activities or unit operations with particular environmental aspects of that
 activity. For example, managing hazardous waste containers is a site-specific activity with environmental
 concerns, such as possible releases to air, and water, that may require additional review through auditing.  By
 using the application guide the user can identify facility specific practices that require more in-depth review. In
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in anyway altered by any statement(s) contained herein.

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


  addition, the application guides will also direct the user to specific protocols and sections (e.g., checklist items) of
  the protocol to determine areas that are regulated and require auditing.
                                                                                                    >J
 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
 PCS       Polychlorinated biphenyl
 PL        Public Law
 POTW     Publicly owned treatment works
 ppm       Part per million
 qt.         Quart
 RCRA     Resource Conservation and Recovery Act
 scf        Standard cubic foot
 scm       Standard cubic meter
 SDWA     Safe Drinking Water Act
This document is intended solely for guidance. No statutory or regulatory
requirements are in anyway altered by any statement(s) contained herein.
                                                                                                   VI

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under KCRA
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
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.
VII

-------
  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 statements) contained herein.
                                                                                            viii

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

                                              Section II
                                          Audit Protocol
This booklet 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).

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.
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 6921-6939b, 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 Environmental Protection Agency (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 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 EPA in a separate protocol titled Protocol for Conducting Environmental
Compliance Audits of Underground and Above Ground Storage Tanks and is expected to be available in 1999.

After assessing air emissions at TSDFs, the EPA ascertained that volatile organic chemicals (VOCs) adversely affect
human health and welfare.  In response, EPA promulgated three subparts of RCRA rules designed to control VOCs. In
 1990, 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.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.

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

 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 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 EPA regulations by
 reference or have promulgated regulations that are identical to the 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.
 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 statements) contained herein.

-------
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 one month 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: Using
    water, which weighs approximately 8.34 lbs./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 anyway altered by any statement(s) contained herein.

-------
 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
ฃ100 kg/mo (220.46
lb./mo)
ฃ1 kg/mo (2.20 lb./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 lb./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. (32 1.87 km)]
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
:MJG''i:V: -.•.' . "'"-'• -:: :....••;•: ••:.'• ; :.';..
Yes
>1,000 kg/mo (2,204.62
lb./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 +
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 statements) contained herein.

-------
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 an LQG, 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.

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;
ป   Characterization of waste generation and waste management costs;
•   Periodic waste minimization assessments;
•   A cost allocation system;
ป   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 pm, Monday through
Friday.

This 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.

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                  ,, Definitioni.	:	:,„:	;.    ~

Acknowledgement of Consent
The cable sent to the 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 EPA hazardous
waste numbers F020, F021, F022, F023, F026, and F027 (40 CFR 261.31) and the P listed wastes in 40 CFR 261.33(e).

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

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

Boiler
An enclosed device using controlled flame combustion and having the following characteristics:
•   The unit has physical provisions for recovering and exporting thermal energy in the form of steam, heated fluids, or
    heated gases; and
•   The unit's combustion chamber and primary energy recovery section(s) must be of integral design; and
•   While in operation the unit maintains a thermal energy recovery efficiency of at least 60 percent; and
•   The unit has been approved by the Administrator of EPA; and
•   The unit must export and utilize at least 75% of the recovered energy (40 CFR 260.10).
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).

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

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


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).

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).

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).

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 meet 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 EPA to each hazardous waste listed in Part 261, Subpart D and to each characteristic identified
in Part 261, Subpart C (40 CFR 260.10).

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

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).

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

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


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 or that exhibits a characteristic of hazardous waste (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:
*   The vapor pressure of one or more of the organic constituents in the material is greater than 0.3 kPa at 20 degrees
    Celsius, and
•   The total concentration of the pure organic constituents having a vapor pressure greater than 0.3 kPa at 20 degrees
    Celsius is equal to or greater than 20 percent by weight (40 CFR 265.1081).

Incompatible Waste
A hazardous waste that is unsuitable for:
•   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
•   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).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.

-------
Protocol 5or Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCKA


Industrial Furnace
Any of the following enclosed devices that are integral components of manufacturing processes and that use controlled
flame devices to accomplish recovery of materials or energy:  cement kilns; lime kilns; aggregate kilns; phosphate
kilns; coke ovens; blast furnaces; smelting, melting and refining furnaces; titanium dioxide chloride process oxidation
reactors; methane reforming furnaces; pulping liquor recovery furnaces; combustion devices used in the recovery of
sulfur values from spent sulfuric acid; certain halogen acid furnaces; and other devices designated by the Administrator
of EPA (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).

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

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


Manifest Document Number
The 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).

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.)

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).

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

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 or more efficient use.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.                                         10

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


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).

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).

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 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).

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).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
11

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


 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:
 *    Whether the waste is amenable to the treatment process,
 •    What pretreatment (if any) is required,
 *    The optimal process conditions needed to achieve the desired treatment,
 *    The efficiency of a treatment process for a specific waste or wastes, or
 •    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 toxicological and health effects studies. A treatability study is
 not a means to commercially treat or dispose of hazardous waste.

 Unsaturated Zone or Zone of Aeration
 The zone between the land surface and the water table (40 CFR 260.10).

 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).

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

-------
Protocol f OT Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA


Wastewater Treatment Unit
A device that (1) is part of a wastewater treatment facility subject to regulation under section 402 or 307 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).
    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.
    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.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
13

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                                                                                   •f *<*#!.ฃ


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 (LOG)
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
' , '" 4' i* t4" Ref
1 ' ' <6heckiist terns " ''
HW.1 through HW.4
HW.5 through HW.8
HW.9 through HW.14
HW.15 through HW.20
HW.21 through HW.22
HW.23 through HW.28
HW.29
HW.30 through HW.32
HW.33 through HW.37
HW.38 through HW.44
HW.45 through HW.46
HW.47 through HW.50
HW.51 through HW.62
HW.63 through HW.68
HW.69 through HW.78
HW.79
HW.80 through HW.82
HW.83 through HW.89
HW.90 through HW.95
HW.96 through HW.100
HW.101 through HW.107
HW.108 through HW.1 15
HW.1 16 through HW.121
HW.122 through HW.123
HW.124
WTO* " s, f . "
Page Numbers ^
15
16-17
18-20
20-22
22
22-23
24
24-25
25-27
28-29
30
31-32
32-43
43-48
49-54
55
55
56-59
59-62
62-63
64-67
68-69
70-71
71
72
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
14

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  .-•>  ^^;?4Jif^^
  All Facilities
  HW.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.

For those open items, indicate what corrective action is planned and milestones
established to correct problems.
  HW.2. Facilities are required to
  comply with state and local
  regulations concerning
  hazardous waste management.
Check 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.
   HW.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.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.
                                                                              15

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
        J	,'Jii
             Compliance Category:
         Hazardous Waste Management
   Regulatory Requirement or
                Practice:
 Reviewer Checks:
   All Sizes of Generators
   HW.5. Facilities that generate
   solid wastes must determine if
   the wastes are hazardous
   wastes (40 CFR 261.3,
   261.4{b), 261.24, and 262.11).
 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
 - A sample which is collected for the sole purpose of testing to determine
   characteristics or composition. (SW.846))

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

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

 Determine if the facility followed EPA criteria for identifying the characteristics of
 hazardous waste and EPA's listed wastes in 40 CFR 261 (see Appendices A, B, C,
 and D. Note: The appendices contained in this document are dated. Auditors
 should consult a current version of the regulations to ensure that accurate lists
 and other requirements are used for assessments.).

 Determine whether the facility generates, transports, treats, stores, or disposes of any
 hazardous waste (see Appendices A, B, C, and D for guidance) and the quantity.

 Waste documentation must be in facility records (40 CFR 262.40).

 (NOTE: The following are examples of solid wastes which are not considered
 hazardous wastes (40 CFR 261.3 and 261.4(b)):
 -  Household waste
 -  Fly ash waste, bottom ash waste, and flue gas emission control waste generated
   primarily from the combustion of coal or other fossil fuels except for facilities that
   bum hazardous waste
 -  Drilling fluids, produced waters and other wastes affiliated with the explorations,
   development, or production of crude oil, natural gas, orgeothermal energy.
 -  Solid waste which consists of discarded arsenic-treated wood or wood products
   which fail the test for Toxicity Characteristics for hazardous waste codes 0004
   through 0017 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 D018 through D043
   only) and are required to meet the corrective action regulations under 40 CFR part
   280
-  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-tern 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
   — any  other equivalent hot-draining method that will remove used oil.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                             16

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                                          aegoiyr   . ^.'      ,:  ,ซ,
  HW.5. (continued)
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.6. 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 CFR
  261.
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.7. 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.8. Generators must not
  offer thejr waste to transporters
  or TSDFs that have not received
  an EPA identification number
  (40CFR262.12(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 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.
                                                                             17

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                             Compliance Category:
                                         Hazardous Waste Management
   Regulatory Requirement or
         jment Practice:
 Reviewer Checks:
   Conditionally Exempt Small Quantity Generators (CESQG)
   HW.9. 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
   CFR261.5).
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 E) 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.

(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 Parts 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 Part 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.)

(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.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                         18

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                           ; Compliance Catigory:
  Regulatory Requirement or
  Management Practice:
• JR^vlewer Checks^sf*~
 "~            *
  HW.10. 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).
 Ensure 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.

 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.
  H W. 11. Training records should
  be maintained for all CESQG
  staff who manage hazardous
  waste (MP).
 Examine training records and verify they 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.
                                                                            19

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
iii 	 ', .. .'. , .'.....-; 	 Compliance Category:
i Hazairdlous Waste Management - "
Regulatory Requirement or
^MMwgjm^^t^tfee:'' M
HW.12. 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).
HW.13. Containers at CESQGs
should be managed in
accordance with specific
management practices (MP).
HW.14. Containers of
hazardous waste should be kept
in designated storage areas at
CESQGs (MP).
Reviewer Checks: - " ป v * J <• '
" u~ '
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 1 1 0 gal. (41 6.40 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 E, 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 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 3 ft. (0.91 m) of aisle space is provided between rows of containers.
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.)
Small Quantity Generators (SQGs)
Genera/
HW.15. 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).
Examine documentation from EPA for the facility's generator identification number.
Verify that correct identification number is used on all appropriate documentation (i.e.,
manifests).
This document is intended solely for- guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
20

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         ; -  Compliance Category:      -
                                         Hazardous Waste Management  ,;
  Regulatory Requirement or
  Management Practice:  v""
Reviewer Cheeks:
  HW.16. 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)(1), 262.34(d)(4),
  262.34(e) and 262.34(f)).
Inspect containers, storage, and records.

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.)
  HW.17. An SQG must not offer
  its hazardous waste to
  transporters or to TSDFs that
  have not received an EPA
  identification number (40 CFR
  262.12(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 EPA
regional office to confirm that these vendors have the appropriate EPA identification
number.
  HW.18. 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.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                          21

-------
 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.19. 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.)
  HW.20. 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.
  Personnel Training
  HW.21.  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.22.  Training records should
  be maintained for alt SQG staff
  who manage hazardous waste
  (MP).
Examine training records and verify they 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.
  Containers
  HW.23. 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 E, 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.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                          22

-------
Ptotocolfor Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  ReguIato;cy'RequIiซn|^t!,fci>r:J^ '
  •ฃ*ฃ"'   , ' -  V  * —S-ฑh „ *.tf  "***** , < :
                                 .ซ,' -. -}•:' >.SJk.' .T^'C-'ij-A'-' ":;& W-':"~' S :M ' fฃ' - •'*.' MC-y.—S-^i','-' '^S •<ป
  HW.24. 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.
  HW.25. 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.26. 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.27. 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 F 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.28. 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 3 ft. (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.
                                                                            23

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Compliance Category: . ' , ':
Hazardous Waste Management -
Regulatory Requirement or
Management Practice:
Reviewer Checks:
f J /$#* •<•
Satellite Accumulation Points
HW.29. 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
-------
Protocol 1or Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
* '"" ฃ'** /'"'-''' ' *''ST -' > ฃompBaซee Category,* ; ^ ' Mf ' ,^ /f r ; *'
%~ > fz J-; ss - -r .& *r/ >teปrdoX* Waste Management .i _*& ^ >!/'.,..*--''
Regulatory f^uMinentof8.^
Management Practice: ซ?* 'ฃ''
HW.31. 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).
HW.32. SQGs must conduct
weekly inspections of container
storage areas (40 CFR
262.34(d)(2) and 265.174).
iReviewejr' Checks:,, *" • "- * ,, ^ . -* ฃ/. •."<-- "l" / "' ซ
ฃ N - ; j ,•& ,' „ ซ**. ->,? ,_• f. „/ ,,•ป; „, ป* __ \ \*^-
^ v'l' ' / '* ^* " -^ ' ASt ,5* "' 	 fff 	
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.
Review procedures employed by facility management to familiarize police, fire
departments, and emergency response teams with the layout of the facility, properties
of the waste being handled, and general operatibns as appropriate for the type of
waste and potential need for such services.
Review procedures employed by facility management to familiarize local hospitals 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.
(NOTE: Where state or local authorities decline to enter into arrangements, the facility
must document this refusal in the operating record.)
Verify that inspections are conducted at least weekly to look for leaking containers and
signs of deterioration of containers.
Disposal of Restricted Wastes
HW.33. SQGs must test their
wastes or use process
knowledge to determine if they
are restricted from land disposal
(40 CFR 268.7(a)(1)).
HW.34. 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)).
Determine whether the generator determines if wastes have to be treated prior to
disposal.
Determine if the facility generates restricted wastes (see Appendix G) by reviewing
test results or reviewing procedures employed by facility management where process
knowledge was applied in making the waste determinations.
(NOTE: EPA is changing the notification requirement under 40 CFR 268.7 to a one-
time notification and certification if the composition of the wastes, the process
generating the wastes, and the treatment facility receiving the waste do not change
(see FR Vol. 62, No. 91, May 12, 1997; pg. 26004).)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
25

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                             Compliance Category;
                                         Hazardous Waste Management
!  Rซguiatory Requirement or
  Management Practice:
Reviewer Checks:
  HW.34 (continued)
Verify that, for waste or soil which does not meet the applicable treatment standards or
exceeds the applicable prohibition levels, the notice is issued and includes:
- The EPA hazardous waste code and manifest numbers
- The waste is subject to the LDRs and the 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.)
- Whether the waste is a nonwastewater or wastewater
- The subcategory of the waste determination, if applicable
- For hazardous debris, when treating with the alternative treatment technologies
  provided in 40 CFR 268.45, the contaminants subject to treatment, as described in
  268.45(b), and an indication that these contaminants are being treated to comply
  with 268.45.
- For contaminated soil subject to LDRs provided in 40 CFR 268.49(a), the
  constituents subject to treatment described in 268.49(d), and the following
  statement: "This contaminated soil [does/does not] exhibit a characteristic of
  hazardous waste and is [subject to/complies with] the soil treatment provided in
  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:
- The EPA hazardous waste code and manifest numbers
- The waste is subject to the LDRs and the 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 notice.)
- Whether the waste is a nonwastewater or wastewater
- The subcategory of the waste determination, if applicable
- For contaminated soil subject to LDRs provided in 40 CFR 268.49(a), the
  constituents subject to treatment described in 268.49(d), and the following
  statement: "This contaminated soil [does/does not] exhibit a characteristic of
  hazardous waste and is [subject to/complies with] the soil treatment provided in
  268.49(c) or the universal treatment standards."
- Waste analysis data, when available
- 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(3)0)).

Verify that, for restricted waste which is 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:
- The EPA hazardous waste code and manifest number
- Statement that this waste is not prohibited from land disposal
- Waste analysis data, when available
- The date the waste is subject to the  prohibition
- For hazardous debris, when treating with the alternative treatment technologies
  provided in 40 CFR 268.45, the contaminants subject to treatment, as described in
  268.45(b), and an indication that these contaminants are being treated to comply
  with 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 3 years after the termination or expiration of the
agreement.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                            26

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                                         .
                                         Hazardous Waste Management ^
                                                                                                           '
  Regulatory Requirement or
  Management Practice:    --
                                Reviewer Checks:
  HW.35. 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 3 years after the termination or expiration of the
                                agreement.)
  HW.36. 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
                                 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.37. 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.
                                                                                                               27

-------
 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)
  General
  HW.38. A generator that
  generates, transports, or
  handles hazardous wastes must
  obtain an EPA identification
  number (40 CFR 262.12(a) and
  262.12(b)).
Examine documentation from EPA for the facility's generator identification number.

Verify that the correct identification number is used on all appropriate documentation
(i.e., manifests).
  HW.39. 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)).
Inspect each 90 day storage area and interview the storage area manager. Verify that:
- 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 265.111 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.40. Generators must not
  offer their waste to transporters
  or TSDFs that have not received
  an EPA identification number
  (40 CFR 262.12(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 EPA
regional office to confirm that these vendors have the appropriate EPA identification
number.
  HW.41. 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 8700-13A) 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.42. 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.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in anyway altered by any statements) contained herein.
                                                                          28

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

  HW.43. Generators are required
  to keep records of waste
  analyses, tests, and waste
  determinations (40 CFR
  262.40(c)).
  HW.44. 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).
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.)
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.

 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.

 Review procedures employed by facility management to familiarize police, fire
 departments, emergency response teams 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.

 Review procedures employed by facility management to familiarize the hospital with
 the site and the types of injuries that could result in an emergency as appropriate for
 the type of waste and potential need for such services.

  (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.
                                                                              29

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                              Compliance Category:
                                          Hazardous Waste Management
   Regulatory Requirement or
            lent Practice:
 Reviewer Checks:
   Personnel Training
   HW.45. 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)).
 Ensure 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.

 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 js 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.
  HW.46. 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)).
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.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                            30

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Contingency Plans and Emergency Coordinators
  262.34(a)(4) and 40 CFR
  265.50 through 265.54).
HW47 Generators must have a  I  (NOTE: Generating activities may be addressed in thei facility's> SPCC plan or other
contingency plan (40 CFR         emergency plan, or if none exists, ,n a separate contmgency 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

                                -  NameTaddresses, 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 oreleases of
                                    hazardous constituents or changes the response  necessary in an emergency
                                 - The list of emergency coordinators changes
                                 - The list of emergency equipment changes.
    HW.48. 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 facihty,
                                 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.       	
   This document is intended solely for guidance. No statutory or regulatory
   requirements are in any way altered by any statement(s) contained herein.
                                                                                                              31

-------
  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.49. 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(i)).
 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 EPA, and appropriate state and local authorities that the facility is in
   compliance with 40 CFR 265.56(h) before operation resumes.
   HW.50. 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
   265.56(j)).
Review facility operating records to determine if incidents have been recorded and
corrective actions taken.

Verify that written reports have been submitted to the regulatory agency within 15 davs
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.
                                                                                                           32

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCKA
'"" - "- ซ.„>- .p >>^ >•" ,"-.fdomi>ndnceCafeg,ory; - ' •*> j1/^ 1^ X4;* , ** 7:
< "'' ^ ' ^ ? > '* c ^MaaardousWaite^Manag^nt , ^'^ ' •"-.!•/ - ?: ">"*"• <" 4f '
Regulatory Requirement or, _
Management Practice:
Reviewer QJjeeks: ,vf ^ ,Jr' *i ,1 , -'^Chjt J'^tt*^v^r r-~" ' ''
Containers
HW.51 . 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).
HW.52. Containers used to
store hazardous waste at
generators must be in good
condition and not leaking (40
CFR 262.34(a)(1)(i) and
265.171).
HW.53. Containers used at
generators must be made of or
lined with materials compatible
with the waste stored in them
(40 CFR 262.34(a)(1)(i) and
265.172).
HW.54. Containers must be
closed during storage and
handled in a safe manner at
generators (40 CFR
262.34(a)(1)(i) and 265.173).
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 1 1 0 gal. (41 6.40 L), no more than 3 percent
by weight of total container capacity remains, or
- When the container is greater than 1 1 0 gal. (41 6.40 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 E, 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.
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.
Verify that containers are compatible with waste. For example, check that strong
caustics and acids are not stored in metal drums.
Verify that containers are closed except when it is necessary to add or remove waste
(check bungs oh drums, look for funnels).
Verify that handling and storage practices do not cause damage to the containers or
cause them to leak.
  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
33

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Compliance Category:
Hazardous Waste Management ^-'' ,
Regulatory Requirement or
Management Practice:
HW.55. The handling of
incompatible wastes, or
incompatible wastes and
materials in containers at
generators must comply with
safe management practices (40
CFR262.34(a)(1)(i)and
265.177).
HW.56. Containers used to
store hazardous waste at
generators should be managed
In accordance with specific
management practices (MP).
Reviewer Checks: ', " ""''<*"
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 F, 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.
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 3 ft. (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.
34

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators untfer RCKA
                                        -; ~ Compliance Category;^, *   ;
                                         Hazardous Waste Management
  Regulatory Requirement pr
  MariagemeW Practice?-,.'' ' "*
Reviewer Checks:
     Sr      ^   s&-~
       t     ~ t *    f
  HW.57.  Containers with design
  capacities greater than 0.1 m
  [-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)(1)(i), 265.178,
  265.1087(a) through
  265.1087(b)(1)(i), and
  265.1087(c)).
(NOTE: The requirements of 40 CFR 265.1087 do not apply to containers in which all
the hazardous waste entering the container meets one of the following (40 CFR
265.1083(c)):
-  The average VO concentration of the hazardous waste at the point of waste
   origination is less than 500 ppmw
-  The organic content of the hazardous waste entering the waste management unit
   has been reduced by an organic destruction or removal process
-  The waste meets the numerical concentration limits for organic hazardous
   constituents as specified in 40 CFR 268.40 or has been treated by the treatment
   technology established by the regulatory agency for the waste in 268.42(a) or an
   equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(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.)

(NOTE: Standards for containers used in waste stabilization processes (40 CFR
265,1087(b)(2)) are in checklist item HW.59.)

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 shutdown of the
      process generating the material being added to the container, whichever
      condition occurs first.
  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
                                                                             35

-------
  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.57. (continued)
 - 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.58. 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)(1)(i), 265.178, and
   265.1087(a) through
   265.1087(b)(1)(ii).
   265.1087(b)(1) (iii), 265.1087(c),
   and 265.1087(d)).
 (NOTE: The requirements of 40 CFR 265.1087 do not apply to containers in which all
 the hazardous waste entering the container meets one of the following (40CFR
 265.1083(c)):
 -  The average VO concentration of the hazardous waste at the point of waste
   origination is less than 500 ppmw
 -  The organic content of the hazardous waste entering the waste management unit
   has been reduced by an organic destruction or removal process
 -  The waste  meets the numerical concentration limits for organic hazardous
   constituents as specified in 40 CFR 268.40 or has been treated by the treatment
   technology established by the regulatory agency for the waste in 268.42(a) or an
   equivalent method approved by the regulatory agency pursuant to 268.42(b).)

 (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.)

 (NOTE: Standards for containers used in waste stabilization processes (40 CFR
 265.1087(b)(2)) are in checklist item HW.59.)

 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.
                                                                           36

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                         „-"  tjompHuBCf'CategoiVjj   -  -  -
                                         HazardbyfeWaste Management     ,;
  Regulatory Requirement or
  Management practice:  -' •
Reviewer'Checks:
                                                                                     3V
                                                                                     <ฃ
  HW.58. (continued)
Verify that, for containers with a design capacity greater than 0.46 m [-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 months 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 material will be
        removed within 15 minutes
      — 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.
  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statements) contained herein.
                                                                              37!

-------
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.58. (continued)
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.59. Containers with design
  capacities greater than 0.1 m
  [~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)(1)(i), 265.178.
  265.1087(a) through
  265.1087(b)(2), and
  265.1087(e)(1) through
  265.1087(e)(3)).
(NOTE: The requirements of 40 CFR 265.1087 do not apply to containers in which all
the hazardous waste entering the container meets one of the following (40 CFR
265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
  origination is less than 500 ppmv
- The organic content of the hazardous waste entering the waste management unit
  has been reduced by an organic destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
  constituents as specified in 40 CFR 268.40 or has been treated by the treatment
  technology established by the regulatory agency for the waste in 268.42(a) or an
  equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(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.)

(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.62).
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                           38

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under KCRA

  HW.60.  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)(1)(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.)

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 year or more, it is
  visually inspected at least once every 12 months 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.)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                             39

-------
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.61. Facilities are required
  to meet documentation
  requirements for containers (40
  CFR 262.34(a)(1)(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.)

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 permanent total
   enclosure as specified ih 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-month 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-month period, including the type of
     maintenance performed and the total number of hours during those 6-months
     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 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.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                            40

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                ^iflfPiW >^: ^i-:jSf'^i ;^|i%S' 'ฃ$j$*$&ijj?- '':*'•
  HW.61. (continued)
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.57 through HW.62), 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 self-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.65.)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                         41

-------
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.62.  Facilities are required
  to meet specific requirements
  for closed-vent systems and
  control devices used to achieve
  compliance (40 CFR
  262.34(a)(1)(i), 265.178, and
  265.1088).
(NOTE: The requirements of 40 CFR 265.1088 do not apply to containers in which all
the hazardous waste entering the container meets one of the following (40 CFR
265.1083(c)):
- The average VO concentration of the hazardous waste at the point of waste
  origination is less than 500 ppmw
- The organic content of the hazardous waste entering the waste management unit
  has been reduced by an organic destruction or removal process
- The waste meets the numerical concentration limits for organic hazardous
  constituents as specified in 40 CFR 268.40 or has been treated by the treatment
  technology established by the regulatory agency for the waste in 268.42(a) or an
  equivalent method approved by the regulatory agency pursuant to 268.42(b).)

(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.)

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 265.1033ฎ (see checklist
  item HW.64)
- 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.64)
- A flare designed and operated in accordance with 40 CFR 265.1033(d) (see
  checklist item HW.64).

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.
                                                                           42

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
    gulplory.-R^ujreirffertilb^^
  HW.62. (continued)
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.64)
- 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.64).

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.
  Emissions from Process Vents
  HW.63. 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)(1)( 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.)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                            43

-------
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.64.  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)(1)(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
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
  M J/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.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                           44

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                          ,
                                         Hazardoui Waste Management
  Regulatory Requwementor*
              '
Reviewer Checks:
  HW.64. (continued)
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
  -  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.
                                                                              45

-------
 Protocol for Conducting Environmentai Compliance Audits of Hazardous Waste Generators under RCRA
                                              Compliance Category:
                                          Hazardous Waste Management
  Regulatory Requirement or
  Management Practice:
 Reviewer Checks:
  HW.64. (continued)
 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.65. Generators are
  required to maintain specific
  records pertaining to process
  vent emissions (40 CFR
  262.34(a)(1)(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.

Verify that records of monitoring operations and inspection information are kept for 3
years.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                            46

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

            : Requirement or,
            MtiO&i&iSiMA*'""*/ ซ
  HW.66.  Closed-vent systems
  are required to be monitored,
  inspected, and leaks repaired
  (40CFR262.34(a)(1)(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 40 CFR
      265.1034(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, portions
 of the system designated as unsafe to monitor are exempt from the visual monitoring

 -  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.)	
  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
                                                                              47

-------
 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.67. 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)(1)(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.68. 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)(1)(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
-  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 statements) contained herein.
                                                                          48

-------
Protocol Tor Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                ""Reviewer <5irfe<$csi>ll:
                                 *     '  "•    *""' "'' '  • s"?'
  Management Practice: ->
  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.69. 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)(1)(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 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. 	
  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statements) contained herein.
                                                                             49

-------
 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.69. (continued)
 (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.70. 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)(1)(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.

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.71.  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)(1)(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.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                           50

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  HW.72.  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)(1)(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,

(NOTE: In-situ sampling systems are exempt from these requirements.)
  HW.73. 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)(1)(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.74. 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)(1)(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.)               	
 ' This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                             51

-------
 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.74. (continued)
 (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.78.)

 (NOTE: Valves that are designated as difficult to monitor are exempt from the
 requirement for monthly monitoring if:
 -  The valve cannot be monitored without elevating the monitoring personnel more
   than 2 meters 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.75. 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
  (40CFR262.34(a)(1)(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
- Tightening of packing gland nuts
- Injection of lubricant into lubricated packaging.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                           52

-------
Protocol 
-------
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.76. (continued)
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.77.  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)(1)(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.69 through HW.76) is marked so that it can
be distinguished from other equipment.
  HW.78. When a generator has
  elected to comply with
  alternative standards, specific
  actions are required (40 CFR
  262.34{a)(1)(i) and 265.1061).
Determine if the owner/operator subject to 40 CFR 265.1057 (see checklist item
HW.74) 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.
                                                                          54

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
i ii%sSlฃ^|KIP^^ ^ -ff^ ;{!-ซ^f; : ฃ
S4'gMlaBr^|4quiri*tt^nWoraI6^
.;Mar^Biistf nt Pi^ftf^' ,-J. j:'. ;
^•^jc^pjric^if ";; W^ff'^:^ '/S^'^S^^:^^1': - if $f •'
Satellite Accumulation Points
HW.79. 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, D, and E 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.
Container Storage Areas
HW.80. At generators,
containers of hazardous waste
should be kept in designated
storage areas (MP).
HW.81 . Containers holding
ignitable or reactive waste must
be located 15 m (50 ft.) from the
property line of the facility (40
CFR262.34(a)(1)(i)and
265.176).
HW.82. Generator personnel
must conduct weekly
inspections of container storage
areas (40 CFR 262.34(a)(1)(i)
and 265.1 74).
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.)
Determine the distance from storage containers holding ignitable or reactive waste to
the property line.
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.
55

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                             Compliance Category:
                                         Hazardous Waste Management
  Regulatory Requirement or
  Management Practice:
Reviewer Checks:
  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.83. 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)(1)(iv) and
  265.1100).
Verify that the containment building meets the following:
-  It is a completely enclosed, self-supporting structure that is designed and
   constructed of manmade 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.84. Containment buildings
  are required to be designed
  according to specific standards
  (40CFR262.34(a)(1)(iv),
  265.1101(a)(1). 265.1101(a)(2),
  265.1101 (a)(4), and
  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
-  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.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                             56

-------
PTO\OCO\ 1or Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                             Compliance
                                         Hazardous Waste Management
  Regulatory Requirement or
  Management Practice:
Reviewer Checks:
  HW.84. (continued)
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 inches (30.5 cm) or more, or
     constructed of synthetic or geonet drainage materials with a transmissivity of 3 x
     10"5m2/secormore
- 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.)

(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)(1) and (2), and 264.193(d).)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
                                                                            57

-------
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.85. Containment buildings
  are required to be operated
  according to specific standards
  (40CFR262.34(a)(1)(iv),
  265.1101 (a)(3). 265.1101(c)(1),
  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
-  Particulate 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.
  HW.86. Containment buildings
  are required to be certified by a
  registered professional engineer
  (40 CFR 262.34{a)(1)(iv) and
  265.1101 (c)(2)).
Verify by reviewing the documentation that the building has been certified.
  HW.87. Leaks in containment
  buildings must be repaired and
  reported (40 CFR
  262.34(a)(1)(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.
This document is intended solely for guidance. No statutory or regulatory
requirements are in anyway altered by any statements) contained herein.
                                                                            58

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
' ' ^Si'-m-M''^'^ JSfrJsMftlS^^^
^ Re'gaHafory,iMequire"iife:ntior^~ .':*
„ .. *" , ,~.^?/i* \,^,'^,, ™' ,V-K &>jtji^,, _, j. ; „ j- i-^-
, ;JMan.ag|mert| Prac|cฃ: J ^ jg
HW.88. Containment buildings
that contain both areas with and
without secondary containment
must meet specific requirements
(40CFR262.34(a)(1)(iv),
264.1101(d), and 265.1101(d)).
HW.89. When a containment
building is closed, specific
requirements must be met (40
CFR 262.34(a)(1)(iv), 264.1102,
and 265.1102).
i^^irj^^SJ: ?$jฃ ^.jfijf'W J^S^0;^^;^^B?l|t
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.
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.
Disposal of Restricted Wasfe
HW.90. Facilities that generate
hazardous wastes must test
their wastes or use process
knowledge to determine if they
are restricted from land disposal
(40 CFR 268.7).
Determine whether the generator tests for restricted wastes.
Determine if the facility generates restricted wastes by reviewing test results or
reviewing procedures employed by facility management where process knowledge
was applied in making the waste determination.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
59

-------
 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.91. When a generator is
  managing a restricted waste, a
  notice must be issued to the
  TSDF in writing of the
  appropriate treatment standards
  and prohibition levels (40 CFR
  268.7(a)(2) through 268.7(a)(4),
  and268.7(a)(10)).
 (NOTE: EPA is changing the notification requirement under 40 CFR 268.7 to a one-
 time notification and certification if the composition of the wastes, the process
 generating the wastes, and the treatment facility receiving the waste do not change
 (see FR Vol. 62, No. 91, May 12,1997; pg. 26004).)

 Verify that, for waste or soil which does not meet the applicable treatment standards or
 exceeds the applicable prohibition levels, the notice is issued and includes:
 -  The EPA hazardous waste code and manifest numbers
 -  The waste is subject to the LDRs and the 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)
 -  Whether the waste is a nonwastewater or wastewater
 -  The subcategory of the waste determination, if applicable
 -  For hazardous debris, when treating with the alternative treatment technologies
   provided in 40 CFR 268.45, the contaminants subject to treatment, as described in
   268.45(b), and an indication that these contaminants are being treated to comply
   with 268.45.
 -  For contaminated soil subject to LDRs provided in 40 CFR 268.49(a), the
   constituents subject to treatment described in 268.49(d), and the following
   statement: "This contaminated soil [does/does not] exhibit a characteristic of
   hazardous waste and [is subject to/complies with] the soil treatment provided in
   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:
 -  The EPA hazardous waste code and manifest numbers
 -  The waste is subject to the LDRs and the 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 notice.)
 -  Whether the waste is a nonwastewater or wastewater
 -  The subcategory of the waste determination, if applicable
 -  For contaminated soil subject to LDRs provided in 40 CFR 268.49(a), the
   constituents subject to treatment described in 268.49(d), and the following
   statement: "This contaminated soil [does/does not] exhibit a characteristic of
   hazardous waste and [is subject to/complies with] the soil treatment provided in
   268.49(c) or the universal treatment standards."
 -  Waste analysis data, when available
 -  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(3)(i)).

 Verify that, for restricted waste which is 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:
-  The EPA hazardous waste code and manifest number
-  Statement that this waste is not prohibited from land disposal
-  Waste analysis data, when available
-  The date the waste is subject to the prohibition
-  For hazardous debris, when treating with the alternative treatment technologies
   provided in 40 CFR 268.45, the contaminants subject to treatment, as described in
   268.45(b), and an indication that these contaminants are being treated to comply
   with 268.45.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                           60

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCKA
                           X-*"
       -   . Compliance Category; / „
        Hazardous Waste Management
  Regulatory Requirement orW
  SfariagemenฅJ*ractice:*   •ซ /
Reviewer Checks:
  HW.92. 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.93. Generators are required
   to keep specific documents
   pertaining to restricted wastes
   on-site (40 CFR 268.7(a)(5)
   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 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 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.94. 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.

 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.	
   This document is intended solely for guidance. No statutory or regulatory
   requirements are in any way altered by any statement(s) contained herein.
                                                                               61

-------
  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.95. 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 RGBs 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.
   Transportation of Hazardous Waste
   HW.96. 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 and 263.22(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 bv
 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.
                                                                                                            62

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCKA
  MMnagerri'entePractice:  ;
  HW.97. 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.

Inspect a sample of containers awaiting transport to verify that containers are properly
constructed and exhibit no leaks, corrosion, or bulges.

Examine end-seams for minor weeping that indicates drum failure.

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.98. 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.99. 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.100. 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
 -  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.
                                                                             63

-------
  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
   Exports of Hazardous Waste for Recovery within the OECD Member Countries
   HW.101.  A U.S. Notifierthat
   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 EPA
 promulgated its OECD regulations in 1996: South Korea, Czech Republic, Poland, and
 Hungary. EPA plans to amend its regulations to reflect these new OECD countries  In
 the interim, 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 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 notitler
 - 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 list
   code), descriptions of each waste type, estimated total quantity of each, RCRA
   waste code, and United Nations number for each waste type and
 -  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.)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                           64

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
               ,4-5
  '!,-'"" ,  Compliance Category:-?
  ฃ~'  hazardous Waste Management
            *•       S'      **      --vSป
  Regulatory Requirement or
  Wanagetneซt Practice^   -
Reviewer Checks:
 •C.  *>''-„  -)„•"  ,
                   •W*
  HW.101. (continued)
(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 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.)

For amber list wastes, verify that 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.

For red list wastes, verify that written consent was received from the importing country
and any transit countries prior to export.
  HW.102.  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 and
-  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
-  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 and
-  Provisions for financial guarantees.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                                             65

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                              Compliance Category:
                                         : Hazardous Waste Management
   RsguJatory Requirement or
   Management Practice:
 Reviewer Checks:
   HW.103.  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.)

   and
-  Appropriate signatures for each custody transfer.
  HW.104. A U.S. notifier must
  comply with special manifest
  requirements (40 CFR 262.84(c)
  and 262.54(a), (b). (c), (e), and
  (9).
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 and
- 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.
This document is intended solely for guidance. No statutory or regulatory
requirements are in anyway altered by any statement(s) contained herein.
                                                                                                           66

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                        r'  Cowplifoce Category:  "  ;,-
                                        Hazardous Waste Management
  Regulatory Requirejrieiritdr
  Management Practice*    -
  HW.105. A primary exporter
  must file an annual report with
  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.

Randomly check several annual reports to determine whether they contain the
following information for all hazardous waste exported for recovery during the previous
year:
- 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 and
- 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.106.  A primary exporter
  must file an exception report with
  EPA under certain
  circumstances (40 CFR
  262.87(b)).
 Verify that an exception report is filed with EPA each time any of the following 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
 -  The waste is returned to the U.S.
  HW.107. A primary exporter
  must maintain records that relate
  to export activities (40 CFR
  262.87(c)).
 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 3 years from the due date of the report), and
 -  Any exception reports and each confirmation of delivery received from the recovery
   facility (at least 3 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.
                                                                            67

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                              Compliance Category;
                                          Hazardous Waste Management
   Regulatory Requirement or
   Management Practice:
  Reviewer Checks:
   Exports of Hazardous Waste (Except to the OECD Member Countries) for Recovery
   HW.108. 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 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.109. The primary exporter
  must attach a copy of an 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 EPA Acknowledgment of Consent is on file by checking the
 records.

 Verify that a copy of this document was attached to the shipment.
  HW.110. 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.111, 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(0).
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 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.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                                                           68

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under KCRA
                                         i'i   Compliance Category;
                                         Hazardous Waste Management
  Regulatory Requirement or "
  Management^ractice:",   ?f
'Reviewer^cheeks:i
-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
                                            Compliance Category:
                                        Hazardous Waste Management
  Regulatory Requirement or
  Management Practice:
Reviewer Checks:
  Imports of Hazardous Waste for Recovery Within the OECD Member Countries
  HW.116. 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 EPA
promulgated its regulations in 1996: South Korea, Czech Republic, Poland, and
Hungary. EPA plans to amend its regulations to reflect these new OECD countries. In
the interim, 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 and
- 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
- Notification prior to re-export to a third country and
- Provisions for financial guarantees.
  HW.117. 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, if 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) and
- 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 statements) contained herein.
                                                                          70

-------
Pvotoeol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA

/RegMlatoBf'^eqiailprt^rttol-'J^
Management ^|l^:f',,J^||jง?:;'
HW.118. A consignee must
comply with general manifest
requirements with certain
modifications (40 CFR 262.84(c)
and 262.60).
HW.119. 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)).
HW.1 20. An owner/operator of a
U.S. recovery facility must send
signed copies of the tracking
document to the notifier, to EPA,
and to the competent authorities
of the exporting and transit
countries within three days of
receipt of imports (40 CFR
262.84(e)).
HW.121. A facility that has
arranged to receive hazardous
waste from a foreign source
must notify EPA (40 CFR
264.12(a)(1) and 265.12(a)(1)).

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 and
- 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.
Verify that the U.S. transporter, consignee, and owner or operator of the recovery
facility have signed the manifest.
Verify that the facility sends signed copies of the tracking document to the notifier, to
EPA, and to the competent authorities of the exporting and transit countries within the
three days.
Verify that the facility notifies the appropriate 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.)
Imports of Hazardous Waste (Except from the OECD Member Countries) for Recovery
HW.1 22. Any person who
imports hazardous waste must
comply with general manifest
requirements with certain
modifications (40 CFR 262.60).
HW.1 23. A facility that has
arranged to receive hazardous
waste from a foreign source
must notify EPA (40 CFR
264.12(a)(1) and 265.12(a)(1)).
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 and
- 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.
Verify that the facility notifies the appropriate 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.
71

-------
 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.124. 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.
Review the generator's waste minimization program to determine if the program
includes practical methods for reducing the volume of hazardous wastes generated.
Determine whether any or all of the following methods suggested by 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.
                                                                         72

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

                      Appendix A:
        Identification and Listing of Hazardous Waste
              (40 CFR 261.30 through 261.31)

-------
THIS PAGE INTENTIONALLY LEFT BLANK

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)	
                      Table 1 - Hazardous Waste from Nonspecific Sources
Industry and
USEPA Hazardous
Waste Number
F001
F002
F003
F004
F005
F006
F007
F008
F009
F010
F011
F012
F019
F020
, • - . u' * ~jV, „ ,/r •.
-,- • ' -„ -,, **c- ^ -.•-.-- ,- ' <>
y * / - * * 7 ฐU$ ! ,- ' M ~" "" ^p '-*" .< ^
Hazardous Waste - ,-i! -" ' 3*! - '* „*• 
"C ', - x , ' &V- '•' ''< ' "" ^ '* /' '
' <|<- _- , S s, ,fkJ. > .. _ > ~ - ' 4~ if p "-y ','& !•"!>
The spent halogenated solvents used in degreasing. Trichloroethylene, methylene chloride, 1,1,1-
trichloroethane, carbon tetrachloride, and the chlorinated fluorocarbons; all spent solvent mixtures
or blends used in degreasing containing before use, a total often percent or more (by volume) of
one or more of the above halogenated solvents listed in F002, F004, F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
The following spent halogenated solvents: tetrachloroethylene, methylene chloride,
trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, l,l,2-trichloro-l,l,2-trifluoroethane,
ortho-dichlorobenzene, trichlorofluorometharie, and 1,1,2-trichloroethane; all spent solvent
mixtures or blends containing, before use, a total often 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.
The spent nonhalogenated solvents, xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether,
methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; and the still bottoms from
the recovery of these solvents and spent solvent mixtures.
The spent nonhalogenated solvents, cresols and cresylic acid, and nitrobenzene; and the still
bottoms from the recovery of these solvents.
The following spent nonhalogenated solvents: toluene, methyl ethyl ketone, carbons disulfide,
isobutanol, pyridine, benzene, 2-ethoxylethanol, and 2-nitropropane; all spent solvent mixtures or
blends containing, before use, a total often percent or more by volume of one or more of the
above nonhalogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms
from the recovery of these solvents.
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.
Spent cyanide plating bath solution from electroplating operations.
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 from use of tri-, or tetrachlorophenol, or intermediates used to produce its pesticide
derivatives. **
Hazard
Code*
i_ L
(t)
(t)
(0
(t)
ftt)
(t)
(r,t)
(r,t)
(r,t)
(r,t)
fct)
(t)
(t)
(h)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
A1

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)	
Industry and
USEPA Hazardous
Waste Number
F021
F022
F023
F024
F025
F026
F027
F028
F032
F034
F035
Hazardous Waste
Wastes of pentachlorophenol, or intermediates used to produce its derivatives. **
Wastes, of tetra-, penta-, or hexachlorobenzenes under alkaline conditions. **
Wastes, of tri- and tetrachlorophenols. **
Wastes, including but not limited to distillation residues, heavy ends, tars and reactor cleanout
wastes from the production of chlorinated aliphatic hydrocarbons, utilizing free radical catalyzed
processes having carbon chain lengths from one to five, (Omits light ends, spent filters and filter
aids, spent desiccants, wastewater, wastewater treatment sludges, spent catalysts and wastes listed
in 40 CFR 261.32).
Condensed light ends, spent filters 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 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 (does not include
hexachlorophene synthesized from prepurified 2,4,5-trichlorophenol as the sole component.
Residues from incineration or thermal treatment of soil contaminated with EPA hazardous waste
Nos. F020, F021, F022, F023, F026 and F027.
Wastewaters (except those that have not come into contact with process contaminants), process
residue, preservative drippage, and spent formulations from wood preserving processes generated
at plants that currently use of have previously used chlorophenolic formulations (except potentially
cross-contaminated wastes that have had the F032 waste code deleted in accordance with 261.35
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 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 sludge from
the treatment of wastewater from wood preserving processes that use creosote and or
pentachlorophenol.
Wastewaters (except those that have 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*
00
00
(t)
(t)
(t)
00
00
(t)
(t)
(t)
(t)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
A2

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)	
                       lazardous Waste
 ndustry and
USEPA Hazardous
Waste Number
  F037
                      ^^^^•^^^^••^^^^•i^^^^—^^—^—
                     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 oily cooling wastewaters from petroleum refiners.  This includes, but is not limited to, sludges
                     generated in: oil/water/solids separators; tanks and impoundments; ditches and other conveyances;
                     sumps; and stormwater units receiving dry weather flow.

                     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 generated in aggressive biological treatment units*** (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.	^^
Hazard
Code*
  F038
                     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*** (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.                                                            	
                                                                                                                (t)
   F039
                      Leachate (liquids that have percolated through land disposed wastes) resulting from the disposal of
                      more than one restricted waste classified as hazardous under 40 CFR 261 Subpart D.

                      (Leachate resulting from the management of one or more of the following wastes and no other
                      hazardous waste retains its hazardous waste number(s): F020, F021, F022, F023, F026, F027,
                      and/or F028.)
  NOTE- The listing of wastewaters that have not come into contact with process contaminants is stayed administratively. The listing for
  plants that have previously used chlorophenolic formulations is administratively stayed whenever these wastes are covered by the F034 or
  F035 listings. These stays will remain in effect until further administrative action is taken.
  * Hazard Codes:
       t = toxic waste
       i = ignitable waste
       r = reactive waste
                                     h = acute hazardous waste
                                     c = corrosive waste
                                     e = toxicity characteristic waste
  ** (except wastewater and spent carbon from hydrogen chloride purification) the manufacturing or production use: as a reactant, chemical
  intermediate, or component in a formulating process. The listing for F020 and F023 does not include wastes from the production of
  hexachlorophene from highly purified 2,4,5-trichlorophenol.

  *** Aggressive biological treatment units are defined as units which employ one of the following treatment methods: activated sludge;
  trickling filter; rotating biological contactor for the continuous accelerated biological oxidation of wastewaters; or high-rate aeration.
  High-rate aeration is a system of surface impoundments or tanks in which intense mechanical aeration is used to completely mix the
  wastes enhance biological activity, and (A) the units employs a minimum of 6 hp per million gallons of treatment volume; and either (B)
  the hydraulic retention time of the unit is no longer than 5 days; or (C) the hydraulic retention time is no longer than 30 days and the unit
  does not generate a sludge that is a hazardous waste by the Toxicity Characteristic.
   This document is intended solely for guidance. No statutory or regulatory
   requirements are in any way altered by any statement(s) contained herein.
                                                                                                                        A3

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix A: Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)	

            Table 2 - Hazardous Waste from Organic and Inorganic Chemical Industries
Industry and
EPA Hazardous
Waste Number
Hazardous Waste 'ซ,-/?
Organic Chemicals , , ,
K009
K010
K011
K013
K014
K015
K016
K017
K018
K019
K020
K021
K022
K023
K024
K025
K026
K027
K028
K029
K030
K083
K085
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 fractionation 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.
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 methyl ethyl pyridines.
Centrifuge residue from toluene diisocyanate production.
Spent catalyst from the hydrochlorinator reactor in the production of 1,1,1-
trichloroethane.
Waste from the product stream 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 of fractionation column bottoms from the production of chlorobenzene.
Hazard
Code*
mmmmmm
(t)
(t)
(r,t)
(r,t)
(t)
(t)
(t)
(t)
(0
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(t)
(M)
(t)
(t)
(t)
(t)
(t)
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A4

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix A: Identification and Listing off Hazardous Waste (40 CFR261.30 through 261.31)	
Industry and
EPA Hazardous
iVsstc Numfour *
K103
K104
K105
K107
K108
K109
K110
K093
K094
K095
K096
Kill
K112
K113
K114
K115
K116
Hazardous Waste ^ ' /ซ\'' v ,
Process residues from aniline extraction from the production of aniline.
Combined wastewater streams generated from nitrobenzene or 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-dimethylhydrazine
(UDMH) from carboxylic acid
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 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
Distillation light ends from the production of phthalic anhydride from erthoxylene.
Distillation bottoms from the production of phthalic anhydride from orthozylene.
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.
Product washwaters from the production of dinitrotoluene via nitration of toluene.
Reaction byproduct water from the drying column in the production of toluenediamine
via hydrogenation of dinitrotoluene.
Condensed liquid light ennation of dinitrotoluene.
Vicinals from the purification of toluenediamine in the production of toluenediamine.
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.
Hazard -
Codf* *
(t)
<*)
(t)
(c,t)
(M)
(t)
(t)
(t)
(t)
(t)
(t)
(M)
(t)
(t)
(t)
(t)
(t)
Inorganic Chemicals __*,- . ' ^ i >'>'.'. ^ •,ฃ ., ~,
K118
K136
K071
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.
Brine purification muds from the mercury cell process in chlorine production, where
separately prepurified brine is not used.
(t)
(t)
(t)
 This document is intended solely for guidance.  No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
A5

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix A; Identification and Listing of Hazardous Waste (40 CFR 261.30 through 261.31)
Industry and
EPA Hazardous
Waste Number
K073
K106
Hazardous Waste
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.
Hazard
Code*
•••••••
(t)
(t)
Hazardous Waste from Explosives Manufacturing ,
K044
K045
K046
K047
Wastewater treatment sludge 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.
(r)
(r)
(0
0)
 * Hazard Codes:
     t ~ toxic waste
     i - ignitable waste
     r* reactive waste
     c - corrosive waste
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
A6

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

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

-------
THIS PAGE INTENTIONALLY LEFT BLANK

-------
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)	

(COMMENT: 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 acute toxicity.)
EPA
Hazardous
Waste No.
U001
U034
U187
U005
U240
U112
U144
U214
see F027
U002
U003
U004
U005
U006
U007
U008
U009
U011
U0i2
U136
U014
U015
U010
U157
U016
U017
U192
1 """' ' '* r,^ "- >" \ h, li>w J;' >vu~ '*••'-....,, „ , ,
" ~C* ~ f ^ > * ' 7* v !& ~~ * * ' % VJ ^ ~
' f<* - *t\, -"f ' ~- , ' '"• ^.Kป-; - /-< *. ,i- ,1, - -,-, vV
„ . i ' y 1 " ' ' ซ•> ' ' ,^1- *ซ, ' -*.?*&.
Substance •ซ• ' s ,-- - ^,/i, - - , ,vฃ*
/ ,, j: j<'^/yVVin ^^ ^35, f! * >. r^ ^1^ Si V^*
^ ป J ! ^ "K- V { ' , ซ > r , ' ' ป * f'-C •* * * "*
acetaldehyde (i)
acetaldehyde, trichloro-
acetamide, N-(4-ethoxyphenyl)-
acetamide, N-9H-fluoren-2-yl-
acetic acid, (2,4-dichlorophenoxy)-, salts and 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)
arsenic acid, dimethyl-
auramine
azaserine
azirino(2,3,3,4(pyrrolo(l,2-a)indole-4,7-dione, 6-amino-8-[((aminocarbqnyl)oxy)methyl]-l,la,2,8,8a,8b-
hexahydro-8a-methoxy-5-methyl-,
benzOJaceanthrylene, l,2-dihydro-3- methyl-
benza[c]ridine
benzal chloride
benzamide, 3,5-dichloro-n- (l,l-diethyl-2-propynyl-
 This document Is intended solely for guidance.  No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
B1

-------
 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)	
EPA
Hazardous
Waste No.
U018
U094
U012
U014
U049
U093
U328
U353
U158
U222
U181
U019
U038
U030
U035
U037
U221
U028
U069
U088
U102
U107
U070
U07I
U072
U060
U017
U223
U239
Substance
benz[a]anthracene
1,2-benzanthracene, 7,12-dimethyl-
benzenamine
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-
benzenamine, 4,4-methylenebis(2-chIoro-
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-benzendicarboxylic acid, [bis(2-ethyl-hexyl)]ester
1,2-benzenedicarboxylic acid, dibutyl ester
1,2-benzenedicarboxylic acid, diethyl ester
1,2-benzendicarboxylic acid, dimethyl ester
1,2-benzenedicarboxylic acid, dioctyl ester
benzene, 1,2-dichloro-
benzene, 1,3-dichloro-
benzene, 1,4-dichloro-
benzene, 1,1'- (2,2-dichloroethylidene) bis[4-chloro-
benzene, (dichloromethyl)-
benzene, 1,3-diisocyanatomethyl- (r,t)
benzene, dimethyl-(i, t)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B2

-------
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)	
EPA
Hazardous
Waste No.
U201
U127
U056
U220
U105
U106
U055
U169
U183
U185
U020
U020
U207
U061
U247
U023
U234
U021
U202
U203
U141
U090
U064
U248
U022
U197
U023
U085
U021
"~ * ""*" ! " ' '"t " ' > "' . ' "*% ~ '** 1J ,*1 ' < ' "ป* . _"- -1' " -
ป— < ~ ' ' h A ^ ' , , "''f^i. ,, ' ,1^'jt -s4 „ % -i.
Substance v f*~' , $ - - *, - /
n ' ' ' • <•- ,~ r> K ป ฑ /:> !
v , „ >. *.""'>• " * "*r '-""* v *"--.ปป' ^ ^ i
1,3-benzenediol
benzene, hexachloro-
benzene, hexahydro- (i)
benzene, methyl-
benzene, l-methyl-2,4-dinitro-
benzene, 2-methyl-l,3-dinitro-
benzene, (l-methylethyl)-(i)
benzene, nitro- (i, t)
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, 1,1 '(2,2,2- trichloroethylidene)[4-methoxy-
benzene, (trichloromethyl)-
benzene, 1,3,5-trinitro-
benzidine
l,2-benzisothiazolin-3-one, 1,1-dioxide and salts
1 ,3-benzodioxole, 5-(2-propenyl)-
1,3-benzodioxole, S-(l-propenyl)-
1,3-benzodioxole, 5-propyl-
benzo[rst]pentaphene
2-H-l-benzopyran-2-on2, 4-hydroxy-3-(3-oxo-l-phenylbu1yl)-, and salts, when present at concentrations of 0.3% or
less
benzo[a]pyrene
p-benzoquinone
benzotrichloride (c,r,t)
2,2-bioxirane (i, t)
( 1 , 1 -bipheny l)-4,4-diamine
 This document is intended solely for guidance.  No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
B3

-------
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)	
EPA
Hazardous
Waste No.
U073
U09!
U095
U225
U030
U128
U172
U031
U159
U160
U053
U074
U143
U031
U136
U032
U238
U178
U097
U114
U062
U215
U033
U156
U033
U211
U034
U035
U036
i . ' i • „"..
[ * i > i ""t'Ffrt&
Substance ' ' f
(1,1 -bipheny l)-4,4-diamine, 3,3-dichloro
(l,l-biphenyl)-4,4-diamine, 3,3- dimethoxy-
(l,l-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, l,4-dichloro-(i, t)
2-butenoic acid, 2-methyl-, 7- [(2,3-dihydroxy-2-(l-methoxyethyl) -3-methyl-l-oxobutoxy)methyl] -2,3,5,7s-
yrytshyfto-1-pyrrolizin-l-yl ester, [lS-[alpha(Z),7(2S,3R), 7aalpha]]-
n-butyl alcohol (i)
cacodylic acid
calcium chromate
carbamic acid, ethyl ester
carbamic acid, methylnitroso- ethyl ester
carbamic chloride, dimethyl-
carbamodithioic acid, 1,2- ethanediylbis-, salts and esters
carbamothioic acid, bis(l-methylethyl)-S- (2,3-dichloro-2-propenyl) ester
carbonic acid, dithallium(l+)salt
carbonic difluoride
carbonochlorodic acid, methyl ester (5, t)
carbon oxyfluoride (r, t)
carbon tetrachloride
chloral
chlorambucil
chlordane, alpha and gamma isomers
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B4

-------
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)	
'
EPA
Hazardous
Waste No.
U026
U037
U039
U041
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
*• -$ * ^ ~ r ^ p i ' ^ ^
Substance " • ' , • ' < *,"-"* * ~ , ' -~ ' -',}"' ' ', ,
' ' "I'r ' * ' 4 ~ ,
chlomaphazine
chlorobenzene
p-chloro-m-cresol
1 -chloro-2,3-epoxypropane
2-chloroethyl vinyl ether
chloroform
chloromethyl methyl ether
beta-chloronaphthalene
o-chlorophenol
4-chloro-o-toluidine, hydrochloride
chromic acid H2CrO4, calcium salt
chrysene
creosote
cresols (cresylic acid)
crotonaldehyde
cumene (i)
cyanogen bromide
2,5-cyclohexadiene-l, 4-dione
cyclohexane (i)
cyclohexane 1,2,3,4,5,6- hexachloro-, (1 alpha, 2alpha, 3beta, 4alpha, 6beta)-
cyclohexanone (i)
1,3-cyclopentadiene, 1,2,3,4,5,5- hexachloro-
cyclophosphamide
2,4-d, salts and esters
daunomycin
ODD
DDT
diallate
dibenz[a,h]anthracene
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered-by any statement(s) contained herein.
B5

-------
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 CFR261.33)	
EPA
Hazardous
Waste No.
U064
U066
U069
U070
U071
U072
U073
U074
U075
U078
U079
U025
U027
U024
U081
U082
U084
U085
UI08
U028
U086
U087
U088
U089
U090
U091
U092
U093
U094
Substance - I-
d ibenzo [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
dichlorocthyl ether
dichloroisopropyl ether
dichloromethoxy ethane
2,4-dichlorophenol
2,6-dichlorophenol
1,3-dichlorpropene
l,2:3,4-diepoxybutane (i, t)
1 ,4-diethyleneoxide
diethylhexyl phthalate
N,N-diethylhydrazine
O,O-diethyl-s-methyldithiophosphate
diethyl phthalate
diethylstilbestrol
dihydrosafrole
3,3'-dimethoxybenzidine
dimethylamine (i)
dimethylaminoazobenzene
7, 1 2-dimethyIbenz[a]anthracene
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B6

-------
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)	
1PA
Hazardous
Waste No,
-*&* .
U095
U096
U097
U098
U099
U101
U102
U103
U105
U106
U107
U108
U109
U110
mil
U041
U001
U174
U155
U067
U076
U077
U131
U024
U117
U025
U184
U208
U209
-,,tV *.'?"' L v •"-',>- T *- *& V ' "
,\ '••--'',- - . , - 4 ' ' ~, ^ " ',,"**
Substance ' ' , — ,L ' '• ' ' 'y^^ &' ' ^ . .. , ,' N
' • ' >'T - ^ ' - ^- fe ' , ,%,„
-, * ,, ป'V/ -f-,jซ* ',5.. <„' V'A; '".%'- .^ •
3,3-dimethylbenzidine
alpha,alpha-dimethylbenzylhydrpperoxide(r)
dimethylcarbamoyl chloride
1 , 1 -dimethy Ihydrazine
1 ,2-dimethy Ihydrazine
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
epichlorhydrin
ethanal (i)
ethanamine, N-ethyl-N-nitroso-
1,2-ethanediamine, n,n- dimethy l-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, 1,1-oxybis- (i)
ethane l,l-oxybis[2-chloro-
ethane, pentachloro-
ethane, 1,1,1,2-tetrachloro-
etiiane, 1,1,2,2-tetrachloro-
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
B7

-------
 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)	
EPA
Hazardous
Waste No.
U218
U359
U173
U004
U043
U042
U078
U079
U210
U228
U112
U113
U238
U117
U114
U067
U077
U359
U115
U116
U076
U118
U1I9
U120
U122
U123
U124
U125
U147
Substance '' -
? ?
ethanethioamide
ethane, 1,1,2-trichloro-
ethanol, 2,2'-(nitrosoimino)bis-
ethanone, 1-phenyl-
cthenc, chloro-
ethene, (2-chloroethoxy-)
ethenc, 1,1-dichloro-
ethene, 1,2-dichloro- (e)
cthene, tetrachloro-
ethene, trichloro
ethyl acetate (i)
ethyl acrylate (i)
ethyl carbamate (urethane)
ethyl ether (i)
ethylenebisdithiocarbamic acid, salts and 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-fiirandione
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B8

-------
Protocol for Conducting Environmenta! 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)	
EPA
Hazardous
Waste Np,
U213
U125
U124
U206
U126
U163
U127
U128
U130
U131
U132
U243
U133
U086
U098
U099
U109
U134
U134
U135
U096
U116
U137
U190
U140
U141
U142
U143
U144
i - -. r •• >-> ซ~*. , t , ,ป•,..ซ
, , <"• t  ^ * * ~J -f ^ f > <• % *
^ rf f 1 >^i^ -^ i -V ~-~ ฃ ^ ^ J-v J?
Substance . , < ' ^ < i"> ป; r^. _
- - " > , - ,- "".'', "*K!-'., ^Kii-"'
* , , ซ 1|..,'' - "" *"J v- . *~
furan, tetrahydro- (i)
furfural (i)
furfuran (i)
glucopyranose, 2-deoxy-2 (3-methyl-3-nitrosoureido)-
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
hydroperoxide, 1-methyl-l-phenylethyl- (r)
2-imidazolidinethione
indeno( 1 ,2,3-cd)pyrene
1,3-isobenzofurandione
isobutyl alcohol (i, t)
isosafrole
kepone
lasiocarpine
lead acetate
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B9

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix B: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
 Toxtc Wastes (40 CFR 261.33)	
EPA
Hazardous
Waste No.
UI46
U145
U146
U129
U163
UI47
U148
U149
U150
U151
U152
U092
U029
U045
U046
U068
U080
U075
U138
UU9
U211
U1S3
U225
U044
U121
U154
U155
U142
U247
Substance
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-
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
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B10

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under KCKA
Appendix B: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as

EPA
Hazardous
Waste No.
••MBH^MMI
U154
U029
U186
U045
U156
U226
U157
U158
U068
U080
U159
U160
U138
U161
U162
U161
U164
U010
U059
U167
U168
U026
U165
U047
U166
U236
U166
U167


1.1 N - i N * , „ i™
>• ^ f~ ~s-*, ***',,' ^
j y ' ^ * >-Cr f ^ ' ~ > *-
Substance ' . <- > ~" % *
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
mitomycin C
5,12-naphthacenedione, (Bs(cis)8- acetyl-10-[(3-amino-2,3,6-trideoxy- alpha-L-lyxo-hexopyranosyl)oxyl]- 7-
8,9,10-tetrahydro-6,8,l 1- trihydroxy-1-methoxy-
1 -naphthalenamine
2-naphthalenamine
naphthalenamine, N,N'-bis (2-chloroethyl)-
naphthalene
naphthalene, 2-chloro-
1 ,4-naphthalenedione
2,7-naphthalenedisulfonic acid, S.S'-KS^'-dimethyl-Cl.l'-biphenyl)- bis(azo)bis(5-amino-4-hydroxy)-, tetrasodium
salt
1 ,4-naphthoquinone
alpha-naphthylamine

  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
B11

-------
 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)	
EPA
Hazardous
Waste No.
U168
U2I7
U169
U170
U171
U172
U173
U174
U176
Ul 77
U178
UI79
U180
U181
U193
U058
U115
UI26
U041
U182
U183
U184
U185
seeF027
U161
U186
U187
U188
U048
Substance
beta-naphthylamine
nitric acid, thallium(l+) salt (2-chloromethyl)-
nitrobenzene (i, t)
p-nitrophenol
2-nitropropane (i)
n-nitrosodi-n-butylamine
n-nitrosodiethanolamine
n-nitrosodiethylamine
n-nitroso-n-ethylurea
n-nitroso-n-methylurea
n-nitroso-n-methylurethane
n-nitrosopiperidine
n-nitrosopyrrolidine
5-nitro-o-toluidine
1,2-oxathiolane, 2,2-dioxide
2H-1 ,3,2-oxazaphosphorine,2[bis(2- chloroethyl)amino]tetrahydro-, 2-oxide.
oxirane (i, t)
oxiranecarboxyaldehyde
oxirane, 2-(chloromethyl)-
paraldehyde
pcntachlorobenzene
pentachloroethane
pentachloronitrobenzene
pentachlorophenol
pentanol, 4-methyl-
1,3-pentadiene (i)
phenacetin
phenol
phenol, 2-chloro-
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
B12

-------
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)		
EPA
Hazardous
Waste No.
H^^^HI^^^HH^^H
U039
U081
U082
U089
U101
U052
U132
U170
seeF027
seeF027
see F027
see F027
U150
U145
U087
U189
U190
U191
U179
U192
U194
Ulll
U110
U066
U083
U149
U171
U027
U193
Substance ' * V +" "*" / " ,' ", ^*'-*v . •> %' * ซ,"' ,
>, ,t.' ซ* ^•& V ' \ 4~, "i'^' tป* p" ? i
' -' /"'" f ^ "' *-,(ฅ* " y > fy', ''.,." " \ >.- 'L,- - -
phenol, 4-chloro-3-methyl-
phenol, 2,4-dichloro-
phenol, 2,6-dichloro-
phenol, 4,4'-(l,2-diethyl- l,2-ethenediyl)bis-,
phenol, 2,4-dimethyl-
phenol, methyl
phenol, 2,2'-methylenebis [3,4,6-trichloro-
phenol, 4-nitro-
phenol, pentachloro-
phenol, 2,3,4,6-tetrachloro-
phenol, 2,4,5-trichloro-
phenol, 2,4,6-trichloro-
1-phenylalanine, 4- [bis(2-chloroethyl)amino]-
phosphoric acid, lead salt
phosphorodithioic acid, 0,0-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
  This document is intended solely for guidance.  No statutory or regulatory
  requirements are in any way altered by any statements) contained herein.
B13

-------
 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)	
EPA
Hazardous
Waste No.
secF027
U235
U140
U002
U007
U084
U243
U009
U152
U008
U113
U118
U162
U194
U083
U148
U196
U191
U237
U164
U180
U200
U201
U202
U203
U204
U204
U205
U205
Substance
propanoic acid, 2-(2,4,5- trichlorophenoxy)-
1 -propanol, 2,3-dibromo-, phosphate (3:1)
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-propanenitriIe, 2-methyl- (i, t)
2-propenoic acid (i)
2-propenic acid, ethyl ester (i)
2-propenoic acid, 2-methyl-, ethyl ester
2-propenoic acid, 2-methyl-, methyl ester (i, t)
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
saccharin and salts
safrole '
selenious acid
selenium dioxide
selenium sulfide
selenium sulfide SeS2 (r, t)
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
B14

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix B: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as

EPA
Hazardous
Waste No.
•^•^•MBVI
U015
see F027
U206
U103
U189
U232
U207
U208
U209
U210
see F027
U213
U214
U215
U216
U216
U217
U218
U153
U244
U219
U244
U220
U221
U223
U328
U353
U222
U011

-' , ,- * - '\ • .-':!'% -> " L>, .-•- ;--,-
— s, , ~~ > * -"•*'*; ft- "" -' -^ x l - "-^i^fi-i
Substance ' ;-1_-7,-.i > '1"r ^^'V^^^*^" ^^1,^2^,^,
" i- ^; ^ -^ ^, . -\ ^'^ j->r. •*> < ^ 	 ' . /. .v^iJLlril^-
i^BBBIIMB^BBBl^BI^BB^BMMBB^BBBBi^BMB**"****1'^^^^^^^^^^^^^^^^^^^^^^^^^
1-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 chloride
thallium chloride T1C1
thallium (i) nitrate
thioacetamide
thiomethanol (i, t)
thioperoxydicarbonic diamide, tetramethyl-
thiourea
thiuram
toluene
toluenediamine
toluene diisocyanate (r, t)
o-toluidine
p-toluidine
o-toluidine hydrochloride
lH-l,2,4-triazol-3-amine

  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
B15

-------
  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)
   EPA
   Hazardous
   Waste No.
   U227
 Substance
 1,1,2-trichloroethane
   U228
 trichloroethylene
   U121
 trichloromonofluoromethane
   U230
 2,4,5-trichlorophenol
   U231
 2,4,6-trichlorophenol
   U234
 1,3,5-trinitrobenzene (r, t)
   U182
 1,3,5-trioxane, 2,4,6-trimethyl-
  U235
tnX2,3-dibromopropyl)phosphate
  U236
                  trypan blue
  U237
uracil mustard
  U176
                  urea, n-ethyl-n-nitroso-
  U177
                  urea, n-methyl-n-nitroso-
  U043
vinyl chloride
  U248
warfarin, when present at concentrations of 0.3% or less
  U239
xylene (i)
  U200
yohimban-16-carboxylic acid, 11.17-dimethoxy-18-[(3,4,5-trimethoxy-benzoyl)oxy], methyl ester
  U249
zinc phosphide, when present at concentrations of 10% or less.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                                                          B16

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

                       Appendix C:
  Toxicity Characteristics Constituents and Regulatory Levels
                     (40CFR261.24)

-------
TfflS PAGE INTENTIONALLY LEFT BLANK

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix C: Toxicity Characteristics Constituents and Regulatory Levels (40 CFR 261.24)	
EPA Hazardous
iVaste No.
D004
D005
D018
D006
D019
D020
D021
D022
D007
D023
D024
D025
D026
D016
D027
D028
D029
D030
DO 12
D031
D032
D033
D034
D008
D013
D009
DO 14
D035
Constituent ' "r " , „
Arsenic
Barium
3enzene
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 hydroxide)
Hexachlorobenzene
Hexachloro-l,3-butadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
i " <--v ^
CA'S No. •
- , -"C'^j >
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
67-72-1
7439-92-1
58-89-9
1
7439-97-6
72-43-5
78-93-3
Chronic Toxicity
Reference Jjeyel/^
0.05
1.0
0.005
0.01
0.005
0.0003
1
0.06
0.05
2
2
2
2
0.1
0.075
0.005
0.007
0.0005
0.0002
0.00008
0.0002
3
0.03
0.05
0.004
0.002
0.1
2
Regulatory Level
(mgflL)
i&" * ^
< "
5.0
100.0
0.5
1.0
0.5
0.03
100.0
6.0
5.0
200.0 '
200.0 '
200.0 '
200.0 '
10.0
7.5
0.5
0.7
0.13 2
0.02
0.008
0.13 2
0.005
3.0
5.0
0.4
0.2
10.0
200.0
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
C1

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix C: Toxicity Characteristics Constituents and Regulatory Levels (40 CFR 261.24)
EPA Hazardous
Waste No.
D036
D037
D038
D010
D011
D039
D015
D040
D041
D042
D017
D043
Constituent
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. '-';' ':';
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
ChronicToxieity
Reference JLevel
0.02
1
0.04
0.01
0.05
0.007
0.005
0.005
4
0.02
0.01
0.002
Regulatory Level
(mg/L)
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
1    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 statements) contained herein.
C2

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

                      Appendix D:
  Identification of Hazardous Waste Hazardous Constituents
                (40 CFR 261, Appendix VIII)

-------
THIS PAGE INTENTIONALLY LEFT BLANK

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D; Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)	
Common Name
Acetonitrile
Acetophenone
2-Acetyiaminefluarone
Acetyl chloride
1 -Acety 1-2-thiourea
Acrolein
Acrylamide
Acrylonitrile
Aflatoxins
Aldicarb
Aldrin
Allyl alcohol
Allyl chloride
Aluminum phosphide
4-Aminobiphenyl
5-(Aminomethy l)-3 -isoxazolol
4-Aminopyridine
Amitrole
Ammonium vanadate
Aniline
Antimony
Antimony compounds, N.O.S.1
Aramite
Arsenic
Arsenic compounds, N.O.S.1
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
f ' f
% > ^ ' T ~ =f
Chemical Abstracts Name ,
' ' t , <_
Same
Ethanone, 1-phenyl-
Acetamide, N-9H-fluoren-2-yl
Same
Acetamide, N-(aminothioxomethyl)-
2-Propenal
2-Propenamide
2-Propenenitrile
Same
Propanal, 2-methyl-2-(mehtylthio)-, O-
[(methylamino)carbonyl]oxime
1 ,4,5,8-Dimethanonaphthalene, 1 ,2,3,4, 1 0, 1 0-10-
hexachloro- l,4,4a,5,8,8a-hexahydro-, (1 alpha, 4alpha,
4abeta, Salpha, Salpha, Sabeta)-
2-Propen-l-ol
1 -Propane, 3-chloro
Same
[1,1 '-Biphenyl]-4-amine
3 (2H)-Isoxazolone, 5-(aminomethyl)-
4-Pyridinamine
lH-l,2,4-Triazol-3-amine
Vanadic acid, ammonium salt
Benzenamine
Same

Sulfurous acid, 2-chloroethyl 2-[4-(l,l-
dimethy lethy l)phenoxy]- 1 -methy lethy 1 ester
Same

Arsenic acid H3AsO4
Arsenic oxide As2O5
Arsenic oxide As2O3
Chemical
Abstract No.
75-05-8
98-86-2
53-96-3
75-36-5
591-08-2
107-02-8
79-06-1
107-13-1
1402-68-2
116-06-3
309-00-2
107-18-6
107-18-6
20859-73-8
92-67-1
2763-96-4
504-24-5
61-82-5
7803-55-6
62-53-3
7440-36-0

140-57-8
7440-38-2

7778-39-4
1303-28-2
1327-53-3
Hazardous
Waste No,
U003
U004
U005
U006
P002
P003
U007
U009

P070
P004
POOS

P006

P007
POOS
U011
PI 19
U012





P010
P011
P012
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D1

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
Auraminc
Azascrinc
Barium
Barium compounds, N.O.S.1
Barium cyanide
Bcnz[c]acridinc
Bcnz[a]anthracene
Bcnzal chloride
Benzene
Bcnzcncarsonic acid
Bcnzidine
Bcnzo[b]flouoranthene
Benzo[j]{luoranthene
Benzo(k)fluoranthenc
Bcnzo[a]pyrene
p-Benzoquinonc
Benzotrichloridc
Benzyl chloride
Beryllium powder
Beryllium coumpounds, N.O.S.1
Bromoacctone
Bromoform
4-Bromophenyl phenyl ether
Brucinc
Butyl benzyl phthalate
Cacodylic acid
Cadmium
Cadmium compounds, N.O.S.1
Calcium chromate
Calcium cyanide
Chemical Abstracts Name
Benzenamine, 4,4'-carbonimidoylbis[N,N-dimethyl
L-Serine, diazoacetate (ester)
Same

Same
Same
Same
Benzene, (dichloromethyl)-
Same
Arsonic acid, phenyl-
[l,l'-Biphenyl]-4,4 1 -diamine
Benz[e]acehpenanthrylene
Same
Same
Same
2,5-Cyclohexadiene-l,4-dione
Benzene, (trichloromethyl)-
Benzene, (chloromethyl)-
Same

2-Propanone, 1-bromo-
Methane, tribromo-
Benzene, l-bromo-4-phenoxy-
Strychnidin-10-one, 2,3-dimethoxy-
1,2-Benzenedicarboxylic acid, butyl phenyl-methyl ester
Arsinic acid, dimethyl-
Same

Chromic acid H2CrO4, calcium salt
Calcium cyanide Ca(CN)2
Chemical
Abstract No.
492-80-8
115-02-6
7440-39-3

542-62-1
225-51-4
56-55-3
98-87-3
71-43-2
98-05-5
92-87-5
205-99-2
205-82-3
207-08-9
50-32-8
106-51-4
98-07-7
100-44-7
7440-41-7

598-31-2
75-25-2
101-55-3
357-57-3
85-68-7
75-60-5
7440-43-9

13765-19-0
592-0108
Hazardous
Waste No,

U015


P013
U016
U018
U017
U019

U021



U022
U197
U023
P028
P015

P017
U225
U030.
P018

U136


U032
P021
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D2

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)

Common Name
Carbon disulfide
Carbon oxyfluoride
Carbon tetrachloride
Chloral
Chlorambucil
Chlordane

Chlordane (alpha and gamma
isomers)
Chlorinated benzenes, N.O.S.1
Chlorinated ethane, N.O.S.1
Chlorinated fluorocarbons, N.O.S.1
Chlorinated naphthalene, N.O.S.'
Chlorinated phenol, N.O.S.1
Chlomaphazin
Chloroacetaldehyde
Chloroalkyl ethers, N.O.S.1
p-Chloroaniline
Chlorobenzene
Chlorobenzilate
p-Chloro-m-cresol
2-Chloroethyl vinyl ether
Chloroform
Chloromethyl methyl ether
beta-Chloronaphthalene
o-Chlorophenol
1 -(o-Chlorophenyl)thiourea
Chloroprene
3-Chloropropionitrile
Chromium
Chromium compounds, N.O.S.'
,
Chemical Abstracts Name '
Same
Carbonic difluoride
Methane, tetrachloro-
Acetaldehyde, trichloro-
Benzenebutanoic acid, 4-[bis(2-chloroethyl)amino]-
4,7-Methano-lH-indene, 1,2,4,5,6,7,8,8-oc-tachloro-
2,3,3a,4,7,7a-hexahydro-






Naphthalenamine, N,N'-bis(2-chloroethyl)-
Acetaldehyde, chloro-

Benzenamine, 4-chloro-
Benzene, chloro-
Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-
alpha-hydroxy-,ethyl ester
Phenol, 4-chloro-3-methyl-
Ethene, (2-chloroethoxy)-
Methane, trichloro-
Methane, chloromethoxy-
Naphthalene, 2-chloro-
Phenol, 2-chloro-
Thiourea, (2-chlorophenyl)-
1,3-Butadiene, 2-chloro
Propanenitrile, 3-chloro-
Same


Abstract No.
75-15-0
353-50-4
56-23-5
75-87-6
305-03-3
57.74.9







494-03-1
107-20-0

106-47-8
108-90-7
510-15-6
59-50-7
110-75-8
67-66-3
107-30-2
91-58-7
95-57-8
5344-82-1
126-99-8
542-76-7
7440-47-3


Hazardous
Waste No,
P022
U033
U211
U034
U035
U036







U026
P023

P024
U037
U038
U039
U042
U044
U046
U047
U048
P026

P027


This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D3

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
Chryscne
Citrus red no. 2
Coal tar creosote
Copper cyanide
Creosote
Cresol (Cresylic acid)
Crotonaldchyde
Cyanides (soluble salts and
complexes) N.O.S.1
Cyanogen
Cyanogen bromide
Cyanogen chloride
Cycasin
2-Cyclohexyl-4,6-dinitrophenol
Cyclophosphamide
2,4-D
2,4-D, salts, esters
Daunomycin
DDD
DDE
DDT
Dialhte
Dibenz[a,h]acridine
Dibenz[aj]acridine
Dibenz[a,h]anthracene
7H-Dibenzo[c,g]carbazole
Dibenzo[a,e]pyrene
Dibenzofa.hjpyrene
Dibenzo[a,i]pyrene
Chemical Abstracts Name
Same
2-Naphthalenol, 1 -[(2,5-dimethoxphenyl)azo]-
Same
Copper cyanide CuCN
Same
Phenol, methyl-
2-Butenal

Ethanedinitrile
Cyanogen bromide (CN)Br
Cyanogen chloride (CN)C1
beta-D-Glucopyranoside, (methyl-ONN-azoxy)methyl
Phenol, 2-cyclohexyl-4,6-dinitro-
2H- 1 ,3,2-Oxazaphosphorin-2-amine, N,N-bis(2-
chloroethyl)tetrahydro-, 2-oxide.
Acetic acid, (2,4-dichlorophenoxy)-

5,12-Naphthacenedione, 8-acetyl-10-[(3-amino-2,3,6-
trideoxy-alpha-L-lyxo-hexopyranosyl)oxy]-7,8,9, 1 0-
tetrahydro-6,8,1 1-trihydroxy-l-methoxy-, (8S-cis)-
Benzene, 1 , 1 '-(2,2-dichloroethylidene)bis[4-chloro-
Benzene, 1 , 1 '-(dichloroethenylidene)bis[4-chloro-
Benzene, 1,1 '-(2.2.2 trichloroethylideneObis[4-chloro-
Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-dichloro-
2-propenyl) ester
Same
Same
Same
Same
Naphtho[l ,2,3,4-def]chrysene
Dibenzo[b,dif]chrysene
Benzo[rst]pentaphene
Chemical
•Abstract No.
218-01-9
6358-53-8
8007-45-2
544-92-3

1319-77-3
4170-30-3

460-19-5
506-68-3
506-77-4
14901-08-7
131-89-5
50-18-0
94-75-7

20830-81-3
72-54-8
72-55-9
50-29-3
2303-16-4
226-36-8
224-42-0
53-70-3
194-59-2
192-65-4
189-64-0
189-55-9
Hazardous
Waste No.
U050


P029
U051
U052
U053
P030
P031
U246
P033

P034
U058
U240
U240
U059
U060

U061
U062


U063



U064
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
D4

-------
          Conducting Environmental Compliance Audits of Hazardous Waste Generators under KCRA

Common Name . '
•••••••••^••••^•i^Hi •
1 ,2-Dibromo-3-chloropropane
Dibutyl phthalate
o-Dichlorobenzene
m-Dichlorobenzene
p-Dichlorobenzene
Dichlororbenzene, N.O.S.1
3,3'-Dichlorobenzidine
1 ,4-Dichloro-2-butene
Dichlorodifluoromethane
Dichloroethylene, N.O.S.1
1 , 1 -Dichloroethylene
1 ,2-Dichloroethylene
Dichloroethyl ether
Dichloroisopropyl ether
Dichloromethoxy ethane
Dichloromethyl ether
2,4-Dichlorophenol
2,6-Dichlorophenol
Dichlorophenylarsine
Dichloropropane, N.O.S.1
Dichloropropanol, N.O.S.1
Dichloropropene, N.O.S.1
1,3-Dichloropropene
Dieldrin
l,2:3,4-Diepoxybutane
Diethylarsine
1 ,4-Diethyleneoxide
Diethylhexyl phthalate
N,N'-Diethylhydrazine
* -' "ป 5,3*1 ' •'"
Chemical Abstracts Name
••••^•^••••^••li^^^^^^^™^^^^*^^^^^^^^^^^^^™ •
Propane, l,2-dibromo-3-chloro-
1,2-Benzenedicarboxylic acid, dibutyl ester
Benzene, 1,2-dichloro-
Benzene, 1,3-dichloro-
Benzene, 1,4-dichloro-
Benzene, dichloro-
[1,1 '-Biphenyl]-4,4'-diamine, 3,3'-dichloro-
2-Butene, 1,4-dichloro
Methane, dichlorodifluoro-
Dichloroethylene
Ethene, 1,1-dichloro
Ethene, 1,2-dichlrol-, (E)
Ethane, l,l'oxybis[2-chloro-
Propane, 2,2'-oxybis[2-chloro
Ethane, l,l'-[methylenebis(oxy)bix[2-chloro-
Methane, oxybis[chloro-
Phenol, 2,4-dichloro-
Phenol, 1,6-dichloro-
Arsonous dichloride, phenyl-
Propane, dichloro-
Propanol, dichloro-
1-Propene, dichloro-
1-Propene, 1,3-dichloro-
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-,
( 1 aalpha,2beta,2aalpha,3beta,6beta,
6aalpha,7beta,7aalpha)-
2,2'-Bioxirane
Arsine, diethyl-
1,4-Dioxane
1,2-Benzenedicarboxylic acid, bis(2-ethyl-hexyl) ester
Hydrazine, 1,2-diethyl-
Chemical
Abstract No,
f * /
96-12-8
84-74-2
95-50-1
541-73-1
106-46-7
25321-22-6
91-94-1
764-41-0
75-71-8
25323-30-2
75-35-4
156-60-5
111-44-4
108-60-1
111-91-1
542-88-1
120-83-2
87-65-0
696-28-6
26638-19-7
26545-73-3
26952-23-8
542-75-6
60-57-1
1464-53-5
692-42-2
123-91-1
117-81-7
1615-80-1

Hazardous
Waste No.
U066
U069
U070
U071
U072

U073
U074
U075

U078
U079
U025
U027
U024
P016
U081
U082
P036



U084
P037
U085
P038
U108
U028
U086

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D5

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
O.O-Dicthyl S-methyl
dilhiophosphate
Diethyl-p-nitrohpenyl phosphate
Diethyl phthalate
O.O-Dicthyl 0-pyrazinyl
phosphoro-thioate
Diethylstilbesterol
Dihydrosafrolc
Diisopropylfluorophosphate (DFP)
Dimcthoatc
3,3'-Dimethoxybenzidine
p-Dimethylaminoazobenzene
7, 1 2-Dimethy lbenz[a]anthracene
3,3'-Dimcthylbcnzidine
Dimcthylcarbamoyl chloride
1 , 1 -Dimethy Ihy drazine
1 ,2-Dimethy Ihy drazine
alpha,alpha-
Dimcthylphenethylamine
2,4-DimethyIphenol
Dimethyl phthalate
Dimethyl sulfate
Dinitrobenzene, N.O.S.1
4,6-Dinitro-o-cresol
4,6-Dinitro-o-cresol salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Dinoscb
Di-n-octyl phthalate
Diphenylaminc
Chemical Abstracts Name
••"•"•••••••••••••••^••••i
Phosphorodithioic acid, O,O-diethyl S-methyl
Phosphoric acid, diethyl 4-nitrophenyl ester
1,2-Benzenedicarboxylic acid, diethyl ester
Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester
Phenol, 4,4'-(l,2-diethyl-l,2-ethenediylObis-,(E)-
1,3-Benzodioxole, 5-propyl-
Phosphorofluoridic, bis(l-mthylethyl) ester
Phosphorodithioic acid, O,O-dimethyl S-[2-
(methylamino)-2-oxoethyl] ester
[1,1 '-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy-
Benzenamine, N,N-dimethyl-4-(phenylazo)-
Benz[a]anthracene, 7,12-dimethyl-
[l,r-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy-
Carbamic chloride, dimethyl-
Hydrazine, 1,1-dimethyl-
Hydrazine, 1,2-dimethyl-
Benzeneethanamine, alpha,alpha-dimethyl
Phenol, 2,4-dimethyl-
1,2-Benzenedicarboxylic acid, dimethyl ester
Sulfuric acid, dimethyl ester
Benzene, dinitro-
Phenol, 2-methyl-4,6-dinitro-

Phenol, 2-methyl-4,6-dinitro-
Benzene, l-methyl-2,4-dinitro-
Benzene, 2-methyl-l,3-dinitro-
Phenol, 2-( 1 -methylpropyl)-4,6-dinitro-
,2-Benzenedicarboxylic acid, dioctyl ester
Jenzenamine, N-phenyl-
Chemical
Abstract No,
mmmimmmmm
3288-58-2
311-45-5
84-66-2
297-97-2
56-53-1
94-58-6
55-91-4
60-51-5
119-90-4
60-11-7
57-97-6
119-90-4
79-44-7
57-14-7
540-73-8
122-09-8
105-67-9
131-11-3
77-78-1
25154-54-5
534-52-1

51-28-5
121-14-2
606-20-2
88-85-7
17-84-0
22-39-4
Hazardous
Waste No.
•••••••••
U087
P041
U088
P040
U089
U090
P043
P044
U091
U093
U094
U095
U097
U098
U099
P046
U101
U102
U103

P047
P047
P048
U105
U106
P020
U017

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                                D6

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VHI)
~ " - *•>. K,
Chemical Abstracts Name ' 1 '^ „
/ ^ i"ป
Hydrazine, 1,2-diphenyl-
1-Propanamine, N-nitroso-N-propyl-
Phosphorodithioic acid, O,Odiethyl S-[2-
(ethylthio)ethyl]ester
Thioimidodicarbonic diamide [(H3N)C(S)]2NH
7-Oxabicyclo[2.2. 1 ]heptane-2,3-dicarboxylic
2,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-
hexachloro-la,2,2a,3,6,6a,7,7a-octa-hydro-,
(laalpha,2beta,2abeta,3alpha,6alpha,
6abeta,7beta,7aalpha)-

Oxirane, (chloromethyl)-
1,2-Benzenediol, 4-[l-hydroxy-2-(methylamino)ethyl]-,
(R)-
Carbamic acid, ethyl ester
Propanenitrile
Carbamodithioic acid, 1,2-ethanediylbis-

Ethane, 1,2-dibromo-
Ethane, 1,2-dichloro-
Ethanol, 2-ethoxy-
Aziridine
Oxirane
2-Imidazolidinethione
Ethane, 1,1-dichloro-
2-Propenoic acid, 2-methyl-, ethyl ester
Methanesulfonic acid, ethyl ester
Phosphorothioic acid, 0-[4-
[(dimethylamino)sulfonyl]phenyl] O,O-di-methyl ester
Same
Same
Acetamide, 2-fluoro-, sodium salt
Same
Chemical
Abstract No,
ฃ >•
122-66-7
621-64-7
298-04-4
541-53-7
145-73-3
72-20-8

106-89-8
51-43-4
51-79-6
107-12-0
111-54-6

106-93-4
107-06-2
110-80-5
151-56-4
75-21-8
96-45-7
75-34-3
97-63-2
65-50-0
52-85-7
206-44-0
7782-41-4
62-74-8
50-00-0
lazardous
Waste No,
U109
mil
P039
P049
P088
P051
P051
U041
P042
U238
P101
U114
U114
U067
U077
U359
P054
U115
U116
U076
U118
U119
P097
U120
P056
P058
U122
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
D7

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
Formic acid
Glycidylaldehyde
Halomethanes, N.O.S.'
Hcptachlor
Hcptachlor cpoxidc
Heptachlor epoxide (alpha, beta,
and gamma isomers).
Hcptachlorodibenzofurans
Heptachlorodibenzo-p-dioxins
Hexachlorobenzene
Hcxachlorobutadiene
Hcxachlorocyclopentadiene
Hexchlorodibenzo-p-dioxins
Hcxehlorodibenzofurans
Hcxachloroethane
Hexachlorophene
Hcxachloropropcne
Hexaethyl tetraphosphate
flydrazine
Hydrogen cyanide
Hydrogen fluoride
Hydrogen sulfide
Indenof 1 ,2,3-cd]pyrene
sobutyl alcohol
sodrin
sosafrole
Cepone
Chemical Abstracts Name
Same
Oxiranecarboxyaldehyde

4,7-Methano-lH-indene, 1,4,5,6,7,8,8-hep-tachloro-
3a,4,7,7a-tetrahydro-
2,5-Methano-2H-indeno[l,2-b]oxirene, 2,3,4,5,6,7,7-
heptachloro-la,lb,5,5a,6,6a-hexa- hydro-, laalpha, Ibbeta,
2alpha, Salpha, Sabeta, 6beta, 6aalpha)-



Benzene, hexachloro-
1,3-Butadiene, 1,1,2,3,4,4-hexachloro-
1 ,3-Cyclopentadiene, 1 ,2,3,4,5,5-hexachloro-


Ethane, hexachloro-
Phenol, 2,2'-methylenebis[3,4,6-trichloro-
1-Propene, 1, 1,2,3,3,3-hexachloro-
Tetraphosphoric acid, hexaethyl ester
Same
Hydrocyanic acid
Hydrofluoric acid
Hydrogen sulfide H2S
Same
1-Propanol, 2-methyl-
l ,4,5,8-Dimethanonaphthalene, 1 ,2,3,4, 1 0, 1 0-hexachloro-
l,4,4a,5,8,8a-hexahydro-,
(lalpha,4alpha,4abeta,5beta,8beta,8abeta)-
1,3-Benzodioxole, 5-(l-propenyl)-
l,3,4-Methano-2H-cyclobuta[cd]pentalen-2-one,
l,la,3,3a,4,5,5,5a,5b,6-decachlorooctahydro-
Chemical
Abstract No,
64-18-6
765-34-4

76-44-8




118-74-1
87-68-3
77-47-4


67-72-1
70-30-4
1888-71-7
757-58-4
302-01-2
74-90-8
7654-39-3
7738-06-4
193-39-3
78-83-1
465-73-6
120-58-1
143-50-0
Hazardous
Waste No.
••••••••
U123
U126

P059




U127
U128
U130


U131
U132
U243
P062
U133
P063
U134
U135
U134
U140
P060
U141
U142
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                               D8

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
L,asiocarpine
Lead
Lead xompounds, N.O.S.1
Lead acetate
Lead phosphate
Lead subacetate
Lindane
Maleic anhydride
Maleic hydrazide
Malononitrile
Melphalan
Mercury
Mercury compounds, N.O.S.1
Mercury fulminate
Methacrylonitrile
Methapyrilene
Methomyl
Methoxychlor
Methyl bromide
Methyl chloride
Methyl chlorocarbonate
Methyl chloroform
3-Methylcholanthrene
4,4'-Methylenebis(2-chioroaniline)
Methylene bromide
Methylene chloride
Methyl ethyl ketone (MEK)
* i- ^ -i *
Chemical Abstracts Name
2-Butenoic acid, 2-memyl-, 7-[[2,3-dihydroxy-2-(l-
methoxyethyl)-3-methyl-f-oxobutoxy]methyl]-2,3,5,7a-
tetrahydro-lH-pyrrolizin-1-yl ester, [S-
[lalpha(Z),7(2S*,3R*),7aalpha]]-
Same

Acetic acid, lead(2+) salt
Phosphoric acid, lead(2+) salt (2:3)
Lead, bus(acetato-O)tetrahydroxytri-
Cyciohexane, 1,2,3,4,5,6-hexachloro-
,(lalpha,2alpha,3beta,4alpha,5alpha,6beta)-.
2,5-Furandione
3,6-Pyridazinedione, 1,2-dihydro-
Propanedinitrile
L-Phenylalanine, 4-[bis(2-chloroethyl)aminol]-.
Same

Fulminic acid, mercury(2+) salt
2Propenenitrile, 2-methyl-
1 ,2-Ethanediamine, NN-dimethyl-N'-2-pyridinyl-N'-(2-
thienylmethyl)-.
Ethanimidothioic acid, N-[[(methylamino)carbonyl]oxy]-,
methyl ester.
Benzene, l,l'-(2,2,2-trichloroethylidene)bis[4-methoxy-.
Methane, bromo-
Methane, chloro-
Carbonochloridic acid, methyl ester
Ethane, 1,1,1-trichloro-
Benz[j]aceanthrylene, l,2-dihydro-3 -methyl
Benzenamine, 4,4'-methylenebis[2-chloro-
Methane, dibromo-
Methane, dichloro-
2-Butanone
Chemical
Abstract No,
303-34-1
7439-92-1

301-04-2
7446-27-7
1335-32-6
58-89-9
108-31-6
123-33-1
109-77-3
148-82-3
7439-97-6

628-86-4
126-98-7
91-80-5
16752-77-5
72-43-5
74-83-9
74-87-3
79-22-1
71-55-6
56-49-5
101-14-4
74-95-3
75-09-2
78-93-3
Hazardous
Waste No,
4143


U144
U145
U146
U129
U147
U148
U149
U150
U151

P065
U152
U155
P066
U247
U029
U045
U158
U226
U157
U158
U068
U080
U159
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
D9

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIIQ
Common Name
Methyl ethyl ketone peroxide
Methyl hydrazine
Methyl iodide
Methyl isocyanate
2-McthylIactonitriIe
Methyl methacrylate
Methyl methanesulfonate
Methyl parathion
Methylthiouracil
Mitomycin C
MNNG
Mustard gas
Naphthalene
1 ,4-Naphthoquinone
alpha-Naphthylamine
beta-Naphthylamine
alpha-Naphthylthiourea
Nickel
Nickel compounds, N.O.S.1
Nickel carbonyl
Nickel cyanide
Nicotine
Nicotine salts
Nitric oxide
p-Nitroaniline
Nitrobenzene
Nitrogen dioxide
Nitrogen mustard
Chemical Abstracts Name
' — ป^— — — -i— ^^^ซซ
2-Butanone, peroxide
Hydrazine, methyl-
Methane, iodo-
Methane, isocyanato-
Propanenitrile, 2-hydroxy-2-methyl-
2-Propenoic acid, 2-methyl-methyl ester
Methanesulfonic acid, methyl ester
Phosphorothioic acid, O,O-dimethyl O-(4-nitrophenyl)
ester
4(1 H)-Pyrimidinone, 2,3-dihydro-6-methyl-2-thioxo-
Azirino[2',3':3,4]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-, [1 aS-
1 aalpha,8beta,8aalpha,8balpha)]-
Guanidine, N-methyl-N'-nitro-N-nitroso-
Ethane, l,l'-thiobis[2-chloro-
Same
1 ,4-Naphthalenedione
1-Naphthalenamine
2-Naphthalenamine
Thiourea, 1-naphthalenyl-
Same

Nickel carbonyl Ni(CO)4, (T-4)-
Nickel cyanide Ni(CN)2
Pyridine, 3-(l-methyl-2-pyrrolidinyl)-, (S)-

Nitrogen oxide NO
Benzeneamine, 4-nitro-
Benzene, nitro-
Nitrogen dioxide NO2
Ethanamine, 2-chloro-N-(2-chloroethyl)-N-methyl-, N-
oxide
Chemical
Abstract No.
1338-23-4
60-34-4
74-88-4
624-83-9
75-86-5
80-62-6
66-27-3
298-00-0
56-04-2
50-07-7
70-25-7
505-60-2
91-20-3
130-15-4
134-32-7
91-59-8
86-88-4
7440-02-0

13463-39-3
557-19-7
54-11-5

0102-43-9
00-01-6
98-95-3
0102-44-0
1-75-2
Hazardous
Waste No.
••••••••
U160
P068
U138
P064
P069
U162

P071
U164
U010
U163

U165
U166
U167
U168
P072


P073
P074
P075
P075
P076
P077
U169
P078

This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                                              D10

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCKA
Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common JNsme
Nitrogen mustard, N-oxide, hydro-
chloride salt.
Nitroglycerin
p-Nitrophenol
2-Nitropropane
Nitrosamines, N.O.S.1
N-Nitosodi-n-butylamine
N-Nitrosodiethanolamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitroso-N-ethylurea
N-Nitrosomethylethylamine
N-Nitroso-N-methylurea
N-Nitroso-N-methylurethane
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonomicotine
N-Nitrosopiperidine
N-Nitrosopyrolidine
N-Nitrososarcosine
5-Nitro-o-toluidine
Octamethylpyrophosphoramide
Osmium tetroxide
Paraldehyde
Parathion
Pentachlorobenzene
Pentachlorodibenzo-p-dioxins
Pentachlorodibenzofurans
Pentachloroethane
Pentachloronitrobenzene (PCNB)
Pentachlorophenol
s ! ~ ?•& * •& * *-"•• > \ < '
. * ' ; .5. J- * ' ' 4 ?"
j f ^ ^ i
Chemical Abstracts Name • >„''.,*•;,. i ; *
- 1 >..> . - ."— ,^1 V {_=,'

1,2,3-Propanetriol, trinitrate
Phenol, 4-nitro-
Propane, 2-nitro-

1-Butamine, N-butyl-N-nitroso
Ethanol, 2,2'-(nitrosoimino)bis-
Ethanamine, N-ethyl-N-nitroso-
Methanamine, N-methyl-N-nitroso-
Urea, N-ethyl-N-nitroso-
Ethanamine, N-methyl-N-nitroso-
Urea, N-methyl-N-nitroso-
Carbamic acid, methylnitroso-, ethyl ester
Vinylamine, N-methyl-N-nitroso-
Morpholine, 4-nitroso-
Pyridine, 3-(l-nitroso-2-pyrrolidinyl)-, (S)
Piperidine, 1-nitroso-
Pyrrolidine, 1-nitroso-
Glycine, N-methyl-N-nitroso-
Benzenamine, 2-methyl-5-nitro-
Diphosphoramide, octamethyl-
Osmium oxide OsO4 (T-4)-
1,3,5-Trioxane, 2,4,6-trimethyl-
Phosphorothioic acid, O,O-diethyl O-(4-nitro-phenyl) ester
Benzene, pentachloro-


Ethane, pentachloro-
Benzene, pentachloronitro-
Phenol, pentachloro-
Cbemical
Abstract No,

55-63-0
100-02-7
79-46-9
35576-91-1D
924-16-3
1116-54-7
55-18-5
62-75-9
759-73-9
10595-95-6
684-93-5
615-53-2
4549-40-0
59-89-2
16543-55-8
100-75-4
930-55-2
13256-22-9
99-55-8
152-16-9
20816-12-0
123-63-7
56-38-2
608-93-5


76-01-7
82-68-8
87-86-5
Hazardous
Waste No,

P081
U170
U171

U172
U173
U174
P082
U176

U177
U178
P084


U179
U180

U181
P085
P087
U182
P089
U183


U184
U185
See F027 ,
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
D11

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIM)
Common Name
Phcnacctin
Phenol
Phenylencdiamine
Phenylmercury acetate
Phenylthiourea
Phosgene
Phosphinc
Phorate
Phthalic acid esters, N.O.S.1
Phthalic anhydride
2-Picoline
Polychlorinatcd biphenyls, N.O.S.1
Potassium cyanide
Potassium silver cyanide
Pronamide
1,3-Propane sultone
n-Propylamine
Propargyl alcohol
Propylene dichloride
1,2-Propylenimine
'ropylthiouracil
'yridinc
Rcserpine
Rcsorcinol
Saccharin
Saccharin salts
Safrole
Selenium
Selenium compounds, N.O.S.1
, , . . " • •.''.- - . -.
Chemical Abstracts Name
•MBMBIMMMHMHi^HHM^^HBBH^
Acetamide, N-(4-ethoxyphenyl)-
Same
Benzenediamine
Mercury, (acetato-O)phenyl-
Thiourea, phenyl-
Carbonic dichloride
Same
Phosphorodithioic, O,O-diethyl S-[(ethylthio)methyl] ester

1 ,3-Isobenzofurandione
Pyridine, 2-methyl-

Potassium cyanide K(CN)
Argentate(l-), bis(cyano-C)-, potassium
Benzamide, 3,5-dichloro-N-( 1 , 1 -dimethyl-2-propynyl)-.
1,2-Oxathiolane, 2,2-dioxide
1-Propanamine
2-Propyn-l-ol
Propane, 1,2-dichloro-
Aziridine, 2-methyl-
4(lH)-Pyrimidinone, 2,3-dihydro-6-propyl-2 thioxo-
Same
Yohimban- 1 6-carboxylic acid, 11,1 7-dimeth-oxy- 1 8-
'(3,4,5-trimethoxybenzoyl)oxy]-smethyl ester,
(Sbeta, 1 6beta, 1 Talpha, 1 8beta,20alpha)-
1,3-Benzenediol
1 ,2-Benzisothiazol-3(2H)-one, 1 , 1 -dioxide

,3-BenzodioxoIe, 5-(2-propenyl)-
Same

Chemical
Abstract No,
62-44-2
108-95-2
25265-76-3
62-38-4
103-85-5
75-44-5
7803-51-2
298-02-2

85-44-9
109-06-8

151-50-8
506-61-6
23950-58-5
1120-71-4
107-10-8
107-19-7
78-87-5
75-55-8
51-52-5
110-86-1
50-55-5
108-46-3
81-07-2

94-59-7
7782-49-2

Hazardous :
Wasfe'No,,:
•••••••••
U187
U188

P092
P093
P095
P096
P094

U190
U191

P098
P099
U192
U193
U194
P102
U083
P067

U196
U200
U201
U202
U202
U203


This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
                                                                                               D12

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
Selenium dioxide
Selenium sulfide
Selenourea
Silver
Silver compounds, N.O.S.1
Silver cyanide
Silvex (2,4,5-TP)
Sodium cyanide
Streptozotocin
Strychnine
Strychnine salts
TCDD
1 ,2,4,5-Tetrachlorobenzene
Tetrachlorodibenzo-p-dioxins
Tetracholodibenzofurans
Tetrachloroethane, N.O.S.1
1,1,1 ,2-Tetrachloroethane
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
2,3,4,6-Tetrachlorophenol
Tetraethyldithiopyrophosphate
Tetraethyl lead
Tetraethyl pyrophosphate
Tetranitrbmethane
Thallium
Thallium compounds, N.O.S. 1
Thallic oxide
Thallium(l) acetate
Thallium(l) carbonate
Thallium(l) chloride
^ * ,
- s -
Chemical Abstracts Name .. , ป •
" * - !
Selenious acid
Selenium sulfide SeS2
Same
Same

Silver cyanide Ag(CN)
Propanoic acid, 2-(2,4,5-trichlorophenoxy)-
Sodium cyanide Na(CN)
D-Glucose, 2-deoxy-2-
[[(methylnitrosoamino)carbonyl]amino]-
Strychnidin- 1 0-one

Dibenzob,e][l,4]dioxin, 2,3,7,8-tetrachloro-
Benzene, 1,2,4,5-tetrachIoro-


Ethane, tetrachloro-, N.O.S.
Ethane, 1,1,1,2-tetrachloro-
Ethane, 1,1,2,-tetrachloro-
Ethene, tetrachloro-
Phenol, 2,3,4,6-tetrachloro-
Thiodiphosphoric acid, tertaethyl ester
Plumbane, tetraethyl-
Diphosphoric acid, tetraethyl ester
Methane, tetranitro-
Same

Thallium oxide, T12O3
Acetic acid, thallium(l+) salt
Carbonic acid, dithallium(l+) salt
Thallium chloride T1C1
Chemical
Abstract No.
F>
7783-00-8
7488-56-4
630-10-4
7440-22-4

506-64-9
93-72-1
143-33-9
18883-66-4
57-24-9

1746-01-6
95-94-3


25322-20-7
630-20-6
79-34-5
127-18-4
58-90-2
3689-24-5
78-00-2
107-49-3
509-14-8
7440-28-0

1314-32-5
563-68-8
6533-73-9
7791-12-0
Hazardous
Waste No.
U204
U205
P103


P104
See F027
P106
U206
P108
P108

U207



U208
U209
U210
See F027
P109
PI 10
Pill
P112


P113
U214
U215
U216
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
D13

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
Thallium(l) nitrate
Thallium sclenite
Thallium{l) sulfate
Thioacetamide
Thiofanox
Thiomcthanol
Thiophenol
Thioseinicarbazide
Thiourca
Thiram
Toluene
Toluenediainine
Toluene-2,4-diamine
Touene-2,6-diamine
Tolucne-3,4-diamine
Toluene diisocyanate
o-Toluidine
o-Toluidine hydrochloride
p-Toluidinc
Toxaphenc
1 ,2,4-Trichlorobenzcne
1,1,2-Trichloroethane
Trichlorocthylene
Trichloromethanethiol
Trichloromonofluoromethane
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-T
Trichloropropane, N.O.S.1
1 ,2,3-Trichloropropane
Chemical Abstracts Name
Nitric acid, thallium(l+) salt
Selenious acid, dithallium(l+) salt
Sulfuric acid, dithallium(l+) salt
Ethanethioamide
2-Butanone, 3,3-dimethyl-l-(methylthio)-, )-
[(methylamino)carbonyl] oxime
Methanethiol
Benzenethiol
Hydrazinecarbothioamide
Same
Thioperoxydicarbonic diamide [(H2N)C(S)]2S2 tetramethyl-
Benzene, methyl-
Benzenediamine, ar-methyl-
1,3-Benzenediamine, 4-methyl-
1,3-Benzenediamine, 2-methyl-
1,2-Benzenediamine, 4-methyl-
Benzene, 1,3-diisocyanatomethyl-
Benzenamine, 2-methyl-
Benzenamine, 2-methyl-, hydrochloride
Benzenamine, 4-methyl-
Same
Benzene, 1,2,4-trichloro-
Ethane, 1,1,3-trichloro-
Ethene, trichloro-
Methanethiol, trichloro-
Methane, trichlorofluoro-
Phenol, 2,4,5-trichloro-
Phenol, 2,4,6-trichloro-
Acetic acid, (2,4,5-trichlorophenoxy)-

Propane, 1,2,3-trichloro-
Chemical
Abstract No*
10102-45-1
12039-52-0
7446-18-6
62-55-5
39196-18-4
74-93-1
108-98-5
79-19-6
62-56-6
137-26-8
108-88-3
25376-45-8
95-80-7
823-40-5
496-72-0
26471-62-5 .
95-53-4
636-21-5
106-49-0
8001-35-2
120-82-1
79-00-5
79-01-6
75-70-7
75-69-4
95-95-4
88-06-2
93-76-5
25735-29-9
96-18-4
Hazardous
Waste No,
U217
PI 14
P115
U218
P045
U153
POM
P116
U219
U244
U220
U221



U223
U328
U222
U353
P123

U227
U228
P118
U121
See F027
See F027
See F027


This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
D14

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
Common Name
O,O,O-Triethyl phosphorothioate
1 ,3,5-Trinitrobenzene
Tris( 1 -aziridiny l)phosphine sulfide
Tris(2,3-dibromopropyl) phosphate
Trypan blue
Uracil mustard
Vanadium pentoxide
Vinyl chloride
Warfarin
Warfarin salts, when present at
concentrations less than 0.3%.
Warfarin salts, when present at
concentrations greater than 0.3%
Zinc cyanide
Zinc phosphide
Zinc phosphide
{ -%' 1 V % l
ฃ• ^ -5*.
,, . >.<-. ,f '
Chemical Abstracts Name " , :
> ! ,. ^lr
Phosphorothioic acid, O,O,O-triethyl ester
Benzene, 1,3,5-trinitro-
Aziridine, l,l',l"-phosphinothioylidynetris-
1-Propanol, 2,3-dibromo-, phosphate (3:1)
2,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-di methyl[l,l'-
biphenyl]-4,4'-diyl)bis(azo)]-bis[5-amino-4-hydroxy-,
tetrasodium salt
2,4-( 1 H,3H)-Pyrimidinedione, 5-[bis(2-
chloroethyl)amino]-
Vanadium oxide V2O5
Ethene, chloro-
2H-l-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-l-
phenylbutyl)-, when present at concentrations greater than
0.3%


Zinc cyanide Zn(CN)2
Zinc phosphide ZnjP^ when present at concentrations
greater than 10%.
Zinc phosphide Zn3P2, when present at concentrations of
10% or less
Chemical
Abstract No.
/
126-68-1
99-35-4

126-72-7
72-57-1
66-75-1
13-14-62-1
75-01-4
81-81-2


557-21-1
1314-84-7
1314-84-7
Hazardous
Waste No.

U234

U235
U236
U237
P120
U043
U248
U248
P001
P121
P122
U248
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
D15

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix D: Identification of Hazardous Waste Hazardous Constituents (40 CFR 261, Appendix VIII)
                              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.
D16

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

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

-------
THIS PAGE INTENTIONALLY LEFT BLANK

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

(COMMENT: 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
P003
P070
P004
POOS
P006
P007
POOS
P009
PI 19
P099
P010
P012
P011
P011
P012
P038
P036
P054
P067
P013
P024
P077
P028
P042
Substance , " ," , ^ > „_„,-,
Acetaldehyde, chloro-
Acetamide, N-(aminothioxomethyl)-
Acetamide, 2-fluoro-
Acetic acid, fluoro-, sodium salt
1 - Acety 1-2-thiourea
Acrolein
Aldicarb
Aldrin
Allyl alcohol
Aluminum phosphide (r, t)
5-(Aminomethyl)-3-isoxazolol
4-Aminopyridine
Ammonium picrate (r)
Ammonium vanadate
Argebtate(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)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
E1

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
 Acute Hazardous Waste (40 CFR 261.33(a) through 261.33(e))
Hazardous Waste No.
P046
P014
P001
P028
POI5
P016
P017
POI8
P021
P021
P022
P095
P023
P024
P026
P027
P029
P029
P030
P031
P033
P033
P034
P016
P036
P037
P038
P041
P040
P043
Substance
Benzeneethanamine, alpha,alpha- dimethyl- (r)
Benzenethiol
2H-l-Benzopyran-2-one,4-hydroxy-3- (3-oxo-l-phenylbutyl)-, and salts when present at
concentrations greater than 0.3%
Benzyl chloride
Beryllium powder
Bis(chloromethyl)ether
Bromoacetone
Brucine
Calcium cyanide
Calcium cyanide Ca(CN)2
Carbon disulfide
Carbonic dichloride
Chloroacetaldehyde
p-Chloroaniline
1 -(o-Chlorophenyl)thiourea
3-Chloropropionitrile
Copper cyanide
Copper cyanide Cu(CN)
Cyanides (soluble cyanide salts), n.o.s.
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
Diisopropyl fluorophosphiate (DEP)
This document Is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
E2

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
Acute Hazardous Waste (40 CFR 261.33(a) through 261.33(e))	
Hazardous Waste No.
P004

P060
P037
P051
P044
P045
P046
P047
P048
P020
P085
Pill
P039
P049
P050
P088
P051
P051
P042
P031
P066
P101
P054
P097
P056
P057
P058
P065
Substance ' l , ,''[•/, ^T"~
4-5 8-Dimethanonapthalene, l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a- hexahydro, (lalpha,
4alpha,4abeta,5alpha, 8alpha,8abeta)-
,4:5,8-Dimethanonapthalene, l,2,3,4,10,10-hexachloro-l,4,4a,5,8,8a- hexahydro-, (lalpha,
4alpha,4abeta,5beta, 8beta,8abeta)-
2,7:3,6-Dimethanonapth[2,3b]oxirane, 3,4,5,6,9,9-hexachloro-la,2,2a,3,6,6a,7,7a-octahydro-,(l-
aalpha, 2beta,2aalpha,3beta,6beta,6aalpha, 7beta,7aalpha)-
2,7:3,6-Dimethanonapth[2,3b]oxirane, octahydro-, (laalpha,2beta,2abeta,
3alpha,6alpha,6abeta,7beta,7aalpha)-
Dimethoate
3,3-Dimethyl-l-(methylthio)-2-butanone, O-[(methylamino)carbonyl]oxime
alpha,alpha-Dimethylphenethylamine
4,6-Dinitro-o-cresol and salts
2,4-Dinitrophenol
Dinoseb
Diphosphoramide,octamethyl-
Diphosphoric acid, tetraethyl ester
Disulfoton
Dithiobiuret
Endosulfan
Endothall
Endrin
Endrin and metabolites
Epinephrine
Ethanedinitrile
Ethanimidothioic acid, N-[[(methylamino)carbony] oxy]-, methyl ester
Ethyl cyanide
Ethyleneimine
Famphur
Fluorine
Fluoroacetamide
Fluoroacetic acid, sodium salt
Fulminic acid,mercury(2+)salt (r, t)
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
E3

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
 Acute Hazardous Waste (40 CFR 261.33(a) through 261.33(e))	
Hazardous Waste No.
P059
P062
P116
P068
P063
P063
P096
P064
P060
P007
P092
P065
P082
P064
P016
PI 12
P118
P050
P059
P066
P068
P064
P069
P071
P072
P073
P073
P074
P074
P075
Substance ' . . . - \- -\ "!.:,.,:;,• .'.-• . . : ••... .'.• , ', I
Heptachlor
Hexaethyl tetraphosphate
Hydrazinecarbothioamide
Hydrazine, methyl-
Hydrocyanic acid
Hydrogen cyanide
Hydrogen phosphide
Isocyanic acid, methyl ester
Isodrin
3(2H)-Isoxazolone, 5-(aminomethyl)-
Mercury (acetato-O)phenyl-
Mercury fulminate (r,t)
Methanamine, N-methyl-N-nitroso
Methane, isocyanato-
Methane, oxybisfchloro-
Methane, tetranitro- (r)
Methanethiol, trichloro-
6,9-Methano-2,4,3-benzodioxathlepen, 6,7,8,9,10,10-hexachloro- l,5,5a,6,9,9a-hexahydro-,3-
oxide
4,7-Methano-lH-indene, 1,4,5,6,7,8,8- heptachloro-3a,4,7,7a-tetrahydro-
Methomyl
Methyl hydrazine
Methyl isocyanate
2-Methyllactonitrile
Methyl parathion
alpha-Naphthylthiourea
Nickel carbonyl
Nickel carbonyl, (T-4)-
Nickel cyanide
Nickel cyanide Ni(CN)2
Nicotine and salts
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
E4

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
Acute Hazardous Waste (40 CFR 261.33(a) through 261.33(e))		
Hazardous Waste No.
MHE^HUMHMMI
P076
P077
P078
P076
P078
P081
P082
P084
P074
P085
P087
P087
P088
P089
P034
P048
P047
P020
P009
P092
P093
P094
P095
P096
P041
P039
P094
P044
P043
P089
Substance , -- , , _ซ", ,/^jT ;, , ^ *
Nitric oxide
p-Nitroaniline
Nitrogen dioxide
Nitrogen oxide NO
Nitrogen oxide
Nitroglycerine (r)
N-Nitrosodimethylamine
N-Nitrosomethylvinylamine
Nickel cyanide
Octamethylpyrophosphoramide
Osmium oxide
Osmium tetroxide
7-Oxabicyclo[2.2.1]heptane-2,3- dicarboxylic acid
Parathion
Phenol, 2-cyclohexyl-4,6-dinitro
Phenol, 2,4-dinitro
Phenol, 2-methyl-4,6-dinitro- and salts
Phenol, 2-(l-methylpropyl)-4,6-dinitro
Phenol, 2,4,6-trinitro-, ammonium salt (r)
Phenylmercuty 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
Phosphorofluoric acid, bis(l-methylethyl) -ester
Phosphorothioic acid, O,O-diethyl O- (4-nitrophenyl) ester
  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
E5

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

Hazardous Waste No.
P040
P097
P071
PllO
P098
P098
P099
P070
PlOl
P027
P069
P081
P017
PI 02
POOS
POOS
P067
P102
POOS
P075
P103
P104
P104
P105
P106
PI 06
PI08
P018
P108
PI 15

Substance
Phosphorothioic acid, O,O-diethyl O- pyrazinyl ester
Phosphorothioic acid, O-[4-[(dimethylamino) sulfonyl]phenyl] O.O-dimethyl ester
Phosphorothioic acid, O,O-dimethyl O- (4-nitrophenyl) ester
Plumbane, tetraethyl-
Potassium cyanide
Potassium cyanide K(CN)
Potassium silver cyanide
Propanal, 2-methyl-2-(methylthio)-, 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- 1 -ol
1 ,2-Propy lenimine
2-Propyn-l -ol
4-Pyridinamine
Pyridine, (S)-3-(l-methyl-2-pyrrolidinyl)-,(S)-, and salts
Selenourea
Silver cyanide
Silver cyanide Ag(CN)
Sodium azide
Sodium cyanide
Sodium cyanide Na(CN)
Strychnidin-10-one, and salts
Strychnidin 10-one, 2,3-dimethoxy-
Strychnine and salts
Sulfuric acid, dithallium(l) salt









requirements are in any way altered by any statements) contained herein.
                                                                                            E6

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
Acute Hazardous Waste (40 CFR 261.33(a) through 261.33(e))	
Hazardous Waste No.
P109
P110
Pill
PI 12
P062
P113
P113
PI 14
P115
P109
P045
P049
P014
P116
P026
P072
P093
P123
P118
P119
P120
P120
P084
P001
P121
P121
P122
Substance - > t !-*ป.'
^ 1 '^ ^ ซW- " " < * ^
Tetraethyldithiopyrophosphate
Tetraethyl lead
Tetraethylpyrophosphate *
Tetranitromethane (r)
Tetraphosphoric acid, hexaethyl ester
Thallic oxide
Thallium(lll) oxide
Thallium(l) selenite
Thallium(l) sulfate
Thiodiphosphoric acid, tetraethyl ester
Thiofanox
Thiomidodicarbonic diamide
Thiophenol
Thiosemicarbazide
Thiourea, (2-chlorophenyl)-
Thiourea, 1-naphthalenyl-
Thiourea, phenyl-
Toxaphene
Trichloromethanethiol
Vanadic acid, ammonium salt
Vanadium oxide V2O3
Vanadium pentoxide
Vinylamine, N-methyl-N-nitroso
Warfarin and salts, when present at concentrations greater than 0.3%
Zinc cyanide t
Zinc cyanide Zn(CN)2
Zinc phosphide Zn3P2, when present at concentrations greater than 0.3%
 This document is intended solely for guidance.  No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
E7

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix E: Commercial Chemical Products or Manufacturing Chemical Intermediates Identified as
  Acute Hazardous Waste (40 CFR 261.33(a) through 261.33(e))	
                            THIS PAGE INTENTIONALLY LEFT BLANK
This document is intended solely for guidance. No statutory or regulatory
requirements are in anyway altered by any statements) contained herein.
                                                                                            E8

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

                      Appendix F:
         Potentially Incompatible Hazardous Wastes
                (40 CFR 264, Appendix V)

-------
THIS PAGE INTENTIONALLY LEFT BLANK

-------
Protocol Tor Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix F: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)	

Below are examples of potentially incompatible wastes and waste components along with the harmful consequences
that result from mixing wastes in one group with wastes in another group. The list is intended as a guide to indicate the
need for special precautions when managing these potentially incompatible waste materials or components. This list is
not intended to be exhaustive. Operators must, as the regulations require, adequately analyze their wastes so they can
avoid creating uncontrolled substances or reactions of the type listed below, whether listed below or not.

In the lists below, the mixing of a Group A material with a Group B material may have the potential consequences as
noted.
 Group 1-A
Group 1-B
 Acetylene sludge
 Alkaline caustic liquids
 Alkaline cleaner
 Alkaline corrosive liquids
 Alkaline corrosive battery acid
 Caustic wastewater
 Lime sludge and other corrosive alkalies
 Lime wastewater
 Lime and water
 Spent caustic
Acid sludge
Acid and water
Battery acid
Chemical cleaners
Electrolyte, acid
Etching acid liquid or solvent
Pickling liquor and other corrosive acids
Spent acid
Spent mixed acid
Spent sulfuric acid
 Potential Consequences: Heat generation, violent reaction.
  Group 2-A
Group 2-B
  Aluminum
  Beryllium
  Calcium
  Lithium  .
  Magnesium
  Potassium
  Sodium
  Zinc powder
  Other reactive metals and metal hydrides
Any waste in Group 1-A or 1-B
 Potential Consequences: Fire or explosion; generation of flammable hydrogen gas.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                      F1

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix F: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)	
  Group 3-A
Group 3-B
  Alcohols
  Water
Any concentrated waste in
Groups1-A or1-B
Calcium
Lithium
Metal hydrides
Potassium
SO2-CI2, SOCIj, PCI3, CH3SICI3
Other water-reactive waste
Potential Consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases.
 Group 4-A
Group 4-B
 Alcohols
 Aldehydes
 Halogenated hydrocarbons
 Nitrated hydrocarbons
 Unsaturated hydrocarbons
 Other reactive organic compounds and solvents
Concentrated Group 1-A or Group 1-B wastes

Group 2-A wastes
Potential Consequences: Fire, explosion, or violent reaction.
Group 5-A
Spent cyanide and sulfide solutions
Group 5-B : ;D ';;'•' ••':_, '^:;;^ .:';2
•'.'...'' 	 	 	 • '• ;.;,"":":_
- > ,'.,•:„„ • ..- ;.-...,. -', ," '• • '.' .
Group 1-B wastes
Potential Consequences: Generation of toxid hydrogen cyanide, or hydrogen sulfide gas.
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                   F2

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix F: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)	
 Group 6-A
Group 6-B
 Chlorates
 Chlorine
 Chlorites
 Chromic acid
 Hypochlorites
 Nitrates
 Nitric acid, fuming
 Perchlorates
 Permanganates
 Peroxides
 Other strong oxidizers
Acetic acid and other organic acids

Concentrated mineral acids
Group 2-A wastes
Group 4-A wastes
Other flammable and combustible wastes
Potential Consequences: Fire, explosion, or violent reaction.

"Law, Regulations, and Guidelines for Handling of Hazardous Waste," California Department of Health, February
1975.
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
                                                     F3

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix F: Potentially Incompatible Hazardous Wastes (40 CFR 264, Appendix V)
                           THIS PAGE INTENTIONALLY LEFT BLANK
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
F4

-------
 Protocol for Conducting Environmental Compliance Audits of
Hazardous Waste Generators under the Resource Conservation
                    and Recovery Act

                      Appendix G:
  Land Disposal Restricted Wastes and Their Effective Dates
                (40 CFR 268, Appendix VII)

-------
THIS PAGE INTENTION ALLY LEFT BLANK

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)

               Table 1 - Land Disposal Restricted Wastes and Their Effective Dates
Waste Code
California list '
California list
California list
California list
California list
RCRA Hazardous Wastes
RCRA Listed Wastes
D001
D002
D003
D004
D004
D005
D006
D007
D007
D008
D008
D009
D010
D011
D012
D013
DOW
D015
Waste Category "' \_ _Jt
,\ •• r -w , „•"- - i "** ' L_ >U
Liquid hazardous wastes, including free liquids associated with solid
or sludge, containing free cyanides at concentrations greater than or
equal to 1000 mg/L or certain metals or compounds of these metals
greater than or equal to the prohibition levels.
Liquid (aqueous) hazardous wastes having a pH less than or equal to
2.
Dilute HOC wastewaters, defined as HOC-waste mixtures that are
primarily water and that contain greater than or equal to 1000 mg/L
but less than 10,000 mg/L.
Liquid hazardous waste containing PCBs greater than or equal to 50
ppm.
Other liquid and nonliquid hazardous wastes containing HOCs in
total concentration greater than or equal to 1000 mg.
Those that contain naturally occurring radioactive materials.
Mixed radioactive/hazardous wastes.
All
All
All
Wastewater
Nonwastewaters
Nonwastewater
All
All
All
Lead materials before secondary smelting
All others
Nonwastewater
All
All
All
All
All
All
Effective Date
8 July 1987
8 July 1987
8 July 1987
8 July 1987
8Novl988
8 May 1992
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G1

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
D016
D017
F001
F001
F002 (1,1,2 -trichloroethane)
F002
F002
F003
F003
F004
F004
F005 (benzene, 2-ethoxy
cthanol, 2-nitropropane).
F005
F005
F006
F006
F006 (cyanides)
F007
F008
F009
F010
F01 1 (cyanides)
F011
F012 (cyanides)
F012
Waste Category
All
All
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Wastewater and Nonwastewater
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and solids.
All others
Wastewater and Nonwastewater
Small quantity generators, CERCLA response/RCRA corrective
action, initial generator's solvent-water mixtures, solvent-containing
sludges and soils.
All others
Wastewater
Nonwastewater
Nonwastewater
All
All
All
All
Nonwastewater
All others
Nonwastewater
All others
Effective Date
8Augl990
8Augl990
8Novl988
8Novl986
8Augl990
8Novl988
8Novl986
8Novl988
8Novl986
8Novl988
8Novl986
8 Aug 1990
8 Nov 1988
8 Nov 1986
8 Aug 1990
8 Aug 1988
8 July 1989
8 July 1989
8 July 1989
8 July 1989
8 June 1989
8 Dec 1986
8 July 1989
8 Dec 1989
8 July 1989
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G2

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
F019
F020
F021
F022
F023
F024 (metals)
F024 (metals)
F024
F025
F026
F027
F028
F039
F039
K001 (organics)b
K001
K002
K003
K004
K004C
K005
K005C
K006
K007
K007C
K008
K008C
K009
K010
K011
K011
Waste Category - - " ^ 7?,^ -, /' "'" ' *
All
All
All
AH
All
Wastewater
Nonwastewater
All others
All
All
All
All
Wastewater
Nonwastewater
All
AH others
All
AH
Wastewater
Nonwastewater
Wastewater
Nonwastewater
All
Wastewater
Nonwastewater
Wastewater
Nonwastewater
All
All
Wastewater
Nonwastewater
Effective Date
8 Aug 1990
8Novl988
8 Nov 1988
8 Nov 1988
8 Nov 1988
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Nov 1988
8 Nov 1988
8 Nov 1988
8 Aug 1990
8 May 1992
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1988
8 June 1989
8 June 1989
8 Aug 1990
8 June 1989
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
G3

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
K013
K013
KOI4
K014
K015
K01S
K016
K017
K018
K019
K020
K021
K021a
K022
K022
K023
K024
K025
K025"
K026
K027
K028 (metals)
K028
K029
K029
K030
K031
K031
K032
K033
K034
Waste Category ' '"/'
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater
All
All
All
All
All
•
Wastewater
Nonwastewater
Wastewater
Nonwastewater
All
All
Wastewater
Nonwastewater
All
All
Nonwastewater
All others
Wastewater
Nonwastewater
All
Wastewater
Nonwastewater
All
All
All
Effective Date
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 June 1989
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G4

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code '
t >. -* ~" f
K035
K036
K036c
K037b
K037
K038
K039
K040
K041
K042
K043
K044C
K045C
K046 (Nonreactive)
K046
K047
K048
K048
K049
K049
K050
K050
K051
K051
K052
K052
K060
K060C
K061
K061
> ' " ^ *^ I Sซ J- N"3^ )* fc '*"
Waste Category ^ _ _. It ' ^ W^XVJf-' *•
-.' > ซ.,.-"* - } ', i , f 4 ,,iiป. *j '_'.,'ซ i >/r ,y
AH
Wastewater
Nonwastewater
Wastewater
Nonwastewater
All
All
All
All
All
All
All
all
Nonwastewater
All others
AH
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater (low zinc) (interim standard for high zinc remains in
effect until 7 Aug 1991).
Effective Date
^ ^ *
8 Aug 1990
8 June 1989
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 June 1989
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Nov 1990
8 Aug 1990
8 Nov 1990
8 Aug 1990
8 Nov 1990
8 Aug 1990
8 Nov 1990
8 Aug 1990
8 Nov 1990
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
 This document is intended solely for guidance.  No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
G5

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix 6: Land Disposal Restricted Wastes and their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
K062
K069 (Non-Calcium Sulfate)*
K069
K071
K073
K083
K084
K084
K085
K086 (organics)b
K086
K087
K093
K094
K095
K095
K096
K096
K097
K098
K099
K100
K1000
K101 (organics)
K101 (metals)
K.101 (organics)
K101 (metals)
K102 (organics)
K102 (metals)
K 102 (organics)
K102 (metals)
Waste Category r
All
Nonwastewater
All others
All
All
All
Wastewater
Nonwastewater
All
All
All others
All
All
All
Wastewater
Nonwastewater
Wastewater
Nonwastewater
All
All
All
Wastewater
Nonwastewater
Wastewater
Wastewater
Nonwastewater
Nonwastewater
Wastewater
Wastewater
Nonwastewater
Nonwastewater
Effective Date
8 Aug 1988
8Augl988
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1988
8 June 1989
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 May 1992
8 Aug 1988
8 Aug 1990
8 Aug 1988
8 May 1992
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G6

-------
Protocol lor Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)	
Waste Code

K103
K104
K105
K106
K106
K113
K114
K115
K116
P001
P002
POOS
P004
POOS
P006
P007
POOS
P009
P010
P010
P011
P011
P012
P012
P013 (barium)
P013
P014
P015
P016
P017
P018
Waste Category ' _ ;' * t ( '- ' .,,
f * _" 4 "~ -i j

All
All
All
Wastewater
Nonwastewater
All
All
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Wastewater
Nonwastewater
Nonwastewater
All others
All
All
All
All
All
.Effective Date
?
*
8 Aug 1988
8 Aug 1988
8 Aug 1990
8 Aug 1990
8 May 1992
8 June 1989
8 June 1989
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 May 1992
8 Aug 1990
8 May 1992
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
G7

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
P020
P021
P022
P023
P024
P026
P027
P028
P029
P030
P031
P033
P034
P036
P036
P037
P038
P038
P039
P040
P041
P042
P043
P044
P045
P046
P047
P048
P049
P050
P051
Waste Category
All
All
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Nonwastewater
All
Wastewater
Nonwastewater
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
8Augl990
8 June 1989
8Augl990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 May 1992
8 June 1989
8 June 1989
8 June 1989
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G8

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)	
Waste Code
P054
P056
P057
P058
P059
P060
P062
P063
P064
P065
P065
P066
P067
P068
P069
P070
P071
P072
P073
P074
P075
P076
P077
P078
P079
P081
P082
P084
P085
P087
P088
Waste Category ~ '/-,<, , * >*
All
All
All
All
All
AH
All
All
All
Wastewater
Nonwastewater
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
N Effective Date
8Augl990
8Augl990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 May 1992
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
G9

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
P089
P092
P092
P093
P094
P095
P096
P099 (silver)
P099
PI01
P102
P103
PI 04 (silver)
P104
P105
PI06
P108
P109
PI 10
Pill
PI 12
P113
PI 14
PI 15
P116
P118
P119
P120
P121
P122
PI 23
Waste Category
All
Wastewater
Nonwastewater
All
All
All
All
Wastewater
All others
All
All
All
Wastewater
All others
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
Effective Date
s
8 June 1989
8 Aug 1990
8 May 1992
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G10

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

Waste Code
MMI^^^HII^^HH^^^M^^^^^^^^^^H I
UOOl
U002
U003
U004
U005
U006
U007
U008
U009
U010
U011
U012
U014
U015
U016
U017
U018
U019
U020
U021
U022
U023
U024
U025
U026
U027
U028
U029
U030
U031
U032


Waste Category <' , . <-,,.*
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^m^^^^^^^^^m^mjjjjmjigjjgjjjijjjajjf^ I
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All


Effective Date
8Augl990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990





















1













  This document is intended solely for guidance. No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
G11

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U033
U034
U035
U036
U037
U038
U039
U041
U042
U043
U044
U045
U046
U047
U048
U049
U050
U051
U052
U053
U055
U056
U057
U058
U059
U060
U061
U062
U063
U064
U066
Waste Category
. . ' • . •'. " •'''.-'.'••
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
AH
All
All
All
All
All
All
All
Effective Date J
8Augl990
8 Aug 1990
8Augl990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statement(s) contained herein.
G12

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

Waste Code
mm ^^ mmmim , (
U067
U068
U069
U070
U071
U072
U073
U074
U075
U076
U077
U078
U079
U080
U081
U082
U083
U084
U084
U085
U086
U087
U088
U089
U090
U091
U092
U093
U094
U095
U096
Waste Category * - „ ' / vV ''•*< ,
". - >• 	 ,.1',. , / 	 '" ;jL^i!L__L *
j!!^^^^^^^^^^^!^^ g^^gl^^^l^^ l^^g^^ I^^I^^^^^^^^H
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All

Effective Date
8 Aug 1990
8Augl990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
1
i











  This document is intended solely for guidance.  No statutory or regulatory
  requirements are in any way altered by any statements) contained herein.
G1.3

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Wปste Code
U097
U098
U099
U101
U101
U103
U105
U106
U107
U108
U109
U110
Ulll
U1I2
U113
U114
U115
UI16
U117
U118
UH9
U120
U121
U122
U123
U124
U125
U126
U127
U128
U129
Waste Category
All
All
All
All
All
All
All
AH
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
AH
AH
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                                               G14

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix Vil)
Waste Code
U130
U131
U132
U133
U134
U135
U136
U136
U137
U138
U140
U141
U142
U143
U144
U145
U146
U147
U148
U149
U150
U151
U151
U152
U153
U154
U155
U156
U157
U158
U159
Waste Category ,„ • - "". ,r
~ -„•" ' ' s '
All
All
All
All
All
All
Wastewater
Monwastewater
All
All
All
All
All
All
All
All
All
All
All
All
All
Wastewater
Nonwastewater
All
All
All
All
All
All
All
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 May 1992
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
  This document is intended solely for guidance.  No statutory or regulatory
  requirements are in any way altered by any statement(s) contained herein.
G15

-------
 Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
 Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U160
UI61
U162
UI63
U164
U165
U166
U167
U168
U169
U170
U171
U172
UI73
U174
U176
U177
UI78
U179
U180
U181
U182
U183
U184
U185
U186
U187
U188
U189
UI90
U191
Waste Category
All
All
All
All
All
All
All
All
All
All
AH
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
AH
All
All
All
Effective Date
8Augl990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
This document is intended solely for guidance.  No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
                                                                                               G16

-------
Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code

U192
U193
U194
U196
U197
U200
U201
U202
U203
U204
U205
U206
U207
U208
U209
U210
U211
U212
U213
U214
U215
U216
U217
U218
U219
U220
U221
U222
U223
U225
U226
Waste Category * t" ' - ,' ;-/*"•*'•'•<• ';•">•:!''>
v ป - *•**' ( H j,; _^_(
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All
All"
All
All
All
All
All
All
All
All
Effective Date
	 > 	
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
 This document is intended solely for guidance. No statutory or regulatory
 requirements are in any way altered by any statements) contained herein.
G17

-------
  Protocol for Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
  Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)
Waste Code
U227
U228
U234
U235
U236
U237
U238
U239
U240
U243
U244
U246
U247
U248
U249
Waste Category
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^•^^^••••BHHHi
All
All
All
All
All
All
All
All
All
All
All
All
All
AH
All
Effective Date
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 June 1989
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
8 Aug 1990
 * This table also does not include contaminated soil and debris wastes.
 b The standard has been revised in the Third Third Final Rule.
 c No land disposal standard has been revised in the Third Third Final Rule.
This document is intended solely for guidance. No statutory or regulatory
requirements are in any way altered by any statements) contained herein.
G18

-------
Protocol Tor Conducting Environmental Compliance Audits of Hazardous Waste Generators under RCRA
Appendix G: Land Disposal Restricted Wastes and Their Effective Dates (40 CFR 268, Appendix VII)

               Table 2 - Summary of Effective Dates of Land Disposal Restrictions
                             for Contaminated Soil and Debris (CSD)
/
1.
2.
3.
4.
5.
6.
7.
8.
9.
Restricted hazardous waste in CSD'- ,,',-, ",
Solvent-(F001-F005) and dioxin-(F020-F023 and F026-F028) containing soil and
debris from CERCLA response of RCRA corrective actions.
Soil and debris not from CERCLA response or RCRA corrective actions
contaminated with less than 1% total solvents (F001-F005) or dioxins (F020-F023
and F026-F028).
Soil and debris contaminated with California list HOCs from CERCLA response or
RCRA corrective actions.
Soil and debris contaminated with California list HOCs not from CERCLA
response or RCRA corrective actions.
All soil and debris contaminated with First Third wastes for which treatment
standards are based on incineration.
All soil and debris contaminated with Second Third wastes for which treatment .
standards are based on incineration.
All soil and debris contaminated with Third Third wastes or, First or Second Third^
"soft hammer" wastes which had treatment standards promulgated in the Third
Third rule, for which treatment standards are based on incineration, vitrification, or
mercury retorting, acid leaching followed by chemical precipitation, or thermal
recovery of metals; as well as all inorganic solids debris contaminated with D004-
D01 1 wastes, and all soil and debris contaminated with mixed RCRA/radioactive
wastes.
Debris that is contaminated with wastes listed in 40 CFR 268.10, 268.1 1, and
268.12 (including such wastes that are mixed radioactive hazardous wastes), and
debris that is contaminated with any characteristic waste for which treatment
standards are established (including such wastes that are mixed radioactive
hazardous wastes).
Hazardous soil having treatment standards based on incineration, mercury retorting
or vitrification, and soils contaminated with hazardous wastes listed in 40 CFR
268. 1 0, 268. 1 1 , 268. 1 2 that are mixed radioactive hazardous wastes.
Effective Date
8 Nov 1990
8Novl990
8 Nov 1990
8 July 1989
8 Aug 1990
8 June 1991
8 May 1993
8 May 1993
8 May 1993
 NOTE:
 1. Appendix VII is provided for the convenience of the reader.
 2. Contaminated Soil and Debris Rule will be promulgated in the future.
 This document is intended solely for guidance.  No statutory or regulatory
 requirements are in any way altered by any statement(s) contained herein.
G19

-------

-------